Date:
December
15,
2003
Subject:
Determination
of
MACT
floors
and
MACT
for
the
Final
Plywood
and
Composite
Wood
Products
Industry
NESHAP
EPA
Contract
No.
68­
D­
01­
079;
EPA
Work
Assignment
No.
2­
12
RTI
Project
No.
08550.002.012
From:
Katie
Hanks
Becky
Nicholson
Kristin
Parrish
To:
Mary
Tom
Kissell
ESD/
WCPG
(
C439­
03)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
I.
Introduction
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
developing
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
the
plywood
and
composite
wood
products
(
PCWP)
source
category.
Plywood
and
composite
wood
products
include
the
following:
medium
density
fiberboard
(
MDF),
particleboard,
hardboard,
fiberboard,
oriented
strandboard
(
OSB),
softwood
plywood
and
veneer,
hardwood
plywood
and
veneer,
engineered
wood
products,
and
kiln­
dried
lumber.
The
NESHAP
was
proposed
in
the
Federal
Register
on
January
9,
2003.1
The
purpose
of
this
memorandum
is
to
document
the
methodology
used
to
determine
the
maximum
achievable
control
technology
(
MACT)
floors
for
new
and
existing
PCWP
facilities
for
the
final
NESHAP.
This
memorandum
also
provides
an
analysis
of
emission
control
options
more
stringent
than
the
MACT
floor.
Specifically,
Section
II
of
this
memorandum
provides
background
information
on
the
development
of
MACT;
Section
III
presents
the
MACT
floor
determinations;
Section
IV
presents
an
analysis
of
control
options
beyond
the
MACT
floor;
and
Section
V
summarizes
the
MACT
recommendations.

II.
Background
Section
112
of
the
Clean
Air
Act
(
CAA)
requires
that
EPA
establish
NESHAP
for
the
control
of
hazardous
air
pollutants
(
HAP)
from
both
new
and
existing
major
sources.
A
major
source
of
HAP
is
defined
as
any
stationary
source
or
group
of
stationary
sources
within
a
contiguous
area
and
under
common
control
that
emits
or
has
the
potential
to
emit,
considering
2
controls,
in
the
aggregate,
10
tons
per
year
or
more
of
any
single
HAP
or
25
tons
per
year
of
combined
HAP.
The
CAA
requires
the
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology,
or
MACT.
The
MACT
floor
is
the
minimum
control
level
allowed
for
NESHAP
and
is
defined
in
Section
112
(
d)(
3)
of
the
CAA.

The
requirements
for
new
sources
are
potentially
more
stringent
than
those
for
existing
sources.
For
new
sources,
Section
112(
d)(
3)
of
the
CAA
requires
EPA
to
set
standards
for
each
category
or
subcategory
that
are
at
least
as
stringent
as
"
the
emission
control
that
is
achieved
in
practice
by
the
best
controlled
similar
source."
For
existing
sources,
Section
112(
d)(
3)
requires
the
HAP
standards
to
be
no
less
stringent
than
"
the
average
emission
limitation
achieved
by
the
best­
performing
12
percent
of
the
existing
sources"
for
source
categories
or
subcategories
with
at
least
30
sources
and
"
the
average
emission
limitation
achieved
by
the
best­
performing
five
sources"
for
source
categories
or
subcategories
with
fewer
than
30
sources.
2
In
a
previous
rulemaking,
the
EPA
promulgated
a
final
rule
(
59
FR
29196)
that
presented
the
Agency's
interpretation
of
the
statutory
language
regarding
the
basis
of
the
MACT
floor.
3
The
EPA's
interpretation
of
the
"
average
emission
limitation"
is
that
it
means
a
measure
of
central
tendency,
such
as
the
median.
If
the
median
is
used
when
there
are
at
least
30
sources,
then
the
emission
level
achieved
by
the
source
and
its
control
system
that
is
at
the
bottom
of
the
top
6
percent
of
the
best­
performing
sources
(
i.
e.,
the
94th
percentile)
then
becomes
the
MACT
floor.
For
example,
assume
that
there
are
100
sources,
and
HAP
emissions
from
approximately
15
of
these
sources
(
15
percent
nationwide)
are
controlled
using
thermal
oxidizers
and
the
HAP
emissions
from
the
remainder
of
the
sources
are
uncontrolled.
In
this
example,
the
94th
percentile
is
represented
by
the
control
system
applied
to
the
source
ranked
at
number
6
(
6/
100
=
6
percent).
However,
in
this
example,
the
same
type
of
add­
on
control
technology
used
by
the
source
at
the
94th
percentile
(
thermal
oxidizer)
is
used
by
sources
ranked
below
the
94th
percentile.
Assuming
that
there
are
no
significant
design
or
operational
differences
between
the
different
thermal
oxidizers
that
would
affect
their
performance,
all
15
sources
equipped
with
thermal
oxidizers
would
be
considered
representative
of
the
MACT
floor.
Thus,
when
determining
the
performance
level
of
the
MACT
floor
technology,
EPA
would
evaluate
the
available
data
for
any
and
all
of
the
sources
equipped
with
thermal
oxidizers.

When
there
less
than
30
sources,
the
emission
level
achieved
by
the
source
and
its
control
system
that
is
the
median
of
the
5
sources
represents
the
MACT
floor.
For
example,
if
there
are
10
sources
nationwide
and
the
emissions
from
2
of
these
sources
are
controlled
with
thermal
oxidizers
and
the
emissions
from
the
remaining
8
are
uncontrolled,
then
the
MACT
floor
is
"
no
emission
reduction"
(
assuming
no
factors
other
than
controls
reduce
emissions)
because
the
top
5
sources
include
the
2
that
are
controlled,
plus
3
that
are
uncontrolled.
In
this
example,
the
median
source
(
the
source
ranked
"
number
3")
is
uncontrolled.

III.
Determination
of
MACT
Floors
This
section
discusses
the
methodology
used
to
determine
the
MACT
floor
for
PCWP
facilities.
The
MACT
floor
determinations
presented
in
this
section
are
based
on
groups
of
similar
3
equipment
across
the
source
category.
The
rationale
for
grouping
according
to
equipment
type
without
subcategorization
by
product
type
is
provided
in
a
separate
memorandum.
4
Similar
equipment
are
equipment
("
process
units")
that
are
similar
with
respect
to
design,
operation,
and
emissions.
Table
1
shows
the
various
process
unit
groups
and
the
equipment
that
are
included
in
each
group.
Separate
MACT
floor
determinations
were
made
for
each
process
unit
group
listed
in
Table
1.
The
general
approach
to
determining
the
MACT
floors
is
discussed
in
Section
II,
below.
The
MACT
floor
determinations
for
each
specific
process
unit
group
are
discussed
in
detail
in
Section
III.

TABLE
1.
PROCESS
UNITS
GROUPS
FOR
MACT
FLOOR
DETERMINATIONS
Process
unit
group
Number
of
process
units
nationwide
Equipment
included
in
process
unit
group
Primary
tube
dryers
71
Single­
stage
and
the
first
stage
of
multi­
stage
tube
dryers
at
particleboard,
MDF,
and
hardboard
plants
Secondary
tube
dryers
22
Second
stage
of
multi­
stage
tube
dryers
at
particleboard,
MDF,
and
hardboard
plants
Rotary
strand
dryers
123
Rotary
strand
dryers
at
OSB
and
LSL
plants
Conveyor
strand
dryers
8
Conveyor
strand
dryers
at
OSB
and
LSL
plants
Rotary
agricultural
fiber
dryers
3
Rotary
dryers
at
agriboard
plants
Dry
rotary
particle
dryers
58
Rotary
particle
dryers
at
particleboard,
MDF,
and
hardboard
plants
processing
furnish
with

30%
(
dry
basis)
inlet
moisture
content
at
dryer
inlet
temperature
of

600oF
Paddle­
type
particle
dryers
2
Dryers
at
one
particleboard
plant
Green
rotary
particle
dryers
84
Rotary
dryers
at
particleboard,
MDF,
and
hardboard
plants
processing
furnish
with
>
30%
(
dry
basis)
inlet
moisture
content
at
dryer
inlet
temperature
of
>
600oF
Hardboard
ovens
20
Heat
treatment
ovens
at
hardboard
plants
Hardboard
humidifiers
23
Humidifiers
at
hardboard
plants
Fiberboard
mat
dryer
(
bagasse)
1
Conveyor­
type
mat
dryer
at
a
fiberboard
plant
using
bagasse
Fiberboard
mat
dryers
(
wood)
10
Conveyor­
type
mat
dryers
at
fiberboard
and
wet/
dry
process
hardboard
plants
Press
preheat
ovens
5
Preheat
ovens
(
predryers)
at
wet/
dry
process
hardboard
plants
Veneer
kilns
10
Veneer
kilns
at
hardwood
and
softwood
plywood
plants
Veneer
redryers
9
Radio­
frequency
veneer
redryers
at
softwood
plywood
plants
Softwood
veneer
dryers
303
Veneer
dryers
at
softwood
plywood,
hardwood
plywood,
LVL,
and
PSL
plants
that
dry

30%
(
by
volume,
annually)
softwood
veneer
Hardwood
veneer
dryers
178
Veneer
dryers
at
softwood
plywood,
hardwood
plywood,
LVL,
and
PSL
plants
that
dry
<
30%
(
by
volume,
annually)
softwood
veneer
TABLE
1.
(
continued)
4
Process
unit
group
Number
of
process
units
nationwide
Equipment
included
in
process
unit
group
Particleboard
press
molds
41
Press
molds
used
for
molded
particleboard
products
Extruders
7
Particleboard
extrusion
presses
Engineered
wood
products
presses
and
curing
devices
96
Presses
and
radio­
frequency
curing
devices
at
LVL,
PSL,
LSL,
glulam,
and
I­
joist
plants
Agriboard
presses
8
Presses
at
agriboard
plants
Softwood
plywood
presses
226
Presses
at
softwood
plywood
plants
Hardwood
plywood
presses
321
Presses
at
hardwood
plywood
plants
Reconstituted
wood
products
presses
166
Presses
at
hardboard,
MDF,
OSB,
and
particleboard
plants
Reconstituted
wood
products
board
coolers
105
Board
coolers
at
hardboard,
MDF,
OSB,
and
particleboard
plants
Pressurized
refiners
43
Pressurized
refiners
(
digester/
refiner
units)
at
MDF
and
hardboard
plants
Stand­
alone
digesters
26
Digesters
at
MDF,
hardboard,
and
fiberboard
plants
Atmospheric
refiners
73
Non­
pressurized
refiners
at
MDF,
hardboard,
and
fiberboard
plants
Lumber
kilns
2934
Lumber
kilns
at
all
types
of
plants
Storage
tanks
>
804
Resin
tanks
at
hardboard,
MDF,
OSB,
softwood
plywood,
and
particleboard
plants
(
i.
e.,
those
plant
types
that
completed
the
MACT
general
survey)

Wastewater
operations
>
241
Wastewater
operations
at
plant
types
that
completed
the
MACT
general
survey
Wastewater
tanks
>
115
Wastewater
tanks
at
plant
types
that
completed
the
MACT
general
survey
Miscellaneous
coating
operations
Not
counted
Miscellaneous
coating
operations
at
plant
types
that
completed
the
MACT
general
survey
Blenders
Not
counted
Rotary
blenders
at
particleboard,
MDF,
or
OSB
plants
Formers
Not
counted
Wet
formers
at
fiberboard
and
hardboard
plants
and
dry
formers
at
particleboard,
MDF,
hardboard,
or
OSB
plants
Sanders
Not
counted
Sanders
at
all
plants
Saws
Not
counted
Saws
at
all
plants
Fiber
washers
Not
counted
Fiber
washers
at
fiberboard
or
hardboard
plants
Chippers
Not
counted
Log
chippers
and
veneer
or
panel
chippers
Log
vats
Not
counted
Log
vats
at
softwood
plywood
plants
MDF
=
medium
density
fiberboard,
OSB
=
oriented
strandboard,
LVL
=
laminated
veneer
lumber,
PSL
=
parallel
strand
lumber,
LSL
=
laminated
strand
lumber,
MACT
=
maximum
achievable
control
technology
5
A.
General
Approach
to
MACT
Floor
Determinations.

Both
uncontrolled
and
controlled
facility­
wide
emissions
data
would
be
needed
for
each
PCWP
facility
in
order
to
determine
the
percent
reduction
in
HAP
emissions
achieved
by
each
facility
and
then
rank
the
PCWP
facilities
based
on
performance.
Information
on
estimated
facility­
wide
HAP
emissions
was
not
collected
through
the
EPA's
industry
survey
because
industry
representatives
indicated
that
these
estimates
would
not
be
meaningful.
At
the
time
of
the
survey,
very
little
HAP
emissions
data
were
available
and
the
industry
(
via
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
[
NCASI])
was
in
the
process
of
completing
a
29­
facility
HAP
emission
test
program
for
the
specific
purpose
of
collecting
speciated
HAP
emissions
data.
While
the
data
from
the
emission
test
program
significantly
increased
the
amount
of
HAP
data
available,
only
selected
process
units
were
tested
at
each
facility.
Thus,
speciated
HAP
data
are
not
available
for
all
operations
at
PCWP
facilities.

Emission
factors
were
developed
to
estimate
facility­
wide
HAP
emissions
and
HAP
emission
reductions
for
each
PCWP
facility
(
for
the
purpose
of
estimating
the
nationwide
uncontrolled
and
baseline
emissions).
5
However,
these
estimated
facility­
wide
emissions
were
not
used
as
the
basis
for
the
MACT
floor
because
more
accurate
and
complete
data
at
the
process­
unit
level
are
available.
A
great
deal
of
information
and
emissions
data
are
available
for
dryers
and
presses,
which
are
generally
the
highest­
emitting
process
units
and
the
ones
most
likely
to
have
add­
on
control
systems
that
reduce
HAP
emissions
at
PCWP
facilities.
Therefore,
the
MACT
floor
methodology
was
applied
at
the
process­
unit
level.
With
this
approach,
the
source­
wide
MACT
floor
is
represented
by
the
MACT
floor
level
of
control
for
each
process
unit
group.

The
following
4­
step
approach
was
used
to
establish
MACT
floors
for
each
process
unit
group:

(
1)
Review
available
data
on
pollution
prevention
techniques
and
the
performance
of
add­
on
control
devices,
and
identify
which
techniques
are
best
at
reducing
HAP
emissions;

(
2)
For
each
process
unit
group
in
Table
1,
rank
the
process
units
in
that
group
from
the
best­
performing
to
the
worst
performing
based
on
the
emission
reduction
technique
applied
to
each
process
unit;

(
3)
For
each
process
unit
group,
identify
the
emission
reduction
technique
or
control
system
that
represents
the
MACT
floor
for
new
and
existing
units;
and
(
4)
Using
available
information,
determine
the
performance
level
of
the
emission
reduction
techniques
that
represent
the
MACT
floor
for
new
and
existing
process
units.

Each
of
these
steps
is
described
in
the
following
four
subsections.

1.
Identifying
the
best­
performing
emission
reduction
techniques.
Emission
reduction
techniques
in
use
the
PCWP
industry
include
add­
on
control
systems
and
incineration
of
process
6
exhaust
in
an
onsite
combustion
unit.
The
potential
for
pollution
prevention
also
exists
in
the
PCWP
industry;
however,
there
are
no
known
and
demonstrated
pollution
prevention
techniques
that
can
be
universally
applied
across
the
industry.
The
emissions
from
PCWP
process
units
are
associated
with
the
wood,
fuel
(
for
direct­
fired
dryers),
and
resin
processed
(
for
presses
and
blowline
tube
dryers).
To
determine
whether
emission
reductions
are
achieved
through
pollution
prevention
or
process
changes,
emissions
test
data
were
analyzed
with
respect
to
the
process
parameters
expected
to
have
the
most
significant
effect
on
HAP
emissions.
These
parameters
included
dryer
firing
method
(
direct
vs.
indirect­
firing),
wood
type
(
hardwood
vs.
softwood)
fuel
type
used
for
direct­
firing
(
natural
gas
vs.
wood),
resin
type
(
phenol­
formaldehyde
[
PF]
vs.
urea­
formaldehyde
[
UF]),
and
tube
dryer
blending
method
(
blowline
vs.
non­
blowline
blending).
The
technical
feasibility
of
process
changes
was
also
considered.
It
was
concluded
that
none
of
the
process
changes
considered
would
be
appropriate
for
consideration
in
MACT
analyses
because
these
process
changes
either
are
not
technically
feasible
or,
based
on
the
available
data,
would
not
result
in
any
emissions
reduction.
6
Any
pollution
prevention
measures
applied
at
PCWP
facilities
would
be
very
facility­
specific.
At
the
present
time,
no
facilities
have
been
identified
that
use
pollution
prevention
measures
to
achieve
an
emission
reduction
comparable
to
that
of
add­
on
control
devices.
Therefore,
the
MACT
analysis
focuses
on
add­
on
control
devices.

Available
data
on
control
device
performance
were
reviewed
to
determine
which
add­
on
control
systems
are
best
at
reducing
HAP
emissions.
The
control
device
performance
evaluation
focused
on
total
hydrocarbon
(
THC),
methanol,
and
formaldehyde.
These
three
pollutants
were
selected
because
they
were:
(
1)
consistently
measured
in
detectable
quantities
at
the
inlet
of
the
control
devices,
(
2)
the
most
prevalent
pollutants
emitted
across
the
various
types
of
process
units,
and
(
3)
the
most
frequently
tested
pollutants
(
thus,
more
data
were
available
for
these
three
pollutants).
Although
THC
is
not
a
HAP,
control
systems
that
are
effective
in
reducing
THC
emissions
are
generally
effective
in
reducing
HAP
emissions.
Therefore,
THC
can
be
a
good
indicator
of
the
performance
of
the
control
device.
Available
data
show
that
a
reduction
in
formaldehyde,
methanol,
or
THC
correlates
with
a
reduction
in
other
HAP
if
the
other
HAP
are
present
in
detectable
quantities
and
at
sufficient
concentration.
A
separate
memorandum
provides
further
details
on
selection
of
pollutants
for
the
compliance
options
in
the
final
PCWP
rule.
7
The
available
control
device
performance
data
for
the
PCWP
industry
shows
that
only
two
types
of
add­
on
air
pollution
control
devices
consistently
and
continuously
reduce
HAP
emissions:
incineration­
based
controls
(
including
regenerative
thermal
oxidizers
[
RTOs],
regenerative
catalytic
oxidizers
[
RCOs],
and
incineration
of
pollutants
in
onsite
process
combustion
equipment
[
process
incineration])
and
biofilters.
For
control
systems
that
use
onsite
process
combustion
equipment
(
e.
g.,
power
boilers
or
fuel
cells)
to
reduce
emissions,
only
those
systems
that
route
100
percent
of
the
process
unit's
exhaust
to
the
combustion
equipment
are
included
in
the
"
incineration­
based
controls"
category.
Several
of
the
process
incineration
systems
are
fully
integrated
systems
that
combine
heat/
energy
recovery
with
pollution
control.
Systems
that
only
incinerate
a
portion
of
the
process
unit
exhaust
stream
(
e.
g.,
less
than
75
percent)
are
referred
to
as
"
semi­
incineration"
and
are
not
included
in
the
incineration­
based
controls
category.

Those
PCWP
facilities
that
practice
semi­
incineration
take
a
portion
of
the
exhaust
stream
and
then
route
these
emissions
to
a
burner
for
use
as
combustion
air.
In
those
situations,
the
HAP
7
emissions
in
the
slip
stream
are
actually
combusted.
However,
some
facilities
with
direct­
fired
dryers
(
i.
e.,
dryers
that
receive
hot
exhaust
air
directly
from
combustion
source)
that
practice
semi­
incineration
may
also
use
the
dryer
exhaust
gas
slip
stream
(
or
fresh
air)
to
cool
the
exhaust
gas
from
the
burners
in
"
blend
chambers."
8
When
the
exhaust
gas
is
routed
to
the
blend
chamber,
the
HAP
in
the
exhaust
gas
are
not
combusted
in
the
dryer,
and
if
the
dryer
emissions
are
uncontrolled,
these
HAP
are
ultimately
emitted
to
the
atmosphere.
The
amount
of
exhaust
gas
recycled
either
to
the
burner
or
to
the
blend
chamber
can
vary
over
time.
Decisions
about
how
much
of
the
recycled
exhaust
stream
are
used
as
combustion
air
and
when
and
how
much
exhaust
air
is
used
in
a
blend
chamber
generally
are
made
by
the
equipment
operators
and
are
affected
by
process
conditions
such
as
the
moisture
content
of
the
incoming
wood
furnish
(
which
affects
the
target
dryer
operating
temperature)
and
the
desired
amount
of
water
removal.
9
Thus,
semiincineration
is
used
to
maintain
the
heat
balance
in
the
drying
system
(
e.
g.,
combustion
unit
and
dryer).
There
is
a
lack
of
detailed
information
on
how
the
semi­
incineration
process
works
at
each
facility,
and
thus,
the
actual
HAP
emission
reductions
that
are
achieved
at
PCWP
facilities
that
practice
semi­
incineration
cannot
be
determined/
verified.
In
addition,
it
may
not
be
possible
to
retrofit
semi­
incineration
onto
existing
process
units,
and
therefore,
semi­
incineration
may
not
be
an
option
for
process
units
that
were
not
originally
designed
to
incorporate
semi­
incineration.
For
the
reasons
stated
above
and
for
the
purpose
of
establishing
MACT
floors
for
the
PCWP
source
category,
semi­
incineration
is
not
considered
a
verified
control
technique
for
reducing
HAP
emissions.
However,
as
explained
later
in
Section
III.
B
of
this
memorandum,
there
are
only
two
process
unit
groups
(
bagasse
fiberboard
mat
dryers
and
hardwood
veneer
dryers)
where
semi­
incineration
is
the
only
available
candidate
for
the
MACT
floor
technology.

The
available
control
device
efficiency
data
show
that
control
devices
installed
for
particulate
matter
(
PM)
abatement
had
no
effect
on
gaseous
HAP
or
THC
emissions.
10
These
control
devices
include
cyclones,
multiclones
(
or
multicyclones),
baghouses
(
or
fabric
filters),
and
electrified
filter
beds
(
EFBs).
The
performance
data
for
wet
electrostatic
precipitators
(
WESPs)
and
wet
scrubbers
installed
for
PM
control
also
showed
no
effect
on
HAP
and
THC
emissions.
These
wet
systems
may
achieve
short­
term
reductions
in
THC
or
gaseous
HAP
emissions,
however,
the
HAP
and
THC
control
efficiency
data,
which
range
from
slightly
positive
to
negative
values,
indicate
that
the
ability
of
these
wet
systems
to
absorb
water­
soluble
compounds
(
such
as
formaldehyde)
diminishes
as
the
recirculating
scrubbing
liquid
becomes
saturated
with
these
compounds.
10
One
wet
scrubbing
system,
a
combination
water
tray
tower/
high
energy
venturi
scrubber
that
uses
treated
water
and
is
designed
to
minimize
emissions
of
both
PM
and
odorous
compounds
from
a
hardboard
press,
did
achieve
notable
HAP
and
THC
emissions
reductions.
This
system
reduces
formaldehyde
and
methanol
emissions
by
65
percent
and
50
percent,
respectively,
and
reduces
THC
emissions
by
86
percent.
10
The
THC,
methanol,
and
formaldehyde
control
device
performance
data
for
incinerationbased
control
and
biofilters
are
presented
in
Attachment
1.
The
information
in
Attachment
1
was
extracted
from
a
separate
memorandum
which
provides
information
on
the
available
control
device
performance
data
for
the
various
types
of
control
devices
applied
to
PCWP
process
units.
10
The
performance
data
for
the
incineration­
based
controls
and
biofilters
showed
methanol
and
formaldehyde
emission
reductions
equal
to
or
greater
than
90
percent,
except
in
some
cases
where
the
pollutant
loadings
of
the
emission
stream
entering
the
control
systems
were
very
low.
The
8
performance
data
for
THC
showed
that
incineration­
based
control
systems
could
achieve
THC
emission
reductions
equal
to
or
greater
than
90
percent.
The
THC
emission
reductions
achieved
with
biofilters
varied
somewhat,
with
THC
reductions
ranging
from
73
percent
to
90
percent.
Although
biofilters
are
effective
in
reducing
the
HAP
compounds
emitted
from
process
units
in
the
PCWP
industry,
they
can
be
less
effective
in
reducing
some
of
the
less
water­
soluble
non­
HAP
compounds,
such
as
pinenes,
that
can
make
up
a
portion
of
the
THC
measurements.

2.
Ranking
of
process
units.
As
discussed
above,
similar
types
of
equipment
were
grouped
together
and
defined,
and
then
separate
process
unit­
based
MACT
floors
were
established
for
each
equipment
group.
These
equipment
groupings
are
shown
in
Table
1
as
"
process
units."
The
process
units
were
ranked
within
each
process
unit
group
according
to
the
HAP
control
devices
that
were
applied.
Information
on
the
number
of
process
units
nationwide
and
the
types
of
add­
on
control
devices
applied
to
process
units
is
based
primarily
on
responses
to
EPA's
survey
of
the
industry
(
MACT
survey)
and
is
summarized
in
the
Background
Information
Document.
11
The
ranked
process
units
equipped
with
incineration­
based
control
systems
or
biofilters
were
treated
as
being
equivalent
with
respect
to
their
potential
to
reduce
HAP
emissions.
The
available
information
(
e.
g.,
RTO
operating
temperatures)
showed
no
significant
design
or
operational
differences
among
each
type
of
control
system
evaluated
that
would
affect
the
ranking
of
process
units.
Details
on
the
number
of
controlled
and
uncontrolled
process
units
in
each
process
unit
group
are
provided
in
Section
III.
B
of
this
memorandum.

3.
Identifying
MACT
floor
technologies.
With
some
exceptions,
there
are
at
least
30
units
in
each
process
unit
group.
As
explained
in
Section
II,
when
there
are
at
least
30
process
units
in
a
process
unit
group,
the
emission
level
achieved
by
the
process
unit
and
its
control
system
that
is
at
the
bottom
of
the
top
6
percent
of
the
best­
performing
process
units
(
i.
e.,
the
94th
percentile)
represents
the
MACT
floor.
When
there
are
less
than
30
process
units
in
a
process
unit
grouping,
the
MACT
floor
is
represented
by
the
emission
level
achieved
by
the
process
unit
and
its
control
system
that
is
the
median
of
the
5
best­
performing
process
units.
Information
on
the
total
nationwide
number
of
process
units
in
each
process
unit
grouping
is
provided
in
Table
1.

4.
Determining
the
performance
level
of
MACT
floor
technologies.
As
described
above,
the
proposed
MACT
floor
technology
for
the
process
units
was
either
determined
to
be
no
emission
reduction
or
equivalent
to
the
emission
reduction
achieved
with
incineration­
based
control
systems
or
biofilters.
Although
some
process
units
are
equipped
with
add­
on
controls
that
perform
at
a
level
somewhere
between
zero
(
no
control)
and
the
performance
level
achieved
with
incineration­
based
controls
and
biofilters,
none
of
these
control
systems
were
identified
as
MACT
floor
control
technologies
because
they
(
1)
do
not
reduce
HAP
emissions
(
e.
g.,
bag
houses)
or
(
2)
do
not
reduce
HAP
emissions
on
a
consistent
basis
(
e.
g.,
WESPs),
or
(
3)
achieve
lower
HAP
emission
reductions
than
biofilters
and
incineration­
based
controls
or
unquantifiable
emission
reductions
(
e.
g.,
semi­
incineration).
Therefore,
the
MACT
floor
analysis
focused
on
incinerationbased
controls
and
biofilters.

For
the
purpose
of
establishing
the
performance
level
of
the
MACT
floor
control
systems,
all
available
data
on
incineration­
based
controls
and
biofilters
were
grouped
together.
This
9
"
group
approach"
was
used
because
some
of
the
control
systems
treat
HAP
emissions
from
multiple
types
of
process
units,
such
as
primary
tube
dryers,
reconstituted
panel
presses,
and
board
coolers.
In
those
cases,
separate
determinations
of
the
performance
of
the
control
system
on
emissions
from
each
type
of
process
unit
were
not
possible.
Also,
for
some
process
unit
groups,
limited
data
were
available
for
the
control
systems
applied
to
the
process
units
in
that
group.
For
example,
there
are
303
softwood
veneer
dryers
nationwide,
and
64
of
these
have
incineration­
based
controls.
In
this
example,
the
94th
percentile
is
represented
by
the
control
system
applied
to
the
softwood
veneer
dryer
ranked
at
number
18
(
18/
303
=
6
percent),
which
is
an
incineration­
based
control
system.
Control
efficiency
data
are
only
available
for
nine
softwood
veneer
dryers;
data
are
not
available
for
the
18th
ranked
dryer.
Therefore,
it
was
necessary
to
conclude
that
the
emission
reduction
achieved
by
the
18th
ranked
veneer
dryer
was
the
same
as
the
emission
reduction
achieved
by
the
incineration­
based
controls
for
which
data
were
available.
By
considering
all
of
the
performance
data
for
incineration­
based
controls
and
biofilters
together,
the
amount
of
available
data
upon
which
the
MACT
floor
level
of
performance
was
based
was
maximized.

The
available
data
for
incineration­
based
controls
and
biofilters
(
provided
in
Attachment
1)
shows
variability
in
performance
from
process
unit
to
process
unit
and
over
time.
In
some
cases,
it
was
not
possible
to
directly
compare
the
performance
of
different
control
systems
because
data
were
not
available
for
the
same
pollutant
(
i.
e.,
not
all
test
reports
included
data
for
THC,
methanol,
and
formaldehyde).
Comparison
of
the
performance
of
the
different
types
of
incineration­
based
control
systems
with
other
incineration­
based
controls
and
with
biofilters
was
also
hampered
by
the
fact
that
the
uncontrolled
emissions
being
treated
by
the
different
control
systems
varied
with
respect
to
pollutant
loading
(
inlet
concentration)
and
pollutant
type.
Because
the
control
device
efficiency
is
somewhat
dependent
on
the
amount
of
HAP
entering
the
device,
the
variability
in
the
uncontrolled
emissions
from
process
units
both
within
and
among
the
different
process
groups
meant
that
the
control
device
efficiencies
also
varied.
With
a
few
exceptions,
when
the
concentration
of
methanol,
formaldehyde,
or
THC
in
the
uncontrolled
emission
stream
was
greater
than
10
parts
per
million
dry
volume
(
ppmvd),
the
associated
HAP
emission
reductions
ranged
from
90
to
99
percent.
In
general,
lower
control
efficiencies
were
achieved
when
the
inlet
pollutant
concentrations
were
below
10
ppmvd;
however,
in
some
cases,
the
control
efficiency
exceeded
90
percent
even
at
the
lower
inlet
concentrations.

To
account
for
the
variability
in
the
type
and
amount
of
HAP
in
the
uncontrolled
emissions
from
the
various
process
units
and
the
effect
of
this
variability
on
control
system
performance,
it
is
recommended
that
the
MACT
floor
performance
level
be
based
on
all
three
of
the
pollutants
analyzed
and
include
maximum
concentration
levels
in
the
outlet
of
the
control
systems
as
an
alternative
to
emission
reductions.
The
MACT
floor
performance
level
is
a
90
percent
reduction
in
THC
or
methanol
or
formaldehyde
emissions.
The
maximum
concentration
level
in
the
outlet
of
the
MACT
floor
control
system
is
20
ppmvd
for
THC,
or
1
ppmvd
for
methanol,
or
1
ppmvd
for
formaldehyde.
The
20
ppmvd
is
recommended
as
the
alternative
maximum
concentration
for
THC
because
20
ppmvd
represents
the
practical
limit
of
control
for
THC.
The
1
ppmvd
is
recommended
as
the
maximum
outlet
concentration
for
both
methanol
and
formaldehyde
because
this
concentration
is
achieved
by
the
MACT
floor
control
10
systems
and
the
method
detection
limits
for
these
compounds
using
the
NCASI
impinger/
canister
emission
test
method
(
NCASI
Method
IM/
CAN/
WP­
99.01)
are
less
than
1
ppmvd.
12
The
six
recommended
options
for
representing
the
MACT
floor
are
shown
in
Table
2.
These
six
options
reflect
the
emission
reductions
and
maximum
outlet
pollutant
concentrations
achieved
at
the
MACT
floor
for
all
process
units
with
a
MACT
floor
technology
represented
by
incineration­
based
controls
or
biofilters.
As
shown
in
Table
2,
it
is
recommended
that
a
restriction
be
placed
on
the
use
of
the
outlet
concentration
options
for
methanol
and
formaldehyde.
The
proposed
restriction
would
be
that
the
concentration
of
the
pollutant
(
methanol
or
formaldehyde)
entering
the
MACT
control
system
must
be
at
least
10
ppmvd
for
the
facility
to
use
the
outlet
concentration
option.
The
purpose
for
this
restriction
is
that
some
process
units
may
have
very
low
uncontrolled
methanol
or
formaldehyde
emissions,
while
still
emitting
significant
quantities
of
HAP,
and
facilities
with
these
process
units
could
claim
that
they
are
achieving
MACT
floor
levels
of
control
without
doing
anything
to
reduce
HAP
emissions.
All
of
the
MACT
floor
control
systems
evaluated
can
meet
at
least
one
of
the
six
control
options
for
add­
on
control
devices,
based
on
the
available
data.
Only
a
few
of
the
MACT
floor
control
systems
evaluated
can
meet
all
six
options;
in
those
cases,
the
control
systems
tend
to
be
applied
to
process
units
with
both
moderately
high
HAP
emissions
and
moderately
high
THC
emissions,
which
would
allow
them
to
meet
the
outlet
concentration­
based
options
for
methanol
and
formaldehyde
as
well
as
the
percent
reduction
options.
For
a
few
process
units,
such
as
the
veneer
dryer
identified
as
plant
No.
170­
XDV1
(
See
Attachment
1,
Table
1)
the
concentration
of
THC
entering
the
control
system
is
very
high
(>
5,000
ppmvd)
and
while
the
applied
control
system
can
achieve
a
high
THC
reduction
(
97.3
percent),
the
outlet
concentration
of
THC
is
greater
than
20
ppmvd,
and
thus,
this
unit
could
not
meet
the
20
ppmvd
THC
outlet
concentration
option.
Formaldehyde
data
for
this
same
veneer
dryer
show
that
it
emits
low
quantities
of
formaldehyde
(
about
4.5
ppmvd)
and
that
it
cannot
meet
the
90
percent
reduction
option
for
formaldehyde
(
data
show
a
51
percent
reduction).
Furthermore,
because
the
concentration
of
formaldehyde
entering
the
control
system
is
less
than
10
ppmvd,
this
process
unit
would
be
not
be
allowed
to
use
the
outlet
concentration
option
for
formaldehyde.
Because
process
units
with
uncontrolled
emissions
of
formaldehyde
and
methanol
less
than
10
ppmvd
are
excluded
from
the
two
outlet
concentration­
based
options
for
formaldehyde
and
methanol,
at
a
maximum,
these
process
units
could
comply
with
only
four
of
the
six
options
in
Table
2.
Therefore,
it
is
recommended
that
facilities
be
required
to
meet
only
one
of
the
six
emission
options
in
Table
2.
11
TABLE
2.
MACT
FLOOR
CONTROL
OPTIONS
Pollutant
Reduce
by
OR
achieve
emissions

methanol
90
percent
1
ppma
...
OR...

formaldehyde
90
percent
1
ppma
...
OR...

THCb
90
percent
20
ppm
a
This
option
would
only
be
applicable
to
units
with
uncontrolled
emissions
of
that
HAP
that
are

10
ppm.
b
Mills
will
be
allowed
to
adjust
THC
measurements
to
subtract
methane.

B.
MACT
Floor
Determinations
by
Process
Unit
Group
The
MACT
floor
determinations
for
each
process
unit
group
shown
in
Table
1
are
discussed
in
the
following
sections.
The
MACT
floors
were
determined
for
new
and
existing
process
unit
groups
using
the
methodology
described
in
Section
III.
A,
above.
This
section
describes
the
equipment
included
in
each
process
unit
group
and
summarizes
the
equipment
and
control
counts
used
in
establishing
the
MACT
floor
for
each
group.
Detailed
control
counts
are
presented
in
Chapter
2
of
the
Background
Information
Document
for
the
proposed
PCWP
rulemaking.
11
1.
Tube
dryers.
Tube
dryers
are
operated
by
plants
that
manufacture
MDF,
dry
process
hardboard,
and
particleboard.
Tube
drying
may
be
performed
in
single­
stage
or
multi­
stage
tube
drying
systems.
Most
of
the
staged
tube
drying
systems
used
in
the
PCWP
industry
incorporate
two
stages.
One
plant
uses
a
three­
stage
tube
drying
system,
but
the
third
stage
at
this
plant
does
not
remove
moisture
from
the
wood
material
and
was
not
considered
to
be
a
dryer
for
the
MACT
floor
analysis.
13
In
multi­
stage
tube
dryers,
there
is
a
primary
tube
dryer
and
a
secondary
tube
dryer
in
series
separated
by
an
emission
point.
Approximately
95
percent
of
the
HAP
from
staged
tube
drying
systems
are
emitted
from
the
primary
tube
dryer.
The
HAP
emissions
from
primary
tube
dryers
in
staged
tube
drying
systems
are
similar
to
the
emissions
from
single­
stage
tube
drying
systems.
Resin
is
often
added
to
the
wood
furnish
through
a
blowline
as
the
furnish
enters
the
primary
tube
dryer.
Therefore,
a
distinction
was
made
between
primary
tube
dryers
(
i.
e.,
single­
stage
tube
dryers
and
the
first
stage
of
multi­
stage
drying
systems)
and
secondary
tube
dryers
(
i.
e.,
the
second
stage
of
multi­
stage
tube
drying
systems).

There
are
a
total
of
71
primary
tube
dryers
used
in
the
PCWP
industry.
Sixteen
(
23
percent)
of
these
primary
tube
dryers
operate
with
incineration­
based
controls
and
one
additional
primary
tube
dryer
operates
with
semi­
incineration.
As
discussed
in
Section
II,
the
MACT
floor
for
existing
sources
is
based
on
the
control
level
achieved
by
the
source
ranked
at
the
6th
percentile
for
equipment
groups
with
at
least
30
units.
Because
there
are
more
than
30
primary
tube
dryers,
and
at
least
6
percent
have
incineration­
based
controls,
the
MACT
floor
control
system
for
existing
primary
tube
dryers
is
the
emission
reduction
achieved
with
12
incineration­
based
control.
The
MACT
floor
for
new
primary
tube
dryers
is
based
on
the
best
controlled
source.
Therefore,
the
MACT
floor
control
system
for
new
primary
tube
dryers
is
also
the
emission
reduction
achieved
with
incineration­
based
control.
Because
blowline
emissions
exit
with
the
primary
tube
dryer
exhaust,
it
follows
that
the
MACT
floor
for
blowline
emissions
integrated
with
existing
or
new
primary
tube
dryers
is
also
the
emission
reduction
achieved
with
incineration­
based
control.

There
are
22
secondary
tube
dryers
operated
in
the
PCWP
industry.
Four
of
these
secondary
tube
dryers
operate
with
incineration­
based
controls.
Because
there
are
less
than
30
secondary
tube
dryers,
the
MACT
floor
for
existing
dryers
is
based
on
the
control
level
achieved
by
the
third
best­
controlled
dryer.
The
third
best­
controlled
dryer
has
incineration­
based
control.
Therefore,
the
MACT
floor
control
system
for
new
and
existing
secondary
tube
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control.

2.
Strand
dryers.
Strand
dryers
are
operated
by
plants
that
manufacture
OSB
and
laminated
strand
lumber
(
LSL).
There
are
two
types
of
strand
dryers:
rotary
strand
dryers
and
conveyor
strand
dryers.
Both
types
of
strand
dryers
are
operated
at
OSB
and
LSL
plants.
Rotary
strand
dryers
operate
at
much
higher
inlet
temperatures
(
e.
g.,
often
900
°
F)
than
do
conveyor
dryers
(
e.
g.,
typically
<
400
°
F),
and
rotary
dryers
provide
greater
agitation
of
the
wood
strands
than
do
conveyor
dryers.
14,15
As
a
result,
the
emissions
from
conveyor
dryers
are
lower
than
the
emissions
from
rotary
strand
dryers.
The
emissions
test
data
for
conveyor
dryers
(
only
formaldehyde
and
THC
data
are
available)
indicate
that
formaldehyde
emissions
from
conveyor
dryers
are
1
to
2
orders
of
magnitude
less
than
for
rotary
strand
dryers.
The
THC
emissions
are
also
lower
for
conveyor
dryers
than
for
rotary
dryers.
5
Thus,
rotary
and
conveyor
strand
dryers
were
treated
separately
for
purposes
of
determining
MACT
floors.

There
are
a
total
of
123
rotary
strand
dryers
in
use
in
the
PCWP
industry.
Of
the
123
dryers,
87
(
or
71
percent)
operate
with
incineration­
based
controls.
Because
there
are
more
than
30
rotary
strand
dryers,
and
more
than
6
percent
have
incineration­
based
controls,
the
MACT
floor
control
system
for
new
and
existing
rotary
strand
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control.

There
are
eight
conveyor
strand
dryers
used
in
the
PCWP
industry.
During
the
public
comment
period
following
proposal
of
the
PCWP
NESHAP,
one
commenter
pointed
out
that
conveyor
dryers
have
distinct
zones
with
their
own
heating
system
and
exhaust.
16
Further
review
of
the
MACT
survey
data
indicates
that
all
of
the
conveyor
dryers
in
the
U.
S.
have
three
zones.
Three
conveyor
dryers
route
emissions
from
zone
1
to
an
onsite
combustion
unit
for
incineration;
the
remaining
zones
from
these
three
conveyor
dryers
have
no
HAP
control.
The
remaining
five
conveyor
dryers
have
no
HAP
control
(
i.
e.,
four
have
an
electrified
filter
bed,
and
one
routes
80
percent
of
the
exhaust
from
each
zone
to
a
blend
chamber
(
which
provides
no
HAP
control),
while
the
remaining
20
percent
of
the
exhaust
is
directed
to
the
atmosphere).
Because
there
are
less
than
30
conveyor
strand
dryers,
the
MACT
floor
is
based
on
the
control
level
achieved
by
the
third
best­
controlled
dryer.
Only
zone
1
of
the
third
best
controlled
conveyor
dryer
has
incineration­
based
control.
Therefore,
the
MACT
floor
for
existing
conveyor
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control
on
zone
1.
13
The
commenter
mentioned
above
noted
that
their
company
operates
12
strand
conveyor
dryers.
Six
of
these
conveyor
dryers
are
located
at
new
plants
that
were
not
included
in
the
MACT
floor
analysis
for
existing
sources.
These
six
conveyor
dryers
route
emissions
from
zones
1
and
2
to
a
closed
loop
incineration
system
for
emissions
control.
16,17
Given
that
newer
facilities
are
incinerating
conveyor
dryer
exhaust
from
zones
1
and
2,
and
that
the
MACT
floor
for
new
sources
is
based
on
the
best­
controlled
similar
sources,
it
was
determined
that
the
MACT
floor
for
new
conveyor
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control
for
exhausts
from
zones
1
and
2.

3.
Rotary
particle
dryers.
Rotary
particle
dryers
are
operated
by
plants
that
manufacture
particleboard
(
including
molded
particleboard
and
agriboard),
hardboard,
and
MDF.
The
emissions
from
rotary
dryers
used
by
agriboard
plants,
which
are
used
to
dry
agricultural
fiber
(
e.
g.,
straw
or
bagasse)
instead
of
wood,
are
different
than
the
emissions
from
rotary
dryers
used
to
dry
wood
particles.
Therefore,
it
is
recommended
that
the
rotary
agricultural
fiber
dryers
be
separated
from
the
rotary
wood
particle
dryers
for
purposes
of
determining
MACT
floors.

There
are
three
rotary
agricultural
fiber
dryers
used
in
the
PCWP
industry.
None
of
these
dryers
operates
with
HAP
controls.
Therefore,
the
MACT
floor
for
new
and
existing
rotary
agricultural
fiber
dryers
is
no
emission
reduction.

Mixtures
of
dry
and
green
material,
particularly
if
uncontrolled,
can
cause
problems
if
introduced
into
the
same
dryer
at
the
same
time.
Thus,
most
particleboard
dryers
are
dedicated
to
drying
either
relatively
dry
furnish
or
relatively
green
furnish.
11
(
Furnish
is
the
wood
material
that
is
dried
in
the
dryer.)
Particle
dryers
that
dry
"
green
wood
furnish"
emit
more
HAP
than
those
particle
dryers
that
dry
"
dry
wood
furnish."
Dry
dryers
(
i.
e.,
rotary
particle
dryers
that
process
dry
furnish)
can
be
characterized
by
low
inlet
furnish
moisture
content
and
low
inlet
dryer
temperature.
There
appears
to
be
an
approximately
linear
relationship
between
total
HAP
emissions
(
lb/
ODT)
and
change
in
furnish
moisture
content
across
the
particle
dryer,
and
between
total
HAP
and
dryer
inlet
temperature.
18
Total
HAP
emissions
appear
to
be
lower
for
smaller
reductions
in
furnish
moisture
and
lower
dryer
inlet
temperatures.
Therefore,
for
purposes
of
determining
MACT
floors,
it
is
recommended
that
a
distinction
be
made
between
dry
rotary
dryers
and
green
rotary
dryers.

Several
parameters
may
be
used
as
criteria
for
distinguishing
between
dry
rotary
dryers
and
green
rotary
dryers
including:
(
1)
reduction
in
furnish
moisture
content
across
the
dryer
(
delta
MC),
(
2)
change
in
operating
temperature
across
the
dryer
(
delta
T),
(
3)
maximum
inlet
furnish
moisture
content,
and
(
4)
maximum
dryer
inlet
temperature.
Although
delta
MC
correlates
more
directly
with
total
HAP
emissions
than
does
the
inlet
furnish
moisture,
the
inlet
furnish
moisture
is
easier
to
measure
and
record
than
delta
MC.
(
Measurement
of
delta
MC
would
require
measurement
of
furnish
moisture
at
both
the
dryer
inlet
and
outlet,
while
the
inlet
furnish
moisture
must
only
be
measured
at
the
dryer
inlet.)
Based
on
the
MACT
survey
results,
nearly
all
rotary
dryers
that
have
a
small
delta
MC
also
have
a
low
inlet
furnish
moisture
content.
Therefore,
inlet
moisture
content
seems
more
reasonable
than
delta
MC
for
distinguishing
between
dryer
and
green
rotary
dryers.
There
was
a
stronger
correlation
between
dryer
inlet
temperature
and
total
HAP
emissions
than
there
is
between
delta
T
and
total
HAP
emissions.
Thus,
maximum
dryer
14
inlet
temperature
was
selected
as
the
temperature
parameter
for
distinguishing
between
dry
and
green
rotary
dryers.

The
moisture
content
of
the
particles
entering
the
dryers
may
be
as
high
as
50
percent
on
a
wet
basis
(
100
percent
on
a
dry
basis).
Planer
shavings
are
the
predominant
material
used
in
the
manufacture
of
particleboard.
19
The
inlet
moisture
content
associated
with
green
planer
shavings
in
the
Northwest
is
about
30
percent
(
dry
basis).
20
The
moisture
content
of
green
pines
is
higher
(
80
to
200
percent,
dry
basis)
than
the
moisture
content
of
green
Douglas
fir
(
40
percent),
a
common
wood
source
in
the
Northwest.
19
Dry
planer
shavings
have
a
moisture
content
of
about
15
percent.
Urban
wood
(
another
source
of
pre­
dried
wood)
has
a
moisture
content
of
15
to
25
percent.
20
Thus,
30
percent
was
selected
as
the
maximum
inlet
moisture
content
for
distinguishing
between
dry
and
green
dryers
because
30
percent
appeared
to
be
the
dividing
line
between
the
wettest
"
dry"
material
and
the
driest
green
material.
Also,
the
30
percent
represents
a
maximum
value
which
cannot
be
exceeded,
as
opposed
to
an
average
value.
The
MACT
survey
data
show
that
the
industry
average
furnish
moisture
content
at
the
rotary
particle
dryer
inlet
(
including
both
dry
and
green
dryers)
is
around
36
percent
(
dry
basis)
and
is
around
9
percent
(
dry
basis)
at
the
rotary
dryer
outlet.
21
Dryer
inlet
temperatures
may
be
as
high
as
1500

F
to
1600

F
if
the
furnish
is
wet;
for
dry
furnish,
inlet
temperatures
are
reduced
to
about
500

F
to
600

F.
Dry
furnish,
such
as
dry
planer
shavings,
is
introduced
into
the
rotary
dryer
at
a
dryer
inlet
temperature
of
600

F
or
less.
19
Thus,
600

F
was
selected
as
the
maximum
inlet
temperature
for
distinguishing
between
dry
dryers
and
green
dryers.

Furnish
moisture
content
ranges
and
dryer
inlet
temperatures
were
reported
in
the
responses
to
the
EPA's
MACT
survey.
14
Based
on
the
survey
responses,
there
are
58
rotary
dryers
in
the
PCWP
industry
that
operate
with
a
maximum
inlet
temperature
of
600

F
or
less
and
process
furnish
with
a
moisture
content
of
30
percent
or
less,
dry
basis.
None
of
the
dry
rotary
particle
dryers
operate
with
HAP
controls.
Therefore,
the
MACT
floor
for
new
and
existing
dry
particle
dryers
is
no
emission
reduction.

Instead
of
rotary
particle
dryers,
one
particleboard
plant
operates
two
paddle­
type
particle
dryers
that
operate
below
600

F
and
process
furnish
with
less
than
30
percent
moisture
content,
dry
basis.
Neither
of
these
dryers
is
controlled.
Thus,
regardless
if
considered
separately
or
with
the
dry
rotary
particle
dryers,
the
MACT
floor
for
these
paddle­
type
dryers
is
no
emission
reduction.

There
are
84
rotary
particle
dryers
in
the
PCWP
industry
that
operate
with
a
maximum
inlet
temperature
of
greater
than
600

F
and
dry
furnish
with
a
moisture
content
greater
than
30
percent,
dry
basis.
Of
these
green
dryers,
nine
(
11
percent)
have
incineration­
based
controls
and
one
has
semi­
incineration.
Because
there
are
more
than
30
green
dryers
and
more
than
6
percent
have
incineration­
based
controls,
the
MACT
floor
control
system
for
new
and
existing
green
rotary
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control.
15
4.
Hardboard
ovens
and
humidifiers.
Hardboard
ovens
and
humidifiers
are
operated
at
wet­,
wet/
dry­
and
dry­
formed
hardboard
plants
to
heat
treat
pressed
hardboard.
Hardboard
ovens
are
used
to
lower
the
moisture
content
of
pressed
hardboard
to
bone
dry
levels
to
improve
dimensional
stability
and
enhance
board
mechanical
properties.
Humidification
of
boards
is
done
immediately
following
heat
treatment
to
bring
the
board
moisture
content
back
into
equilibrium
with
ambient
air
conditions.
22
Humidifiers
are
often
integrated
with
hardboard
ovens
(
i.
e.,
the
boards
coming
out
of
the
hardboard
oven
go
straight
into
the
humidifier).
However,
the
hardboard
oven
and
humidifier
have
separate
vents,
and
thus,
are
separate
emission
points.
22
Because
humidifiers
serve
only
to
add
moisture
to
boards,
they
are
not
a
significant
source
of
HAP
emissions.
Total
HAP
emissions
from
hardboard
ovens
are
much
higher
than
the
total
HAP
emissions
from
humidifiers.
Therefore,
it
is
recommended
that
hardboard
ovens
and
humidifiers
be
treated
separately
for
purposes
of
determining
MACT
floors.
It
is
also
recommended
that
the
PCWP
regulation
clearly
distinguish
between
the
heat
treating
chambers
of
hardboard
ovens
and
the
humidifier
so
that
applicability
determinations
will
not
be
confused
for
integrated
systems.

There
are
a
total
of
20
hardboard
ovens
used
in
the
PCWP
industry.
Of
these
20
ovens,
3
operate
with
incineration­
based
controls.
Because
there
are
less
than
30
hardboard
ovens,
the
MACT
floor
for
existing
ovens
is
based
on
the
control
level
achieved
by
the
third
best­
controlled
oven.
Thus,
the
MACT
floor
control
system
for
new
and
existing
hardboard
ovens
is
the
emission
reduction
achieved
with
incineration­
based
control.

There
are
a
total
of
23
humidifiers
in
the
PCWP
industry.
All
of
these
humidifiers
are
uncontrolled.
Therefore,
the
MACT
floor
for
new
and
existing
humidifiers
is
no
emission
reduction.

5.
Fiberboard
mat
dryers.
Fiberboard
mat
dryers
are
conveyor­
type
dryers
used
to
dry
wet­
formed
fiber
mats
at
fiberboard
and
wet/
dry­
process
hardboard
plants.
The
mat
dryers
at
fiberboard
and
hardboard
plants
are
of
similar
design
and
operate
at
similar
temperatures.
Therefore,
it
is
recommended
that
the
dryers
be
grouped
for
purposes
of
determining
the
MACT
floor.

There
is
one
fiberboard
mat
dryer
that
dries
a
bagasse
fiber
slurry.
It
is
expected
that
the
emissions
from
the
bagasse
fiberboard
dryer
differ
from
wood
fiber
dryer
emissions.
Therefore,
it
is
recommended
that
the
MACT
floor
be
determined
separately
for
the
bagasse
fiber
dryer.
The
bagasse
dryer
operates
with
semi­
incineration
followed
by
a
wet
scrubber.
Based
on
the
survey
response
for
this
plant,
it
is
estimated
that
approximately
25
percent
of
the
dryer
exhaust
is
routed
to
a
combustion
unit;
however,
as
noted
in
Section
III.
A
of
this
memorandum,
the
potential
emission
reductions
associated
with
semi­
incineration
have
not
been
verified
and
no
HAP
emission
reductions
are
expected
to
result
from
the
use
of
wet
scrubbers
designed
for
particulate
control.
Therefore,
the
MACT
floor
for
both
new
and
existing
bagasse
fiberboard
mat
dryers
is
no
emission
reduction.

There
are
a
total
of
10
wood
fiber
mat
dryers
used
in
the
PCWP
industry.
One
of
these
dryers
is
controlled
by
an
RTO
and
one
is
controlled
by
semi­
incineration.
Because
there
are
less
than
30
fiberboard
mat
dryers,
and
because
the
third
best­
controlled
dryers
has
no
control,
the
16
MACT
floor
for
existing
fiberboard
mat
dryers
is
no
emission
reduction.
However,
the
MACT
floor
control
system
for
new
fiberboard
mat
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control.

6.
Press
preheat
ovens.
Press
preheat
ovens
are
operated
by
wet/
dry
process
hardboard
plants.
There
are
a
total
of
five
preheat
ovens
used
in
the
PCWP
industry.
Two
of
the
preheat
ovens
operate
with
incineration­
based
controls.
Because
there
are
less
than
30
preheat
ovens,
and
because
the
third
best­
controlled
oven
has
no
control,
the
MACT
floor
for
existing
preheat
ovens
is
no
emission
reduction.
However,
the
MACT
floor
control
system
for
new
press
preheat
ovens
is
the
emission
reduction
achieved
with
incineration­
based
control.

7.
Veneer
dryers.
Veneer
dryers
operate
at
softwood
and
hardwood
plywood
plants,
laminated
veneer
lumber
(
LVL)
plants,
and
parallel
strand
lumber
(
PSL)
plants.
There
is
a
difference
in
the
annual
emissions
from
hardwood
and
softwood
veneer
dryers
when
all
veneer
dryers
in
the
PCWP
industry
are
considered
together.
Hardwood
veneer
dryers
typically
process
far
less
veneer
on
an
annual
basis
than
do
softwood
veneer
dryers,
and
as
a
result
have
much
lower
emissions.
Therefore,
it
is
recommended
that
hardwood
and
softwood
veneer
dryers
be
treated
separately
for
purposes
of
determining
MACT
floors.
Wood
type
ratio
(
e.
g.,
volume
percent
softwood
or
hardwood)
may
be
used
to
distinguish
between
hardwood
and
softwood
veneer
dryers.
According
to
the
results
of
EPA's
MACT
survey,
the
majority
of
veneer
dryers
in
the
PCWP
industry
are
used
to
process
either
100
percent
hardwoods
or
100
percent
softwoods
on
an
annual
volume
basis.
Some
dryers
process
both
hardwoods
and
softwoods
during
a
given
year
but
are
generally
dedicated
to
processing
only
one
wood
type
(
e.
g.,
the
dryer
processes
92
percent
hardwoods
and
8
percent
softwoods
on
an
annual
basis).
To
allow
facilities
operational
flexibility
with
respect
to
processing
some
incidental
amounts
of
the
minority
wood
type
(
e.
g.,
8
percent
softwoods
in
the
above
example),
it
is
recommended
that
the
wood
type
ratio
used
to
distinguish
between
softwood
and
hardwood
veneer
dryers
be
30
percent
softwoods.
Using
this
ratio,
a
softwood
veneer
dryer
would
be
considered
to
be
a
veneer
dryer
that
processes
at
least
30
percent
(
by
volume)
softwood
species
on
an
annual
basis.
Conversely,
a
hardwood
veneer
dryer
would
be
considered
to
be
a
veneer
dryer
that
processes
less
than
30
percent
softwood
species
annually.

Some
plants
use
veneer
kilns
to
dry
veneer.
Veneer
kilns
operate
in
the
same
manner
as
lumber
kilns
(
described
in
subsection
10
below).
Because
veneer
kilns
are
designed
differently
than
conventional
veneer
dryers,
it
is
recommended
that
the
veneer
kilns
be
distinguished
from
conventional
veneer
dryers
for
purposes
of
determining
MACT
floors.
There
are
ten
veneer
kilns
(
two
softwood
kilns
and
eight
hardwood
kilns)
used
in
the
PCWP
industry.
None
of
the
veneer
kilns
have
air
pollution
controls.
Therefore
the
MACT
floor
for
new
and
existing
veneer
kilns
is
no
emission
reduction.

It
is
also
recommended
that
radio­
frequency
(
RF)
veneer
redryers
be
separated
from
conventional
veneer
dryers
for
purposes
of
determining
the
MACT
floors.
Radio­
frequency
veneer
redryers
have
much
lower
HAP
emissions
than
do
conventional
veneer
dryers,
and
RF
dryers
only
dry
a
fraction
of
the
veneer
typically
dried
in
conventional
dryers.
There
are
nine
RF
17
redryers
in
use
in
the
PCWP
industry.
Because
none
of
these
veneer
redryers
are
controlled,
the
MACT
floor
for
new
and
existing
RF
veneer
redryers
in
no
emission
reduction.

There
are
303
softwood
veneer
dryers
operated
in
the
PCWP
industry.
Of
these
softwood
veneer
dryers,
64
(
or
21
percent)
have
incineration­
based
controls.
An
additional
12
softwood
veneer
dryers
have
semi­
incineration.
Because
there
are
more
than
30
veneer
dryers
and
more
than
6
percent
have
incineration­
based
controls,
the
MACT
floor
for
new
and
existing
softwood
veneer
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control.

There
are
178
hardwood
veneer
dryers
in
use
in
the
PCWP
industry.
One
of
these
hardwood
veneer
dryers
operates
with
semi­
incineration.
Because
there
are
more
than
30
veneer
dryers
and
less
than
6
percent
have
controls,
the
MACT
floor
for
existing
hardwood
veneer
dryers
is
no
control.
Because
the
best
controlled
hardwood
veneer
dryer
employs
semi­
incineration,
which
represents
an
undefined
level
of
control,
the
MACT
floor
for
new
hardwood
veneer
dryers
is
also
no
emission
reduction.

8.
Presses
and
board
coolers.
Board
or
panel
presses
are
operated
by
plants
that
manufacture
hardboard,
MDF,
OSB,
particleboard,
agriboard,
and
plywood.
These
panel
presses
are
typically
multi­
opening,
platen
presses,
although
some
plants
operate
single­
opening
continuous
presses.
Other
types
of
presses
are
operated
by
engineered
wood
products
plants.
Board
coolers
are
typically
operated
by
particleboard
and
MDF
plants.
However,
some
hardboard
and
OSB
plants
also
operate
board
coolers.

Molded
particleboard
plants
operate
numerous
press
molds,
which
are
designed
differently
than
platen
particleboard
presses.
In
addition,
some
plants
produce
particleboard
panels
using
extruders
instead
of
multi­
opening
presses.
The
annual
HAP
emissions
from
press
molds
and
extruders
are
estimated
to
be
only
a
fraction
of
the
annual
HAP
emissions
from
conventional
particleboard
presses.
Plants
manufacturing
engineered
wood
products
such
as
LVL,
PSL,
and
LSL
use
microwave
or
RF
presses
to
press
billets,
which
are
much
thicker
than
panels.
Glulam
plants
use
clamps
to
press
laminated
beams
at
room­
temperature.
I­
joist
plants
do
not
use
presses,
but
use
curing
chambers
to
cure
the
adhesive
in
the
I­
joists.
The
emissions
from
engineered
wood
products
presses
and
curing
devices
are
much
lower
then
the
total
annual
HAP
emissions
from
most
panel
presses.
Given
the
differences
in
design
and
annual
HAP
emissions,
it
is
recommended
that
panel
presses
(
used
at
hardboard,
MDF,
OSB,
particleboard,
agriboard,
and
plywood
plants)
be
distinguished
from
press
molds,
extruders,
and
engineered
wood
products
presses
for
purposes
of
determining
the
MACT
floor
for
PCWP
presses.

There
are
41
particleboard
press
molds
and
there
are
believed
to
be
seven
extruders
used
in
the
PCWP
industry.
None
of
these
press
molds
and
extruders
have
HAP
controls.
Therefore,
the
MACT
floor
for
new
and
existing
press
molds
and
extruders
is
no
emission
reduction
regardless
of
whether
these
presses
are
grouped
together.

There
are
96
engineered
wood
products
presses
and
curing
devices
used
in
the
PCWP
industry
(
including
43
LVL
presses,
2
LSL
presses,
2
PSL
presses,
22
glulam
presses,
17
I­
joist
curing
ovens,
and
10
RF
curing
devices).
Emissions
from
all
of
these
engineered
wood
product
18
presses
and
curing
devices
are
uncontrolled;
therefore,
the
MACT
floor
for
new
and
existing
engineered
wood
product
presses
is
no
emission
reduction.

The
agriboard
presses
currently
used
in
the
PCWP
industry
are
typically
smaller
(
i.
e.,
fewer
openings)
with
much
lower
annual
throughputs
compared
to
conventional
particleboard
presses.
Agriboard
is
made
with
agricultural
fiber
that
is
pressed
using
methylene
diphenyl
diisocyanate
(
MDI)
resin.
The
small
amount
of
information
available
on
agriboard
press
emissions
suggests
that
the
emissions
of
MDI
are
very
low.
Due
to
the
difference
in
emissions
from
agriboard
presses
and
conventional
particleboard
presses,
it
is
recommended
that
agriboard
presses
be
treated
separately
from
the
particleboard
presses
for
purposes
of
determining
the
MACT
floor.
Eight
agriboard
presses
are
currently
used
in
the
PCWP
industry.
None
of
the
agriboard
presses
are
controlled.
Therefore,
the
MACT
floor
for
new
and
existing
agriboard
presses
is
no
emission
reduction.

Total
annual
HAP
emissions
from
plywood
presses
are
lower
than
the
HAP
emissions
from
the
reconstituted
wood
product
(
e.
g.,
hardboard,
MDF,
OSB,
and
particleboard)
presses.
Typical
emissions
from
softwood
plywood
presses
are
around
6
tons
per
year
(
tpy).
For
hardwood
plywood
presses,
the
typical
emissions
are
less
than
1
tpy.
The
average
emissions
from
reconstituted
wood
product
presses
are
typically
greater
than
20
tpy.
Also,
unlike
reconstituted
wood
product
presses
that
have
automatic
loaders
and
unloaders,
many
plywood
presses
are
loaded
manually.
Forklifts
must
often
travel
in
close
proximity
to
plywood
presses
to
collect
stacks
of
freshly
pressed
plywood.
For
these
reasons,
it
may
not
be
feasible
to
construct
an
enclosure
around
plywood
presses
to
capture
and
route
emissions
to
a
control
device.
23
Therefore,
it
is
recommended
that
a
distinction
be
made
between
plywood
presses
and
reconstituted
wood
product
presses
for
purposes
of
determining
the
MACT
floor.
Given
the
difference
in
emissions
from
hardwood
plywood
presses
and
softwood
plywood
presses,
it
is
also
recommended
that
hardwood
and
softwood
plywood
presses
be
treated
as
separate
equipment
groups
for
purposes
of
determining
the
MACT
floor.

There
are
321
hardwood
plywood
presses,
and
226
softwood
plywood
presses
in
use
in
the
PCWP
industry.
None
of
these
presses
have
HAP
controls.
Therefore,
the
MACT
floor
for
new
and
existing
hardwood
and
softwood
plywood
presses
is
no
emission
reduction.

The
reconstituted
wood
product
presses
used
by
hardboard,
MDF,
particleboard,
and
OSB
plants
are
of
similar
design.
The
ranges
of
total
annual
HAP
emissions
overlap
for
reconstituted
wood
product
presses.
24
Therefore,
it
is
recommended
that
reconstituted
wood
product
presses
be
treated
as
one
equipment
group
for
purposes
of
determining
the
MACT
floor.
Similarly,
it
is
recommended
that
the
board
coolers
operated
by
hardboard,
MDF,
particleboard,
and
OSB
plants
be
treated
as
one
equipment
group
for
purposes
of
determining
the
MACT
floor.

There
are
166
reconstituted
wood
product
presses
operated
at
hardboard,
MDF,
particleboard,
and
OSB
plants
in
the
PCWP
industry.
According
to
the
responses
to
EPA's
MACT
survey
and
information
collected
during
a
follow­
up
to
the
survey,
24
presses
are
equipped
with
an
enclosure
(
i.
e.,
essentially
100
percent
of
the
emissions
from
the
press
enclosure
are
captured)
followed
by
incineration­
based
controls
or
biofilters.
One
press
has
a
partial
19
enclosure
that
has
a
tested
capture
efficiency
of
99.8
percent
followed
by
an
incineration­
based
control
device.
11,25
Because
there
are
more
than
30
reconstituted
wood
product
presses,
and
15
percent
(
i.
e.,
25
of
166)
capture
and
control
HAP
emissions,
MACT
for
new
and
existing
presses
is
based
on
the
emission
reduction
achieved
with
a
control
system
that
incorporates
a
capture
device
and
incineration­
based
controls
or
biofilters.

The
majority
of
the
MACT
floor
press
enclosures
include
the
press
loader,
press,
and
the
press
unloader.
Because
the
loader
and
unloader
are
included
in
the
press
enclosure,
the
MACT
floor
for
the
loader
and
unloader
is
effectively
incineration­
based
control
or
a
biofilter.
Emissions
have
been
observed
from
hot
pressed
boards
in
the
unloader
and
emissions
data
indicate
that
emissions
from
the
unloader
may
be
significant
(
e.
g.,
13%
of
total
HAP
emissions
from
the
press
enclosure).
25
However,
because
the
resinated
wood
mats
are
formed
prior
to
the
loader
and
no
heat
is
applied
in
the
loader,
there
is
no
reason
to
believe
that
there
are
HAP
emissions
associated
with
the
press
loader.
Therefore,
it
is
recommended
that
reconstituted
wood
products
presses
be
defined
to
include
the
press
and,
if
applicable,
the
press
unloader
(
press
unloaders
would
not
be
applicable
for
continuous
presses).
Although
there
are
a
sufficient
number
of
MACT
floor
press
enclosures
that
include
the
loader,
emissions
data
are
not
available
to
support
that
the
loader
is
an
emission
source
by
itself.

There
are
105
reconstituted
wood
product
board
coolers
operated
at
hardboard,
MDF,
particleboard,
and
OSB
plants
in
the
PCWP
industry.
Of
these
board
coolers,
nine
operate
with
incineration­
based
controls
or
biofilters.
According
to
the
responses
to
EPA's
MACT
survey
six
(
or
5.7
percent)
of
the
controlled
coolers
are
fully
enclosed.
Because
there
are
more
than
30
reconstituted
wood
product
coolers,
and
less
than
6
percent
capture
and
control
HAP
emissions,
the
MACT
floor
for
existing
board
coolers
is
no
control.
However,
the
MACT
floor
for
new
board
coolers
is
based
on
the
emission
reduction
achieved
with
a
control
system
that
incorporates
a
capture
device
and
incineration­
based
controls
or
biofilters.

Information
submitted
during
the
public
comment
period
following
proposal
of
the
PCWP
NESHAP
indicates
that
the
press
enclosures
used
in
the
wood
products
industry
have
been
designed,
but
not
certified,
according
to
EPA
Method
204
criteria
(
40
CFR
part
51,
appendix
M)
for
permanent
total
enclosures
(
PTE).
26
A
review
of
available
permit
information
confirms
that
few
permits
have
required
full
Method
204
certification
for
reconstituted
wood
products
press
enclosures
although
many
of
these
press
enclosures
were
constructed
based
on
the
Method
204
design
criteria.
There
are
also
concerns
about
the
technical
feasibility
of
installing
a
Method
204
certified
PTE
around
heated
batch
pressing
operations.
Because
of
the
internal
pressurization
within
PCWP
press
enclosures,
small
amounts
of
fugitive
emissions
may
appear
around
the
outside
of
these
enclosures.
The
percentage
of
press
emissions
that
may
be
escaping
from
some
of
these
enclosures
has
not
been
quantified
but
is
expected
to
be
small
based
on
available
information.
The
presence
of
these
small
amounts
of
fugitive
emissions
would
preclude
Method
204
certification
of
these
presses,
despite
the
fact
that
they
were
designed
according
to
Method
204
specifications.
Completely
eliminating
these
fugitive
emissions
would
likely
require
increasing
the
flow
rate
to
the
control
device
by
a
factor
or
3
to
4
times
to
overcome
the
pressurization
within
the
enclosure;
however,
no
PCWP
facilities
have
attempted
to
do
this
because
the
existing
press
enclosures
meet
State
permit
requirements
and
increasing
the
flow
rate
20
would
significantly
increase
control
costs
due
to
the
need
for
new
control
equipment
to
handle
a
much
larger
and
more
dilute
emission
stream.
This
same
issue
applies
to
board
coolers
because
board
cooler
exhaust
is
sometimes
directed
into
the
press
enclosures
and
those
board
coolers
with
separate
enclosures
have
not
been
certified
according
to
EPA
Method
204.
Therefore,
the
MACT
floor
for
new
and
existing
presses
and
new
board
coolers
is
the
emission
reduction
achieved
by
an
enclosure
that
includes
most
of
the
design
elements
of
EPA
Method
204
(
but
is
not
certified
as
being
a
Method
204
PTE)
followed
by
incineration­
based
control
or
a
biofilter.
An
enclosure
around
a
press
or
new
board
cooler
that
meets
the
MACT
floor
would
incorporate
the
design
criteria
included
in
the
definition
of
"
wood
products
enclosure"
provided
below.

Wood
products
enclosure
means
a
permanently
installed
containment
that
was
designed
to
meet
the
following
physical
design
criteria:
1.
Any
natural
draft
opening
(
NDO)
shall
be
at
least
four
equivalent
opening
diameters
from
each
HAP­
emitting
point,
except
for
where
board
enters
and
exits
the
enclosure,
unless
otherwise
specified
by
the
Administrator.
2.
The
total
area
of
all
NDOs
shall
not
exceed
5
percent
of
the
surface
area
of
the
enclosure's
four
walls,
floor,
and
ceiling.
3.
The
average
facial
velocity
(
FV)
of
air
through
all
NDOs
shall
be
at
least
3,600
m/
hr
(
200
ft/
min).
The
direction
of
airflow
through
all
NDOs
shall
be
into
the
enclosure.
4.
All
access
doors
and
windows
whose
areas
are
not
included
in
2
and
are
not
included
in
the
calculation
of
FV
in
3
shall
be
closed
during
routine
operation
of
the
process.
5.
The
enclosure
is
designed
and
maintained
to
capture
all
emissions
for
discharge
through
a
control
device.

9.
Digesting
and
refining
operations.
Digesting
and
refining
operations
are
performed
at
hardboard,
fiberboard,
and
MDF
plants.
Digesting
is
the
process
of
steaming
or
water
soaking
wood
chips
so
that
the
chips
may
be
more
easily
rubbed
apart
or
ground
into
fibers
in
the
refiners.
There
are
varying
methods
for
digesting
and
refining
wood
chips.
Some
plants
operate
pressurized
refiners
that
perform
both
digesting
and
refining
in
one
processing
unit
while
maintaining
continuous
internal
pressure.
Other
plants
operate
stand­
alone
digesters
that
feed
into
one
or
more
atmospheric
refiners.
Most
stand­
alone
digesters
and
atmospheric
refiners
have
separate
emission
points
(
i.
e.,
each
digester
and
refiner
has
an
emission
point).
Pressurized
refiners
have
only
one
emission
point
at
the
refiner
outlet.
Pressurized
refiners
typically
operate
as
continuous
processing
units
(
i.
e.,
with
continuous
infeed
and
outfeed
of
wood
material),
while
stand­
alone
digesters
are
either
batch
or
continuous
units.
Because
of
the
different
designs,
it
is
recommended
that
a
distinction
be
made
between
pressurized
refiners,
stand­
alone
digesters,
and
atmospheric
refiners
for
purposes
of
determining
the
MACT
floor
for
existing
units.

Based
on
review
of
available
literature
and
review
of
MACT
survey
responses,
nearly
all
MDF
plants
and
many
dry
process
hardboard
plants
use
pressurized
refiners.
22
Some
wet/
dry
process
hardboard
plants
may
also
use
pressurized
refiners.
There
are
believed
to
be
43
pressurized
refiner
systems
in
use
in
the
PCWP
industry.
At
least
seven
(
and
possibly
as
many
as
14)
of
these
pressurized
refiners
vent
directly
into
tube
dryers
and
eventually
exhaust
through
the
incineration­
based
controls
at
the
tube
dryer
outlet.
The
pressurized
refiner
counts
were
based
on
process
flow
diagrams
and
other
information
submitted
with
the
MACT
survey
responses.
Given
21
the
varying
level
of
detail
on
the
flow
diagrams,
obtaining
an
exact
count
of
pressurized
refiners
was
not
possible.
However,
it
is
clear
that
at
least
seven
of
the
pressurized
refiners
are
controlled.
There
would
have
to
be
at
least
116
pressurized
refiners
operating
in
the
PCWP
industry
in
order
for
the
MACT
floor
for
pressurized
refiners
to
be
based
on
no
emission
reduction.
The
estimated
number
of
pressurized
refiners
(
43)
is
far
less
than
116.
Therefore,
it
was
concluded
that
the
MACT
floor
for
new
and
existing
pressurized
refiners
is
the
emission
reduction
achieved
with
incineration­
based
control.

Wet­
formed
hardboard
plants
typically
operate
stand­
alone
digesters
and
atmospheric
refiners.
Some
fiberboard
plants
also
operate
digesters,
and
all
operate
atmospheric
refiners.
The
stand­
alone
digesters
at
wet
hardboard
and
fiberboard
plants
use
either
steam
or
process
water
to
heat
the
wood
chips.
Based
on
the
process
flow
diagrams
submitted
with
the
MACT
survey
responses,
there
are
approximately
26
stand­
alone
digesters
and
73
atmospheric
refiners
operated
in
the
PCWP
industry.
None
of
the
stand­
alone
digesters
and
atmospheric
refiners
have
HAP
controls.
Therefore,
the
MACT
floor
for
new
and
existing
stand­
alone
digesters
and
atmospheric
refiners
is
no
emission
reduction.

10.
Lumber
kilns.
Lumber
kilns
are
used
to
produce
kiln­
dried
lumber.
Lumber
kilns
may
be
co­
located
with
plants
that
produce
particleboard,
plywood
or
other
types
of
wood
products
in
addition
to
the
kiln­
dried
lumber.
There
are
an
estimated
356
lumber
kilns
that
are
co­
located
with
facilities
that
manufacture
other
types
of
PCWP,
and
an
estimated
2,578
lumber
kilns
in
operation
at
plants
where
kiln­
dried
lumber
is
the
only
PCWP
manufactured
at
the
plant
(
e.
g.,
stand­
alone
sawmills).
27
Information
on
air
pollution
controls
was
available
only
for
the
356
co­
located
lumber
kilns.
None
of
these
kilns
is
equipped
with
emission
controls.
A
MACT
floor
determination
for
all
kilns
was
based
on
the
presence/
absence
of
controls
at
the
356
co­
located
kilns
because
the
co­
located
kilns
are
the
kilns
most
likely
to
be
located
at
major
source
facilities,
and
therefore,
are
the
most
likely
to
be
controlled.
Given
that
there
are
an
estimated
2,934
lumber
kilns,
176
(
0.06
x
2,934)
existing
lumber
kilns
would
have
to
be
equipped
with
air
pollution
controls
for
the
MACT
floor
for
lumber
kilns
to
be
something
other
than
no
emission
reduction.
Because
no
lumber
kilns
with
air
pollution
controls
have
been
identified,
the
MACT
floor
for
new
and
existing
lumber
kilns
was
determined
to
be
no
emission
reduction.

11.
Storage
tanks.
Resin
storage
tanks
are
located
at
most
PCWP
plants.
The
tanks
contain
UF,
PF,
MDI,
or
other
types
of
resins.
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.
23
Use
of
a
fixed
roof
does
not
reduce
emissions
unless
coupled
with
a
vapor
recovery
system.
Thus,
the
MACT
floor
for
existing
storage
tanks
is
no
emission
reduction.

One
plant
reported
use
of
a
carbon
canister
adsorber
on
an
MDI
resin
tank.
The
canister
is
used
to
prevent
moisture
from
entering
the
MDI
resin
system.
The
uncontrolled
emissions
from
this
MDI
tank
were
reported
to
be
negligible
and
the
control
achieved
by
the
carbon
canister
was
reported
as
unknown.
The
average
uncontrolled
annual
emissions
reported
for
individual
resin
22
tanks
are
less
than
0.01
ton
per
year
for
formaldehyde,
phenol,
methanol,
and
VOC;
and
less
then
0.001
ton
for
MDI.
21
The
annual
emissions
from
storage
tanks
are
low
because
the
resins
contained
in
the
storage
tanks
are
not
volatile
compounds
and
generally
have
a
low
percentage
of
HAP
(
e.
g.,
less
than
5
weight
percent
for
formaldehyde,
phenol,
and
methanol).
The
resins
used
by
the
PCWP
industry
are
around
30
to
65
percent
solids
(
i.
e.,
non­
volatile
material).
21
Because
of
the
low
volatility
of
the
materials
stored
in
PCWP
storage
tanks
and
because
most
tank
volumes
are
relatively
small,
nearly
all
of
the
PCWP
storage
tanks
would
be
exempted
from
the
Hazardous
Organic
NESHAP
(
HON)
storage
vessel
provisions
applicable
to
the
chemical
industry.
28
The
MDI
tank
with
the
carbon
canister
would
also
be
exempt
from
the
HON.
Given
that
the
carbon
canister
on
the
MDI
tank
does
little
to
reduce
HAP
emissions
(
because
the
uncontrolled
emissions
from
the
tank
are
negligible),
and
that
most
storage
tanks
would
be
exempt
from
the
HON
provisions
for
storage
vessels,
it
was
determined
that
the
MACT
floor
for
new
storage
tanks
is
also
no
emission
reduction.

12.
Wastewater
operations
and
tanks.
Wastewater
operations
are
operations
(
e.
g.,
lagoons,
log
vats,
clarifiers,
settling
ponds,
etc.)
used
for
handling
HAP­
containing
process
waters
or
wastewaters.
Wastewater
sources
at
PCWP
plants
include
hardboard
process
water,
various
wash
waters
(
e.
g.,
from
washing
of
the
glue
line,
blender,
dryers,
RTO,
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
flow
rates
were
provided.
When
comparing
the
flow
rates
and
concentrations
provided
for
these
23
wastewater
operations
to
the
applicability
criteria
for
the
HON
wastewater
provisions
(
40
CFR
63,
subpart
G),
it
was
determined
that
only
two
of
the
operations
could
emit
HAP
concentrations
high
enough
to
trigger
control
requirements
under
the
HON.
The
highest
reported
concentration
would
result
in
only
0.31
tpy
of
methanol
emitted
from
the
wastewater
stream.
The
results
from
sampling
of
water
streams
performed
by
the
NCASI
show
some
water
streams
with
methanol
concentrations
for
some
wastewater
streams
higher
then
those
reported
in
the
MACT
survey
responses.
However,
no
information
on
the
flow
rate
is
available
to
use
in
calculating
potential
emissions
from
the
wastewater
operations
tested.
28
Potential
control
methods
for
wastewater
operations
include
handling
of
the
wastewater
in
order
to
minimize
emissions
(
e.
g.,
through
hard
piping
or
a
closed
system),
use
of
biological
treatment,
or
use
of
closed
vent
systems
and
control
devices.
Available
data
indicate
that
no
PCWP
facilities
are
currently
employing
these
techniques
to
control
air
emissions
from
wastewater
operations.
Also,
no
data
are
available
to
suggest
that
HAP
emissions
from
wastewater
operations
are
the
subject
of
control
measures
that
could
correspond
to
an
identifiable
numerical
emission
level
or
reduction
rate.
Therefore,
based
on
the
available
information,
the
MACT
floor
for
new
and
existing
wastewater
operations
at
PCWP
facilities
was
determined
to
be
no
emission
reduction.

There
are
115
wastewater
storage
tanks
listed
in
the
non­
confidential
responses
to
the
MACT
survey.
14
The
HON
requires
that
certain
wastewater
storage
tanks
have
a
fixed
roof
and
other
tanks
(
containing
liquid
with
higher
vapor
pressures)
to
use
a
fixed
roof
and
closed
vent
system
that
routes
vapors
to
control
device;
use
fixed
roof
and
internal
floating
roof;
or
use
an
external
floating
roof.
It
is
expected
that
PCWP
wastewater
storage
tanks
would
meet
the
HON
23
applicability
for
tanks
required
to
have
a
fixed
roof
and
that
most
PCWP
tanks
already
have
a
fixed
roof.
Use
of
a
fixed
roof
does
not
reduce
emissions
unless
coupled
with
a
control
device.
Therefore,
based
on
the
available
information,
the
MACT
floor
for
new
and
existing
wastewater
storage
tanks
at
PCWP
facilities
was
determined
to
be
no
emission
reduction.

13.
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.
Table
3
summarizes
the
information
on
miscellaneous
coatings
received
in
response
to
the
MACT
survey.
Based
on
the
available
information,
there
is
no
basis
to
conclude
that
the
MACT
floor
for
new
or
existing
sources
is
represented
by
any
emission
reduction
for
several
of
miscellaneous
coating
processes
(
i.
e.,
antiskid
coatings,
primers,
wood
patches
applied
to
plywood,
concrete
forming
oil,
veneer
composing,
and
fire
retardants
applied
during
forming).

In
their
survey
responses
some
facilities
reported
the
use
of
water­
based
coatings
for
edge
seals,
nail
lines,
logo
paint,
shelving
edge
fillers,
and
trademark/
gradestamp
inks.
Other
facilities
reported
use
of
"
solvent­
based"
coatings
for
these
processes.
In
some
instances,
a
few
respondents
provided
information
on
the
percent
HAP
content
of
a
solvent­
based
coating.
14
However,
there
is
no
way
of
knowing
if
the
anecdotal
information
provided
by
these
facilities
is
representative
of
the
"
solvent­
based"
coatings
used
by
other
facilities.
A
search
of
online
MSDS
from
one
of
the
well­
established
PCWP
coating
suppliers
indicated
that
"
solvent­
based"
coatings
do
not
always
contain
HAP.
29
For
example,
the
solvent
may
be
mineral
oil,
acetone,
or
isopropyl
alcohol,
which
are
not
HAP.
Water­
based
coatings
typically
do
not
contain
HAP.
Thus,
the
water­
based
and
some
of
the
solvent­
based
coatings
reported
in
the
responses
to
the
MACT
survey
are
"
non­
HAP"
coatings.
These
coatings
were
analyzed
further
for
potential
MACT
floor
implications
as
shown
in
Table
4.
While
the
emission
reduction
that
will
be
achieved
as
a
result
of
these
coating
substitutions
cannot
be
determined,
it
is
clear
that
use
of
non­
HAP
coating
represents
the
MACT
floor.
It
is
recommended
that
the
miscellaneous
coating
processes
with
a
MACT
floor
requirement
to
use
non­
HAP
coating
be
identified
as
"
Group
1
miscellaneous
coating
operations"
in
the
final
rule,
where:

Group
1
miscellaneous
coating
operations
means
application
of
edge
seals,
nail
lines,
logo
(
or
other
information)
paint,
shelving
edge
fillers,
trademark/
gradestamp
inks,
and
wood
putty
patches
to
plywood
and
composite
wood
products
(
except
kiln­
dried
lumber)
on
the
same
site
where
the
plywood
and
composite
wood
products
are
manufactured.
Group
1
miscellaneous
coating
operations
also
include
application
of
synthetic
patches
to
plywood
at
new
affected
sources.

Kiln­
dried
lumber
is
excluded
from
the
requirement
to
use
non­
HAP
coatings
because
coatings
used
at
kiln­
dried
lumber
manufacturing
facilities
were
not
included
in
the
MACT
floor
analysis.
No
information
is
available
to
determine
the
floor
for
coatings
applied
to
kiln­
dried
lumber.
Although
trademarks/
gradestamps
are
applied
to
kiln
dried
lumber,
the
only
processes
covered
24
under
the
PCWP
affected
source
at
kiln­
dried
lumber
manufacturing
facilities
are
lumber
kilns.
It
is
also
recommended
that
the
definition
of
"
non­
HAP
coating"
be
based
on
the
description
of
non­
HAP
coatings
in
the
final
Wood
Building
Products
NESHAP
(
subpart
QQQQ).
30
This
definition
allows
for
unavoidable
trace
amounts
of
HAP
that
may
be
contained
in
the
raw
materials
used
to
produce
certain
coatings.
The
recommended
definition
of
non­
HAP
coating
is
as
follows:

Non­
HAP
coating
means
a
coating
with
HAP
contents
below
0.1
percent
by
mass
for
OSHA­
defined
carcinogens
as
specified
in
29
CFR
1910.1200(
d)(
4),
and
below
1.0
percent
by
mass
for
other
HAP
compounds.

TABLE
3.
MISCELLANEOUS
PROCESSES
PERFORMED
AT
PLYWOOD
AND
COMPOSITE
WOOD
PRODUCTS
PLANTS14,24,29,30,31
Description
of
Process
Product
typesa
Types
of
Material
Used
in
Process
Potential
HAP
emissions
Edge
seals
applied
to
a
reconstituted
wood
product
or
plywood
FB(
2),
FBB(
1),
HB(
1),
OSB(
24),
PB(
4),
PLY(
3),
SPW(
40)
water­
based
paint/
sealer,
wax,
putty
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.

Anti­
skid
coatings
applied
to
reconstituted
wood
products
HB(
2)
clear
liquid
slipsheet
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.

Primers
applied
to
siding
HB(
3)
latex
paint
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.

Manufacture
of
high
or
medium
density
overlay
(
HDO
or
MDO)
panels
PLY(
1),
SPW(
5)
phenolic
impregnated
paper,
overlay
or
selfadhesive
paper
sheets
Emissions
from
application
of
HDO
or
MDO
prior
to
pressing
exit
with
the
press
emissions.
Application
of
HDO
and
MDO
following
PCWP
pressing
is
covered
under
the
Wood
Building
Products
NESHAP.

Painting
of
company
logo,
information
on
plywood
or
reconstituted
wood
products
FB(
4),
FBB(
1),
HB(
8),
MDF(
2),
OSB(
24),
PB(
8),
PLY(
6),
SPW(
68)
water­
based
paint,
water­
based
ink,
solvent­
based
paint,
solvent­
based
ink,
oilbased
ink
Survey
data
include
one
aerosol
spray
paint
with
toluene
and
xylene.
However,
most
commonly
used
are
water­
based
products.
A
few
solvent­
based
products
are
used.
The
highest
(
and
only)
reported
HAP
content
for
any
of
these
is
20%
ethylene
glycol
and
4
%
methanol.

Application
of
trademarks
and
grade
stamp
to
reconstituted
wood
products
or
plywood
FB(
4),
HB(
3),
MDF(
4),
OSB(
24),
PB(
7),
PLY(
5),
SPW(
66),
SV(
1)
water­
based
ink,
oilbased
ink,
solventbased
ink
Survey
data
shows
some
solvent­
based
inks,
with
the
highest
reported
HAP
content
being
5%
ethylene
glycol.
Oilbased
likely
contain
mineral
oil
(
non­
HAP).
TABLE
3.
(
continued)
25
Description
of
Process
Product
typesa
Types
of
Material
Used
in
Process
Potential
HAP
emissions
Application
of
nail
lines
to
reconstituted
wood
products
or
plywood
FB(
3),
OSB(
10),
PB(
3)
water­
based
paint,
water­
based
ink,
oilbased
ink
One
facility
reports
using
solvent­
based
black
ink,
but
the
solvent
is
not
specified
and
no
percent
HAP
is
provided.

Synthetic
patches
applied
to
plywood
PLY(
7),
SPW(
69)
2­
part
epoxy,
polyurethane­
based
patch,
isocyanate­
based
patch,
water­
based
patch
Survey
data
show
that
some
contain
MDI
and/
or
ethylene
glycol.
The
highest
reported
HAP
content
is
45%
MDI
(
no
ethylene
glycol
percentage
is
reported).
As
shown
in
Appendix
H
of
the
baseline
emissions
memo,
only
a
small
fraction
of
MDI
is
emitted
during
hot
pressing
operations.
Synthetic
patches
are
not
hot
pressed
so
potential
MDI
emissions
from
synthetic
patching
are
likely
to
be
very
low.

Wood
patches
applied
to
plywood
PLY(
3),
SPW(
42)
wood/
veneer
patch,
hot
melt
patch,
polyurethane­
based
patch
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.

Wood
putty
applied
to
plywood
PLY(
4),
SPW(
25)
epoxy­
based
putty,
solvent­
based
putty,
water­
based
putty
Survey
data
shows
a
few
patches
to
be
solvent
based
while
rest
are
water
based.
Search
of
vendor
websites
shows
that
the
percent
solids
is
high
(>
50%),
meaning
the
putties
are
low
volatility.

Application
of
concrete
forming
oil
to
plywood
PLY(
2),
SPW(
37)
diesel
oil,
petroleumbased
oil,
napthenic
oil,
hydraulic
oil,
other
oils,
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.
(
Although
napthalene
is
a
HAP
it
may
not
volatilize
because
concrete
oil
application
occurs
at
ambient
temperature).

Veneer
composing
PLY(
7),
SPW(
34),
SV(
1)
string,
tape,
hot
melt
glue,
wax
adhesive
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures
Application
of
shelving
edge
fillers
to
reconstituted
wood
products
PB(
5)
water­
based
putty,
acetone­
based
paste
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures
Fire
retardants
applied
to
reconstituted
wood
products
prior
to
or
during
the
forming
process
(
e.
g.,
added
in
with
the
resin).
MDF(
1),
SPW(
1)
urea
polyphosphate,
borax
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.
TABLE
3.
(
continued)
26
Description
of
Process
Product
typesa
Types
of
Material
Used
in
Process
Potential
HAP
emissions
Other
FB(
2),
HB(
6),
MDF(
1),
OSB(
1),
PB(
2),
PBM(
2),
PLY(
1),
SPW(
16),
SV(
1)
asphalt,
ink
marking/
indicators,
foil
application,
finishing,
resins,
oils
Survey
data
has
no
indication
of
HAP
emissions
or
emission
reduction
measures.
Additional
information
collected
to
address
overlap
with
Wood
Building
Products
NESAHP
for
asphalt
coatings
shows
no
HAP
in
asphalt
coatings.

a
Number
in
parentheses
indicates
the
number
of
process
lines
where
the
miscellaneous
process
is
performed.
FBB
=
fiberboard
(
bagasse),
PLY
=
plywood,
FB
=
fiberboard,
HB
=
hardboard,
w/
d
HB
=
wet/
dry
process
hardboard,
PB
=
particleboard,
MDF
=
medium
density
fiberboard,
OSB
=
oriented
strandboard,
SPW
=
softwood
plywood,
HPW
=
hardwood
plywood,
SV
=
softwood
veneer,
PB
=
molded
particleboard
TABLE
4.
MACT
FLOOR
ANALYSIS
FOR
MISCELLANEOUS
COATING
OPERATIONS
WITH
NON­
HAP
BASED
COATINGS
AS
AN
EMISSION
REDUCTION
TECHNIQUE
Miscellaneous
coating
type
Existing
MACT
floor
New
MACT
floor
Notesa
Edge
seals
non­
HAP
coating
non­
HAP
coating
59
of
76
(
78%)
of
the
edge
seal
coatings
reported
in
survey
responses
are
waterbased

Nail
lines
non­
HAP
coating
non­
HAP
coating
12
of
16
(>
5)
of
the
nail
line
coatings
reported
in
survey
responses
are
waterbased
Logo
paint
non­
HAP
coating
non­
HAP
coating
89
of
121
(
74%)
of
the
logo
paints/
inks
reported
in
survey
responses
are
waterbased
Shelving
edge
fillers
non­
HAP
coating
non­
HAP
coating
4
of
5
(>
3)
of
the
shelving
edge
fillers
reported
in
the
survey
responses
are
waterbased
Trademark/
gradestamp
inks
non­
HAP
coating
non­
HAP
coating
19
of
119
(
16%)
of
the
trademark/
gradestamp
inks
are
water
based.

Wood
putty
patches
non­
HAP
coating
non­
HAP
coating
15
of
30
(
50%)
of
the
wood
putty
patches
reported
are
water­
based.

Synthetic
patches
no
emission
reduction
non­
HAP
coating
3
of
76
(
4%)
of
the
synthetic
patches
are
waterbased
27
aCounts
of
the
water­
based
coatings
reported
in
the
MACT
survey
responses
are
summed
in
the
table.
However,
additional
coatings
may
be
non­
HAP
coatings
(
e.
g.,
mineral­
oil
based
coatings).

14.
Other
miscellaneous
equipment.
In
addition
to
dryers,
presses,
and
board
coolers,
PCWP
plants
may
also
operate
one
or
more
of
the
following:
blenders,
formers,
sanders,
saws,
fiber
washers,
chippers,
and
log
vats.
None
of
these
equipment
currently
operate
with
HAP
controls.
Therefore,
the
new
and
existing
unit
MACT
floor
for
these
equipment
was
determined
to
be
no
emission
reduction.

IV.
Evaluation
of
Controls
More
Stringent
than
the
MACT
Floors
Section
III
of
this
memorandum
presented
an
evaluation
of
the
MACT
floors
for
process
unit
groups
at
new
and
existing
facilities.
Emission
reduction
techniques
more
stringent
than
the
MACT
floors
were
also
considered
for
each
process
unit
group
in
a
beyond­
the­
floor
analysis.
As
discussed
in
section
III.
A,
there
are
no
known
and
demonstrated
pollution
prevention
techniques
that
can
be
universally
applied
across
the
industry,
and
no
technically
feasible
process
changes
that
would
reduce
HAP
emissions
have
been
identified.
Therefore,
the
beyond­
the­
floor
analysis
focuses
on
the
application
of
add­
on
control
devices.
The
criteria
used
for
determining
whether
beyond­
the­
floor
control
options
represent
MACT
include
the
HAP
emission
reduction
achieved,
the
cost
of
achieving
such
emission
reduction,
and
any
non­
air
quality
health
and
environmental
impacts
and
energy
requirements.

Table
5
summarizes
the
beyond­
the­
floor
control
options
considered
for
each
process
unit
group.
There
are
no
beyond­
the­
floor
control
options
for
process
units
groups
with
MACT
floors
based
on
incineration­
based
controls
or
biofilters
because
no
technology
is
currently
available
that
achieves
a
greater
reduction
in
emissions.
The
control
option
identified
for
most
new
and
existing
process
units
was
use
of
incineration­
based
control.
The
least
costly
beyond­
the­
floor
control
option
for
resin
tanks
and
wastewater
tanks
is
use
of
an
internal
floating
roof.
Other
control
options
for
tanks
were
not
considered
once
it
was
determined
that
even
the
least
costly
option
would
not
be
not
cost­
effective.
Beyond­
the­
floor
control
options
for
existing
conveyor
dryers
could
include
incineration­
based
control
of
exhaust
from
either
zone
2,
or
zones
2
and
3,
in
addition
to
zone
1.
A
beyond­
the­
floor
control
option
for
new
conveyor
dryers
could
be
incineration­
based
control
of
zone
3
exhaust
in
addition
to
control
of
exhaust
from
zones
1
and
2.
Potential
beyond­
the
floor
options
for
wastewater
operations
include
use
of
hard
piping
or
a
closed
system
to
contain
the
wastewater;
biological
treatment;
or
use
of
a
closed
vent
system
and
control
device.
No
beyond­
the­
floor
options
that
would
reduce
emissions
were
identified
for
several
miscellaneous
coating
operations
(
i.
e.,
anti­
skid
coatings,
primers,
wood
patches
applied
to
plywood,
concrete
forming
oil,
veneer
composing,
and
fire
retardants
applied
during
forming)
at
new
and
existing
sources.
The
MACT
floor
for
other
"
group
1
miscellaneous
coating
operations"
is
based
on
use
of
non­
HAP
coatings.
No
further
reduction
in
emissions
can
be
achieved
for
group
1
miscellaneous
coatings.
Use
of
non­
HAP
coatings
was
considered
as
a
beyond­
the­
floor
option
for
synthetic
patching
operations
as
existing
sources.

Attachment
2
presents
the
average
control
cost
per
ton
of
HAP
reduced
($/
ton)
for
each
type
of
process
unit.
Attachment
2
also
provides
a
qualitative
discussion
of
the
non­
air
quality
28
health
and
environmental
impacts
and
energy
requirements
associated
with
the
beyond­
the­
floor
control
options.
The
cost­
effectiveness
values
(
in
terms
of
total
annualized
cost
per
ton
of
HAP
reduced)
presented
in
Attachment
2
range
from
approximately
$
11,000/
ton
to
over
$
1,000,000/
ton.
The
median
cost
effectiveness
value
exceeds
$
200,000/
ton.
The
higher
cost
effectiveness
values
are
due
largely
to
the
fact
that
many
of
the
process
units
for
which
beyondthe
floor
options
were
considered
have
relatively
low
HAP
emissions
(
e.
g.,
1
to
2
tpy),
and
the
cost
of
installing
and
operating
controls
is
high.
The
costs
that
individual
facilities
would
have
to
expend
to
comply
with
the
PCWP
rule
at
the
MACT
floor
control
level
are
relatively
high,
and
therefore,
the
environmental
benefits
would
have
to
be
substantial
to
justify
any
additional
costs.
As
discussed
in
Attachment
2,
although
a
small
reduction
in
HAP
emissions
would
be
achieved
by
going
beyond­
the­
floor,
most
of
the
beyond­
the­
floor
control
options
would
increase
onsite
criteria
pollutant
emissions
(
except
PM),
secondary
air
emissions
(
i.
e.,
emissions
from
electricity
generation),
onsite
wastewater
generation,
onsite
solid
waste
generation,
and
onsite
energy
use.
Thus,
it
was
concluded
that
the
increased
costs
associated
with
the
beyond­
the­
floor
control
options
for
all
process
units
are
not
justified
by
environmental
benefits.
29
TABLE
5.
SUMMARY
OF
THE
BEYOND­
THE­
FLOOR
OPTIONS
CONSIDERED
FOR
EACH
PROCESS
UNIT
GROUP
Process
units
Beyond­
the­
floor
control
options
considered
for
process
units
at
existing
sources
Beyond­
the­
floor
control
options
considered
for
process
units
at
new
sources
Primary
tube
dryers;
secondary
tube
dryers;
rotary
strand
dryers;
green
particle
rotary
dryers;
hardboard
ovens;
softwood
veneer
dryers;
pressurized
refiners
NA
NA
Fiberboard
mat
dryers;
press
preheat
ovens;
and
reconstituted
wood
products
board
coolers
Incineration­
based
control
NA
Blenders;
stand­
alone
digesters;
agriboard
dryers;
particleboard
press
molds;
dry
particle
rotary
dryers;
particleboard
extruders;
paddletype
particle
dryers;
engineered
wood
products
presses
(
LVL,
LSL,
and
PSL
presses);
I­
joist
curing
ovens;
RF
curing
devices;
glulam
presses;
softwood
plywood
presses;
hardwood
plywood
presses;
hardboard
humidifiers;
agriboard
presses;
bagasse
fiber
mat
dryer;
atmospheric
refiners;
veneer
kilns;
lumber
kilns;
RF
veneer
redryers;
hardwood
veneer
dryers;
formers;
sanders;
saws;
fiber
washers;
chippers;
and
log
vats
Incineration­
based
control
Incineration­
based
control
Conveyor
strand
dryers
Incineration­
based
control
of
zone
2
(
or
zone
2
and
3)
exhaust
Incineration­
based
control
of
zone
3
exhaust
Resin
tanks,
wastewater
tanks
Internal
floating
roof
Internal
floating
roof
Miscellaneous
coating
operations
(
other
than
"
group
1
miscellaneous
coating
operations)
NA
(
except
non­
HAP
coatings
were
considered
for
synthetic
patching
operations)
NA
Wastewater
operations
Hard
piping
or
a
closed
system
to
contain
the
wastewater;
biological
treatment;
or
use
of
a
closed
vent
system
and
control
device
Hard
piping
or
a
closed
system
to
contain
the
wastewater;
biological
treatment;
or
use
of
a
closed
vent
system
and
control
device
NA
­
Not
applicable.
Maximum
emissions
reductions
are
achieved
at
the
MACT
floor
control
level.
No
technologies
that
reduce
emissions
further
are
available.
30
V.
Summary
of
MACT
for
Existing
and
New
PCWP
Process
Units
Table
6
summarizes
MACT
for
each
equipment
group
at
new
and
existing
PCWP
facilities.
The
MACT
represents
the
level
of
control
that
would
be
required
by
the
final
PCWP
NESHAP.
31
TABLE
6.
SUMMARY
OF
MACT
FOR
PCWP
PROCESS
UNITS
AT
NEW
AND
EXISTING
SOURCES
Process
unit
MACT
for
process
units
at
existing
sources
MACT
for
process
units
at
new
sources
Primary
tube
dryers;
secondary
tube
dryers;
rotary
strand
dryers;
conveyor
strand
dryers;
green
particle
rotary
dryers;
hardboard
ovens;
softwood
veneer
dryers;
pressurized
refiners
emission
reduction
achieved
with
incineration­
based
controla
emission
reduction
achieved
with
incineration­
based
controla
Conveyor
strand
dryers
emission
reduction
achieved
with
incineration­
based
control
for
zone
1a
emission
reduction
achieved
with
incineration­
based
control
for
zones
1
and
2a
Reconstituted
wood
product
presses
emission
reduction
achieved
with
a
wood
products
enclosure
and
incineration­
based
controla
or
biofilter
emission
reduction
achieved
with
a
wood
products
enclosure
and
incinerationbased
controla
or
biofilter
Reconstituted
wood
product
board
coolers
No
emission
reduction
emission
reduction
achieved
with
a
wood
products
enclosure
and
incinerationbased
controla
or
biofilter
Fiberboard
mat
dryers
(
wood);
hardboard
press
preheat
ovens
No
emission
reduction
emission
reduction
achieved
with
incineration­
based
controla
Rotary
agricultural
fiber
dryers;
dry
particle
rotary
dryers;
paddle­
type
particle
dryers;
hardboard
humidifiers
fiberboard
mat
dryers
(
bagasse);
veneer
kilns;
radio­
frequency
veneer
redryers;
hardwood
veneer
dryers;
particleboard
press
molds;
particleboard
extruders;
engineered
wood
products
presses;
agriboard
presses;
softwood
plywood
presses;
hardwood
plywood
presses
standalone
digesters;
atmospheric
refiners;
blenders;
formers;
sanders
saws;
fiber
washers;
chippers;
log
vats;
lumber
kilns
No
emission
reduction
No
emission
reduction
a
Incineration­
based
control
includes
RTOs,
RCOs,
TCOs,
TOs,
and
incineration
of
process
exhaust
in
combustion
unit.
32
33
VI.
References
1.
U.
S.
Environmental
Protection
Agency.
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products;
Proposed
Rule.
68
FR1276.
Washington,
DC.
U.
S.
Government
Printing
Office.
January
9,
2003.

2.
United
States
Congress.
Clean
Air
Act,
as
amended
October
1990.
42
U.
S.
C.
7401
et
seq.
Washington,
DC.
U.
S.
Government
Printing
Office.

3.
U.
S.
Environmental
Protection
Agency.
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Category:
Organic
Hazardous
Air
Pollutants
from
the
Synthetic
Organic
Chemical
Manufacturing
Industry
and
Other
Processes
Subject
to
the
Negotiated
Regulation
for
Equipment
Leaks;
Determination
of
MACT
"
Floor."
59
FR
29196.
Washington,
DC.
U.
S.
Government
Printing
Office.
June
6,
1994.

4.
Memorandum
from
B.
Nicholson
and
K.
Hanks,
MRI
to
M.
Kissell,
EPA/
ESD.
June
7,
2002.
Determination
of
MACT
floors
and
MACT
for
the
Plywood
and
Composite
Wood
Products
Industry.

5.
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.

6.
Memorandum
from
K.
Parrish
and
K.
Hanks,
RTI
to
M.
Kissell,
EPA/
ESD.
Review
of
Correlations
Between
Process
Variables
and
Emissions
for
the
Plywood
and
Composite
Wood
Products
Industry.
November
26,
2003.

7.
Memorandum
from
K.
Hanks
and
K.
Parrish,
RTI
to
M.
Kissell,
EPA/
ESD.
Selection
of
HAPs
for
Compliance
Options
in
the
Final
Plywood
and
Composite
Wood
Products
Rule.
November
26,
2003.

8.
Memorandum
from
K.
Hanks
and
B.
Nicholson,
MRI,
to
P.
Lassiter,
EPA/
ESD.
April
16,
1998
(
Finalized
5/
28/
98).
Trip
report
for
February
12,
1998
site
visit
to
Timber
Products
Company
particleboard
and
hardwood
plywood
plant
in
Medford,
Oregon.

9.
R.
Nicholson,
MRI,
to
D.
Word,
NCASI.
February
17,
2000
(
Confirmed
via
Email
on
9/
7/
00).
Contact
report
to
(
1)
find
out
if
oxygen
measurement
data
were
available
from
the
NCASI
MACT
emissions
test
program,
and
(
2)
to
get
some
information
on
typical
oxygen
concentrations
in
dryer
and
press
exhaust
at
plywood
and
composite
wood
products
plants.

10.
Memorandum
from
R.
Nicholson,
MRI,
to
M.
Kissell,
EPA/
ESD.
May
26,
2000.
Control
Device
Efficiency
Data
for
Add­
on
Control
Devices
at
PCWP
Plants.
34
11.
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,
EPA­
453/
R­
01­
004,
September,
2000.

12.
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
(
NCASI)
Method
IM/
CAN/
WP­
99.01,
Impinger/
Canister
Source
Sampling
Method
for
Speciated
HAPs
at
Wood
Products
Facilities.
1999.

13.
T.
Peters,
MacMillan
Bloedel
Clarion,
Limited
Partnership
(
Temple­
Inland
Forest
Products
Corporation),
to
EPA/
ESD.
Response
to
information
request
for
Shippenville,
Pennsylvania
facility.
1998.

14.
Memorandum
from
D.
Bullock,
K.
Hanks,
and
B.
Nicholson,
MRI
to
M.
Kissell,
EPA/
ESD.
April
28,
1999.
Summary
of
Responses
to
the
1998
EPA
Information
Collection
Request
(
MACT
Survey)
­­
General
Survey.

15.
K.
Hanks,
B.
Threatt,
and
B.
Nicholson,
MRI,
to
M.
Kissell,
EPA/
ESD.
January
20,
2000.
Summary
of
Responses
to
the
1998
EPA
Information
Collection
Request
(
MACT
Survey)
­­
Engineered
Wood
Products.

16.
P.
Quosai,
Norbord
Industries
Inc.,
to
EPA.
March
10,
2003.
Comments
on
the
Plywood
and
Composite
Wood
Products
Proposed
Rule
­
Applicability
to
low­
temperature
OSB
strand
conveyor
dryers.

17.
Email
correspondence
from
P.
Quosai,
Norbord
Industries
Inc.,
to
K.
Hanks,
RTI.
July
23,
2003.
Information
on
conveyor
dryers
operated
by
Norbord
in
the
U.
S.

18.
Volatile
Organic
Compound
Emissions
From
Wood
Products
Manufacturing
Facilities,
Part
IV
­
Particleboard.
Technical
Bulletin
No.
771,
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
(
NCASI),
Research
Triangle
Park,
NC,
January
1999.
p.
88.

19.
Maloney,
T.
M.
Modern
Particleboard
and
Dry­
Process
Fiberboard
Manufacturing,
Miller
Freeman
Inc.,
San
Francisco,
1993,
pp.
28­
29,
284­
285,
and
294.

20.
Memorandum
from
B.
Nicholson
and
K.
Hanks,
MRI,
to
P.
Lassiter,
EPA/
ESD.
October
28,
1998.
Trip
report
for
February
11,
1998
site
visit
to
Roseburg
Forest
Products
plant
in
Dillard,
Oregon.

21.
Memorandum
from
D.
Bullock,
K.
Hanks,
and
B.
Nicholson,
MRI
to
M.
Kissell,
EPA/
ESD.
April
28,
1999.
Summary
of
Responses
to
the
1998
EPA
Information
Collection
Request
(
MACT
Survey)
­­
General
Survey.

22.
Suchsland,
O.,
and
G.
E.
Woodson,
Fiberboard
Manufacturing
Practices
in
the
United
States.
Forest
Products
Research
Society,
1990,
pp.
1,
3,
72­
80,
151,
168,
and
176.
35
23.
Memorandum
from
K.
Hanks,
MRI,
to
M.
Kissell,
EPA/
ESD.
November
18,
1999.
Minutes
of
November
16,
1999
Meeting
with
Wood
Products
Industry
and
Trade
Association
Representatives.

24.
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.

25.
Memorandum
from
B.
Nicholson,
MRI,
to
Project
File.
June
6,
2002.
Verification
of
Press
Equipment
Included
in
Press
Enclosures.

26.
T.
Hunt,
American
Forest
&
Paper
Association,
to
EPA.
March
7,
2003.
Comments
of
the
American
Forest
&
Paper
Association,
Inc.:
National
Emission
Standards
for
Hazardous
Air
Pollutants;
Plywood
and
Composite
Wood
Products;
Proposed
Rule.

27.
Memorandum
from
M.
Icenhour,
MRI,
to
Project
File.
May
21,
2002.
Lumber
Kilns
at
Stand­
alone
Kiln­
dried
Lumber
Manufacturing
Facilities.

28.
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.

29.
K.
Parrish,
RTI,
to
Project
Files.
December
1,
2003.
Web
Search
for
Information
on
Potential
Emissions
from
Miscellaneous
Coating
Operations.

30.
U.
S.
Environmental
Protection
Agency.
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Surface
Coating
of
Wood
Building
Products;
Final
Rule.
68
FR
31746.
Washington,
DC.
U.
S.
Government
Printing
Office.
May
28,
2003
.

31.
Facsimile
from
A.
Casey,
Masonite
International
Corporation,
to
K.
Hanks,
RTI.
November
21,
2002.
Information
on
asphalt
coatings
applied
to
wood
products.

32.
Facsimile
from
J.
Orynawka,
Temple­
Inland,
to
K.
Hanks,
RTI.
November
1,
2002.
Information
on
asphalt
coatings
applied
to
wood
products.
Attachment
1
Control
Device
Performance
Data
for
RTOs,
RCOs
and
Biofilters
Table
1.
RTO
Control
Efficiency
and
Emissions
Data
Sorted
by
Plant
and
Process
Unit
Plant
Pollutant
Pretreatment
Control
Inlet
ppm
Outlet
ppm
CE
Product
Process
unit
122
formaldehyde
NONE
RTO
NL
NL
96.0
OSB
OSB
press
122
THC
as
carbon
NONE
RTO
284
3.60
98.8
OSB
OSB
press
135
THC
as
carbon
MC
RTO
6.57
97.5
MDF
D­
T1,
D­
T2,
D­
T3,
D­
T4,
PMDF1
P­
MDF2
137
THC
as
carbon
NONE
RBP/
RTO
460
6.00
99.7
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
189
7.60
99.5
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
190
3.00
99.3
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
204
3.00
98.9
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
201
10.00
97.9
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
149
10.20
97.6
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
144
7.60
92.8
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
137
THC
as
carbon
NONE
RBP/
RTO
6.00
*
1.20
*
78.1*
MDF
D­
T3,
P­
MDF1,
BC2,
DIG1
167
formaldehyde
BH/
WESP
RTO
5.49
1.30
69.1
MDF
D­
T1,
D­
T2,
D­
T3,
P­
MDF
167
THC
as
carbon
BH/
WESP
RTO
247
2.03
98.9
MDF
D­
T1,
D­
T2,
D­
T3,
P­
MDF
167
THC
as
carbon
BH/
WESP
RTO
237
18.00
92.7
MDF
D­
T1,
D­
T2,
D­
T3,
P­
MDF
167
THC
as
carbon
BH
RTO
159
15.20
90.1
MDF
D­
T1,
D­
T2,
D­
T3,
P­
MDF
010­
1PB1
formaldehyde
NONE
RTO
43.2
0.09
99.8
PB
PB
batch
press
010­
1PB1
methanol
NONE
RTO
109
0.34
99.7
PB
PB
batch
press
010­
1PB1
THC
as
carbon
NONE
RTO
556
4.93
99.0
PB
PB
batch
press
039­
6DR1
formaldehyde
NONE
WESP/
RTO
1.00
0.11
86.2
PB
PB
rotary
pre­
dryer
039­
6DR1
methanol
NONE
WESP/
RTO
3.97
0.35
88.5
PB
PB
rotary
pre­
dryer
039­
6DR1
THC
as
carbon
NONE
WESP/
RTO
488
6.43
99.2
PB
PB
rotary
pre­
dryer
039­
6DR1
formaldehyde
WESP
RTO
1.06
0.11
89.8
PB
PB
rotary
pre­
dryer
039­
6DR1
methanol
WESP
RTO
4.47
0.35
92.0
PB
PB
rotary
pre­
dryer
039­
6DR1
THC
as
carbon
WESP
RTO
488
6.43
99.2
PB
PB
rotary
pre­
dryer
053­
2DF1
formaldehyde
NONE
RTO
4.39
0.11
97.1
FB
FB
dryer
and
HB
press
preheater
053­
2DF1
methanol
NONE
RTO
9.34
0.26
96.8
FB
FB
dryer
and
HB
press
preheater
053­
2DF1
THC
as
carbon
NONE
RTO
352
4.67
98.5
FB
FB
dryer
and
HB
press
preheater
083­
2PB1
formaldehyde
NONE
RTO
5.63
0.54
89.2
OSB
OSB
hot
press,
No.
2
083­
2PB1
methanol
NONE
RTO
17.7
0.83
94.8
OSB
OSB
hot
press,
No.
2
083­
2PB1
THC
as
carbon
NONE
RTO
51.4
3.31
92.8
OSB
OSB
hot
press,
No.
2
083­
XDR1
formaldehyde
WESP
RTO
45.2
13.1
66.0
OSB
OSB
rotary
dryers
(
2)

083­
XDR1
methanol
WESP
RTO
24.0
4.57
77.8
OSB
OSB
rotary
dryers
(
2)

083­
XDR1
THC
as
carbon
WESP
RTO
390**
57.19**
82.8**
OSB
OSB
rotary
dryers
(
2)
Table
1.
(
continued)

Plant
Pollutant
Pretreatment
Control
Inlet
ppm
Outlet
ppm
CE
Product
Process
unit
145­
1PB1
formaldehyde
NONE
RTO
3.4
0.19
94.9
OSB
OSB
hot
press
145­
1PB1
methanol
NONE
RTO
25.4
0.26
99.1
OSB
OSB
hot
press
145­
1PB1
THC
as
carbon
NONE
RTO
255
0.50
99.8
OSB
OSB
hot
press
145­
XDR2
formaldehyde
WESP
RTO
19.1
0.14
99.0
OSB
OSB
rotary
dryers
(
5)

145­
XDR2
methanol
WESP
RTO
6.85
0.25
94.8
OSB
OSB
rotary
dryers
(
5)

145­
XDR2
THC
as
carbon
WESP
RTO
1,190
43.8
99.1
OSB
OSB
rotary
dryers
(
5)

179A
formaldehyde
NONE
RTO
20.1
1.18
93.8
PB
PB
press
179A
methanol
NONE
RTO
81.4
0.76
99.0
PB
PB
press
234­
1OT1
formaldehyde
NONE
RTO
2.6
0.07
96.6
HB
HB
tempering
oven
234­
1OT1
methanol
NONE
RTO
8.4
0.38
94.0
HB
HB
tempering
oven
234­
1OT1
THC
as
carbon
NONE
RTO
764
0.50
99.9
HB
HB
tempering
oven
404­
XUM1
formaldehyde
RBP
RTO
16.3
0.18
98.7
MDF
Dryer/
continuous
press
404­
XUM1
methanol
RBP
RTO
28.6
0.27
98.9
MDF
Dryer/
continuous
press
404­
XUM1
THC
as
carbon
RBP
RTO
201
9.6
93.8
MDF
Dryer/
continuous
press
410­
1PB1
formaldehyde
NONE
RTO
2.42
0.07
95.9
OSB
OSB
hot
press
410­
1PB1
methanol
NONE
RTO
19.7
0.27
98.2
OSB
OSB
hot
press
410­
1PB1
THC
as
carbon
NONE
RTO
219
4.36
97.4
OSB
OSB
hot
press
410­
XDR2
formaldehyde
NONE
RTO
22.9
2.13
90.1
OSB
OSB
rotary
dryer
(
5)

410­
XDR2
methanol
NONE
RTO
8.6
0.71
91.5
OSB
OSB
rotary
dryer
(
5)

410­
XDR2
THC
as
carbon
NONE
RTO
766
29.4
95.9
OSB
OSB
rotary
dryer
(
5)

165­
XDV1
formaldehyde
NONE
RTO
4.38
0.12
96.78
SPW
Dryer(
s)

165­
XDV1
methanol
NONE
RTO
5.51
0.40
91.82
SPW
Dryer(
s)

165­
XDV1
THC
as
carbon
NONE
RTO
1814.16
87.11
96.27
SPW
Dryer(
s)

170­
XDV1
formaldehyde
NONE
RTO
4.53
2.12
50.80
SPW
Dryer(
s)

170­
XDV1
methanol
NONE
RTO
21.71
1.18
94.18
SPW
Dryer(
s)

170­
XDV1
THC
as
carbon
NONE
RTO
5090.20
130.06
97.33
SPW
Dryer(
s)

*
The
emissions
test
report
for
this
facility
states
that
"
during
the
burner
mode
testing
the
process
line
experienced
upsets
which
led
to
the
line
going
down...
EPA
Method
18
(
THC)
tests
were
stopped
and
restarted
when
L­
P
personnel
notified
the
test
team
that
the
process
was
up
and
stable."
Also,
the
THC
data
are
not
considered
representative
due
to
the
low
inlet
concentration
(
6
ppm)
which
is
orders
of
magnitude
lower
than
similar
units
and
orders
of
magnitude
lower
than
was
seen
in
other
tests
of
this
same
unit.

**
This
value
was
calculated
without
correcting
for
methane
in
the
RTO
outlet;
methane
made
up
50%
of
the
total
hydrocarbon
value
for
a
similar
unit
(
page
89
of
NCASI
Technical
Bulletin
No.
772
[
OSB]))
.
Other
available
data
for
this
plant
show
that
the
RTO
can
achieve
VOC
emission
reductions
greater
than
90%.
Table
2.
RCO
Control
Efficiency
and
Emissions
Data
Sorted
by
Plant
and
Process
Unit
Plant
Pollutant
Pretreatment
Control
Inlet
ppm
Outlet
ppm
CE
Product
Process
unit
43
THC
as
carbon
NONE
RCO
148
24.8
98.6
HB
Hardboard
dryer
083­
1PB1
formaldehyde
NONE
RCO
3.54
2.59
18.4
OSB
OSB
hot
press,
No.
1
083­
1PB1
methanol
NONE
RCO
13.3
3.90
67.4
OSB
OSB
hot
press,
No.
1
083­
1PB1
THC
as
carbon
NONE
RCO
43.6
14.7
62.4
*
OSB
OSB
hot
press,
No.
1
194­
XDV1
formaldehyde
NONE
RCO
20.8
7.9
51.0
SPW
Dryer(
s)

194­
XDV1
methanol
NONE
RCO
9.3
0.94
86.7
SPW
Dryer(
s)

194­
XDV1
THC
as
carbon
NONE
RCO
1831
153
92.0
SPW
Dryer(
s)

*
This
value
has
not
been
corrected
for
methane;
the
plant
is
required
to
maintain
a
VOC
destruction
efficiency
of
at
least
90%.

Table
3.
Biofilter
Control
Efficiency
and
Emissions
Data
Sorted
by
Plant
and
Process
Unit
Plant
Pollutant
Pretreatment
Control
Inlet
ppm
Outlet
ppm
CE
Product
Process
unit
118­
1PB1
formaldehyde
NONE
BIO
2.90
0.07
97.1
OSB
OSB
hot
press
118­
1PB1
methanol
NONE
BIO
90.3
17.5
78.5
OSB
OSB
hot
press
118­
1PB1
THC
as
carbon
NONE
BIO
129
23.0
80.1
OSB
OSB
hot
press
183­
1PC1
formaldehyde
NONE
BIO
13.4
0.22
98.1
PB
PB
press
and
cooler
183­
1PC1
methanol
NONE
BIO
18.8
0.32
98.0
PB
PB
press
and
cooler
183­
1PC1
THC
as
carbon
NONE
BIO
117
27.4
72.7
PB
PB
press
and
cooler
188
formaldehyde
QUENCH
BIO
99.8
PB
PB
press
and
cooler
188
formaldehyde
NONE
BIO
7.87
0.15
97.8
PB
PB
press
and
cooler
188
THC
as
carbon
QUENCH
BIO
84.2
7.10
90.2
PB
PB
press
and
cooler
Plant
Pollutant
Pretreatment
Control
Inlet
ppm
(
min)
Inlet
ppm
(
max)
Outlet
ppm
(
min)
Outlet
ppm
(
max)
CE
(
min)
CE
(
max)

188*
THC
as
carbon
NONE
BIO
69.5
234
4.90
124
5.39
96.9
*
This
data
set
for
plant
188
covers
a
10­
month
period
beginning
at
startup;
the
ranges
above
(
min
and
max
values)
correspond
to
the
results
of
testing
during
this
10­
month
period.
Attachment
2
Cost
Effectiveness
of
Beyond­
the­
Floor
Controls
Analysis
of
the
Cost­
Effectiveness
and
Environmental
Benefits
of
Beyond­
the­
Floor
Controls
An
analysis
was
conducted
to
determine
whether
beyond­
the­
floor
control
options
for
several
PCWP
process
units
would
be
cost
effective
and
result
in
environmental
benefits.
Cost­
effectiveness
(
i.
e.,
the
cost
per
ton
of
HAP
emission
reduction)
is
determined
by
dividing
the
total
annualized
cost
(
TAC)
of
the
control
technology
by
the
tons
of
HAP
that
would
be
reduced.
In
addition
to
costeffectiveness
non­
HAP
environmental
and
energy
impacts
are
also
considered
in
deciding
if
beyondthe
floor
control
measures
are
justified.

1.
Cost­
effectiveness
Analysis
For
process
units
with
incineration­
based
control
as
the
beyond­
the­
floor
option,
the
cost
analysis
was
based
on
the
industry
average
exhaust
flow
for
each
process
unit,
the
typical
number
of
each
process
unit
per
plant,
the
industry
average
amount
of
HAP
emitted
from
the
process
units,
and
the
assumption
that
an
RTO
would
be
used
to
control
emissions
from
each
process
unit.
The
average
exhaust
flow
rates
and
typical
number
of
process
units
per
plant
were
determined
using
the
results
from
EPA's
MACT
survey.
If
no
flow
rate
information
was
provided
for
a
particular
type
of
process
unit,
then
the
average
flow
rate
from
available
emissions
test
data
was
used.
In
a
few
cases
where
no
survey
or
test
data
were
available,
engineering
judgement
was
used
to
determine
the
flow
rate
(
e.
g.,
considering
the
flow
rates
for
similarly
designed
process
units).
The
average
HAP
emissions
were
determined
using
the
methodology
described
in
the
baseline
emissions
memo.
1
The
HAP
reduction
was
calculated
using
the
methodology
described
in
the
baseline
emissions
memo
assuming
that
an
RTO
would
achieve
an
average
95
percent
reduction
in
HAP.
The
annualized
RTO
cost
was
calculated
based
on
flow
rate
using
the
methodology
described
in
the
Background
Information
Document.
2
Table
1
presents
the
results
of
the
cost
effectiveness
analysis
for
those
process
units
with
incineration­
based
control
as
a
beyond­
the­
floor
control
option.
The
beyond­
the
floor
cost
analysis
assumes
that
facilities
will
not
be
able
to
route
the
emissions
from
process
units
to
an
existing
control
device
or
to
a
new
control
device
installed
to
meet
the
PCWP
standards
(
i.
e.,
that
a
separate
RTO
must
be
purchased
to
handle
the
additional
flow
from
each
type
of
process
unit).
As
of
April
2000,
it
was
estimated
that
166
of
233
major
source
facilities
(
i.
e.,
74
percent)
would
need
to
install
new
APCD
to
meet
the
MACT
floor.
2
Many
facilities
have
installed
APCD
since
April
2000.
Thus,
many
facilities
already
have
APCD
in
place
and
those
APCD
are
unlikely
to
have
the
capacity
to
accept
additional
flow
from
other
process
units.
Also,
some
facilities
may
have
physical
difficulty
routing
emissions
from
green
end
operations
(
e.
g.,
blenders,
digesters)
to
APCD
located
after
drying
or
pressing
operations
because
the
dryers
and
presses
may
be
located
a
long
distance
away
from
the
green
end
emission
points.
In
addition,
several
plants
would
need
to
use
most
of
an
RTO's
capacity
to
control
emissions
from
process
units
with
a
MACT
floor
of
incineration­
based
control.
Even
if
additional
RTO
capacity
was
available,
facilities
must
still
pay
for
the
additional
operating
costs
to
control
the
added
exhaust
stream
(
operating
costs
are
approximately
50
percent
of
the
TAC),
and
therefore,
little
TAC
would
be
eliminated
(
although
some
capital
costs
would
be
eliminated).
Furthermore,
although
this
beyond­
the­
floor
analysis
is
based
on
"
typical"
numbers
of
process
units,
there
are
varying
numbers
of
process
units
at
each
PCWP
facility
(
e.
g.,
one
facility
may
have
three
dryers
and
four
blenders,
while
another
facility
making
the
same
product
may
have
four
dryers
and
two
blenders),
thereby
making
it
difficult
to
accurately
estimate
the
number
and
capacity
of
APCD
that
would
be
installed
if
more
equipment
were
to
be
controlled
than
at
the
MACT
floor
control
level.
For
these
reasons,
we
determined
that
it
would
be
inappropriate
for
our
beyond­
to­
floor
analysis
to
assume
that
all
facilities
can
treat
emissions
in
RTO's
installed
to
meet
the
MACT
floor
requirements
for
most
dryers
and
presses.
However,
the
beyond­
the­
floor
analysis
does
account
for
situations
when
multiple
process
units
of
the
same
type
could
potentially
be
routed
to
the
same
APCD.

Emissions
capture
may
be
an
issue
for
several
of
the
process
units
included
in
the
beyond­
thefloor
analysis.
For
example,
lumber
kilns
and
veneer
kilns
have
multiple
vents
that
oscillate
from
functioning
as
air­
intake
vents
to
exhaust
vents
several
times
throughout
the
kiln
cycle.
Also,
all
types
of
presses
and
process
units
such
as
particleboard
extruders
may
require
an
enclosure
to
capture
emissions.
Enclosure
costs
are
primarily
capital
costs
which
do
not
factor
into
the
cost­
effectiveness
calculation
(
the
life
span
of
the
enclosure
is
expected
to
be
unlimited
and
thus
capital
recovery
costs
were
neglected).
Therefore,
enclosure
costs
were
not
estimated
for
purposes
of
the
beyond­
the­
floor
analysis.

The
MACT
floor
for
conveyor
strand
dryers
at
existing
sources
is
based
on
use
of
incineration­
based
control
of
zone
1
emissions.
For
new
conveyor
strand
dryers,
the
MACT
floor
is
based
on
use
of
incineration­
based
control
of
zone
1
and
2
emissions.
Control
options
beyond­
thefloor
for
conveyor
strand
dryers
are
based
on
control
of
additional
dryer
zones.
For
the
costeffectiveness
analysis
it
was
assumed
that
an
RTO
would
be
installed
to
control
emissions
from
the
additional
zones
because
the
combustion
unit
used
to
control
emissions
from
zones
1
and/
or
2
may
be
unable
to
handle
the
exhaust
from
additional
zones.
Emissions
data
for
each
conveyor
zone
were
obtained
from
a
company
that
operates
multiple
conveyor
dryers.

The
lowest­
cost
beyond­
the­
floor
control
option
for
tanks
is
use
of
an
internal
floating
roof
(
IFR),
which
would
achieve
a
90
percent
reduction
in
HAP
emissions.
The
costs
of
retrofitting
an
IFR
were
estimated
based
on
the
methodology
used
in
developing
other
NESHAP
which
is
presented
in
the
algorithm
shown
in
Table
2.
No
data
is
available
for
use
in
estimating
the
baseline
emissions
from
wastewater
storage
tanks;
however,
it
is
expected
that
potential
emissions
from
wastewater
storage
tanks
would
be
less
than
the
emissions
from
PCWP
resin
tanks.
Therefore,
use
of
an
IFR
on
PCWP
wastewater
storage
tanks
is
likely
to
be
less
cost
effective
than
for
resin
tanks.

Potential
beyond­
the­
floor
options
for
wastewater
operations
include
use
of
hard
piping
or
a
closed
system
to
contain
the
wastewater;
biological
treatment;
or
use
of
a
closed
vent
system
and
control
device.
Based
upon
the
limited
available
data,
the
worst
case
total
HAP
emissions
from
PCWP
wastewater
operations
are
approximately
0.32
tpy.
3
Given
this
low
amount
of
HAP,
any
control
option
that
would
be
cost­
effective
would
have
to
cost
no
more
than
a
few
thousand
dollars
to
operate.
It
is
highly
doubtful
that
retrofit
of
any
of
the
control
options
for
wastewater
operations
could
be
accomplished
at
this
low
price.

The
MACT
floor
for
several
miscellaneous
coating
operations
(
i.
e.,
anti­
skid
coatings,
primers,
wood
patches
applied
to
plywood,
concrete
forming
oil,
veneer
composing,
and
fire
retardants
applied
during
forming)
at
new
and
existing
sources
is
no
emission
reduction.
The
MACT
floor
for
other
"
group
1
miscellaneous
coating
operations"
is
based
on
use
of
non­
HAP
coatings.
No
further
reduction
in
emissions
can
be
achieved
for
group
1
miscellaneous
coatings.
With
the
exception
of
synthetic
patches,
no
beyond­
the­
floor
options
that
would
result
in
any
emissions
reduction
could
be
identified
for
miscellaneous
coating
operations.
The
MACT
floor
for
synthetic
patches
is
no
emissions
reduction
for
existing
sources,
and
is
based
on
use
of
non­
HAP
coating
for
new
sources.
Very
few
facilities
use
non­
HAP
(
water­
based)
synthetic
patches,
which
indicates
that
use
of
water­
based
patches
is
not
preferred
by
the
industry.
Use
of
non­
HAP
synthetic
patches
is
a
beyond­
the­
floor
option
for
existing
sources;
however,
potential
emissions
from
synthetic
patch
application
are
expected
to
be
very
low
such
that
the
cost
associated
with
switching
patch
types
would
not
be
justified
by
the
environmental
benefits.

2.
Analysis
of
Environmental
Benefits
This
section
provides
a
qualitative
discussion
of
the
environmental
benefits
that
could
be
achieved
through
application
of
beyond­
the­
floor
measures.
A
qualitative
discussion
is
presented
instead
of
quantified
environmental
benefits
because
significant
effort
(
including
data
gathering)
would
be
necessary
to
fully
quantify
the
environmental
benefits.
The
environmental
impacts
of
RTO
use
were
quantified
for
process
units
with
MACT
floors
based
on
use
of
incineration­
based
control,
and
those
same
impacts
are
relevant
to
the
process
units
for
which
an
RTO­
based
beyond­
the­
floor
option
was
considered.
2
Use
of
RTO
on
PCWP
process
units
significantly
reduces
HAP
and
total
hydrocarbon
(
THC)
emissions.
The
HAP
emission
reductions
that
could
be
obtained
from
RTO
use
are
shown
in
Table
1
for
those
process
units
with
incineration­
based
control
as
a
potential
beyond­
the­
floor
option.
However,
criteria
pollutant
impacts
associated
with
RTO
use
can
vary.
Due
to
the
combustion
of
fuel
and
relatively
dilute
exhaust
streams
exhibited
by
most
PCWP
process
units,
it
is
likely
that
use
of
an
RTO
would
generate
NOx
emissions.
Furthermore,
for
process
units
without
significant
inlet
CO
emissions
(
e.
g.,
process
units
other
than
direct­
fired
dryers),
RTO
can
generate
more
CO
than
they
oxidize
to
CO
2.
Thus,
CO
emissions
could
increase
for
many
of
the
process
units
for
which
the
RTObased
beyond­
the­
floor
analysis
was
conducted.
Although
RTO
use
might
increase
NOx
and
CO
emissions,
it
is
possible
that
PM
emissions
from
the
process
units
analyzed
would
decrease
if
the
process
units
are
sources
of
PM
and
are
not
already
controlled
for
PM
(
e.
g.,
with
a
baghouse).
No
data
are
available
to
numerically
evaluate
the
baseline
CO
and
PM
emissions
from
the
process
units.
Use
of
RTO
as
a
beyond­
the­
floor
technology
would
increase
wastewater
generation
and
solid
waste
generation
from
PCWP
facilities.
In
addition,
energy
use
would
increase
as
a
result
of
RTO
use
as
a
beyond­
the­
floor
technology.
TABLE
1.
COST
EFFECTIVENESS
ANALYSIS
FOR
PROCESS
UNITS
WITH
INCINERATION­
BASED
CONTROL
AS
A
BEYOND­
THE­
FLOOR
CONTROL
OPTION
Process
Unit
Typical
emissions
(
tpy)
Flow
(
dscfm)
Typical
number
per
plant
Total
capital
cost
($)
Total
annualized
cost
($)
HAP
emission
reduction
(
tpy)
a
Cost
effectiveness
$/
ton
Blender
­
PB
45
13,590
2
Blender
­
OSB
11
13,590
2
Blender
(
average)
28
13,590
2
$
1,184,312
$
394,486
27
$
14,830
Stand­
alone
digester
­
FB
14
7,587
2
Stand­
alone
digester
­
HB
14
7,587
2
Stand­
alone
digester
(
average)
14
7,587
2
$
1,018,666
$
358,359
13
$
26,944
Fiberboard
mat
dryer
­
FB
8
49,389
1
Fiberboard
mat
dryer
­
w/
d
HB
12
19,491
1
Fiberboard
mat
dryer
(
average)
10
34,440
1
$
1,284,479
$
418,076
9.5
$
44,008
Press
preheat
oven
­
w/
d
HB
15
21,812
1
$
1,110,250
$
377,904
14
$
26,520
Board
cooler
­
PB
5
41,423
1
Board
cooler
­
MDF
3
79,483
1
Board
cooler
(
average)
4
60,453
1
$
1,643,380
$
514,795
3.8
$
135,472
Agriboard
dryer
­
PBS
2
4,557
1
$
872,184
$
329,179
1.9
$
173,252
Dry
rotary
particle
dryer
3
31,466
1
$
1,243,447
$
408,247
2.9
$
143,245
Paddle­
type
particle
dryer
<
1
31,466
2
$
1,677,585
$
525,106
0.95
$
552,744
Hardboard
humidifier
2
23,175
1
$
1,129,056
$
382,047
1.9
$
201,078
Bagasse
fiber
mat
dryer
<<
1
49,389
1
$
1,490,730
$
471,187
0.95
$
495,987
Veneer
kiln
­
SPW
<
1
12,062
2
Veneer
kiln
­
HPW
<
1
12,062
2
Veneer
kiln
(
average)
<
1
12,062
2
$
1,142,149
$
384,959
0.95
$
405,220
RF
veneer
redryer
­
SPW
<
1
618
1
$
817,840
$
318,968
0.95
$
335,755
Hardwood
veneer
dryer
­
SPW
8
12,728
2
Hardwood
veneer
dryer
­
LVL
4
12,728
2
Hardwood
veneer
dryer
­
HPW
<
1
12,728
2
Hardwood
veneer
dryer
(
average)
4
12,728
2
$
1,160,529
$
389,083
3.8
$
102,390
I­
joist
curing
ovens
<
1
288
1
$
813,284
$
318,126
0.95
$
334,870
RF
curing
devices
<
1
618
1
$
817,837
$
318,967
0.95
$
335,755
Glulam
presses
4
11633
1
$
969,811
$
348,350
3.8
$
91,671
SPW
presses
7
33470
1
$
1,271,096
$
414,845
6.7
$
62,383
HPW
presses
<
1
33054
1
$
1,265,356
$
413,466
0.95
$
435,228
Particleboard
press
mold
<
1
13,000
12
$
2,961,642
$
1,105,600
0.95
$
1,163,790
TABLE
1.
(
continued)

Process
Unit
Typical
emissions
(
tpy)
Flow
(
dscfm)
Typical
number
per
plant
Total
capital
cost
($)
Total
annualized
cost
($)
HAP
emission
reduction
(
tpy)
a
Cost
effectiveness
$/
ton
Particleboard
extruder
<
1
11,633
3
$
1,290,812
419614.278
3
0.95
$
441,699
Engineered
wood
press
­
PSL
5
38,005
1
$
1,333,665
$
430,171
4.8
$
90,562
Engineered
wood
press
­
LVL
2
38,005
1
$
1,333,665
$
430,171
1.9
$
226,406
Engineered
wood
press
­
LSL
<
1
29,007
1
$
1,209,520
$
400,294
0.95
$
421,362
Agriboard
press
4
14,199
2
$
1,201,113
$
398,348
3.8
$
104,828
Atmospheric
refiners
­
PB
<
1
25,124
2
Atmospheric
refiners
­
HB
<
1
1,142
2
Atmospheric
refiners
(
average)
<
1
13,133
2
$
1,171,698
$
391,611
0.95
$
412,222
Lumber
kiln
1
6,774
4
$
1,183,154
$
394,221
0.95
$
414,970
Former
­
HB
5
12,386
1
Former
­
MDF
2
12,386
1
Former
(
average)
4
12,386
1
$
980,200
$
350,455
3.8
$
92,225
Sander
­
PB
2
42691
1
Sander
­
SPW
2
40617
1
Sander
­
MDF
<
1
48,600
1
Sander
(
average)
2
43,969
1
$
1,415,955
$
451,195
1.9
$
237,471
Saw
­
SPW
1
36,408
1
Saw
­
PB
<
1
25,263
1
Saw
­
MDF
<
1
28,978
1
Saw
(
average)
<
1
30,216
1
$
1,226,205
$
404,186
0.95
$
425,459
Fiber
washer
6
22,787
1
$
1,123,702
$
380,863
5.7
$
66,818
Chipper
­
FB
<<
1
1,570
1
Chipper
­
SPW
2
32,173
1
Chipper
(
average)
1
16,871
1
$
1,042,086
$
363,259
0.95
$
382,378
Log
vat
­
SPW
1
7,116
1
$
907,489
$
335,987
0.95
$
353,670
Conveyor
strand
dryer
zone
2
0.88
12,006
3
$
1,306,250
$
423,388
0.84
$
506,444
Conveyor
strand
dryer
zones
2
and
3
0.88
12,005
3
$
1,306,209
$
423,377
0.84
$
506,432
Conveyor
strand
dryer
zone
3
1.76
24,011
3
$
1,803,149
$
564,764
1.67
$
337,777
a
A
typical
emissions
value
of
"
1"
was
used
in
calculating
the
HAP
emissions
reduction
for
process
units
with
typical
emissions
reported
as
"<
1"
or
"<<
1"
in
the
table.
FB
=
fiberboard,
HB
=
hardboard,
w/
d
HB
=
wet/
dry
process
hardboard,
PB
=
particleboard,
MDF
=
medium
density
fiberboard,
OSB
=
oriented
strandboard,
SPW
=
softwood
plywood,
HPW
=
hardwood
plywood,
LVL
=
laminated
veneer
lumber,
PSL
=
parallel
strand
lumber,
LSL
=
laminated
strand
lumber,
PBS
=
agriboard
(
particleboard
made
from
straw),
tpy
=
tons
per
year,
dscfm
=
dry
standard
cubic
feet
per
minute
TABLE
2.
ALGORITHM
USED
TO
ESTIMATE
INTERNAL
FLOATING
ROOF
COST
Average
PCWP
resin
tank
parameters:
Notes
Capacity
(
gal)
11800
From
MACT
survey
Formaldehyde
emissions
(
tpy)
0.052
From
MACT
survey
Phenol
emissions
(
tpy)
0.086
From
MACT
survey
Methanol
emissions
(
tpy)
0.018
From
MACT
survey
Total
HAP
emissions
(
tpy)
0.156
HAP
reduction
(
tpy)
0.140
90%
reduction
Existing
tank
retrofit
costs:

Degassing
cost
$
936
Degas
=
7.61
x
capacity0.5132
Tank
diameter
(
ft)
11.6
Tank
diameter
=
(
capacity
/
7.481)
1/
3
IFR
$
7,085
IFR
=
509
x
tank
diameter
+
1160
Total
capital
investment
(
TCI)
$
8,021
TCI
=
Degas
+
IFR
Escalated
TCI
$
8,276
From
1989
to
1997
$

Total
annualized
cost
(
TAC)
$
1,736
TAC
=
(
TCI
x
0.2098)
­
(
HAP
reduction
x
0.1)

Cost­
effectiveness
($/
ton)
$
12,367
Cost­
effectiveness
=
TAC/
HAP
reduction
New
tank
IFR
costs:

Degasing
cost
$
­
NA
for
new
tanks
Tank
diameter
(
ft)
11.6
Tank
diameter
=
(
capacity
/
7.481)
1/
3
IFR
$
7,085
IFR
=
509
x
tank
diameter
+
1160
Total
capital
investment
(
TCI)
$
7,085
TCI
=
Degas
+
IFR
Escalated
TCI
$
7,311
From
1989
to
1997
$

Total
annualized
cost
(
TAC)
$
1,534
TAC
=
(
TCI
x
0.2098)
­
(
HAP
reduction
x
0.1)

Cost­
effectiveness
($/
ton)
$
10,925
Cost­
effectiveness
=
TAC/
HAP
reduction
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.
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.

3.
Memorandum
from
K.
Hanks,
RTI,
to
M.
Kissell
and
D.
Pagano,
EPA/
ESD.
November
7,
2003.
Estimates
of
Ancillary
Plywood
and
Composite
Wood
Products
Process
Emissions
for
Use
in
Risk
Modeling.
