Date:
January
21,
2004
Subject:
Environmental
and
Energy
Impacts
for
the
Final
Plywood
and
Composite
Wood
Products
NESHAP
EPA
Contract
No.
68­
D­
1­
079;
EPA
Work
Assignment
No.
2­
12
RTI
Project
No.
08550.002.012
From:
Kristin
Parrish
To:
Mary
Tom
Kissell,
ESD/
WCPG
(
C439­
03)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
I.
Introduction
National
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
were
proposed
for
the
plywood
and
composite
wood
products
(
PCWP)
industry
on
January
9,
2003.1
Nationwide
environmental
and
energy
impacts
were
estimated
prior
to
proposal
of
the
PCWP
NESHAP
using
the
methodology
described
in
the
proposal
Background
Information
Document
(
BID).
2
The
impacts
associated
with
the
PCWP
standards
were
estimated
for
each
plant
and
were
summed
to
arrive
at
nationwide
impacts
estimates.
Impact
estimates
were
developed
only
for
those
plants
that
were
determined
to
be
major
sources.
3
The
impact
estimates
were
developed
based
on
the
control
equipment
(
e.
g.,
regenerative
thermal
oxidizers
[
RTO]
or
wet
electrostatic
precipitators
[
WESP]
in
series
with
RTO)
that
plants
would
likely
install
to
comply
with
the
PCWP
standards
at
the
MACT
floor
control
level.
Impact
estimates
were
not
developed
for
process
units
that
had
already
installed
the
necessary
control
equipment
as
of
April
2000.
The
impact
estimates
represent
a
worst­
case
estimate
of
impacts
because
the
use
of
RTO
results
in
greater
energy
usage
and
secondary
air
impacts
relative
to
other
control
technologies
such
as
regenerative
catalytic
oxidizers
(
RCO)
and
biofilters,
and
because
some
existing
PCWP
facilities
installed
new
controls
(
primarily
RTO
and
RCO)
after
April
2000
and
prior
to
publication
of
the
proposed
PCWP
NESHAP.

The
environmental
and
energy
impacts
associated
with
the
PCWP
NESHAP
include
a
reduction
in
emissions
of
hazardous
air
pollutants
(
HAP)
and
total
hydrocarbons
(
THC);
changes
in
onsite
criteria
pollutant
emissions
(
i.
e.,
carbon
monoxide
[
CO],
particulate
matter
less
than
10
micrometers
in
aerodynamic
diameter
[
PM
10],
and
nitrogen
oxides
[
NO
X])
after
compliance
with
the
PCWP
NESHAP;
wastewater
generated
by
the
operation
and
maintenance
of
air
pollution
2
control
devices
(
APCD);
solid
waste
generated
by
the
operation
and
maintenance
of
APCD;
secondary
air
impacts
(
i.
e.,
emissions
of
criteria
pollutants
associated
with
the
generation
of
electricity
necessary
to
power
APCD);
and
fuel
and
electricity
use
by
APCD.

Since
proposal
of
the
PCWP
NESHAP,
we
have
analyzed
additional
information
regarding
the
estimated
environmental
and
energy
impacts.
As
a
result,
we
have
revised
some
of
the
environmental
impact
estimates.
Section
II
of
this
memorandum
addresses
changes
made
to
the
estimate
for
emissions
of
NO
X;
Section
III
discusses
revisions
to
the
estimate
for
wastewater
generation;
and
Section
IV
discusses
additions
to
the
secondary
air
impacts
estimate.
A
summary
of
the
estimated
environmental
and
energy
impacts
associated
with
the
promulgation
of
the
PCWP
NESHAP
are
presented
in
Section
V.
The
proposal
BID
documents
the
methodology
used
to
estimate
the
environmental
impacts
that
we
did
not
revise,
including
the
estimated
HAP
and
THC
reduction,
onsite
emissions
of
CO
and
PM
10,
solid
waste
impacts,
and
energy
impacts.
2
Another
purpose
of
this
memorandum
is
to
document
calculations
that
we
performed
when
responding
to
public
comments
regarding
environmental
and
energy
impacts.
Attachment
1
explains
our
methodology
for
estimating
a
baseline
for
NO
X
emissions
from
PCWP
facilities
as
well
as
our
methodology
for
converting
our
estimated
NO
X
emissions
from
APCD
into
a
percentage
of
that
baseline.
Attachment
2
documents
the
source
of
baseline
energy
usage
values
and
methodology
for
estimating
the
increase
in
the
baseline
of
the
energy
impacts.

II.
Onsite
NO
X
Emissions
As
discussed
in
the
proposal
BID,
NO
X
is
formed
when
nitrogen
(
from
ambient
air
or
fuel)
is
exposed
to
the
high
temperatures
in
the
presence
of
oxygen
(
i.
e.,
through
combustion
processes).
Nitrogen
oxides
are
present
in
the
exhaust
streams
from
PCWP
process
units
that
incorporate
combustion
units
(
e.
g.,
direct­
fired
dyers).
Because
RTO
use
combustion
to
destroy
pollutants,
they
may
also
generate
some
NO
X.
The
total
amount
of
NO
X
emitted
includes
the
NO
X
emissions
from
the
PCWP
process
unit
plus
the
NO
X
generated
in
the
RTO.

The
NO
X
air
impacts
associated
with
the
PCWP
standards
result
from
the
increase
in
NO
X
emissions
across
the
RTO.
Prior
to
proposal,
we
used
information
from
RTO
vendors,
including
vendor
test
results
from
1994
and
performance
guarantees,
to
conservatively
estimate
the
typical
NO
X
increase
across
an
RTO
as
10
parts
per
million
by
volume
(
ppmv).
4,5,6
In
July
of
2003,
the
National
Council
for
Air
and
Stream
Improvement
(
NCASI)
published
the
results
of
a
PCWP
industry­
sponsored
study
of
RTO
emissions
and
control
efficiency.
7
The
results
of
those
tests
are
displayed
in
Table
1.
These
data
are
much
more
recent
and
reflect
the
performance
of
newer
RTO
models.
Therefore,
we
adjusted
our
estimate
of
the
typical
NO
X
increase
across
an
RTO
to
5
ppmv,
the
largest
average
value
observed
during
the
NCASI
study.
The
following
equation
was
used
to
estimate
the
revised
increase
in
NO
X
emissions:

NO
X
increase
(
ton/
yr)
=
(
8,000
hr/
yr)
*
(
5
ppm)
*
(
10­
6)
*
(
46.01
lb
NO
2/
lbmole)
*
(
dscfm)
*
(
60
min/
hr)
/
(
385.3
ft3/
lbmole
ideal
gas
at
528

R)
/
(
2,000
lb/
ton)
3
The
above
equation
was
applied
to
estimate
the
NO
X
increase
for
each
RTO
expected
to
be
installed
as
a
result
of
the
PCWP
standards.
The
plant­
specific
NO
X
increase
was
calculated
by
summing
the
NO
X
increase
for
each
RTO,
and
the
nationwide
NO
X
increase
was
calculated
by
summing
the
plant­
specific
NO
X
increases.
The
revised
nationwide
estimates
for
the
NO
X
increase
from
RTO
operation
are
presented
in
Section
V
of
this
memorandum.

III.
Wastewater
Impacts
Potential
wastewater
impacts
are
associated
with
use
of
RTO
and
WESP.
Routine
cleaning
for
RTO,
either
through
periodic
bakeouts
or
washing
out
of
the
RTO
beds,
is
necessary
to
remove
particulate
buildup.
Wastewater
is
generated
as
a
result
of
washing
out
RTO.
Wastewater
is
also
generated
by
WESP,
which
often
precede
RTO
to
protect
the
RTO
from
particulate
matter
that
can
plug
the
bed
and
reduce
performance.
The
WESP
blowdown
is
the
fraction
of
the
recirculated
WESP
water
that
is
purged
from
the
WESP
system.
Wastewater
impacts
were
based
on
use
of
RTO,
although
other
control
devices,
such
as
biofilters,
are
also
sources
of
wastewater.
We
based
our
wastewater
estimates
largely
on
information
provided
by
PCWP
facilities
in
their
PCWP
survey
responses.
8
We
also
used
some
vendor
information
in
developing
the
wastewater
impact
estimates.
9
The
methodology
used
to
estimate
the
wastewater
generated
by
RTO
operation
and
maintenance
is
described
in
the
proposal
BID.
2
The
annual
volume
of
WESP
blowdown
was
originally
determined
based
on
a
1­
gallon
per
minute
(
gpm)
blowdown
system
sized
to
treat
27,650
dry
standard
cubic
feet
per
minute
(
dscfm)
of
OSB
rotary
dryer
exhaust
described
by
a
WESP
vendor.
9
The
vendor
estimate
of
1
gpm
for
volume
of
WESP
blowdown
per
year
is
within
of
the
range
of
blowdown
rates
reported
in
the
PCWP
survey
responses
for
individual
WESP.
The
PCWP
survey
responses
had
a
median
of
4
gpm,
and
many
reported
values
were
in
the
1
to
2
gpm
range.
Using
an
operation
rate
of
8,000
hours
per
year
(
hr/
yr),
we
estimated
that
a
1­
gpm
blowdown
system
would
produce
480,000
gallons
per
year
(
gal/
yr)
of
wastewater.

During
the
public
comment
period
following
proposal,
we
received
a
comment
that
provided
additional
information
regarding
wastewater
amounts
and
treatment
methods.
10
After
closely
reviewing
that
data,
we
revised
our
estimate
of
the
WESP
blowdown
rate
to
4
gpm.
Using
an
operation
rate
of
8,000
hr/
yr,
our
revised
estimate
for
the
amount
of
wastewater
produced
by
each
WESP
is
1,920,000
gal/
yr.

The
total
amount
of
wastewater
expected
to
be
generated
by
each
plant
as
a
result
of
the
PCWP
standards
was
calculated
as
the
sum
of
the
wastewater
generated
from
each
control
device
(
RTO
and
WESP).
The
nationwide
wastewater
impacts
were
calculated
by
summing
the
wastewater
impacts
for
each
plant.
Section
V
presents
the
revised
nationwide
wastewater
impacts.
4
IV.
Secondary
Air
Impacts
Emissions
of
criteria
air
pollutants
are
produced
from
generation
of
the
electricity
necessary
to
power
APCD.
The
secondary
air
impacts
associated
with
increased
electricity
consumption
were
estimated
as
described
in
the
proposal
BID.
Energy
Information
Administration
(
EIA)
statistics
indicate
that
most
of
the
existing
U.
S.
electric
utility
capacity
uses
coal
as
the
energy
source.
11
Therefore,
prior
to
proposal,
we
assumed
that
electricity
would
be
generated
at
coal­
fired
utility
plants
built
since
1978.
Utility
plants
built
since
1978
are
subject
to
the
new
source
performance
standards
(
NSPS)
in
40
CFR
part
60,
subpart
Da.
12
The
NSPS
emission
limits
were
used
to
estimate
the
sulfur
dioxide
(
SO
2),
PM
10,
and
NO
X
(
as
NO
2)
emissions
from
coal
combustion.
These
limits
for
coal­
fired
utilities
for
SO
2,
total
particulate
matter
(
PM),
and
NO
X
(
as
NO
2)
are
1.20,
0.03,
and
0.60
pound
of
pollutant
per
million
British
thermal
units
of
heat
input
(
lb/
MMBtu),
respectively.
(
Note:
Use
of
the
NSPS
emission
limit
for
PM
overstates
the
secondary
air
pollutant
emissions
for
PM
10.
According
to
AP­
42,
PM
10
is
about
37
percent
of
the
total
PM.
13)
The
CO
emissions
were
estimated
using
an
AP­
42
emission
factor
because
CO
emissions
are
not
covered
by
the
NSPS.
13
The
power
plant
thermal
efficiency
(
i.
e.,
the
efficiency
with
which
coal
is
converted
into
electricity)
was
taken
to
be
one­
third,
based
on
a
typical
value
for
power
plants
fired
by
fossil
fuels
reported
in
literature.
14
The
heating
value
for
bituminous
coal
(
the
type
of
coal
most
commonly
used
for
electricity
generation)
was
taken
to
be
12,750
Btu/
lb
coal,
as
fired.
13,15
The
equations
used
to
calculate
the
annual
secondary
air
emissions
estimates
for
SO
2,
PM,
NO
X,
and
CO
are
described
in
the
proposal
BID.
2
Assuming
that
all
utility
plants
are
coal­
fired
results
in
worst­
case
estimates
of
the
secondary
air
impacts.
Many
utilities
use
cleaner­
burning
fuels
such
as
natural
gas.
Therefore,
to
better
reflect
the
range
of
fuels
used
for
U.
S.
electricity
generation,
we
calculated
a
second
set
of
estimates
for
utility
plants
burning
natural
gas.
The
results
of
these
two
sets
of
calculations
are
presented
as
a
range
for
the
estimates
of
secondary
air
impacts
in
Table
3.

To
calculate
estimates
for
utilities
burning
natural
gas,
we
used
emission
factors
obtained
from
AP­
42
for
all
four
criteria
pollutants.
These
emission
factors
for
natural
gas­
fired
utilities
for
SO
2,
PM,
NO
X
(
as
NO
2),
and
CO
are
0.6,
7.6,
140,
and
84
pounds
of
pollutant
per
million
standard
cubic
feet
of
natural
gas
fired
(
lb/
106
scf),
respectively.
16
Again,
use
of
the
emission
factor
for
total
PM
overstates
the
secondary
air
pollutant
emissions
for
PM
10.
Because
natural
gas
is
a
fossil
fuel,
the
power
plant
thermal
efficiency
was
again
taken
to
be
one­
third.
The
heating
value
for
natural
gas
was
taken
to
be
1,035
Btu
per
cubic
feet
(
Btu/
ft3),
as
fired.
15
The
following
equation
was
used
to
calculate
the
annual
secondary
air
emissions
of
SO
2,
PM,
and
NO
X
from
natural
gas­
fired
utility
plants:
5
EM
=
EF
*
10

6
*
E
/
TE
/
HV
*
(
3,415
Btu/
kWh)
/
(
2,000
lb/
ton)

where:

EM
=
emissions,
tons
per
year
(
ton/
yr)

EF
=
emission
factor
from
AP­
42,
lb/
106
scf
(
0.6
for
SO
2,
7.6
for
PM,
140
for
NO
X
as
NO
2,
and
84
for
CO)

E
=
plant­
specific
RTO
and/
or
WESP
electricity
consumption
calculated
as
described
in
the
BID,
kilowatt
hours
per
year
(
kWh/
yr)

TE
=
thermal
efficiency
of
power
plant
(
33
percent)

HV
=
heating
value
of
natural
gas,
1,035
Btu/
ft3
The
plant­
specific
secondary
air
impacts
associated
with
the
PCWP
standards
were
calculated
by
summing
the
impacts
estimated
for
each
RTO
and/
or
WESP
expected
to
be
installed
at
each
plant.
The
nationwide
secondary
air
impacts
were
calculated
by
summing
the
plantspecific
impacts.
Section
V
summarizes
the
range
of
estimated
nationwide
secondary
air
impacts
from
electricity
generated
by
utility
plants
burning
coal
and
natural
gas.

V.
Summary
of
Environmental
and
Energy
Impacts
Tables
2
through
5
summarize
the
environmental
and
energy
impacts
estimated
for
the
final
PCWP
NESHAP.
Each
table
presents
the
nationwide
environmental
impacts
by
product
type.

Table
2
summarizes
the
nationwide
reduction
in
total
HAP
and
THC
estimated
to
result
from
the
PCWP
standards
at
the
MACT
floor
control
level
(
the
control
level
selected
as
MACT).
Table
3
summarizes
the
nationwide
change
in
emissions
of
onsite
criteria
air
pollutants
and
the
secondary
air
impacts
associated
with
the
MACT
floor
control
level.
As
shown
in
Attachment
1,
we
estimate
a
10
percent
increase
in
NO
X
emissions
from
the
baseline.
For
secondary
air
impacts,
burning
natural
gas
results
in
higher
CO
emissions
than
burning
coal,
but
the
secondary
emissions
of
SO
2,
PM
10
and
NO
X
are
reduced
when
burning
natural
gas.
The
results
of
calculations
assuming
first
coal
and
then
natural
gas
are
presented
in
Table
3
as
an
estimated
range.
The
actual
secondary
air
impacts
are
expected
to
fall
within
this
estimated
range.

Table
4
summarizes
the
nationwide
wastewater
and
solid
waste
impacts.
Table
5
summarizes
the
nationwide
energy
impacts.
As
shown
in
Attachment
2,
we
estimate
a
2
percent
increase
in
energy
use
from
the
baseline.
6
7
TABLE
1.
NO
X
INCREASE
ACROSS
RTO
OBSERVED
DURING
NCASI
STUDY
a,
7
Mill
118
Mill
170b
Mill
425
(
east
RTO)
Mill
425
(
west
RTO)

RTO
temperature,
°
F
NOX
increase,

ppmvd
RTO
temperature,
°
F
NOX
increase,

ppmvd
RTO
temperature,
°
F
NOX
increase,

ppmvd
RTO
temperature,
°
F
NOX
increase,

ppmvd
1550
2
1480
2.8
1430
3
1430
1
1600
4
1510
3.7
1470
5
1470
6
1625
4
1530
1.9
1570
5
1570
8
1650
4
1550
4.4
1675
5
1675
3.5
Avg.
=
3.8
Avg.
=
3.3
Avg.
=
4.3
Avg.
=
5
a
A
separate
3­
run
test
was
conducted
for
varying
RTO
combustion
chamber
temperatures.

b
Inlet
NOX
was
not
tested
because
the
RTO
at
mill
170
controls
emissions
from
steam­
heated
veneer
dryers.
Conservatively
assuming
that
there
is
no
NOX
in
the
emissions
stream
entering
the
RTO,
all
of
the
NOX
at
the
outlet
of
the
RTO
was
assumed
to
be
generated
by
the
RTO.
8
TABLE
2.
ESTIMATED
NATIONWIDE
REDUCTION
IN
TOTAL
HAP
AND
THC
Product
type
Total
HAP
(
ton/
yr)
THC
(
ton/
yr)

Baseline
MACT
floor
Reduction
Baseline
MACT
floor
Reduction
Softwood
plywood/
veneer
3,700
3,043
657
19,631
9,709
9,922
Hardwood
plywood/
veneer
161
161
0b
640
640
0b
Medium
density
fiberboard
2,469
345
2,124
4,763
572
4,191
Oriented
strandboard
3,513
753
2,760
5,362
1,755
3,607
Particleboard
(
molded
and
conventional)
5,377
2,787
2,590
12,632
6,724
5,908
Particleboard
(
agriboard)
not
estimateda
not
estimateda
0b
not
estimateda
not
estimateda
0b
Hardboard
3,291
752
2,539
5,478
2,103
3,374
Fiberboard
78
78
0b
398
398
0b
Engineered
wood
products
298
230
68
793
617
176
TOTAL
18,933
8,196
10,737
49,706
22,529
27,178
a
Baseline
emissions
were
not
estimated
for
agriboard
plants
because
sufficient
data
was
not
available
to
estimate
the
baseline
emissions.
However,
agriboard
plants
are
not
impacted
by
the
PCWP
standards
because
none
are
believed
to
be
major
sources
of
HAP
emissions.
Because
agriboard
plants
are
not
impacted
by
the
PCWP
standards,
there
are
no
environmental
or
energy
impacts
for
agriboard
plants
resulting
from
the
standards.

b
There
is
no
impact
because
no
plants
are
impacted
by
the
PCWP
standards
at
the
MACT
floor
control
level.
9
TABLE
3.
ESTIMATED
NATIONWIDE
CHANGE
IN
ONSITE
NO
X,
CO,
AND
PM
10
EMISSIONS
AND
ESTIMATED
NATIONWIDE
SECONDARY
AIR
IMPACTS
Product
type
Criteria
Pollutant
Impacts
(
ton/
yr)
a
Secondary
Air
Impacts
(
ton/
yr)
b
NOX
CO
PM10
NOX
CO
PM10
SO2
Softwood
plywood/
veneer
350
1,278
(
5,070)
72
­
321
10
­
43
4
­
16
0
­
642
Hardwood
plywood/
veneer
0c
0c
0c
0c
0c
0c
0c
Medium
density
fiberboard
428
(
162)
(
1,823)
87
­
388
13
­
52
5
­
19
0
­
775
Oriented
strandboard
440
(
4,386)
(
2,214)
103
­
457
15
­
62
6
­
23
0
­
914
Particleboard
(
molded
and
conventional)
652
(
7,253)
(
2,044)
134
­
592
19
­
80
7
­
30
1
­
1,183
Particleboard
(
agriboard)
0c
0c
0c
0c
0c
0c
0c
Hardboard
463
17
(
1,357)
95
­
420
14
­
57
5
­
21
0
­
839
Fiberboard
0c
0c
0c
0c
0c
0c
0c
Engineered
wood
products
43
(
267)
(
176)
12
­
52
2
­
7
1
­
3
0
­
104
TOTAL
2,375
(
10,772)
(
12,684)
502
­
2,229
73
­
301
27
­
111
2
­
4,457
a
Negative
numbers
representing
emission
reductions
are
presented
in
parentheses.
Numbers
without
parentheses
represent
emissions
increases.

b
Range
reflects
values
calculated
assuming
utility
plants
burn
either
natural
gas
(
low
end
of
range
for
NOX,
PM10,
and
SO2;
high
end
of
range
for
CO)
or
coal
(
high
end
of
range
for
NOX,
PM10,
and
SO2;
low
end
of
range
for
CO).

c
There
is
no
impact
because
no
plants
are
impacted
by
the
PCWP
standards
at
the
MACT
floor
control
level.
10
TABLE
4.
ESTIMATED
NATIONWIDE
SOLID
WASTE
AND
WASTEWATER
IMPACTS
Product
type
Solid
Waste
Impacts
(
ton/
yr)
Wastewater
Impacts
(
1,000
gal/
yr)

RTO
media
WESP
wastewater
solidsa
RTO
washwater
WESP
blowdowna
Softwood
plywood/
veneer
589
NAb
2,112
NA
Hardwood
plywood/
veneer
0c
0c
0c
0c
Medium
density
fiberboard
719
NA
832
NA
Oriented
strandboard
740
810
768
17,280
Particleboard
(
molded
and
conventional)
1,096
NA
1,677
NA
Particleboard
(
agriboard)
0c
0c
0c
0c
Hardboard
779
NA
630
NA
Fiberboard
0c
0c
0c
0c
Engineered
wood
products
72
180
156
3,840
TOTAL
3,995
990
6,175
21,120
a
WESP
wastewater
solids
and
blowdown
are
only
estimated
for
plants
with
rotary
strand
dryers
(
i.
e.,
OSB
and
engineered
wood
products
plants)
b
NA
=
Not
applicable.
Upstream
WESP
are
not
necessary
for
PM
control
for
this
industry
sector.
c
There
is
no
impact
because
no
plants
are
impacted
by
the
PCWP
standards
at
the
MACT
floor
control
level.
11
TABLE
5.
ESTIMATED
NATIONWIDE
ENERGY
IMPACTS
Product
type
RTO
natural
gas
consumption
(
Billion
Btu/
yr)
RTO
electricity
consumption
(
GWh/
yr)
WESP
electricity
consumption
(
GWh/
yr)
b
Softwood
plywood/
veneer
175
103
NA
Hardwood
plywood/
veneer
0c
0c
0c
Medium
density
fiberboard
346
125
NA
Oriented
strandboard
269
129
19
Particleboard
(
molded
and
conventional)
434
191
NA
Particleboard
(
agriboard)
0c
0c
0c
Hardboard
385
135
NA
Fiberboard
0c
0c
0c
Engineered
wood
products
29
13
4
TOTALa
1,638
695
23
a
Totals
may
not
sum
exactly
due
to
rounding.
b
WESP
electricity
consumption
is
only
estimated
for
plants
with
rotary
strand
dryers
(
i.
e.,
OSB
and
engineered
wood
products
plants).
c
There
is
no
impact
because
no
plants
are
impacted
by
the
PCWP
standards
at
the
MACT
floor
control
level.
12
References
1.
U.
S.
Environmental
Protection
Agency.
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products;
Proposed
Rule.
68
FR
1276.
Washington,
DC.
U.
S.
Government
Printing
Office.
January
9,
2003.

2.
U.
S.
Environmental
Protection
Agency.
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.

3.
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.

4.
Smith
Environmental
Corporation.
Environmental
Newsletter
for
the
Wood
Industry.
August
1994.

5.
Smith
Engineering
Corporation.
Wood
Industry
Environmental
Newsletter.
March
1994.

6.
R.
Grzanka,
REECO.
An
Engineered
Solution
for
Fugitive
Emissions
Control
from
Three
Veneer
Dryers
at
a
Plywood
Plant.
Undated.

7.
An
Evaluation
of
Control
Efficiency
at
Different
Combustion
Chamber
Temperatures
for
Regenerative
Thermal
Oxidizers
Installed
on
Panel
Plant
Wood
Furnish
Dryers,
Technical
Bulletin
865,
National
Council
for
Air
and
Stream
Improvement,
Inc.,
Research
Triangle
Park,
NC,
July
2003.

8.
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.

9.
Letter
and
attachments
from
S.
Jaasund,
Geoenergy
International
Corporation,
to
B.
Nicholson,
MRI.
March
28,
2000.
Geoenergy
WESP
Capital
and
Operating
Costs.

10.
Public
Comment
from
T.
G.
Hunt,
Senior
Director,
Air
Quality
Programs,
American
Forest
&
Paper
Association,
Washington,
DC.
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.
Attachment
K.

11.
Energy
Information
Administration,
Form
EIA­
860A.
Annual
Electric
Generator
Report
 
Utility.

12.
40
CFR
Part
60.
Subpart
Da.
13
13.
Compilation
of
Air
Pollutant
Emission
Factors,
AP­
42,
5th
Edition,
Supplement
E.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
Volume
I:
Stationary
Point
and
Area
Sources.
Section
1.1:
Bituminous
and
Subbituminous
Coal
Combustion.
September
1998.

14.
Carbon
Dioxide
Emissions
from
the
Generation
of
Electric
Power
in
the
United
States.
Washington,
DC,
U.
S.
Department
of
Energy
and
U.
S.
Environmental
Protection
Agency,
Washington,
D.
C.
October
15,
1999.

15.
R.
H.
Perry
and
D.
W.
Green,
Eds.
Perry's
Chemical
Engineers'
Handbook.
6th
Edition.
New
York,
McGraw­
Hill.
1984.
pp.
9­
18.

16.
Compilation
of
Air
Pollutant
Emission
Factors,
AP­
42,
5th
Edition,
Supplement
D.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
Volume
I:
Stationary
Point
and
Area
Sources.
Section
1.4:
Natural
Gas
Combustion.
July
1998.
Attachment
1
Baseline
and
Percent
Increase
Calculations
for
NO
X
Emissions
1U.
S.
Environmental
Protection
Agency.
1999
National
Emission
Inventory
Documentation
and
Data.
Final
1999
NEI
Version
2.
October,
2002.
As
shown
in
Table
3
of
this
memorandum,
the
nationwide
estimate
for
NO
X
emissions
from
APCD
is
2,375
ton/
yr.
We
estimated
that
161
plants
would
need
to
install
APCD
(
RTO
was
assumed
for
the
impacts
analyses).
Using
these
data,
we
calculated
an
estimated
increase
in
NO
X
of
15
ton/
yr
per
plant
as
a
result
of
operating
APCD.

To
put
this
value
into
context,
we
examined
two
different
sources
of
information
to
develop
a
baseline
estimate
of
NO
X
emissions
from
the
PCWP
industry.
These
sources
are
(
1)
information
from
roughly
40
permits
readily
available
in
our
files
and
(
2)
criteria
pollutant
data
in
the
1999
National
Emission
Inventory
(
NEI).
The
information
in
the
NEI
is
continually
updated
as
EPA
receives
information
from
States
and
other
sources.
At
the
time
the
NEI
data
files
were
examined
for
this
analysis,
two
versions
of
the
data
were
available:
final
1999
NEI
version
2
and
draft
1999
NEI
version
3.
The
draft
of
version
3
was
posted
solely
to
allow
State,
local,
and/
or
tribal
air
management
agencies
to
review
the
data
and
submit
any
corrections.
Therefore,
version
2
was
the
most
recent
source
of
NEI
data
suitable
for
performing
data
analyses.
1
When
we
compared
the
permit
data
with
the
NEI
data
for
individual
facilities,
we
found
large
variations
in
the
facility
baseline
NO
X
emissions.
Therefore,
we
combined
the
information
from
the
two
sources
to
estimate
a
ballpark
facility
baseline
NO
X
emissions
value
for
each
sector.
Using
the
averages
from
the
two
information
sources
and
the
estimate
of
a
15
ton/
yr
increase
across
an
RTO,
we
then
determined
the
average
baseline
NO
X
for
all
facilities
and
the
percent
increase
in
baseline
NO
X.
See
Table
1
for
the
results
of
this
analysis.

Based
on
our
various
analyses,
we
estimate
that
the
increase
in
NO
X
emissions
from
APCD
installed
to
comply
with
the
PCWP
NESHAP
will
be
no
more
than
10
percent
of
the
baseline
NO
X
emissions.

TABLE
1.
AVERAGE
BASELINE
NO
X
EMISSIONS
FROM
PCWP
MAJOR
SOURCE
FACILITIES
FROM
TWO
INFORMATION
SOURCES
Averages
(
Ranges)
of
NOX
emissions
(
ton/
yr)

Final
1999
NEIa
Permit
Dataa
Ballpark
baseline
per
facility
Overall
average
146
(
0
­
2,682)
189
(
7
­
576)
167
Percent
increase
of
baseline
from
APCD
10.1%
7.8%
8.8%

a
Numbers
in
parentheses
indicate
the
range
of
data.
Attachment
2
Baseline
and
Percent
Increase
Calculations
for
Energy
Impacts
1Energy
Information
Administration
(
EIA).
Table
N3.1.
Fuel
Consumption,
1998.
http://
www.
eia.
doe.
gov/
emeu/
mecs/
mecs98/
datatables/
d98n3_
1.
pdf
To
obtain
a
baseline
value
for
the
annual
amount
of
energy
used
by
the
PCWP
industry
to
operate
the
various
process
lines,
we
looked
at
information
collected
by
the
EIA.
The
EIA
Table
N3.1
and
Table
N3.2
display
annual
fuel
consumption
data
for
1998
by
industry
using
the
North
American
Industry
Classification
System
(
NAICS)
code
for
each
industry.
The
NAICS
code
3212
(
Veneer,
Plywood,
and
Engineered
Woods)
includes
hardwood
plywood,
softwood
plywood,
reconstituted
wood
products,
and
engineered
woods.
We
extracted
annual
values
of
fuel
consumed
for
the
PCWP
industry
of
10,556
million
kWh
(
10,556
gigawatt
hours
[
GWh])
of
electricity,
47
billion
cubic
feet
(
ft3)
of
natural
gas,
and
220
trillion
Btu
from
all
energy
sources.
1
These
values
are
the
baseline
values
for
the
PCWP
industry.

Table
5
in
Section
V
of
this
memorandum
provides
the
estimate
of
the
energy
increase
associated
with
PCWP
NESHAP
compliance.
The
total
electricity
consumption
is
the
sum
of
the
RTO
and
WESP
electricity
consumption,
718
GWh.
The
RTO
consume
1,582
million
ft3,
or
1.6
billion
ft3,
of
natural
gas
per
year.
The
estimated
overall
energy
requirement
was
then
calculated
using
the
following
formula:

TE
=
[
NG
R
*
1.035
trillion
Btu/
billion
ft3]
+
[
E
RW
*
0.003415
trillion
Btu/
GWh]

where
TE
=
total
estimated
energy
consumption,
trillion
Btu
NG
R
=
annual
natural
gas
consumption
estimate
for
RTO,
billion
ft3
E
RW
=
sum
of
annual
electricity
estimates
for
RTO
and
WESP,
GWh
The
result
of
this
calculation
was
an
estimate
of
4.1
trillion
Btu
necessary
to
operate
APCD
nationwide.

To
compare
the
baseline
energy
use
for
the
industry
and
our
estimates
of
the
energy
increase
associated
with
APCD,
we
converted
the
estimated
energy
increase
to
a
percentage
of
the
baseline
value.
Using
this
methodology,
we
determined
that
APCD
are
estimated
to
increase
the
annual
energy
consumption
of
the
PCWP
industry
by
less
than
2
percent
of
the
baseline.
Table
9
presents
the
relevant
values
and
calculations
for
this
analysis.
TABLE
1.
CALCULATION
OF
PERCENT
INCREASE
IN
1998
TOTAL
ENERGY
USE
FOR
THE
PCWP
INDUSTRY
EIA,
NAICS
code
32121,2
PCWP
NESHAP
Compliance
Percent
Increase
Electricity
Use,
GWh
10,556
718
Natural
Gas
Consumption,
billion
ft3
47
1.6
Overall
Consumption,
trillion
Btu
220
4.1
1.9%
