"
Bromberg,
Kevin
L."
To:
Mary
Kissell/
RTP/
USEPA/
US@
EPA,
Mike
<
kevin.
bromberg@
s
Thrift/
DC/
USEPA/
US@
EPA,
Dave
ba.
gov>
Guinnup/
RTP/
USEPA/
US@
EPA,
"'
Edmond_
Toy@
omb.
eop.
gov'"
02/
25/
2004
11:
22
AM
<
Edmond_
Toy@
omb.
eop.
gov>,
"
Holman,
Keith
W."
<
Keith.
Holman@
sba.
gov>,
Ken
Hustvedt/
RTP/
USEPA/
US@
EPA
cc:
Subject:
Plywood
Changes
­
Acrolein
and
Benzene
Testing
These
chemicals
were
either
not
detected
at
all
or
were
detected
were
in
a
very
small
percentage
of
tests
(
all
less
than
5%),
and
that
number
of
small
positives
is
expected
in
a
large
dataset.
See
analysis
entitled
"
Evaluation
of
Wood
Products
Source
Categories"
for
further
details.

We're
waiting
for
the
EPA
technical
reply,
in
the
meantime
­
here
is
the
suggested
rule
language
that
would
make
the
appropriate
changes:

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Table
2
Modifications
Needed:

Instead
of
paragraph
(
5)
listing
acetaldehyde,
acrolein,
formaldehyde,
and
phenol,
exclude
acrolein,
and
create
its
own
new
paragraph
(
6)
for
acrolein
which
will
exclude:

Wood
products
presses
except
hardboard
(
included)
Steam­
Heated
or
Indirectly
Fired
Wood
products
dryers
­
except
in
the
hardboard
and
fiberboard
industries
Misc
Sources
­
except
in
the
hardboard
and
fibreboard
industries
Modify
old
paragraph
(
6)
for
benzene
to
exclude:

Wood
Products
presses
Steam­
Heated
or
Indirectly
Fired
Wood
products
dryers
Misc.
Wood
products
sources
(
other
than
dryers,
presses
and
boilers)

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Current
version
of
Table
2
Table
2
to
Appendix
B
to
Subpart
DDDD
of
40
CFR
part
63.
Emission
Test
Methods.
For...
You
must...
Using...
(
1)
each
process
unit
select
sampling
ports'
Method
1
or
1A
of
40
CFR
location
and
the
number
part
60,
appendix
A
of
traverse
points
(
as
appropriate).
(
2)
each
process
unit
determine
velocity
and
Method
2
in
addition
to
volumetric
flow
rate;
Method
2A,
2C,
2D,
2F,
or
2G
in
appendix
A
to
40
CFR
part
60
(
as
appropriate).
(
3)
each
process
unit
conduct
gas
molecular
weight
Method
3,
3A,
or
3B
in
analysis
appendix
A
to
40
CFR
part
60
(
as
appropriate).
(
4)
each
process
unit
measure
moisture
content
of
Method
4
in
appendix
A
the
stack
gas
to
40
CFR
part
60.

(
5)
each
process
unit
measure
emissions
of
the
NCASI
Method
following
HAP:
IM/
CAN/
WP­
99.02
(
IBR,
acetaldehyde,
acrolein,
see
40
CFR
63.14(
f));
OR
formaldehyde,
and
phenol
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
fb))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.
(
6)
each
process
unit
measure
emissions
of
benzene
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14
(
fb))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.
(
7)
each
press
that
measure
emissions
of
MDI
Method
320
in
appendix
A
processes
board
to
40
CFR
part
63;
OR
containing
MDI
resin
Conditional
Test
Method
(
CTM)
031
which
is
posted
on
http://
www.
epa.
gov/
ttn/
e
mc/
ctm.
html
(
8)
each
direct­
fired
measure
emissions
of
the
Method
29
in
appendix
A
process
unit
following
HAP
metals:
to
40
CFR
part
60.
You
arsenic,
beryllium,
cadmium,
must
analyze
samples
chromium,
lead,
manganese,
using
atomic
absorption
and
nickel.
spectroscopy
(
AAS).
(
9)
each
reconstituted
meet
the
design
specifications
wood
product
press
or
included
in
the
definition
of
reconstituted
wood
wood
products
enclosure
in
product
board
cooler
§
63.2292
of
subpart
DDDD
of
with
a
HAP
control
40
CFR
part
63
device
ok
­­­­­
Original
Message­­­­­
From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]
Sent:
Wednesday,
February
25,
2004
9:
54
AM
To:
Bromberg,
Kevin
L.
Cc:
'
Guinnup.
Dave@
epamail.
epa.
gov';
'
Edmond_
Toy@
omb.
eop.
gov';
Holman,
Keith
W.;
'
Hustvedt.
Ken@
epamail.
epa.
gov';
'
thrift.
mike@
epamail.
epa.
gov'
Subject:
Re:
Plywood
­
Benzene/
Acrolein
Response
and
other
SBA
Issues
for
Boilers
and
Plywood
If
you
send
any
more
faxes,
please
also
send
them
to
(
919)
685­
3219.

"
Bromberg,
Kevin
L."
To:
"'
Edmond_
Toy@
omb.
eop.
gov'"
<
kevin.
bromberg@
s
<
Edmond_
Toy@
omb.
eop.
gov>
ba.
gov>
cc:
Mike
Thrift/
DC/
USEPA/
US@
EPA,
Mary
Kissell/
RTP/
USEPA/
US@
EPA,
Ken
02/
25/
2004
09:
41
AM
Hustvedt/
RTP/
USEPA/
US@
EPA,
Dave
Guinnup/
RTP/
USEPA/
US@
EPA,
"
Holman,
Keith
W."
<
Keith.
Holman@
sba.
gov>
Subject:
Plywood
­
Benzene/
Acrolein
Response
and
other
SBA
Issues
for
Boilers
and
Plywood
Mary
­
still
need
that
contractor
response
on
the
benzene/
acrolein
that
you
promised
last
night­
otherwise
recommend
that
EPA
modify
table
2,
according
to
the
technical
analysis
showing
that
benzene
and
acrolein
are
not
detected
in
all
processes,
based
on
EPA's
own
dataset.

Other
significant
issues
yet
to
be
resolved
on
plywood
and
plywood:

1.
EPA
"
may"
approve
look­
up
table
risk­
based
exemptions
2.
co­
located
issue
(
boilers)
3.
property
boundary
­
risk
analysis
4.
12
month
rolling
average
vs.
monthly
­
note
that
all
the
recent
MACT
rules
(
to
my
recollection)
were
12
month
rolling
averages,
instead
of
monthly
limits
(
I
worked
on
a
series
of
coating
rules
most
recently).
5.
For
Dave
Guinnup
to
consider
on
the
issue
of:
14
month
deadline
for
submission
of
risk
analyses
­
two
suggestions
to
consider
­
24
months
if
facility
needs
to
make
modifications/
18
months
for
the
others
in
the
preamble
­
EPA"
s
expectation
that
lookup
analyses
will
be
reviewed
within
30
days;
tiered
analyses
within
60
days
to
determine
if
more
information
is
required.
Expect
approvals
within
90
days
of
receiving
all
appropriate
information
14
months
is
a
rather
short
deadline
­
EPA
won't
need
all
this
time.
The
expectations
in
the
guidance
will
help
provide
incentives
for
early
submission
without
Mike
Thrift's
legal
problem
of
tying
the
agency
to
a
deadline.
