Date:
November
7,
2003
Subject:
Estimates
of
Ancillary
Plywood
and
Composite
Wood
Products
Process
Emissions
for
Use
in
Risk
Modeling
EPA
Contract
No.
68­
D­
1­
079;
EPA
Work
Assignment
No.
2012
RTI
Project
No.
08550.002.012
From:
Katie
Hanks
To:
Mary
Tom
Kissell,
ESD/
WCPG
(
C439­
03)
Dennis
Pagano,
ESD/
REAG
(
C404­
01)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
I.
Introduction
When
developing
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
the
plywood
and
composite
wood
products
(
PCWP)
industry,
emission
sources
were
identified
based
on
responses
to
the
Environmental
Protection
Agency's
(
EPA's)
maximum
achievable
control
technology
(
MACT)
surveys
and
available
emissions
test
data.
Facility­
specific
emissions
estimates
were
developed
based
on
emission
factors
and
process
throughput
provided
in
the
responses
to
the
MACT
surveys.
The
emission
factors
were
developed
using
available
emissions
test
data
from
nearly
100
test
reports
collected
through
EPA's
MACT
survey,
data
from
EPA's
Compilation
of
Air
Pollutant
Emission
Factors,
Volume
I:
Stationary
Point
and
Area
Sources
(
commonly
referred
to
as
AP­
42),
and
extensive
data
from
the
industry­
sponsored
test
program
performed
by
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
(
NCASI).
Separate
memoranda
discuss
in
detail
how
the
emission
factors
were
developed
and
emissions
were
estimated.
1,2
Some
ancillary
PCWP
processes
were
not
included
in
the
facilityspecific
emissions
estimates
described
in
these
memoranda
because
no
emissions
test
data
were
available
for
these
processes.
The
mass
of
HAP
emitted
from
these
processes
was
expected
to
be
minute
compared
to
the
mass
of
HAP
emitted
from
dryers,
presses,
and
the
other
PCWP
processes
for
which
emissions
data
were
available.

Following
development
of
the
emission
estimates
described
above,
the
EPA
has
considered
the
carcinogenic
and
non­
carcinogenic
risk
associated
with
PCWP
emissions.
The
mass
of
HAP
emitted
does
not
always
dictate
the
risk
associated
with
emissions.
The
potency
of
each
individual
pollutant
is
considered
when
determining
risk.
Emissions
of
a
small
mass
of
a
highly
potent
pollutant
may
have
more
risk
than
emissions
of
a
greater
mass
of
a
less
potent
2
pollutant.
Therefore,
for
purposes
of
conducting
a
conservative
screening
of
the
risk
associated
with
PCWP
emissions,
emission
estimates
of
all
pollutants
from
all
processes
(
including
ancillary
processes
with
low
HAP
emissions)
are
necessary.
The
purpose
of
this
memorandum
is
to
provide
conservative
estimates
of
the
HAP
emissions
from
ancillary
processes
for
which
emissions
estimates
were
not
previously
developed.
This
memorandum
discusses
the
methodology
used
to
generate
emission
estimates
for
HAP
metals
emissions
associated
with
combustion
(
see
section
II),
and
organic
HAP
emissions
associated
with
resin
tanks,
miscellaneous
coating
operations,
and
wastewater
operations
(
see
section
III).
This
memorandum
also
provides
an
estimated
emissions
release
height
for
these
ancillary
processes.

II.
Emissions
of
HAP
Metals
From
Combustion
The
PCWP
industry
uses
combustion
to
provide
process
heat
and
generate
steam
for
both
indirect­
fired
processes
(
where
combustion
gases
do
not
mix
with
process
gases)
and
direct­
fired
processes
(
where
the
combustion
gases
mix
with
process
gases).
Separate
NESHAP
are
under
development
for
industrial
boilers
and
process
heaters;
these
NEHASP
cover
boilers
and
process
heaters
that
indirectly
fire
PCWP
process
units.
Combustion
in
direct­
fired
process
units
is
not
covered
by
the
Industrial
Boilers
and
Process
Heaters
NESHAP
and
is
covered
by
the
PCWP
NESHAP.
3
The
EPA's
MACT
survey
requested
information
on
emissions
of
all
HAP.
Approximately
100
emissions
test
reports
containing
HAP
data
were
submitted
with
the
responses
to
the
MACT
survey.
However,
no
emissions
test
data
for
HAP
metals
were
received.
The
emissions
estimates
developed
previously
for
direct­
fired
process
units
account
for
any
organic
HAP
emitted
from
combustion
sources
used
to
directly
fire
PCWP
process
units.
Because
no
emissions
data
were
available
for
metal
HAP,
the
emissions
estimates
developed
previously
for
direct­
fired
process
units
do
not
include
metal
HAP
emissions,
and
HAP
metals
emissions
were
not
considered
for
purposes
of
developing
the
PCWP
NESHAP.
1
The
EPA
is
aware
that
combustion
of
certain
fuels
can
result
in
metal
HAP
emissions,
and
that
certain
metal
HAP
are
relatively
potent.
Thus,
HAP
metal
emissions
were
estimated
for
direct­
fired
PCWP
process
units
for
purposes
of
conducting
a
conservative
risk
screening
analysis
for
the
PCWP
source
category.
The
fuels
most
predominantly
used
in
the
PCWP
industry
include
wood
and
natural
gas.
Combustion
of
natural
gas
typically
does
not
produce
HAP
metals,
so
the
estimates
of
HAP
metals
emissions
were
limited
to
those
PCWP
process
units
that
fire
wood
(
i.
e.,
direct
wood
fired
dryers).
The
process
units
most
commonly
direct
fired
using
wood
fuel
include
oriented
strandboard
(
OSB)
rotary
dryers,
particleboard
rotary
dryers,
hardboard
and
medium
density
fiberboard
(
MDF)
tube
dryers,
and
some
veneer
dryers.
The
types
of
combustion
units
used
to
directly
fire
PCWP
dryers
vary
from
suspension
burners
that
are
part
of
the
dryer
to
stand­
alone
combustion
units
that
supply
combustion
exhaust
to
heat
multiple
dryers.
To
estimate
metals
HAP
emissions
from
direct­
wood
firing,
we
used
the
trace
element
emission
factors
from
AP­
42
Section
1.6,
Wood
Residue
Combustion
in
Boilers,
to
the
industry
average
burner
capacity
for
each
of
the
four
types
of
dryers
described
above.
4,5
Table
1
presents
the
metal
HAP
emissions
3
associated
with
each
dryer
based
on
these
estimates.
These
metal
HAP
emissions
from
Table
1
were
then
multiplied
by
the
number
of
dryers
at
each
facility
to
estimate
the
potential
facility
total
HAP
metal
emissions.

We
acknowledge
that
there
may
be
differences
in
the
types
of
combustion
units
used
in
PCWP
processes
and
wood
residue
fired
boilers.
For
example,
all
of
the
emission
tests
referenced
in
developing
the
AP­
42
trace
element
emission
factors
were
boilers
as
opposed
to
suspension
burners.
Wood
residue
includes
hogged
wood,
bark,
sawdust,
shavings,
wood
chips,
mill
rejects,
sanderdust
or
wood
trim.
Bark
is
more
commonly
fired
in
boilers
than
in
suspension
burners.
Suspension
burners
may
have
some
bark
mixed
in
their
fuel,
but
typically
fire
other
types
of
wood
residue
(
e.
g.,
sawdust,
trim,
and
sanderdust).
Regardless
of
the
potential
differences
in
the
boiler
data
used
to
develop
the
AP­
42
emission
factors
and
PCWP
combustion
units,
in
the
absence
of
more
PCWP
industry­
specific
emissions
data,
we
believe
the
approach
outlined
above
is
appropriate
for
purposes
of
developing
a
conservative
estimate
of
potential
HAP
metals
emissions
from
PCWP
direct
wood
fired
process
units.

Emissions
from
the
direct­
fired
dryers
for
which
HAP
metals
were
estimated
are
released
through
a
dryer
stack
approximately
70
feet
(
ft)
high.
6
III.
Organic
HAP
Emissions
From
Resin
Tanks,
Miscellaneous
Coating
Operations,
and
Wastewater
Operations
The
following
three
subsections
describe
the
methodology
used
to
develop
estimates
of
organic
HAP
emissions
from
resin
tanks,
miscellaneous
coating
operations,
and
wastewater
operations.
These
sections
also
described
the
limitations
of
the
data
used
to
develop
the
emission
estimates,
and
present
an
estimate
of
the
emissions
release
height
for
each
of
the
ancillary
processes.

A.
Resin
Tanks
Resin
storage
tanks
are
located
at
most
PCWP
plants.
The
tanks
contain
ureaformaldehyde
(
UF),
phenol­
formaldehyde
(
PF),
methylene
diphenyl
diisocyanate
(
MDI),
or
other
types
of
resins
or
additives
(
e.
g.,
wax,
scavenger).
Specific
information
on
storage
tanks
was
collected
through
EPA's
general
MACT
survey,
but
was
not
requested
for
hardwood
plywood
or
engineered
wood
products
plants.
Based
on
the
general
survey
responses,
there
are
at
least
809
storage
tanks
in
use
in
the
PCWP
industry.
The
average
tank
volume
is
around
12,000
gallons.
The
majority
of
the
storage
tanks
are
fixed­
roof
tanks
with
no
vapor
recovery
system.
5
The
MACT
survey
requested
information
on
resin
tanks
used
to
store
PCWP
resins.
These
resins
exhibit
low
vapor
pressures
and
are
not
volatile.
The
MACT
survey
also
requested
information
on
potential
HAP
emissions
from
resin
tanks.
Only
about
35
percent
of
survey
respondents
provided
information
on
HAP
emissions
from
resin
tanks,
and
these
estimates
varied
by
four
orders
of
magnitude
(
e.
g.,
1.3E­
5
to
7.6E­
1
tons
per
year
(
tpy)
for
formaldehyde).
The
4
maximum
emissions
reported
for
any
single
tank
are
summarized
in
Table
2.5
The
number
of
tanks
reported
by
survey
respondents
ranged
from
one
to
14
tanks
per
facility,
with
an
average
of
four
tanks
per
facility.
The
reported
tank
capacity
varied
from
100
to
130,000
gallons,
and
there
was
also
a
large
variation
in
tank
throughput.
To
estimate
potential
facility­
wide
HAP
emissions
associated
with
resin
storage
tanks
for
use
in
risk
screening,
the
emissions
estimates
in
Table
2
were
multiplied
by
the
average
number
of
tanks
per
facility.
These
estimates
are
uncertain
given
that
few
survey
respondents
provided
tank
emission
estimates,
the
wide
range
of
reported
tank
emissions,
the
wide
range
in
the
number
of
tanks
per
facility,
and
the
wide
range
in
tank
capacity
and
throughput.

Resin
storage
tanks
are
typically
located
outside
of
PCWP
buildings.
Emissions
are
released
through
a
vent
in
the
fixed
roof
of
the
tank.
Assuming
that
PCWP
resin
storage
tanks
are
cylindrical,
a
12­
ft
tank
diameter
(
obtained
from
an
OSB
facility
permit),
and
the
average
capacity
of
12,000
gallons
per
storage
tank,
it
is
estimated
that
the
release
height
for
resin
storage
tank
emissions
is
roughly
14
ft
above
ground.
This
estimate
appears
to
be
conservative
because
the
tank
heights
reported
in
the
permit
were
34
ft
for
two
MDI
tanks
and
20
ft
for
two
wax
tanks.
However
these
tanks
mentioned
in
the
permit
had
capacities
greater
than
12,000
gallons.
7
B.
Miscellaneous
Coating
Operations
Most
PCWP
plants
perform
some
type
of
miscellaneous
coating
operations.
These
miscellaneous
coating
operations
are
finishing
operations
such
as
application
of
anti­
skid
coatings,
concrete
forming
oil,
edge
seals,
fire
retardants,
inks,
nail
lines,
primers,
patches,
edge
fillers,
or
putty.
Information
on
these
miscellaneous
coating
operations,
such
as
the
type
of
operation
and
amount
of
coating
material
used,
was
requested
in
the
EPA's
general
MACT
survey.
However,
no
information
on
potential
emissions
from
these
operations
was
requested,
although
a
few
facilities
provided
the
percentage
of
HAP
(
if
any)
contained
in
some
of
their
coatings.
Some
HAP
percentages
were
provided
for
solvent­
based
paints
or
inks
used
to
apply
company
logos
and
trademarks/
gradestamps
to
PCWP
products.
Company
logos
and
gradestamps
typically
are
applied
to
all
types
of
PCWP
products.
One
facility
reported
using
3,300
gallons
per
year
(
gal/
yr)
of
logo
paint
with
20
percent
ethylene
glycol
and
4
percent
methanol.
This
same
facility
reported
using
270
gal/
yr
trademark/
gradestamp
ink
with
up
to
5
percent
ethylene
glycol.
Worst­
case
emission
estimates
were
developed
assuming
all
of
the
ethylene
glycol
and
methanol
is
emitted.
Table
3
shows
the
amount
of
HAP
emitted
from
the
miscellaneous
coating
operations
at
this
facility.
Assuming
that
all
of
the
ethylene
glycol
and
methanol
is
emitted
is
an
overestimate
because,
in
reality,
only
a
fraction
of
the
HAP
contained
in
a
coating
is
emitted.
The
remainder
of
the
HAP
remains
in
the
paint
or
ink
after
it
is
applied
to
the
substrate.
At
ambient
temperature,
ethylene
glycol
has
a
vapor
pressure
three
orders
of
magnitude
lower
than
the
vapor
pressure
of
water,
and
therefore
is
much
less
volatile
than
water.
It
is
reasonable
to
expect
that
very
little
of
the
ethylene
glycol
evaporates
into
emissions.
Methanol,
on
the
other
hand,
is
slightly
more
volatile
than
water.

The
same
facility
for
which
logo
and
gradestamp
emissions
were
estimated
also
uses
two­
5
part
synthetic
patches
(
i.
e.,
the
two
parts
of
the
patch
material
are
mixed
immediately
prior
to
application).
Part
2
of
the
patch
contains
45
percent
MDI
and
55
percent
higher
oligomers
of
MDI.
The
facility
reported
use
of
4,097
gal/
yr
of
Part
2.
The
MDI
emissions
from
this
patching
operation
are
likely
to
be
negligible
because
nearly
all
of
the
MDI
remains
in
the
patch.
In
appendix
H
to
the
baseline
emission
memo,
we
estimated
that
less
than
one
percent
of
the
MDI
contained
in
an
MDI
resin
is
emitted
during
hot
pressing
operations.
1
The
MDI
resins
used
by
the
PCWP
industry
have
a
similar
percentage
of
MDI
in
them
as
the
synthetic
patch.
However,
synthetic
patches
are
not
hot
pressed.
MDI
is
a
solid
under
atmospheric
conditions,
and
therefore,
is
not
prone
to
evaporation.
Another
reason
for
not
including
MDI
emissions
in
the
worst­
case
estimate
is
because
synthetic
patches
are
only
applied
to
plywood
products
as
opposed
to
all
products
like
logos
and
gradestamps;
thus
MDI
emissions
are
not
typical
for
all
types
of
PCWP
facilities..

Based
on
the
available
information,
it
appears
as
if
the
worst­
case
facility
emissions
associated
with
miscellaneous
coating
operations
are
3.1
tpy
of
ethylene
glycol
and
0.4
tpy
of
methanol,
as
shown
in
Table
3.
These
estimates
were
based
on
information
provided
by
one
facility
that
provided
the
highest
of
the
HAP
percentages
included
in
the
survey
responses.
However,
it
should
be
noted
that
different
facilities
use
different
coatings
(
many
with
no
HAPs)
and
different
amounts
of
coatings.
The
available
information
is
not
conducive
to
meaningful
comparisons
among
coatings
(
e.
g.,
coating
usage
amounts
were
reported
in
lb/
yr,
gal/
yr,
rolls/
yr,
etc.
and
HAP
percentages
in
the
coatings
(
if
any)
generally
were
not
provided).
The
worst­
case
estimated
emissions
presented
in
Table
3
may
not
be
representative
of
any
other
facilities,
and
are
likely
an
overestimate
for
the
facility
at
hand
(
because
some
of
the
HAP
remains
in
the
coating
after
it
is
applied).
While
this
worst­
case
estimate
may
be
used
for
conservative
estimates
of
risk,
the
estimate
is
not
representative
of
every
facility
in
the
PCWP
industry.
However,
the
worstcase
estimate
does
indicate
that
the
potential
emissions
from
miscellaneous
coating
operations
are
not
of
the
same
magnitude
as
drying
and
pressing
operations
at
PCWP
facilities.

Miscellaneous
coatings
are
typically
applied
manually
inside
a
building.
Emissions
associated
with
miscellaneous
coating
operations
are
expected
to
exit
through
building
ventilation.
Building
height
at
PCWP
facilities
is
roughly
40
ft.
Thus,
an
emissions
release
height
of
40
ft
may
be
assumed
for
miscellaneous
coating
operations.

C.
Wastewater
Operations
Wastewater
operations
(
e.
g.,
lagoons,
log
vats,
clarifiers,
settling
ponds,
tanks,
etc.)
are
used
for
handling
process
waters
or
wastewaters,
which
may
contain
traces
of
HAP.
Wastewater
sources
at
PCWP
plants
include
hardboard
process
water,
various
wash
waters
(
e.
g.,
from
washing
of
the
glue
line,
blender,
dryers,
regenerative
thermal
oxidizers,
etc.),
control
device
recirculated
and
blowdown
water,
and
condensates.
Information
on
wastewater
flow
was
provided
in
the
non­
confidential
MACT
survey
responses
for
241
wastewater
operations.
(
An
additional
92
wastewater
operations
were
reported,
but
no
flow
rates
were
provided.)
However,
HAP
concentration
data
were
provided
for
only
23
of
the
241
wastewater
operations
for
which
6
flow
rates
were
provided.
The
highest
reported
HAP
concentration
was
41.5
milograms
per
liter
(
mg/
l)
of
methanol
in
wet
scrubber
water.
Another
stream
of
wastewater
from
a
wet
electrostatic
precipitator
(
WESP)
was
reported
to
contain
4.34
mg/
l
acetaldehyde,
5.72
mg/
l
methanol,
and
1.07
mg/
l
methyl
ethyl
ketone
(
MEK).
These
are
the
only
two
wastewater
streams
with
concentrations
and
flow
rates
great
enough
to
trigger
applicability
under
the
Hazardous
Organic
NESHAP
(
HON)
(
had
these
facilities
actually
been
subject
to
the
HON).
The
potential
methanol
emissions
associated
with
the
41.5
mg/
l
wastewater
stream
were
determined
to
be
0.31
tpy.
The
potential
HAP
emissions
from
the
WESP
wastewater
stream
with
are
0.016
tpy
which
includes
acetaldehyde
(
0.0091
tpy),
methanol
(
0.0043
tpy),
and
MEK
(
0.0023).
8
Thus,
for
purposes
of
conservatively
determining
risk
associated
with
wastewater
operations
based
on
the
available
data,
one
could
assume
that
each
PCWP
facility
emits
0.31
tpy
methanol,
0.0091
tpy
acetaldehyde,
and
0.0023
tpy
MEK
from
wastewater
operations.
However,
it
is
not
known
how
the
potential
emissions
from
PCWP
wastewater
operations
could
vary
from
facility
to
facility
because
HAP
concentrations
were
only
reported
for
23
wastewater
operations,
there
are
various
sources
of
wastewater,
and
there
is
a
wide
range
of
wastewater
flow
rates
and
handling
methods.

It
is
not
clear
from
the
MACT
survey
data
where
wastewater
emissions
may
occur
for
the
two
wastewater
streams
with
HAP
emission
estimates
above.
Assuming
the
wastewater
streams
mentioned
above
are
collected
in
ponds,
then
the
emissions
would
be
released
as
fugitive
emissions
at
ground
level.
There
is
no
additional
information
beyond
the
estimates
provided
above
to
use
in
estimating
potential
emissions
from
wastewater
storage
tanks.

D.
Conclusions
Regarding
Organic
HAP
from
Ancillary
Processes
Table
4
presents
a
summary
of
the
worst­
case
organic
HAP
emissions
estimates
and
emissions
release
heights
for
resin
tanks,
miscellaneous
coating
operations,
and
wastewater
operations.
The
sum
of
the
organic
HAP
emitted
is
9.8
tpy.
Based
on
these
worst­
case
estimates,
the
HAP
emissions
associated
with
resin
tanks,
miscellaneous
coating
operations,
and
wastewater
operations
alone
would
not
cause
a
facility
to
be
a
major
source
of
HAP
emissions
(
i.
e.,
the
emissions
do
not
exceed
the
10/
25
tpy
emission
thresholds
to
trigger
major
source
status).
For
comparison,
the
average
facility
baseline
total
HAP
emissions
previously
estimated
are
as
follows:
9
°
Particleboard
121
tpy
°
MDF
103
tpy
°
OSB
90
tpy
°
Hardboard
86
to
240
tpy
(
depending
on
process)

°
Softwood
plywood
36
tpy
The
worst­
case
emission
estimates
for
resin
tanks,
miscellaneous
coating
operations,
and
7
wastewater
operations
were
based
on
the
best
available
information.
However,
as
noted
in
the
previous
subsections,
the
information
used
to
develop
the
emission
estimates
is
very
limited.
Therefore,
it
is
recommended
that
the
estimates
presented
in
this
memorandum
be
used
only
for
proposes
of
developing
a
conservative
risk
screening
model.
8
Table
1.
Estimated
HAP
metals
emissions
for
various
PCWP
dryer
types.

Pollutant
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Hexavalent
chromium
Cobalt
Lead
Manganese
Mercury
Nickel
Selenium
Emission
factors
(
lb/
MMBTU)
a
7.94E­
06
2.20E­
05
1.09E­
06
4.09E­
06
2.06E­
05
3.51E­
06
6.50E­
06
4.77E­
05
1.55E­
03
3.54E­
06
3.33E­
05
2.79E­
06
Process
unit
Burner
capacity
MMBTU/
hrb
Metals
emissions
(
lb/
yr)

OSB
rotary
dryer
39
2.5
6.9
0.34
1.3
6.4
1.1
2.0
15
484
1.1
10
0.87
Particleboard
rotary
dryer
33
2.1
5.8
0.29
1.1
5.4
0.93
1.7
13
409
0.93
8.8
0.74
Tube
dryer
35
2.2
6.2
0.31
1.1
5.8
1.0
1.8
13
434
1.0
9.3
0.78
Veneer
dryer
26
1.7
4.6
0.23
0.85
4.3
0.73
1.4
9.9
322
0.74
6.9
0.58
aAP­
42
Section
1.6,
Wood
Residue
Combustion
in
Boilers
bThe
typical
capacity
of
each
burner
was
estimated
based
on
the
average
of
the
burner
capacities
listed
in
the
general
survey
data
base
for
each
type
of
process
unit.

lb
=
pounds,
MMBtu
=
million
British
thermal
units,
yr
=
year,
hr
=
hour
9
Table
2.
Worst­
case
HAP
emissions
from
resin
storage
tanks.

Pollutant
Emissionsa
(
tons/
yr)
Estimated
emissions
per
PCWP
facilityb
Formaldehyde
0.76
3.0
Phenol
0.70
2.8
Methanol
0.032
0.13
MDI
0.005
0.02
a
Maximum
reported
uncontrolled
emissions
for
each
HAP
from
any
individual
storage
tank.
5
b
The
PCWP
facility­
wide
tank
emissions
were
estimated
by
multiplying
the
individual
tank
emissions
by
an
average
of
four
tanks
per
facility.

Table
3.
Worst­
case
facility
HAP
emissions
from
miscellaneous
coatings.

Coating
Pollutant
Percent
in
coating
Coating
use
(
gal/
yr)
Maximum
emissions
(
tpy)

trademark
and
gradestamp
ink
Ethylene
glycol
5%
270
0.1
logo
paint
Ethylene
glycol
20%
3,300
3.0
logo
paint
Methanol
4%
3,300
0.4
Total
Ethylene
glycol
Methanol
3.1
tpy
0.4
tpy
Emissions
(
tpy)
=
(%
HAP
in
coating)
x
(
gallons/
yr
coating
used)
x
(
density
of
HAP
(
lb/
gallon))
/
(
2000
lb/
ton)
10
Table
4.
Summary
of
worst­
case
facility­
wide
emission
estimates
for
miscellaneous
coating
operations,
wastewater
operations,
and
resin
tanks.

Ancillary
process
Release
height
(
ft)
Worst­
case
estimates
HAP
emissions
(
tpy)

Acetaldehyde
Ethylene
glycol
Formaldehyde
MDI
MEK
Methanol
Phenol
Miscellaneous
coatings
40
3.1
0.4
Wastewater
operations
ground
level
0.0091
0.0023
0.31
Resin
tanks
14
3.0
0.02
0.13
2.8
Pollutant
total
0.0091
3.1
3.0
0.02
0.0023
0.84
2.8
Total
HAP
emissions
9.8
tpy
11
IV.
References
1.
Memorandum
from
K.
Hanks
and
D.
Bullock,
MRI,
to
M.
Kissell,
EPA/
ESD.
June
9,
2000.
Baseline
Emission
Estimates
for
the
Plywood
and
Composite
Wood
Products
Industry.

2.
Memorandum
from
D.
Bullock
and
K.
Hanks,
MRI,
to
M.
Kissell,
EPA/
ESD.
April
27,
2000.
Documentation
of
Emission
Factor
Development
for
the
Plywood
and
Composite
Wood
Products
Manufacturing
NESHAP.

3.
National
Emission
Standards
for
hazardous
Air
Pollutants
for
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters.
Proposed
Rule.
68
FR
1660.
January
13,
2003.

4.
Background
Document
Report
on
Revisions
to
5th
Edition
AP­
42,
Section
1.6,
Wood
Residue
Combustion
in
Boilers.
Prepared
by
Eastern
Research
Group
for
U.
S.
EPA.
July
2001.

5.
Memorandum
from
D.
Bullock,
K.
Hanks,
and
B.
Nicholson,
MRI
to
M.
Kissell,
EPA/
ESD.
April
28,
2000.
Summary
of
Responses
to
the
1998
EPA
Information
Collection
Request
(
MACT
Survey)
­­
General
Survey.

6.
Memorandum
from
M.
Icenhour,
MRI,
to
Project
file.
February
20,
2002.
Documentation
of
Stack
Parameters
Provided
in
2002
submittal
of
National
Emission
Inventory
(
NEI)
data
and
as
Inputs
for
Risk
Assessment
7.
Title
V
Permit
Application
for
Louisiana­
Pacific
Corporation
Oriented
Strandboard
Mill
in
Roxboro,
North
Carolina.
February
18,
1997.

8.
Memorandum
from
K.
Hanks,
MRI,
to
Plywood
and
Composite
Wood
Products
Project
File.
June
29,
2000.
Applicability
of
the
Hazardous
Organic
NESHAP
(
HON)
Provisions
to
Plywood
and
Composite
Wood
Products
Tanks
and
Wastewater
Operations.

9.
U.
S.
EPA.
Background
Information
Document
for
Plywood
and
Composite
Wood
Products
NESHAP.
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC
27711.
September,
2000.
