From:
Kristin
Parrish
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
July
21,
2003
Project:
Plywood
and
Composite
Wood
Products
(
PCWP)
NESHAP
Re:
Meeting
Minutes
for
the
July
18,
2003
Conference
Call
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA),
the
American
Forest
and
Paper
Association
(
AF&
PA),
and
Representatives
of
the
PCWP
Industry
1.
Purpose
The
EPA
participated
in
a
conference
call
with
members
of
AF&
PA
and
other
representatives
of
the
PCWP
industry
on
July
18,
2003,
to
discuss
EPA's
consideration
of
various
industry
comments
submitted
during
the
public
comment
period
for
the
proposed
Plywood
and
Composite
Wood
Products
(
PCWP)
NESHAP.
The
list
of
participants
is
included
as
Attachment
1.

2.
Discussion
The
industry
representatives
asked
EPA
for
the
status
of
the
decision­
making
phase
of
the
final
PCWP
NESHAP.
The
EPA
representative
replied
that
the
EPA
is
continuing
to
respond
to
non­
risk
comments,
some
of
which
require
further
research.
The
EPA
has
not
yet
made
final
decisions
on
many
of
the
issues.

To
address
the
issue
of
lumber
kiln
coverage
in
the
PCWP
NESHAP,
the
EPA
representative
stated
that
EPA
plans
to
schedule
a
meeting
in
August
with
stakeholders.
The
2
industry
representatives
noted
that
they
still
feel
strongly
that
all
lumber
kilns
should
be
included
in
PCWP
NESHAP.
They
noted
that
the
smaller
companies
may
not
be
aware
of
the
long­
term
advantages,
including
the
cessation
of
case­
by­
case
MACT
determinations.
The
EPA
representative
clarified
that
the
only
kilns
under
consideration
for
removal
from
the
PCWP
NESHAP
are
lumber
kilns
not
co­
located
with
a
PCWP
facility;
the
co­
located
kilns
will
still
be
included.
The
industry
representatives
assured
EPA
that
they
understood
the
issue
correctly
and
noted
that
their
larger
companies
represent
many
of
the
non­
co­
located
kilns
as
well
as
the
colocated
kilns.
The
industry
representatives
asked
EPA
to
identify
the
adverse
commenters,
and
RTI
responded
that
the
Southeastern
Lumber
Manufacturers
Association
(
SLMA),
Brooks
Manufacturing
Company,
and
various
members
of
the
Western
Wood
Preservers
Institute
want
to
remove
stand­
alone
kilns
from
the
PCWP
NESHAP.
The
industry
representatives
noted
that
they
may
wait
to
contact
these
commenters
since
the
August
meeting
request
has
not
been
sent
to
any
of
the
stakeholders
yet.

The
discussion
then
turned
to
the
issues
of
startup,
shutdown,
and
malfunction
(
SSM)

events
and
process
and
control
device
downtime.
First,
the
industry
representatives
requested
that
EPA
change
the
wording
of
the
rule
regarding
SSM
events
and
remove
the
word
"
scheduled"

from
the
reference
to
the
startup
and
shutdown
exemption
to
be
consistent
with
latest
version
of
the
NESHAP
General
Provisions.
Second,
the
industry
representatives
reiterated
that
EPA
should
specifically
address
gas­
fired
veneer
dryer
relights
in
the
rule
and
consider
the
safety
issues
involved.
They
stated
this
is
an
important
issue
because
relights
occur
frequently
and
may
not
fit
well
into
the
SSM
provisions.
Third,
the
industry
representatives
requested
that
EPA
reanalyze
the
data
provided
by
the
industry
and
grant
a
longer
routine
control
device
maintenance
downtime
allowance.
The
industry
representatives
noted
that
the
data
EPA
used
to
determine
the
downtime
allowance
covered
a
one­
year
period
and
may
not
include
some
of
the
large
maintenance
events
that
do
not
occur
annually
(
e.
g.,
media
replacements).
An
RTI
representative
noted
that
the
project
team
has
been
focusing
on
overarching
issues
that
affect
the
entire
rule,
such
as
MACT
floor
determinations.
The
RTI
representative
added
that
issues
relating
to
SSM
and
control
device
maintenance
downtime
are
important
but
have
not
yet
been
given
as
much
attention
because
these
issues
are
considered
to
be
fine­
tuning
of
the
rule.

Regarding
press
enclosure
requirements
and
continuous
presses,
the
industry
representatives
stated
that
they
had
spoken
with
representatives
from
J.
M.
Huber
and
that
both
3
parties
agreed
on
all
the
press
issues.
However,
the
AF&
PA
members
are
more
concerned
with
the
requirement
in
the
proposed
PCWP
NESHAP
to
certify
all
permanent
total
enclosures
(
PTEs)

by
Method
204.
The
issues
surrounding
Method
204
certification
are
the
same
for
both
batch
and
continuous
presses.
The
EPA
representative
responded
that
EPA
is
trying
to
set
up
a
site
visit
at
a
facility
with
a
long
continuous
press
sometime
in
August
to
help
them
better
understand
the
issues.
The
EPA
representative
noted
that
the
project
team
has
discussed
the
press
enclosure
requirements
with
EPA's
Emission
Measurement
Center
(
EMC).
Several
possibilities
have
been
discussed,
including
the
industry
representatives'
suggestion
of
dropping
the
Method
204
certification
requirement,
but
EPA
has
not
yet
made
a
decision.

The
next
issue
of
concern
to
the
industry
representatives
was
the
monitoring
and
recordkeeping
requirements.
Rather
than
summarize
all
of
their
detailed
public
comments,
the
industry
representatives
focused
on
the
issue
most
important
to
them
and
specifically
emphasized
that
the
proposed
3­
hour
block
averages
should
be
changed
to
12­
hour
block
averages
because
of
measurement
variability.
The
EPA
representative
acknowledged
the
request,
noted
that
no
decisions
have
been
made
with
regard
to
monitoring
and
recordkeeping,
and
stated
that
EPA
would
contact
the
industry
representatives
if
any
further
clarification
was
needed.

The
industry
representatives
then
stated
that
as
a
follow­
up
to
the
June
4,
2003,
meeting
(
see
Docket
A­
98­
44,
Item
#
IV­
E­
6
for
meeting
minutes),
they
are
preparing
a
paper
discussing
the
potential
overlap
of
the
PCWP
MACT
with
the
Boiler
MACT.
During
that
meeting,
EPA
representatives
asked
for
information
on
the
amount
of
time
that
combustion
exhaust
bypassed
a
control
device,
and
this
paper
should
help
to
answer
that
question.
The
industry
representatives
noted
that
their
paper
should
be
available
by
mid­
August.

The
production­
based
emission
limits
(
PBELs)
were
the
next
topic
of
discussion.
Phil
Ferguson
of
International
Paper
and
Lawrence
Otwell
of
Georgia­
Pacific
referred
to
emails
that
they
sent
to
EPA
earlier
in
July
(
see
Attachment
2
and
Attachment
3).
The
emails
provided
a
partial
list
of
current
pollution
prevention
(
P2)
projects
and
a
few
options
for
incorporating
addon
control
devices
with
the
PBEL.
Regarding
the
list
of
P2
projects,
the
industry
representatives
noted
that
the
list
is
not
complete
and
asked
EPA
if
process
incineration
could
be
considered
P2.

The
industry
representatives
noted
that
incineration­
based
add­
on
control
devices
require
natural
gas,
and
one
industry
representative
estimated
that
the
price
of
natural
gas
is
as
much
as
$
5
or
4
$
6/
MMBtu.
In
addition,
using
onsite
boilers
to
incinerate
process
exhaust
is
better
overall
for
the
environment
than
operating
add­
on
control
devices.
The
EPA
representative
responded
that
EPA
needs
to
be
consistent
with
the
PCWP
MACT
floor
determinations
and
with
other
regulations.

The
industry
representatives
noted
that
people
who
have
already
spent
a
lot
of
money
on
P2
practices
will
have
to
spend
more
money
in
order
to
comply
with
the
rule.
The
industry
representatives
then
addressed
the
combined
use
of
add­
on
controls
and
the
PBEL.
They
noted
that
a
facility
that
uses
P2
to
achieve
the
PBEL
faces
limited
flexibility
in
the
operation
of
the
plant
and
extra
recordkeeping,
as
well
as
the
real
possibility
that
they
will
not
be
able
to
achieve
continuous
compliance.
As
a
result,
PCWP
facilities
consider
all
the
factors
of
attempting
a
P2
project
carefully
before
making
a
commitment.
If
a
facility
is
only
going
to
save
a
small
amount
of
money
by
implementing
a
P2
project,
that
facility
will
be
more
likely
to
install
add­
on
controls
and
have
the
flexibility
to
run
the
plant
under
a
wider
range
of
conditions.
There
are
other
costs
built
into
P2
projects
as
well;
for
example,
if
a
facility
runs
a
dryer
at
a
lower
temperature,
then
the
facility
has
to
have
more
dryers
to
achieve
the
same
level
of
production.
The
industry
representatives
proposed
that
facilities
be
allowed
to
install
an
add­
on
device
and
then
"
discount"

the
PBEL.
In
other
words,
facilities
combining
add­
on
controls
and
PBEL
would
have
to
achieve
a
lower
emission
limit.
(
See
Attachment
2
and
Attachment
3
for
more
details
on
this
proposal.)

The
industry
representatives
noted
that
achieving
continuous
compliance
is
the
key,
and
the
variability
of
the
process
will
make
it
hard
to
stay
below
the
PBEL
without
add­
on
controls.
The
industry
representatives
asked
when
EPA
will
make
a
decision
on
this
issue,
and
the
EPA
representative
stated
that
the
project
team
needs
to
make
most
of
the
decisions
on
the
non­
risk
issues,
including
the
PBEL,
by
the
end
of
August.
The
EPA
representative
stated
again
that
the
PBEL
is
not
as
stringent
as
MACT
and
was
developed
in
order
to
recognize
low­
emitting
sources.

The
industry
representatives
then
asked
EPA
about
the
MACT
floor
for
new
sources.

The
industry
representatives
acknowledged
that
some
emission
points
show
better
than
90
percent
control
but
noted
that
there
is
a
lot
of
variation
in
the
data.
The
industry
representatives
stated
that
there
is
support
for
their
position
in
the
case
law,
which
says
that
EPA
must
consider
the
performance
of
the
best­
controlled
unit
under
the
reasonably
foreseeable
worst
case
operating
conditions
and
variability
of
new
and
existing
sources.
The
EPA
representative
acknowledged
the
variability
and
stated
that
she
plans
to
recommend
that
the
control
efficiency
at
new
sources
5
remain
at
90
percent.

John
Bradfield
of
the
Composite
Panel
Association
(
CPA)
mentioned
the
email
that
he
sent
to
EPA
concerning
antifungal
coatings.
The
EPA
representative
stated
that
EPA
will
review
the
proposed
language
provided
by
CPA.
(
See
Attachment
4
for
a
copy
of
the
email.)

The
industry
representatives
then
stated
that
they
thought
they
had
answered
all
of
EPA's
questions
from
the
June
4
meeting
(
see
Docket
A­
98­
44,
Item
#
IV­
E­
6,
Attachment
4).

The
industry
representatives
asked
EPA
to
contact
them
if
any
further
clarification
is
needed.
The
EPA
representative
agreed
and
asked
the
industry
representatives
to
contact
Sally
Shaver,

Director
of
the
Emission
Standards
Division,
or
the
project
team
if
they
plan
to
meet
with
the
EPA
management
to
discuss
any
non­
risk
issues.

The
industry
representatives
noted
that
they
are
planning
an
implementation
workshop
during
the
summer
of
2004
and
asked
EPA
if
they
were
planning
to
prepare
implementation
materials.
The
EPA
representative
stated
that
implementation
materials
are
not
generally
written
that
soon
after
promulgation
and
noted
that
Karen
Blanchard
is
the
group
leader
for
the
Program
Implementation
and
Review
Group
within
the
Office
of
Air
Quality
Planning
and
Standards.
The
EPA
representative
stated
that
EPA
will
likely
prepare
implementation
materials
to
assist
the
States
and
EPA
Regions
with
implementation.

Finally
the
industry
representatives
asked
if
EPA
would
like
to
try
to
set
up
a
site
visit
with
one
of
their
members
to
see
a
long
continuous
press.
The
EPA
representative
noted
that
the
project
team
is
currently
discussing
site
visits
with
Norbord,
but
the
plant
being
considered
is
further
away
than
they
would
like.
The
industry
representatives
then
asked
what
EPA's
criteria
are
for
choosing
a
site
to
visit.
The
RTI
representatives
responded
that
there
is
not
a
long
list;

they
mainly
want
to
visit
a
plant
with
a
long
continuous
press
that
is
close
to
North
Carolina
to
minimize
travel
time
and
cost.
If
possible,
they
would
like
to
visit
with
a
company
that
has
tried
both
partial
and
total
enclosures
on
long
continuous
presses,
and
if
the
press
has
a
partial
enclosure,
they
would
like
to
see
the
pick­
up
points.
The
industry
representatives
noted
that
Weyerhaeuser's
Bennettsville,
SC,
facility
has
a
long
continuous
press
and
a
building
enclosure,

and
they
indicated
that
a
visit
to
that
plant
might
be
possible.
The
EPA
representative
noted
that
EPA
wants
to
make
sure
that
they
make
the
right
decision
on
this
issue
since
long
continuous
presses
seem
to
be
the
trend
of
the
future.
6
The
EPA
representative
mentioned
that
she
had
been
asked
by
an
environmental
group
for
documentation
of
meetings
with
industry
that
occurred
after
proposal.
She
stated
that
the
documents
would
be
sent
to
the
environmental
group
well
as
to
the
docket.

The
teleconference
was
then
adjourned.
Attachment
1
List
of
Participants
U.
S.
EPA
Mary
Tom
Kissell,
OAQPS
PCWP
Industry
Kurt
Bigbee,
APA
­
The
Engineered
Wood
Association
John
Bradfield,
Composite
Panel
Association
Allison
Casey,
Masonite
Victor
Dallons,
Weyerhaeuser
Phil
Ferguson,
International
Paper
Larry
Gill,
Simpson
Timber
David
Harvey,
Louisiana­
Pacific
Corporation
Don
Hejna,
Potlatch
Corporation
Tim
Hunt,
American
Forest
and
Paper
Association
Rob
Kaufman,
Georgia­
Pacific
Corporation
Claudia
O'Brien,
Latham
and
Watkins,
Counsel
for
American
Forest
and
Paper
Association
John
Orynawka,
Temple­
Inland
Corporation
Lawrence
Otwell,
Georgia­
Pacific
Corporation
John
Pinkerton,
National
Council
for
Air
and
Stream
Improvement
Jim
Rabe,
Masonite
Paul
Vasquez,
Georgia­
Pacific
Corporation
Louis
Wagner,
American
Fiberboard
Association/
Composite
Panel
Association
Stephen
Woock,
Weyerhaeuser
Research
Triangle
Institute
Katie
Hanks
Rebecca
Nicholson
Kristin
Parrish
Attachment
2
Email
from
Phil
Ferguson
to
EPA
on
July
15,
2003
Regarding
Pollution
Prevention
and
Production
Based
Emission
Limits
From:
Phil
Ferguson
[
mailto:
Phil.
Ferguson@
ipaper.
com]
Sent:
Tuesday,
July
15,
2003
5:
41
PM
To:
rlnicholson@
rti.
org;
kissell.
mary@
epa.
gov
Cc:
tim_
hunt@
afandpa.
org;
chuck.
vaught@
weyerhaeuser.
com;
dave.
harvey@
lpcorp.
com;
kurt.
bigbee@
apawood.
org;
jbradfield@
cpamail.
org;
lpotwell@
gapac.
com;
acasey@
masonite.
com
Subject:
Production
Based
Emission
Limits
To
comply
with
your
request
for
brevity,
I
have
outlined
two
ideas/
varations
on
PBEL's
that
we
could
discuss
during
the
Friday
conference
call.
I
will
also
answer
the
question;
what
the
industry
considers
pollution
prevention
per
your
request
during
our
June
4
RTP
meeting.
We
appreciate
the
opportunity
to
continue
this
dialogue
and
hope
that
these
ideas
will
stimulate
further
flexibility
in
the
PBEL
compliance
option.

The
first
is
a
variation
on
the
ability
to
use
of
add
on
control
in
conjunction
with
PBEL.
Add
on
controls
such
as
an
on­
site
process
boiler
or
a
smaller
RTO
could
be
used,
but
only
if
the
PBEL
was
discounted
by
some
determined
percent.
We
suggest
10
to
20
%.
For
example
plywood
veneer
dryers
have
a
PBEL
of
0.022
lb/
MSF
3/
8.
If
any
add
on
controls
were
utilized,
the
PBEL
would
be
reduced
by
some
fixed
percent,
in
this
example
10%
to
0.02
lb/
MSF
3/
8.
This
option
would
further
reduce
HAP's
and
would
encourage
the
use
of
smaller
control
devices
or
on­
site
process
incineration
that
do
not
have
or
have
less
collateral
emissions
than
compliance
with
the
90%
options.
The
industry
would
agree
that
any
control
device
used
in
conjunction
with
a
PBEL
limit
would
need
to
operate
at
90%
control
efficiency.
This
could
diminish
the
concern
that
facilities
would
detune
a
control
device.

In
the
second
variation,
the
limits
of
add
on
control
should
be
based
on
the
same
emission
rates
used
to
initially
establish
the
PBEL
(
i.
e.,
the
emission
rate
of
3
lbs
HAP/
MSF
¾
was
used
as
a
basis
for
the
OSB
press
PBEL).
Limiting
the
amount
of
control
that
can
be
achieved
to
10­
25%
of
the
emission
rate
used
to
establish
the
PBEL
(
0.3
lb
to
0.75
lb/
MSF
3/
4)
would
force
plants
to
achieve
most
of
their
emission
reductions
through
P2.
Compliance
tests
would
require
a
plant
to
show
that,
prior
to
application
of
add
on
control,
emissions
were
within
the
required
percentage
chosen
by
EPA.
This
feature
would
give
plants
with
continuous
compliance
concerns
the
incentive
to
proceed
with
P2
efforts.

We
consider
the
following
a
partial
list
of
pollution
prevention
within
our
industry.
We
believe
additional
examples
and
innovations
will
be
contemplated
if
people
believe
they
are
close
to
or
have
a
realistic
shot
at
meeting
a
PBEL.

Low
Temperature
Drying
­
Reducing
rated
capacity
of
dryers
by
drying
at
lower
temperatures.
Conveyor
Drying
­
Utilizes
partial
control
by
routing
exhaust
gases
from
the
first
dryer
section
into
a
burner
section
and
recycling
the
heat
back
into
the
dryer.
Species
Control/
Substitution
­
Facilities
could
utilize
lower
HAP
emitting
species
of
raw
material
or
combinations
of
such.
Resin
Reformulation
­
Utilize
lower
HAP
emitting
resins.
Reducing
Moisture
Variability/
Precision
Process
Control
­
Using
precision
process
control,
facilities
can
limit
high
moisture
regions
in
boards
and
flakes
that
contribute
to
overdrying
and
high
HAP
emissions.
Green
Screening
­
By
removing
fines,
facilities
can
reduce
HAP
emissions
by
eliminating
these
small
particles
that
because
of
their
surface
area
overdry
and
release
additional
HAP's.
Reduction
of
Temperature
Stratification
­
Reduce
the
temperature
stratification
within
flake
dryers
that
prevent
overdrying.

If
you
have
any
questions
or
need
additional
clarification,
please
contact
me
at
(
901)
419­
3880.
Attachment
3
Email
from
Lawrence
Otwell
to
EPA
on
July
17,
2003
Regarding
Production
Based
Emission
Limits
From:
Otwell,
Lawrence
P.
[
mailto:
LPOTWELL@
GAPAC.
com]
Sent:
Thursday,
July
17,
2003
3:
57
PM
To:
'
Ferguson,
Phil
(
IP)';
'
Nicholson,
Becky
(
RTI)';
'
Kissell,
Mary
Tom
(
EPA)'
Cc:
'
Hunt,
Tim
(
AF&
PA)';
'
Vaught,
Chuck
(
WEYCO)';
'
Harvey,
Dave
(
LP)';
'
Bigbee,
Kurt
(
APA)';
'
Bradfield,
John
(
CPA)';
'
Casey,
Allison
(
Masonite)'
Subject:
RE:
PBELs
I'm
re­
forwarding
the
mssg
below
because
it
either
did
not
go
thru
or
was
partially
cut
off
for
others.
The
original
was
sent
via
a
remote
system.
A
second
attempt
ran
into
some
address
copying
and
firewall
issues.

Mary
Tom
and
Becky,
just
to
add
a
bit
of
addition
clarification
to
Phil's
excellent
digest
of
our
thoughts,
we
came
upon
the
"
discounting"
notion
while
reviewing
some
of
the
difficulties
with
the
notion
of
limiting
the
use
of
addons
to
some
fixed
small
percentage
of
the
overall
PBEL­
required
reduction.
The
main
difficulty
would
be
in
determining
and
documenting
the
starting
point.
P2
projects
begin
with
something
of
a
site­
specific
baseline
that
has
a
significant
degree
of
variability
and
then
a
number
of
iterative,
incremental
changes
are
made
over
time
to
reduce
emissions.
This
makes
the
starting
point
difficult
to
pin
down.
There
also
might
be
a
temptation
to
run
hard,
hot,
and
dirty
to
establish
that
baseline
and
inflate
the
emissions
available
for
addon
control.

The
discount
approach
was
envisioned
to
eliminate
some
of
these
uncertainties
while
addressing
your
legitimate
concerns
re:
abuse
of
add­
on
controls.
I
think
it's
very
important
to
recognize,
however,
that
from
a
practical
standpoint
no
one
is
going
to
even
consider
the
use
of
add­
ons
within
a
PBEL
unless
the
sizing
on
the
add­
on
is
significantly
less
than
that
required
for
full
control.
An
add­
on
of,
say,
75%­
80%
of
full
control
will
cost
almost
as
much
to
install
and
operate
and
the
PBEL
portion
will
add
significant
monitoring/
recordkeeping/
reporting
burdens
as
well
as
compliance
risk.
It
will
also
limit
process
operational
flexibility.
As
a
purely
business
decision,
one
would
not
even
consider
doing
that
when
you
could
pay
a
very
little
more
and
run
your
process
as
hot,
hard,
and
dirty
as
you
wanted.
Realistically,
I
personally
think
an
add­
on
within
a
PBEL
would
have
to
be
50%
or
less
of
the
size
of
a
full
control
to
even
be
considered
in
the
business
context.
By
discounting
the
PBEL
if
an
add­
on
is
used,
that
critcal
sizing
point
is
pushed
down
even
further,
assuring
that
deeper
P2
cuts
are
needed
to
support
the
50%
or
less
sizing
threshold.
The
environment
gets
the
benefit
of
the
additional
emissions
reductions
from
the
discount
plus
the
energy,
greenhouse
gas,
and
collateral
emissions
benefit
of
the
small
add­
on
control.
The
additional
compliance
margin
from
the
add­
on
control
also
then
opens
up
more
options
for
P2
that
might
otherwise
be
viewed
as
being
too
risky
from
a
continuous
compliance
standpoint.

Thanks
for
your
continued
attention
and
patience
on
this
important
issue.

L.
Otwell
Lawrence
Otwell
Senior
Environmental
Engineer
Technical
Support
Group
Georgia­
Pacific
Corporation
Phone:
(
404)
652­
5081
Fax:
(
404)
654­
4706
E­
mail:
lpotwell@
gapac.
com
Attachment
4
Email
from
John
Bradfield
to
EPA
on
July
16,
2003
Regarding
Miscellaneous
Coating
Operations
MACT
Definitions
From:
Bradfield,
John
[
mailto:
jbradfield@
cpamail.
org]

Sent:
Wednesday,
July
16,
2003
8:
52
AM
To:
Hanks,
Katie
P.

Cc:
KISSELL
MARY
TOM
(
KISSELL,
MARY
TOM);
Otwell
Lawrence
(
Otwell,
Lawrence);
Otwell
Lawrence
(
home)
(
Otwell,
Lawrence
(
home));
Vasquez
Paul
(
Vasquez,
Paul);
Hunt
Tim
(
Hunt,
Tim);
George
Ellis
(
E­
mail);
Ferguson,
Phil;
Bigbee
Kurt
(
Bigbee,
Kurt);
Wagner,
Louis
Subject:
MACT
Definitions
Katie,

At
our
June
meeting
we
promised
to
provide
you
with
some
language
to
help
clarify
coverage/
overlap
issues
that
were
not
completely
resolved
in
the
final
Wood
Building
Products
surface
Coating
MACT.
Here
are
our
suggestions.

<<
MACT
Overlap­
Antifungal
fiberboard
Fix.
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
MEMORANDUM
TO:
Katie
Hanks,
RTI
FROM:
John
Bradfield
DATE:
July
16,
2003
SUBJECT:
Coating
Definition
At
our
June
meeting
we
promised
to
provide
you
with
some
language
to
help
clarify
coverage/
overlap
issues
that
were
not
completely
resolved
in
the
final
Wood
Building
Products
surface
Coating
MACT.
Here
are
our
suggestions.
Changes
are
in
.

As
recommended
in
the
AF&
PA
comments:

Miscellaneous
coating
operations
means
application
of
any
of
the
following
to
plywood
or
composite
wood
products:
edge
seals,
moisture
sealants,
anti­
skid
coatings,
company
logos,
trademark
or
grade
stamps,
nail
lines,
synthetic
patches,
wood
patches,
wood
putty,
concrete
forming
oils,
glues
for
veneer
composing,
and
shelving
edge
fillers.
Miscellaneous
coating
operations
also
include
the
application
of
coatings
to
full
sheets
of
panel
products
such
as
primer
to
OSB
siding
or
fills
to
create
a
smooth
surface
that
occurs
at
the
same
site
as
OSB
manufacture.

Suggestions
to
clarify
coverage
related
to
Wood
Building
Products
Surface
Coating
MACT.

Miscellaneous
coating
operations
means
application
of
any
of
the
following
to
plywood
or
composite
wood
products
edge
seals,
moisture
sealants,
anti­
skid
coatings,
company
logos,
trademark
or
grade
stamps,
nail
lines,
synthetic
patches,
wood
patches,
wood
putty,
concrete
forming
oils,
glues
for
veneer
composing,
and
shelving
edge
fillers.
Miscellaneous
coating
operations
also
include
the
application
of
coatings
to
full
sheets
of
panel
products
such
as
primer
to
OSB
siding
or
fills
to
create
a
smooth
surface
that
occurs
at
the
same
site
as
OSB
manufacture.
