From:
Kristin
Parrish
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
August
8,
2003
Project:
Plywood
and
Composite
Wood
Products
(
PCWP)
NESHAP
Re:
Meeting
Minutes
for
the
August
6,
2003
Conference
Call
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
Industry
Stakeholders
to
Discuss
Inclusion
of
Lumber
Kilns
in
the
PCWP
Source
Category
I.
Purpose
The
EPA
invited
industry
stakeholders
to
discuss
the
issues
surrounding
the
inclusion
of
all
lumber
kilns
in
the
Plywood
and
Composite
Wood
Products
(
PCWP)
NESHAP.
The
conference
call
was
held
on
August
6,
2003.
The
list
of
participants
is
included
as
Attachment
1.

II.
Discussion
The
EPA
representatives
began
the
meeting
by
summarizing
the
rationale
for
including
all
lumber
kilns,
regardless
of
location,
in
the
proposed
PCWP
NESHAP.
The
rationale
was
discussed
fully
in
the
PCWP
proposal
preamble.
Since
EPA
received
comments
opposed
to
including
all
lumber
kilns
in
the
PCWP
source
category
during
the
public
comment
period,
they
wanted
stakeholders
to
clarify
their
positions.

The
stakeholders
in
the
wood
treating
industry
stated
that
they
believe
their
lumber
kiln
operations
differ
from
PCWP
operations
because
they
do
not
add
chemicals
to
the
wood
that
is
being
dried.
They
are
particularly
concerned
about
being
regulated
by
a
NESHAP
for
a
source
2
category
that
does
not
apply
to
their
industry,
noting
that
most
companies
with
lumber
kilns
not
located
at
a
PCWP
plant
site
would
not
know
to
look
to
the
PCWP
NESHAP
for
lumber
kiln
regulations.
They
also
noted
that
wood
treating
facilities
were
declared
an
area
source
in
June
2002
and
will
be
regulated
as
a
separate
source
category
in
the
future.
The
industry
would
prefer
to
track
and
implement
as
few
regulations
as
possible.

The
representatives
of
the
PCWP
industry
stated
that
they
support
inclusion
of
all
lumber
kilns
in
the
PCWP
source
category
for
the
reasons
stated
in
the
preamble
to
the
proposed
PCWP
NESHAP.
Specifically,
the
PCWP
industry
representatives
want
to
eliminate
uncertainty
surrounding
the
regulation
of
lumber
kilns
and
extend
the
MACT
floor
determination
of
no
emissions
reduction
to
all
lumber
kilns.
They
pointed
out
that
a
lumber
kiln
may
cause
a
facility
to
be
a
major
source
of
HAP
either
on
its
own
or
in
conjunction
with
a
boiler.
Including
all
lumber
kilns
in
the
PCWP
NESHAP
would
eliminate
the
need
for
the
case­
by­
case
MACT
determinations
required
by
section
112(
g)
of
the
Clean
Air
Act
(
CAA).
The
representative
from
Louisiana­
Pacific
noted
that
the
members
of
his
company
had
a
similar
debate
and
concluded
that
inclusion
of
all
lumber
kilns
in
the
PCWP
source
category
would
result
in
less
regulatory
burden
for
everyone.
The
permit­
writing
process
would
be
streamlined
because
the
control
requirements
for
lumber
kilns
would
already
be
set.

The
Southeastern
Lumber
Manufacturers
Association
(
SLMA)
representative
stated
that
she
represents
stand­
alone
sawmills,
some
of
which
have
wood
treatment
facilities.
She
noted
that
a
MACT
floor
determination
of
no
emissions
reduction
for
lumber
kilns
is
certainly
a
benefit,

but
SLMA
has
concerns
about
the
future.
If
changes
are
made
to
the
PCWP
NESHAP
after
it
is
promulgated,
she
pointed
out
that
those
changes
could
negatively
affect
the
lumber
kilns
at
facilities
that
do
not
otherwise
fit
into
the
PCWP
source
category.

The
EPA
representatives
explained
that
EPA
has
an
obligation
to
conduct
a
residual
risk
analysis
eight
years
after
promulgation
of
the
PCWP
NESHAP.
The
PCWP
industry
representatives
noted
that
it
is
unlikely
that
the
residual
risk
analysis
would
change
the
controls
for
lumber
kilns
because
the
main
HAP
in
the
kiln
emissions
are
methanol
and
formaldehyde,

which
the
PCWP
industry
representatives
believe
are
not
high­
risk
pollutants.
The
PCWP
industry
representatives
added
that
a
compliance
option
for
low­
risk
facilities
was
mentioned
in
the
preamble
to
the
proposed
PCWP
NESHAP
and
the
requirements
for
choosing
that
compliance
option
(
if
adopted)
would
be
more
stringent
than
the
residual
risk
analysis.
They
3
speculated
that
if
a
large
PCWP
facility
can
meet
the
risk
requirements
proposed
in
the
PCWP
NESHAP,
then
smaller
facilities
with
lumber
kilns
should
have
no
problem
complying
with
future
residual
risk
guidelines.

The
EPA
representatives
then
asked
the
wood
treating
industry
representatives
for
further
clarification
on
the
listing
of
wood
treating
facilities
as
an
area
source.
The
wood
treating
industry
representatives
stated
that
wood
treating
was
added
to
the
list
of
area
source
categories
in
2002.
The
PCWP
industry
representatives
then
stated
that
they
thought
the
decision
to
list
wood
treating
was
based
on
the
wood
treating
process
and
chromated
copper
arsenate
(
CCA)

preservatives.
They
thought
it
unlikely
that
the
area
source
determination
would
extend
to
lumber
kilns
at
wood
treating
facilities.
The
wood
treating
industry
representatives
responded
that
the
listing
focused
on
the
entire
treating
process
and
was
not
limited
to
CCA
preservatives.

The
wood
treating
industry
representatives
stated
that
a
MACT
floor
determination
of
no
emissions
reduction
for
all
lumber
kilns
would
be
beneficial,
but
noted
again
that
the
wood
treating
industry
does
not
want
to
have
to
track
the
PCWP
NESHAP.
The
EPA
representatives
then
asked
if
they
would
like
for
lumber
kilns
at
wood
treating
facilities
to
be
covered
by
the
future
wood
treating
standards.
The
wood
treating
industry
representatives
responded
that
separating
the
lumber
kilns
would
be
their
preferred
solution.
They
suggested
that
EPA
could
compose
definitions
for
both
the
PCWP
NESHAP
and
the
future
wood
treating
rule
to
clarify
which
kilns
would
be
covered
by
each
rule.
The
wood
treating
industry
representatives
suggested
that
lumber
kilns
used
to
dry
material
that
will
be
treated
could
be
removed
from
the
PCWP
NESHAP
and
noted
that
many
white
poles
are
dried
in
lumber
kilns.
They
also
noted
that
there
are
other
lumber
kilns
that
would
need
to
be
removed
from
the
PCWP
NESHAP
as
well,
such
as
those
used
at
sawmills.

The
PCWP
industry
representatives
stated
that
making
a
decision
on
the
MACT
floor
determination
for
all
lumber
kilns
now
provides
regulatory
certainty
to
all
parties
involved.
They
noted
that
it
may
be
more
elegant
to
cover
lumber
kilns
not
located
at
PCWP
facilities
under
a
separate
lumber
kiln
standard,
but
developing
regulatory
standards
is
not
a
trivial
matter.
They
stated
that
not
regulating
all
lumber
kilns
in
the
PCWP
NESHAP
will
place
a
significant
regulatory
burden
on
all
parties
that
have
to
work
through
section
112(
j)
of
the
CAA.
The
PCWP
industry
representatives
stated
that
all
lumber
kilns
are
eventually
going
to
be
regulated
by
some
standard.
Furthermore,
if
a
facility
that
is
a
major
source
of
HAP
has
a
boiler,
that
facility
is
4
already
subject
to
two
MACT
standards.
They
emphasized
that
a
future
lumber
kiln
regulation
may
not
conclude
that
the
MACT
floor
is
no
emissions
reduction
and
the
States
may
not
be
consistent
in
their
case­
by­
case
determinations.

The
wood
treating
industry
representatives
stated
that
they
were
aware
of
the
boiler
MACT.
They
noted
that
lumber
kilns
are
not
listed
as
a
separate
source
category
and
were
not
being
considered
for
any
regulation
prior
to
the
proposed
PCWP
NESHAP
in
January
2003.
The
EPA
representatives
noted
that
lumber
kilns
removed
from
the
PCWP
source
category
may
become
a
separate
source
category
under
section
112(
c)(
1)
of
the
CAA
since
some
of
them
are
major
sources.
An
RTI
representative
noted
that
about
50
facilities
that
are
not
PCWP
facilities
and
that
have
lumber
kilns
may
be
major
sources
because
they
have
multiple
kilns.
The
EPA
representatives
noted
that
EPA
would
promulgate
a
rule
within
two
years
of
the
source
category
listing
for
lumber
kilns
removed
from
the
PCWP
source
category
and
included
in
a
new
source
category.
They
also
noted
that
lumber
kilns
removed
from
the
PCWP
NESHAP
are
subject
to
section
112(
g)
of
the
CAA.

The
wood
treating
industry
representatives
then
asked
about
the
types
of
wood
dried
in
the
lumber
kilns
used
in
the
PCWP
industry.
The
wood
treating
industry
representatives
noted
that
wood
is
never
redried
in
their
industry;
the
lumber
kilns
are
used
to
remove
just
enough
water
from
green
wood
so
that
the
treating
chemicals
can
enter
the
wood
effectively.
The
PCWP
industry
representatives
responded
that
they
dry
green
wood
as
well
and
that
they
do
not
add
anything
to
the
wood.
They
again
stated
that
drying
green
wood
in
lumber
kilns
can
produce
enough
HAP
to
classify
the
facility
as
a
major
source.

The
SLMA
representative
asked
if
controls
added
to
one
lumber
kiln
would
be
required
for
all
lumber
kilns
in
the
source
category
and
if
the
process
used
for
the
residual
risk
analysis
would
be
different
from
the
process
used
to
determine
the
MACT
floor.
The
PCWP
industry
representatives
noted
that
once
EPA
makes
a
MACT
floor
determination
of
no
emissions
reduction
for
all
lumber
kilns,
there
is
no
need
for
facilities
with
lumber
kilns
to
track
the
PCWP
NESHAP
until
the
residual
risk
analysis
begins.
The
PCWP
industry
representatives
speculated
that
the
EPA
would
consider
facilities
and
process
units
in
a
different
context
for
the
residual
risk
analysis
than
for
MACT
floor
determinations.
The
wood
treating
industry
representatives
then
asked
if
the
MACT
floor
determination
of
no
emissions
reduction
would
apply
unless
the
PCWP
residual
risk
analysis
provided
evidence
that
lumber
kilns
needed
additional
control.
They
also
5
asked
for
more
details
on
how
the
residual
risk
analysis
might
be
conducted
(
e.
g.,
whether
or
not
lumber
kiln
risk
would
be
evaluated
based
on
the
entire
source
category
or
individual
facilities,
or
how
the
lumber
kilns
are
used).
Specifically,
they
were
interested
in
knowing
if
the
residual
risk
analysis
might
determine
that
controls
would
be
necessary
for
some
lumber
kilns
and
not
others.

The
EPA
representatives
responded
that
it
would
be
possible
to
look
at
types
of
facilities
rather
than
the
whole
category
and
noted
that
they
are
just
now
making
decisions
about
how
residual
risk
analyses
will
be
conducted.
Currently,
EPA
is
considering
a
low­
risk
(
10­
6)
trigger
for
cancer
risks.
Health
risks
higher
than
10­
4
would
need
to
be
lowered.
The
EPA
representatives
also
stated
that
the
residual
risk
standards
will
be
promulgated
eight
years
after
the
PCWP
NESHAP
promulgation,
so
it
will
probably
be
necessary
to
start
writing
the
residual
risk
standards
about
four
years
after
the
PCWP
NESHAP
is
promulgated.
The
EPA
representatives
noted
that
the
purpose
of
the
residual
risk
analysis
is
to
ensure
that
the
risks
are
low
enough
to
be
safe
for
human
health.

The
wood
treating
industry
representatives
noted
that
if
lumber
kilns
not
located
at
a
PCWP
facility
are
included
in
the
PCWP
source
category,
the
data
that
EPA
has
collected
on
PCWP
lumber
kilns
will
not
necessarily
apply
to
all
lumber
kilns.
They
asked
how
EPA
would
handle
that
situation
in
terms
of
the
residual
risk
analysis
procedure
and
if
EPA
would
need
to
collect
additional
data.
The
EPA
representatives
responded
that
they
want
to
have
the
best
information
possible
in
order
to
accurately
characterize
emissions.
The
EPA
representatives
stated
that
they
may
choose
to
collect
more
data,
possibly
through
a
survey,
if
more
information
is
needed.

The
wood
treating
industry
representatives
asked
how
EPA
would
handle
the
area
source
rulemaking
for
wood
treating
facilities
if
lumber
kilns
are
covered
under
the
PCWP
NESHAP.
The
EPA
representatives
stated
that
lumber
kilns
and
boilers
would
both
be
exempt
from
the
wood
treating
rule
because
they
would
be
covered
by
other
NESHAP.

The
PCWP
industry
representatives
asked
if
EPA
could
develop
a
notification
form
to
send
to
facilities
with
lumber
kilns
not
located
at
PCWP
facilities
to
inform
them
that
their
kilns
are
covered
by
the
PCWP
NESHAP.
They
noted
that
this
form
could
also
serve
as
the
initial
notification
form
required
by
the
PCWP
NESHAP,
and
it
would
help
to
minimize
the
tracking
burden
for
facilities
with
lumber
kilns.
The
EPA
representatives
responded
that
the
suggestion
sounded
feasible.
6
The
EPA
representatives
then
asked
if
any
of
the
stakeholders'
opinions
had
changed
during
the
meeting.
The
wood
treating
industry
representatives
stated
that
they
may
be
willing
to
reconsider
their
initial
position
and
asked
about
the
recordkeeping
burden
for
non­
PCWP
facilities
if
lumber
kilns
are
included
in
the
PCWP
NESHAP.
The
EPA
representatives
stated
that
non­

PCWP
facilities
would
submit
only
one
report
­
an
initial
notification
form.
The
wood
treating
industry
representatives
stated
that
many
facilities
in
the
wood
treating
industry
do
not
have
any
idea
that
EPA
plans
to
regulate
their
lumber
kilns
and
noted
that
many
facilities
(
generally
nonmajor
sources)
do
not
belong
to
trade
organizations
or
subscribe
to
industry
journals.
The
EPA
representatives
stated
that
the
initial
notification
is
required
only
from
major
sources.
The
SLMA
representative
agreed
to
talk
to
her
members
and
added
that
she
thought
the
comfort
level
with
the
issues
would
be
different
now.
The
wood
treating
industry
representatives
and
the
SLMA
representative
agreed
to
contact
EPA
soon
with
feedback.

The
teleconference
was
then
adjourned.
Attachment
1
List
of
Participants
U.
S.
EPA
K.
C.
Hustvedt,
ESD
Mary
Tom
Kissell,
OAQPS
Mike
Thrift,
OGC
Industry
Stakeholders
Debbie
Burns,
Southeastern
Lumber
Manufacturers
Association
David
Harvey,
Louisiana­
Pacific
Corporation
Jim
Healey,
Koppers
Industries,
Inc.

Tim
Hunt,
American
Forest
and
Paper
Association
Leslie
Hyde,
Koppers
Industries,
Inc.

Research
Triangle
Institute
Katie
Hanks
Kristin
Parrish
