From:
Kristin
Parrish
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
January
12,
2004
Project:
Plywood
and
Composite
Wood
Products
(
PCWP)
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)

Re:
Meeting
Minutes
for
the
September
12,
2003
Conference
Call
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
Industry
Stakeholders
to
Discuss
Inclusion
of
Lumber
Kilns
in
the
PCWP
Source
Category
I.
Purpose
The
EPA
met
with
wood
treating
industry
stakeholders
from
Koppers
Industries
to
discuss
the
issues
surrounding
the
inclusion
of
all
lumber
kilns
in
the
Plywood
and
Composite
Wood
Products
(
PCWP)
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP).

The
conference
call
was
held
on
September
12,
2003.
The
list
of
participants
is
included
as
Attachment
1.

II.
Discussion
The
Koppers
Industries
representatives
began
the
call
by
expressing
their
continued
concern
about
EPA's
plans
to
include
lumber
kilns
at
all
facilities
in
the
PCWP
NESHAP.
They
stated
that
the
PCWP
NESHAP
is
not
a
lumber
kiln
regulation
and
that
all
lumber
kilns
are
covered
by
this
NESHAP
because
the
PCWP
industry
requested
that
they
be
included.
The
Koppers
Industries
representatives
noted
that
they
are
not
aware
of
all
their
options.
They
stated
that
they
wanted
to
use
the
teleconference
to
share
their
thoughts
on
the
issue
with
EPA
and
receive
ideas
on
their
potential
options.
They
noted
that
they
thought
that
one
option
might
be
to
2
delist
the
lumber
kiln
category
completely.
The
EPA
representatives
explained
that
since
lumber
kilns
are
currently
included
the
PCWP
source
category,
there
is
no
lumber
kiln
category
to
delist.

They
noted
that
separating
lumber
kilns
into
a
new
source
category
might
not
bring
the
desired
results.
Once
EPA
has
listed
a
new
category,
they
have
an
obligation
to
consider
MACT
standards
for
that
category.
The
EPA
could
only
begin
to
consider
delisting
a
lumber
kiln
category
if
they
could
conclusively
prove
that
none
of
the
facilities
with
lumber
kilns
were
major
sources.
The
EPA
representatives
noted
that
the
requirements
to
delist
a
category
are
riskrelated
so
they
would
also
need
to
ensure
that
no
single
source
poses
a
risk,
which
would
be
a
time­
consuming
process.

The
Koppers
Industries
representatives
stated
that
one
of
their
concerns
about
being
included
in
the
PCWP
NESHAP
is
future
regulation
(
e.
g.,
under
the
residual
risk
provisions
of
the
Clean
Air
Act
or
by
States).
To
avoid
a
situation
in
which
all
lumber
kilns
might
be
subject
to
a
regulation
that
only
applies
to
kilns
used
in
the
PCWP
industry,
the
Koppers
Industries
representatives
asked
if
several
lumber
kiln
subcategories
could
be
created
within
the
PCWP
source
category.
The
EPA
representatives
responded
that
if
any
regulations
are
proposed
for
lumber
kilns
in
the
future,
there
is
no
reason
why
EPA
cannot
create
subcategories
(
e.
g.
large
kilns
and
small
kilns,
etc.)
at
that
time
if
there
are
technical
reasons
to
support
such
an
action.

Any
decisions
that
might
be
made
about
regulating
lumber
kilns
would
not
automatically
apply
to
all
kilns
without
an
examination
of
the
emissions
levels
from
different
types
of
lumber
kilns.

The
Koppers
Industries
representatives
then
noted
that
the
future
residual
risk
analysis
is
not
as
big
of
a
concern
for
their
industry
as
the
possibility
of
more
stringent
regulations
implemented
by
individual
States.
Even
if
EPA
sets
a
MACT
floor
of
"
no
emissions
reduction"

for
lumber
kilns
and
finds
that
beyond­
the­
floor
options
are
not
cost­
effective,
the
States
still
may
choose
to
require
some
type
of
control
for
lumber
kilns.
In
the
past,
some
States
have
gone
beyond
federal
regulations
for
various
reasons,
including
lawsuits,
and
required
facilities
in
other
industries
to
control
additional
process
units
as
part
of
State
implementation
plans
(
SIP).
The
Koppers
Industries
representatives
are
concerned
that
including
all
lumber
kilns
in
the
PCWP
NESHAP
without
a
specific
control
requirement
will
bring
them
to
the
States'
attention
and
increase
the
risk
that
States
may
choose
to
regulate
them.
The
EPA
representatives
clarified
that
they
cannot
provide
the
wood
treating
industry
with
protection
from
criteria
pollutant
regulations
implemented
by
States.
The
EPA
representatives
also
noted
that
some
companies
and
industries
3
prefer
that
EPA
provide
some
type
of
regulation
for
any
process
unit
that
might
be
affected
so
that
States
have
guidance
for
implementation.
These
industries
feel
that
the
absence
of
mention
in
a
federal
regulation
may
leave
sources
more
vulnerable
than
a
determination
by
EPA
that
the
MACT
floor
is
"
no
emissions
reduction."
Any
MACT
floor
determination
made
by
EPA,

including
a
"
no
emissions
reduction"
determination,
indicates
to
the
States
that
someone
has
reviewed
and
analyzed
the
available
data.

The
Koppers
Industries
representatives
then
asked
if
EPA
could
specify
that
wood
treating
lumber
kilns
are
not
included
in
the
PCWP
source
category
and
are
not
major
sources.

The
Koppers
Industries
representatives
contended
that
EPA
has
promulgated
MACT
standards
for
as
few
as
three
sources,
so
small
source
categories
are
not
a
problem.
The
EPA
representatives
responded
that
they
would
need
more
information
about
the
lumber
kilns
in
the
category
before
they
could
make
that
determination.
The
Koppers
Industries
representatives
stated
that
their
lumber
kilns
are
not
major
sources,
and
wood
treating
facilities
that
are
major
sources
are
only
classified
as
such
because
of
other
equipment
at
the
site.
They
suggested
that
kilns
at
plywood
plants
might
emit
more
pollutants
than
kilns
at
wood
treating
plants,
and
they
asked
if
EPA
could
issue
a
statement
of
acknowledgment
that
lumber
kilns
are
different
sizes.

The
EPA
representatives
stated
that
since
neither
the
preamble
nor
the
PCWP
NESHAP
discuss
lumber
kilns
in
detail,
there
is
no
appropriate
location
for
such
language
within
the
regulation.

The
EPA
representatives
noted
that
it
might
be
possible
to
create
subcategories
for
lumber
kilns
based
on
the
amount
of
wood
dried,
but
they
also
noted
that
they
currently
have
no
information
to
support
such
an
action.

The
Koppers
Industries
representatives
stated
that
from
their
standpoint,
the
ideal
solution
would
allow
interested
parties
to
look
at
the
affected
source
list
and
clearly
see
that
lumber
kilns
not
located
at
PCWP
facilities
are
not
regulated
by
the
PCWP
NESHAP.
They
noted
that
the
best
way
to
accomplish
that
goal
might
be
to
change
the
affected
source
definition
to
clearly
state
that
lumber
kilns
at
wood
treating
facilities
are
not
covered.
They
noted
again
that
they
may
not
know
the
best
way
to
achieve
their
purposes,
so
they
want
to
present
their
ideas
and
have
EPA
help
with
the
logistics
and
implementation.
The
EPA
representatives
noted
that
the
major
point
of
contention
for
the
Koppers
Industries
representatives
appeared
to
be
the
phrase
"
and
any
other
kind
of
facility"
in
the
affected
source
definition.
The
Koppers
Industries
representatives
agreed
with
that
assessment,
noting
that
the
wording
made
the
definition
4
ambiguous
and
open
to
interpretation.
The
Koppers
Industries
representatives
again
noted
that
the
lumber
kilns
that
they
operate
are
not
major,
and
they
added
that
the
wood
treating
industry
would
rather
have
their
lumber
kilns
in
a
separate
category
than
remain
a
part
of
the
PCWP
NESHAP.

The
EPA
representatives
then
explained
that
all
lumber
kilns
were
considered
when
drafting
the
proposal
of
the
PCWP
NESHAP.
An
RTI
representative
clarified
that
RTI
examined
lumber
kilns
at
PCWP
facilities
and
other
facilities
to
the
best
of
their
ability.
The
operators
of
the
kilns
at
other
facilities
were
not
directly
surveyed,
but
all
of
the
information
obtained
on
any
lumber
kiln
was
analyzed.
Therefore,
the
MACT
floor
for
lumber
kilns
in
the
PCWP
NESHAP
is
based
on
all
lumber
kilns,
not
just
those
in
the
PCWP
industry.

The
Koppers
Industries
representatives
noted
that
most
wood
treaters
do
not
operate
more
than
one
small
lumber
kiln
for
drying
both
poles
and
dimensional
lumber,
and
they
asked
for
clarification
on
the
factors
used
to
determine
whether
a
source
is
a
major
source.
An
RTI
representative
responded
that
all
of
the
emission
sources
at
facility
must
be
considered.
If
the
only
emission
sources
at
a
facility
are
lumber
kilns,
then
the
emissions
from
one
lumber
kiln
alone
usually
are
not
high
enough
to
classify
a
facility
as
a
major
source.
The
EPA
representatives
added
that
the
major
source
determination
and
resulting
Title
V
permits
are
based
on
a
source's
potential
to
emit,
not
actual
emissions.

The
Koppers
Industries
representatives
then
asked
the
EPA
representatives
for
their
ideas
on
how
EPA
might
be
able
to
help
them.
The
EPA
representatives
responded
that
if
EPA
decided
to
remove
either
all
lumber
kilns
not
located
at
PCWP
facilities
or
only
lumber
kilns
in
the
wood
treating
industry
from
the
PCWP
NESHAP,
the
course
of
action
would
depend
on
the
status
of
the
lumber
kilns.
If
any
kilns
were
discovered
to
be
major
sources,
EPA
would
have
an
obligation
to
list
lumber
kilns
as
a
source
category
and
develop
MACT
standards
for
the
category.

Unlike
the
risk­
based
process
used
for
delisting
source
categories,
the
MACT
standard­
setting
process
is
technology­
based.
The
EPA
would
survey
facilities
with
lumber
kilns
to
gather
emissions
data
and
determine
the
emission
levels
of
the
best­
performing
sources.
The
Koppers
Industries
representatives
noted
that
10
years
from
now,
technology
will
be
different,
and
there
may
be
changes
in
control
technology
for
lumber
kilns.
The
EPA
representatives
agreed
with
that
statement,
adding
that
every
industry
faces
that
issue.
However,
although
EPA
reviews
the
5
residual
risks
of
every
regulated
industry
every
8
years
after
promulgation
of
the
regulations,
they
are
not
required
to
determine
new
MACT
floors
every
8
years.

The
Koppers
Industries
representatives
stated
that
they
wanted
to
contact
other
individuals
and
groups
about
the
lumber
kiln
issue.
They
mentioned
that
they
had
been
working
with
organizations
not
involved
in
the
first
conference
call
with
EPA
regarding
lumber
kilns
on
August
6,
2003.
They
then
asked
how
much
information
RTI
had
collected
on
lumber
kilns
not
located
at
PCWP
facilities.
An
RTI
representative
responded
that
RTI
surveyed
every
PCWP
facility
and
later
collected
the
names
of
facilities
in
the
wood
treating
industry.
The
RTI
representative
noted
that
the
information
on
the
lumber
kilns
in
the
wood
treating
industry
is
not
as
detailed
as
the
information
for
the
lumber
kilns
at
PCWP
facilities.
All
of
the
information
that
RTI
collected
can
be
found
in
the
docket.
The
Koppers
Industries
representatives
stated
that
they
would
examine
that
information
before
deciding
on
their
course
of
action.
The
EPA
representatives
explained
that
since
the
PCWP
NESHAP
must
be
signed
by
February
2004,
EPA
will
need
to
finish
making
decisions
about
any
changes
and
revising
the
proposal
by
November
so
that
the
final
rule
can
be
reviewed
by
the
U.
S.
Office
of
Management
and
Budget.

The
teleconference
was
then
adjourned.
6
Attachment
1
List
of
Participants
U.
S.
EPA
Mary
Tom
Kissell,
OAQPS
Mike
Thrift,
OGC
Industry
Stakeholders
Leslie
Hyde,
Koppers
Industries,
Inc.

Ken
_______,
Koppers
Industries,
Inc.

Research
Triangle
Institute
Katie
Hanks
Kristin
Parrish
