From:
Brian
Shrager
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
August
4,
2003
Project:
Plywood
and
Composite
Wood
Products
NESHAP
Re:
Meeting
Minutes
for
the
July
28,
2003
Meeting
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
Louisiana­
Pacific
(
L­
P).

I.
Purpose
The
EPA
participated
in
a
meeting
with
L­
P
on
July
28,
2003
to
discuss
issues
specific
to
L­
P's
operations,
including
application
of
MACT
standards
to
innovative
process
technologies
and
MACT
for
wet­
wet
hardboard
presses.
The
list
of
participants
is
included
as
Attachment
1.

II.
Discussion
The
L­
P
representatives
provided
a
confidential
handout
that
outlined
several
innovative
process
technologies
that
L­
P
has
developed
or
may
develop
and
presented
concerns
about
how
the
upcoming
MACT
standards
would
apply
to
these
technologies.
Attachment
2
is
a
nonconfidential
discussion
of
L­
P's
issues
and
concerns.
The
main
point
presented
by
L­
P
is
that
the
restriction
in
the
rule
that
an
add­
on
air
pollution
control
device
cannot
be
used
to
meet
the
production­
based
emission
limits
(
PBELs)
is
overly
restrictive
and
does
not
encourage
the
use
of
innovative
process
technologies
that
reduce
emissions
to
a
level
that
may
or
may
not
meet
the
PBELs
without
some
additional
control.
This
restriction
in
the
standards
as
proposed
removes
what
otherwise
would
be
a
powerful
incentive
for
investing
in
source
reduction
technologies
such
as
those
being
considered
by
L­
P.
The
L­
P
representatives
requested
that
EPA
remove
the
restriction
from
the
rule,
and
noted
that
EPA
policy
and
the
Pollution
Prevention
Act
require
EPA
to
consider
ways
to
encourage
source
reduction
in
the
MACT
rule.
The
EPA
indicated
that
the
project
team
needs
to
discuss
the
issue
and
determine,
for
the
PCWP
industry,
what
types
of
activities
qualify
as
pollution
prevention.
Additional
information
on
the
specific
innovative
process
technologies
being
developed
or
considered
by
L­
P
is
contained
in
EPA's
confidential
business
information
(
CBI)
files
for
the
PCWP
project.
2
The
discussion
then
turned
to
MACT
for
wet/
wet
hardboard
presses,
an
issue
of
concern
for
L­
P's
Roaring
River
facility.
A
handout
outlining
L­
P's
presentation
on
wet/
wet
hardboard
presses
is
included
as
Attachment
3.
The
L­
P
representatives
stated
that
wet/
wet
hardboard
presses
should
be
a
separate
MACT
subcategory,
and
the
MACT
floor
for
the
subcategory
would
be
no
control.
The
justification
for
creating
separate
subcategories
for
wet/
wet
hardboard
presses
and
other
(
wet/
dry
and
dry/
dry)
presses
includes
the
following:
(
1)
the
water
content
into
the
press
is
60
percent,
compared
to
0
percent
for
both
dry/
dry
and
wet/
dry
hardboard
presses;
(
2)
the
exhaust
gas
temperature
from
wet/
wet
presses
is
lower;
(
3)
the
exhaust
gas
volume
from
wet/
wet
presses
is
higher
because
of
the
large
amount
of
water;
(
4)
the
exhaust
gas
HAP
content
(
concentration)
is
lower,
especially
for
short­
cycle
wet
presses;
(
5)
a
large
mass
(
10,000
to
12,000
lb/
hr)
of
water
is
emitted
as
part
of
the
exhaust
stream;
and
(
6)
safety
within
an
enclosure
is
a
concern
because
of
the
need
to
inspect
for
and
free
sticking
boards.
The
L­
P
representatives
then
indicated
that
the
L­
P
Roaring
River
wet/
wet
hardboard
presses
are
unique
in
the
industry.
First,
the
out­
of­
press
board
moisture
content
is
20
percent,
compared
with
0
percent
for
all
other
hardboard
presses.
Second,
because
of
the
remaining
moisture
and
the
short
press
cycle,
the
resin
does
not
fully
catalyze
in
the
press,
resulting
in
lower
phenol
and
formaldehyde
emissions.
Finally,
the
presses
are
followed
by
bake
ovens,
which
fully
set
and
catalyze
the
resin
and
reduce
board
moisture
to
"
bone
dry."
Some
other
presses
are
followed
by
tempering
ovens,
but
not
bake
ovens.
Safety
is
of
particular
concern
for
the
L­
P
Roaring
River
facility
because
the
boards
exiting
the
facility's
presses
still
contain
20
percent
moisture
and,
therefore,
tend
to
stick
to
the
press
platens.
The
problem
of
boards
sticking
to
the
press
platens
is
further
exacerbated
because
the
resin
does
not
fully
set
and
catalyze
in
the
press.
Workers
must
(
almost
constantly)
inspect
the
press
for
and
free
the
sticking
boards.
L­
P
believes
that,
because
of
the
safety
concerns,
a
permanent
total
enclosure
is
not
technologically
feasible
for
a
wet/
wet
hardboard
press.
In
addition,
the
cost­
to­
control
the
high­
volume,
high­
moisture,
low­
HAP
(
concentration)
exhaust
stream
is
exorbitantly
high.
The
L­
P
representatives
added
that
only
one
of
40
hardboard
presses
(
dry
and
wet)
is
controlled,
and
wet
presses
are
not
currently
controlled
in
the
industry.
Finally,
L­
P
representatives
stated
that
the
bake
ovens
that
follow
the
wet
presses
have
significant
emissions
and
would
be
feasible
to
control
as
required
under
the
rule
(
as
proposed).

Following
L­
P's
presentation,
RTI
posed
several
questions
to
the
L­
P
representatives.
First,
RTI
asked
the
product
thickness
associated
with
the
press
and
bake
oven
emission
factors
provided
in
L­
P's
public
comments
(
0.52
lb/
MSF
and
0.46
lb/
MSF,
respectively).
The
L­
P
representatives
responded
that
the
emission
factors
are
based
on
a
7/
16
inch
thickness.
Second,
RTI
asked
if
L­
P
realized
that
the
PBEL
for
reconstituted
wood
products
presses
is
based
on
a
wet/
wet
hardboard
press,
and
if
a
subcategory
were
created
for
wet/
wet
hardboard
presses,
the
PBEL
for
all
other
reconstituted
wood
products
presses
would
be
more
stringent
than
at
proposal.
The
L­
P
representatives
indicated
that
they
recognize
that
potential
outcome
of
subcategorization.
Third,
RTI
asked
if
L­
P
realized
that
the
board
coolers
MACT
floor
also
could
be
impacted
(
made
more
stringent)
by
the
subcategorization.
The
L­
P
representatives
stated
that
the
subcategorization
would
not
have
to
carry
over
to
board
coolers
since
technological
differences
are
not
evident
between
board
coolers
following
the
various
types
of
presses.
An
EPA
representative
added
that
the
issue
of
whether
wet/
wet
hardboard
presses
should
be
grouped
separately
from
other
press
types
would
be
evaluated
technically,
regardless
of
the
outcome
for
the
reconstituted
press
PBEL
or
board
cooler
MACT
floor.
Fourth,
RTI
asked
if
L­
P
had
looked
at
the
possibility
of
controlling
digesters
at
the
Roaring
River
facility
and
emissions
averaging
the
digesters
with
the
press.
The
L­
P
representatives
indicated
that
they
looked
at
the
possibility,
but
there
are
some
other
issues
that
would
have
to
be
considered.
The
3
L­
P
representatives
added
further
that
the
main
point
of
this
meeting
was
to
demonstrate
that
MACT
controls
do
not
apply
to
the
presses
at
the
Roaring
River
facility.
Fifth,
RTI
asked
if
the
80
percent
biofilter
control
efficiency
presented
in
L­
P's
comments
was
based
on
HAP
or
VOC.
The
L­
P
representatives
stated
that
they
would
have
to
check
the
basis
for
the
control
efficiency,
and
added
that
they
expect
higher
control
efficiencies
for
methanol
than
for
aldehydes.
Finally,
RTI
asked
if
L­
P
was
aware
of
a
currently­
operating
biofilter
with
the
capacity
to
treat
600,000
actual
cubic
feet
per
minute
of
exhaust
gas.
The
L­
P
representatives
indicated
that
they
had
knowledge
of
a
large
biofilter
but
they
did
not
know
the
actual
capacity
of
the
unit.
The
L­
P
representatives
also
added
that
because
of
the
high
exhaust
stream
moisture
content,
the
Roaring
River
plant
would
have
to
use
a
wet
scrubber
prior
to
a
biofilter
to
control
press
emissions,
and
the
facility
already
is
operating
near
it's
permitted
allowable
water
discharge.

Following
the
discussion,
L­
P
indicated
that
EPA
could
contact
Mr.
John
Joyce
with
any
questions
specific
to
the
Roaring
River
facility
or
Mr.
Dave
Harvey
with
any
other
questions
or
information
needs.
Attachment
1
 
List
of
Participants
U.
S.
EPA
K.
C.
Hustvedt
Mary
Tom
Kissell
Gary
McAlister
Candace
Sorrell
Lousiana­
Pacific
Dave
Harvey,
L­
P
Russ
Frye,
Collier
Shannon
Scott
John
Joyce,
L­
P
William
Baird,
L­
P
Research
Triangle
Institute
Katie
Hanks
Brian
Shrager
