"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>

To:
Mary
Kissell/
RTP/
USEPA/
US@
EPA,
Mike
Thrift/
DC/
USEPA/
US@
EPA,
Dave
Guinnup/
RTP/
USEPA/
US@
EPA,
"'
Edmond_
Toy@
omb.
eop.
gov'"
<
Edmond_
Toy@
omb.
eop.
gov>,
"
Holman,
Keith
W."
<
Keith.
Holman@
sba.
gov>,
Ken
Hustvedt/
RTP/
USEPA/
US@
EPA
cc:
Subject:
RE:
Plywood
Changes
­
Acrolein
and
Benzene
Testing
­
Response
on
Detection
Limits
­
Data
had
low
nondetect
Levels
02/
25/
2004
03:
04
PM
Edmond
indicated
some
concern
with
the
technical
basis
for
the
exemptions
based
on
potentially
high
non­
detect
limits
in
the
tests.
I've
checked
with
Tim
Hunt.
The
detect
limits
were
.16
for
acrolein
and
.1
for
benzene,
both
well
below
the
1
ppm
specified
in
Appendix
B
(
see
below).
Therefore,
there
should
be
no
problem
in
relying
on
these
tests
for
the
exemption.

.............................

(
f)
Nondetect
data.
You
may
treat
emissions
of
an
individual
HAP
as
zero
if
all
of
the
test
runs
result
in
a
nondetect
measurement
and
the
conditions
in
paragraphs
(
1)
and
(
2)
of
this
section
are
met
for
the
relevant
test
method.
Otherwise,
nondetect
data
(
as
defined
in
§
63.2292
of
40
CFR
part
63,
subpart
DDDD)
for
individual
HAP
must
be
treated
as
one­
half
of
the
method
detection
limit.
(
1)
The
method
detection
limit
is
less
than
or
equal
to
1
part
per
million
by
volume,
dry
(
ppmvd)
for
pollutant
emissions
measured
using
Method
320
in
appendix
A
to
40
CFR
part
63;
or
the
NCASI
Method
IM/
CAN/
WP­
99.02
(
incorporated
by
reference
(
IBR),
see
40
CFR
63.14(
f));
or
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
fb)).

­­­­­
Original
Message­­­­­
From:
Bromberg,
Kevin
L.
Sent:
Wednesday,
February
25,
2004
11:
23
AM
To:
'
Kissell.
Mary@
epamail.
epa.
gov';
'
thrift.
mike@
epa.
gov';
'
Guinnup.
Dave@
epamail.
epa.
gov';
'
Edmond_
Toy@
omb.
eop.
gov';
Holman,
Keith
W.;
'
Hustvedt.
Ken@
epamail.
epa.
gov'
Subject:
Plywood
Changes
­
Acrolein
and
Benzene
Testing
These
chemicals
were
either
not
detected
at
all
or
were
detected
were
in
a
very
small
percentage
of
tests
(
all
less
than
5%),
and
that
number
of
small
positives
is
expected
in
a
large
dataset.
See
analysis
entitled
"
Evaluation
of
Wood
Products
Source
Categories"
for
further
details.

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

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Table
2
Modifications
Needed:

Instead
of
paragraph
(
5)
listing
acetaldehyde,
acrolein,
formaldehyde,
and
phenol,
exclude
acrolein,
and
create
its
own
new
paragraph
(
6)
for
acrolein
which
will
exclude:
Wood
products
presses
except
hardboard
(
included)
Steam­
Heated
or
Indirectly
Fired
Wood
products
dryers
­
except
in
the
hardboard
and
fiberboard
industries
Misc
Sources
­
except
in
the
hardboard
and
fibreboard
industries
Modify
old
paragraph
(
6)
for
benzene
to
exclude:

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

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

(
4)
each
process
unit
measure
moisture
content
of
the
stack
gas
Method
4
in
appendix
A
to
40
CFR
part
60.
(
5)
each
process
unit
measure
emissions
of
the
following
HAP:
acetaldehyde,
acrolein,
formaldehyde,
and
phenol
NCASI
Method
IM/
CAN/
WP­
99.02
(
IBR,
see
40
CFR
63.14(
f));
OR
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
fb))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.
(
6)
each
process
unit
measure
emissions
of
benzene
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14
(
fb))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.
(
7)
each
press
that
processes
board
containing
MDI
resin
measure
emissions
of
MDI
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
Conditional
Test
Method
(
CTM)
031
which
is
posted
on
http://
www.
epa.
gov/
ttn/
emc/
ctm.
html
(
8)
each
direct­
fired
process
unit
measure
emissions
of
the
following
HAP
metals:
arsenic,
beryllium,
cadmium,
chromium,
lead,
manganese,
and
nickel.
Method
29
in
appendix
A
to
40
CFR
part
60.
You
must
analyze
samples
using
atomic
absorption
spectroscopy
(
AAS).
(
9)
each
reconstituted
wood
product
press
or
reconstituted
wood
product
board
cooler
with
a
HAP
control
device
meet
the
design
specifications
included
in
the
definition
of
wood
products
enclosure
in
§
63.2292
of
subpart
DDDD
of
40
CFR
part
63
ok
­­­­­
Original
Message­­­­­
From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]

Sent:
Wednesday,
February
25,
2004
9:
54
AM
To:
Bromberg,
Kevin
L.
Cc:
'
Guinnup.
Dave@
epamail.
epa.
gov';
'
Edmond_
Toy@
omb.
eop.
gov';
Holman,
Keith
W.;
'
Hustvedt.
Ken@
epamail.
epa.
gov';
'
thrift.
mike@
epamail.
epa.
gov'
Subject:
Re:
Plywood
­
Benzene/
Acrolein
Response
and
other
SBA
Issues
for
Boil
ers
and
Plywood
If
you
send
any
more
faxes,
please
also
send
them
to
(
919)
685­
3219.

"
Bromberg,
Kevin
L."
To:
"'
Edmond_
Toy@
omb.
eop.
gov'"
<
kevin.
bromberg@
s
<
Edmond_
Toy@
omb.
eop.
gov>

ba.
gov>
cc:
Mike
Thrift/
DC/
USEPA/
US@
EPA,
Mary
Kissell/
RTP/
USEPA/
US@
EPA,
Ken
Hustvedt/
RTP/
USEPA/
US@
EPA,
02/
25/
2004
09:
41
Dave
Guinnup/
RTP/
USEPA/
US@
EPA,
"
Holman,
Keith
W."
AM
<
Keith.
Holman@
sba.
gov>

Subject:
Plywood
­
Benzene/
Acrolein
Response
and
other
SBA
Issues
for
Boil
ers
and
Plywood
Mary
­
still
need
that
contractor
response
on
the
benzene/
acrolein
that
you
promised
last
night­
otherwise
recommend
that
EPA
modify
table
2,
according
to
the
technical
analysis
showing
that
benzene
and
acrolein
are
not
detected
in
all
processes,
based
on
EPA's
own
dataset.

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

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