Gary
Gramp
<
gramp@
hpva.
org>
To:
Lynn
Dail/
RTP/
USEPA/
US@
EPA;
Mary
Kissell/
RTP/
USEPA/
US@
EPA
cc:
Please
respond
to
Gary
Gramp
Subject:
Cold
Pressing
of
Hardwood
Plywood
12/
02/
03
03:
51
PM
Dear
Mary
Tom
and
Lynn,

Our
industry
is
concerned
with
the
proposition
of
having
the
manufacture
of
hardwood
plywood
covered
under
two
NESHAPs.
The
letter
attached
to
this
E­
mail
suggests
a
simple
solution
to
this
dual
applicability.
Changing
the
definition
of
plywood
in
the
Plywood
and
Composite
Wood
Products
NESHAP
to
"
Plywood
means
a
panel
product
consisting
of
layers
of
wood
veneers
hot
or
cold
pressed
together
with
resin.
Plywood
includes
panel
products
made
by
hot
or
cold
pressing
(
with
resin)
veneers
to
a
substrate
such
as
particleboard,
MDF,
or
lumber".

Based
on
information
supplied
to
Lynn
last
August,
we
believe
the
intent
of
both
rulemakings
was
to
cover
the
manufacture
of
hardwood
plywood
substrates
exclusively
under
the
PCWP
NESHAP.
We
respectfully
request
that
a
change
be
made
in
the
definition
of
plywood
in
the
PCWP
NESHAP
to
include
cold
pressing,
and
subsequently
elimination
of
the
manufacture
of
hardwood
completely
from
applicability
under
the
WBP
Surface
Coating
NESHAP.

Thank
you.

Best
Regards,

Gary
Gary
D.
Gramp
Technical
Director
HPVA
PO
Box
2789,
Reston,
Virginia,
20195­
0789
1825
Michael
Faraday
Drive,
Reston,
Virginia,
20190­
5350
Phone:
703­
435­
2900
Fax:
703­
435­
2537
http://
www.
hpva.
org
(
See
attached
file:
MACT
Overlap
Letter.
doc)
Hardwood
Plywood
&
Veneer
Association
P.
O.
Box
2789,
Reston,
VA
20195­
0789
1825
Michael
Faraday
Drive,
Reston,
VA
20190­
5350
Phone:
703­
435­
2900;
FAX:
703­
435­
2537
E­
mail:
gramp@
hpva.
org
Web
Site:
www.
hpva.
org
December
2,
2003
Ms.
Mary
Tom
Kissell
Mr.
Lynn
Dail
Waste
and
Chemical
Processes
Group
Coatings
and
Consumer
Products
Group
Emissions
Standards
Division
Emissions
Standards
Division
(
C539­
03)
U.
S.
EPA
U.
S.
EPA
Research
Triangle
Park,
North
Carolina
27711
Research
Triangle
Park,
North
Carolina
27711
Re:
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products;
Proposed
Rule
Dear
Mary
Tom
and
Lynn,

As
you
are
aware
there
is
an
overlap
issue
between
the
Plywood
and
Composite
Wood
Products
(
PCWP)
NESHAP
and
the
Wood
Building
Products
(
WBP)
Surface
Coating
NESHAP
as
far
as
the
manufacture
of
hardwood
plywood
is
concerned.
Based
on
Lynn's
interpretation
letter
of
September
25,
2003,
hardwood
plywood
manufactured
using
a
hot
press
is
covered
by
the
PCWP
NESHAP,
while
hardwood
plywood
manufactured
by
cold
pressing
is
covered
by
the
WBP
NESHAP.
Our
industry
is
concerned
by
this
dual
coverage,
and
would
like
to
find
a
way
to
incorporate
both
processes
into
the
PCWP
MACT.

The
split
applicability
decision
was
apparently
influenced
by
one
major
factor.
The
definition
of
plywood
in
the
PCWP
NESHAP
includes
a
reference
to
hot
pressing
with
no
mention
of
cold
pressing.
Did
the
Coatings
and
Consumer
Products
Group
interpret
this
to
mean
production
of
hardwood
plywood
by
cold
pressing
was
not
covered
by
the
PCWP
MACT?
If
yes,
is
there
a
way
to
include
the
cold
pressing
process
in
the
PCWP
NESHAP
to
avoid
dual
applicability?

To
the
best
of
our
knowledge,
cold
pressing
represents
less
than
two
percent
of
hardwood
plywood
production.
HPVA
has
one
member
that
cold
presses
100
percent
of
their
plywood
production
using
ureaformaldehyde
resins.
This
member
shut
down
their
hot
press
operation
because
they
could
not
meet
the
formaldehyde
emission
requirements
under
Title
V.
They
have
no
problem
with
formaldehyde
emissions
using
the
cold
press
process,
so
formaldehyde
emissions
should
not
be
a
factor
in
this
decision.

One
solution
would
be
to
add
cold
pressing
to
the
definition
of
hardwood
plywood
in
the
PCWP
NESHAP.
If
this
approach
were
acceptable
to
both
of
you,
we
would
also
like
to
see
another
interpretation
letter
indicating
lamination
of
a
wood
veneer
to
any
substrate
is
exclusively
covered
by
the
PCWP
NESHAP.
We
believe
this
was
the
original
intent
of
both
rulemakings
from
the
start.

Thank
you
for
your
consideration.
I
look
forward
to
your
response.

Sincerely,

Gary
D.
Gramp
Technical
Director
