Date:
December
7,
2004
(
Revised
April
12,
2005)

Subject:
Procedures
for
Determining
Emissions
from
Plywood
and
Composite
Wood
Products
Process
Units
for
Low­
risk
Demonstrations
EPA
Contract
No.
68­
D­
1­
079;
EPA
Work
Assignment
No.
3­
04
RTI
Project
No.
08550.003.004
From:
Katie
Hanks,
Kristin
Parrish,
and
David
Randall
To:
Mary
Tom
Kissell,
ESD/
WCPG
(
C439­
03)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
I.
Introduction
Final
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
were
promulgated
by
the
Environmental
Protection
Agency
(
EPA)
Administrator
for
the
plywood
and
composite
wood
products
(
PCWP)
source
category
on
July
30,
2004
(
40
CFR
part
63,
subpart
DDDD).
The
NESHAP
applies
to
PCWP
manufacturing
facilities
that
are
located
at
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions,
except
for
facilities
the
EPA
determines
are
part
of
the
de­
listed
low­
risk
subcategory
of
PCWP
manufacturing
facilities.
To
become
part
of
the
low­
risk
subcategory
and
not
be
subject
to
the
requirements
of
subpart
DDDD,
facilities
must
submit
a
low­
risk
demonstration,
as
specified
in
appendix
B
to
subpart
DDDD,
for
EPA
approval.
Following
signature
of
the
final
PCWP
rule,
industry
stakeholders
raised
concerns
regarding
the
emission
testing
requirements
specified
in
Appendix
B
to
subpart
DDDD.
This
memorandum
explores
the
merits
of
the
stakeholders'
concerns.

Section
II
of
this
memorandum
outlines
the
stakeholders'
concerns
with
the
Appendix
B
testing
requirements.
Section
III
provides
an
assessment
of
the
stakeholders'
concerns.
Section
IV
describes
recommended
emission
estimation
procedures
for
selected
process
units.
Section
V
presents
a
summary
of
the
recommended
procedures
for
determining
HAP
emissions
for
possible
inclusion
in
an
amendment
of
Appendix
B
to
subpart
DDDD.
It
is
helpful
to
refer
to
the
summary
tables
in
Section
V
while
reading
this
memorandum.
2
II.
Stakeholders'
Concerns
with
Appendix
B
Testing
Requirements
Prior
to
promulgation
of
the
final
rule,
the
EPA
determined
that
the
majority
of
the
risk
at
PCWP
affected
sources
is
accounted
for
by
the
following
13
HAP:
acetaldehyde,
acrolein,
benzene,
arsenic,
beryllium,
cadmium,
hexavalent
chromium,
lead,
nickel,
formaldehyde,
phenol,
manganese,
and
methylene
diphenyl
diisocyanate
(
MDI).
Therefore,
Appendix
B
limits
the
list
of
HAP
that
must
be
included
in
the
low­
risk
demonstration
to
these
13
HAP.
Table
1
summarizes
the
process
units
that
must
be
tested
for
each
HAP
if
a
PCWP
source
seeks
to
become
part
of
the
low­
risk
subcategory
and
the
emissions
test
methods
specified
in
Appendix
B,
as
promulgated,
for
each
HAP.
1
Table
1.
Emissions
test
methods
specified
in
Appendix
B,
as
promulgated.

HAP
Process
units
Specified
test
method(
s)

Acetaldehyde,
acrolein,
formaldehyde,
phenol
All
process
unitsa
­
NCASI
IM/
CAN/
WP­
99.02
­
EPA
M320
or
ASTM
D6348­
03
Benzene
All
process
unitsa
­
EPA
M320
or
ASTM
D6348­
03
MDI
Presses
that
process
board
containing
MDI
resin
­
EPA
M320
­
Conditional
Test
Method
031
Arsenic,
beryllium,
cadmium,
chromium,
lead,
nickel,
manganese
Direct­
fired
process
unitsb
­
EPA
M29
MDI
=
methylene
diphenyl
diisocyanate
aAs
promulgated,
Appendix
B
requires
emissions
testing
for
all
PCWP
process
units
(
i.
e.,
testing
is
not
limited
to
the
process
units
with
control
or
work
practice
requirements
defined
in
subpart
DDDD).
bThe
potential
for
HAP
metals
emissions
from
direct­
fired
process
units
originates
from
combustion.

Stakeholders
have
expressed
concern
about
the
number
of
emissions
tests
that
are
required
by
Appendix
B
(
as
promulgated)
if
a
source
chooses
to
do
a
low­
risk
demonstration
and
the
resources
associated
with
conducting
and
reviewing
these
emissions
tests.
The
stakeholders
stated
that
emissions
testing
is
not
feasible
or
necessary
for
every
process
unit.
The
stakeholders
stated
that
many
PCWP
process
units
are
not
configured
for
emissions
testing
and
that
testing
of
every
type
of
PCWP
process
unit
(
especially
those
with
what
they
claim
are
insignificant
emissions)
is
not
reasonable.
2,3,4
In
addition,
the
stakeholders
stated
that
requiring
emissions
testing
for
acrolein
and
benzene
from
all
PCWP
process
units
is
not
justified
by
the
available
data
that
show
that
emissions
of
acrolein
and
benzene
are
frequently
not
detected
in
the
exhausts
from
many
types
of
PCWP
process
units.
2,5
The
stakeholders
requested
that
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
(
NCASI)
Method
IM/
CAN/
WP­
99.02
be
listed
in
Appendix
B
to
subpart
DDDD
for
measurement
of
benzene
as
well
as
for
measurement
of
acetaldehyde,
acrolein,
formaldehyde,
and
phenol.
They
also
requested
that
EPA
Method
18
be
allowed
for
benzene
testing.
The
stakeholders
also
suggested
that
only
one
of
multiple
identical
dryers
at
a
facility
would
need
to
be
tested
(
e.
g.,
only
one
of
three
identical
veneer
dryers)
and
that
the
emissions
data
from
the
one
dryer
tested
could
be
applied
to
the
other
identical
dryers.
The
stakeholders
further
suggested
that
only
one
of
multiple
identical
process
3
units
from
separate
facilities
within
the
same
company
would
need
to
be
tested.
Finally,
stakeholders
stated
that
HAP
metals
emissions
testing
is
not
necessary
for
direct­
fired
process
units
using
only
natural
gas.
21
III.
Assessment
of
Stakeholder's
Concerns
A.
Process
Units
to
Be
Considered
in
Low­
risk
Demonstration
1.
Background
Information
and
Issues
Table
1
of
the
preamble
to
the
final
PCWP
rule
(
provided
in
Attachment
1)
lists
most
of
the
PCWP
process
units
for
which
maximum
achievable
control
technology
(
MACT)
determinations
were
made
under
the
PCWP
NESHAP.
The
final
PCWP
rule
(
subpart
DDDD)
does
not
contain
definitions
for
all
of
the
process
units
listed
in
Table
1
of
the
preamble;
only
those
process
units
with
control
or
work
practice
requirements
are
defined
in
subpart
DDDD.
Even
though
some
process
units
are
not
specifically
defined
in
subpart
DDDD,
all
of
the
process
units
listed
in
Table
1
of
the
preamble
to
the
final
rule
are
part
of
the
PCWP
affected
source
(
as
defined
in
subpart
DDDD),
and
Appendix
B
requires
testing
of
all
of
the
process
units
within
the
affected
source
if
the
source
wishes
to
become
exempt
from
section
112.
Other
(
less
common)
process
units
that
are
not
listed
in
Table
1
of
the
preamble
to
the
final
rule
are
also
part
of
the
PCWP
affected
source
(
e.
g.,
paddle­
type
particle
dryers,
bagasse
fiberboard
mat
dryers,
veneer
kilns,
particleboard
press
molds,
and
particleboard
extruders).
These
processs
units
were
considered
in
the
MACT
development
process
and
are
required
to
be
considered
in
the
low­
risk
demonstration.
6
Stakeholders
suggested
that
EPA
eliminate
from
the
Appendix
B
emissions
testing
requirements
those
process
units
that
do
not
emit
"
significant
quantities"
of
the
HAP
listed
in
Appendix
B,
or
that
generally
emit
them
at
less
than
1
part
per
million
(
ppm)
(
the
limit
of
detection
that
the
stakeholders
believe
to
be
established
by
the
final
rule).
2
Because
the
low­
risk
demonstrations
are
to
be
based
on
the
cumulative
risk
from
all
process
units
within
each
PCWP
affected
source,
emissions
from
each
process
unit
must
be
considered
in
the
low­
risk
demonstration,
regardless
of
how
insignificant
these
emissions
may
seem.
For
example,
inclusion
of
the
emissions
from
four
types
of
process
units
at
a
facility
may
bring
the
facility
to
the
edge
of
the
low­
risk
criteria,
and
emissions
from
other
types
of
process
units
(
with
seemingly
insignificant
emissions)
could
render
the
facility
non­
low­
risk.
However,
if
the
emissions
from
process
units
(
with
seemingly
insignificant
emissions)
were
not
considered,
then
the
facility
would
be
considered
low­
risk
even
though
emissions
from
all
process
units
were
not
accounted
for.
Also,
given
the
high
exhaust
flow
rates
characteristic
of
many
PCWP
process
units,
it
should
be
noted
that
1
ppm
is
not
necessarily
an
insignificant
amount
of
HAP.
For
example,
a
process
unit
with
an
exhaust
flow
rate
of
50,000
dry
standard
cubic
feet
per
minute
(
dscfm)
emitting
1
ppm
of
benzene
would
be
emitting
over
2
tons
of
benzene
per
year
(
assuming
the
unit
operates
8,000
hours
per
year
[
hr/
yr]).
4
Furthermore,
there
appears
to
be
a
misconception
among
stakeholders
regarding
the
1
ppm
criteria
for
test
method
detection
limits
(
MDL).
Appendix
B
states
that
facilities
may
treat
emissions
of
an
individual
HAP
as
zero
if
all
of
the
test
runs
result
in
a
non­
detect
measurement
and
the
MDL
is
less
than
or
equal
to
1
part
per
million,
dry
volume
basis
(
ppmvd)
for
pollutant
emissions
measured
using
EPA
Method
320;
NCASI
Method
IM/
CAN/
WP­
99.02
(
NICM),
or
ASTM
International
(
ASTM)
D6348­
03.
Otherwise,
non­
detect
data
for
individual
HAP
must
be
treated
as
one­
half
of
the
method
detection
limit.
The
1
ppm
criteria
for
non­
detects
is
not
an
applicability
limit
below
which
emissions
from
process
units
are
disregarded
for
subpart
DDDD
or
Appendix
B.
Concentration­
based
applicability
cutoffs
were
rejected
by
EPA
prior
to
promulgation
(
see
section
2.6.5
of
the
promulgation
comment­
response
document).
7
Emissions
from
process
units
may
be
considered
to
be
zero
only
if
all
of
the
test
runs
result
in
non­
detect
measurements
and
the
MDL
was
less
than
1
ppm.

2.
Recommendations
We
recommend
that
emissions
from
each
type
of
process
unit
(
that
could
potentially
emit
any
of
the
HAP
listed
in
Appendix
B)
continue
to
be
considered
in
the
low­
risk
demonstration
through
emissions
testing
or
estimation,
depending
on
the
technical
feasibility
of
emission
testing.
Given
that
the
purpose
of
the
low­
risk
demonstration
is
to
certify
that
a
PCWP
affected
source
poses
insignificant
risk
to
human
health
and
the
environment,
and
therefore,
is
eligible
to
become
exempt
from
MACT
compliance
and
section
112
regulation,
emissions
test
data
are
preferable
to
emissions
estimates
when
emissions
test
data
can
be
obtained.
We
also
recommend
that
a
table
be
included
in
Appendix
B
which
lists
each
type
of
process
unit
and
indicates
whether
emissions
testing
is
required
or
if
emissions
estimation
is
to
be
allowed
as
an
option.
Suggested
definitions
for
process
units
that
are
not
defined
in
subpart
DDDD
are
presented
in
Attachment
2.

The
following
sections
(
a
through
d)
explore
the
feasibility
of
emissions
testing
for
four
classes
of
process
units:
(
a)
process
units
with
control
requirements
under
subpart
DDDD,
(
b)
process
units
without
control
requirements,
but
having
work
practice
requirements
under
subpart
DDDD,
(
c)
process
units
without
control
or
work
practice
requirements
under
subpart
DDDD,
and
(
d)
other
process
units
not
listed
in
Preamble
Table
1.
When
determining
the
feasibility
of
emissions
testing,
our
primary
considerations
were
how
to
most
accurately
account
for
emissions
and
whether
the
process
units
in
each
group
are
commonly
configured
to
allow
emissions
testing.
Process
units
that
are
not
configured
for
emissions
testing
would
require
reconfiguration
(
if
possible)
before
testing
so
that
flow
rates
and
emissions
could
be
measured
accurately.
Such
reconfigurations
could
be
time
consuming
and
costly
given
that
multiple
process
units
of
each
type
are
usually
located
at
a
single
facility.
For
many
process
units
(
i.
e.,
those
with
relatively
low
emissions
of
Appendix
B
HAP),
reconfiguring
the
process
units
and
conducting
emissions
testing
often
would
not
result
in
an
emission
rate
more
significant
(
for
purposes
of
the
low­
risk
demonstration)
than
an
emission
rate
that
could
be
generated
using
available
emission
estimation
techniques.
We
recommend
that
all
process
units
be
considered
in
the
low­
risk
demonstration;
however,
we
acknowledge
that
lower
emitting
process
units
will
have
less
impact
on
the
risk
demonstration.
Although
process
units
were
evaluated
based
on
the
technical
feasibility
of
testing
and
not
based
on
their
potential
emissions,
we
note
that
generally
the
lower­
emitting
process
units
5
have
not
been
the
subject
of
control
requirements
and
are
less
likely
to
be
configured
for
emissions
testing.
For
the
most
part,
the
process
units
that
drive
risk
are
configured
for
emissions
testing
and
are
recommended
for
testing
in
this
memorandum.

a.
Process
units
with
control
requirements
under
subpart
DDDD
Subpart
DDDD
contains
emissions
control
requirements
for
the
following
types
of
process
units:

fiberboard
mat
dryer
heated
zones
green
rotary
dryers
hardboard
ovens
press
predryers
pressurized
refiners
primary
tube
dryers
secondary
tube
dryers
reconstituted
wood
product
board
coolers
reconstituted
wood
product
presses
softwood
veneer
dryer
heated
zones
rotary
strand
dryers
conveyor
strand
dryer
zones
one
and
two
Emissions
testing
is
feasible
for
these
types
of
process
units.
Emissions
testing
is
also
feasible
for
the
remaining
zones
of
conveyor
strand
dryers
and
fiberboard
mat
dryers.
However,
the
cooling
zones
of
softwood
(
and
hardwood)
veneer
dryers
have
multiple
emission
points
that
are
often
not
configured
for
emissions
testing,
and
therefore,
emission
estimation
is
recommended
for
veneer
dryer
cooling
zones
in
section
IV.
A.
13.
It
is
also
not
practical
to
measure
fugitive
emissions
from
fiberboard
mat
dryers
or
softwood
veneer
dryers;
estimates
of
fugitive
emissions
from
these
dryers
are
discussed
in
section
IV.
A.
13.

b.
Process
units
without
control
requirements,
but
having
work
practice
requirements
under
subpart
DDDD
Subpart
DDDD
does
not
require
emissions
tests
for
process
units
that
have
work
practice
requirements
but
no
control
requirements.
There
are
three
types
of
PCWP
process
units
that
have
work
practice
requirements
only
under
subpart
DDDD:
dry
rotary
particle
dryers,
veneer
redryers,
and
hardwood
veneer
dryers.
The
primary
difference
in
these
three
types
of
process
units
and
their
counterparts
with
subpart
DDDD
control
requirements
(
i.
e.,
green
rotary
dryers
and
softwood
veneer
dryers)
relates
to
how
the
units
are
operated.
With
the
exception
of
radiofrequency
(
RF)
heated
veneer
redryers,
emission
testing
is
feasible
for
process
units
with
work
practice
requirements.
Therefore,
we
recommend
that
emissions
testing
be
required
in
Appendix
B
for
dry
rotary
dryers,
veneer
redryers
(
heated
by
conventional
means),
and
hardwood
veneer
dryer
heated
zones.
By
definition
in
subpart
DDDD,
veneer
redryers
do
not
include
veneer
redryers
that
are
heated
by
RF.
We
recommend
that
emission
estimation
procedures
(
discussed
in
section
IV.
A.
14)
be
allowed
for
RF­
heated
veneer
redryers
because
these
units
typically
are
not
configured
for
emissions
testing.

c.
Process
units
without
control
or
work
practice
requirements
under
subpart
DDDD
6
A
number
of
PCWP
process
units
without
subpart
DDDD
control
or
work
practice
requirements
have
not
been
the
subject
of
organic
emissions
control
requirements
and
often
are
not
configured
for
emissions
testing.
Process
units
that
do
not
have
control
or
work
practice
requirements
under
subpart
DDDD
include:

softwood
plywood
presses
sanders
hardwood
plywood
presses
saws
engineered
wood
products
presses
fiber
washers
humidifiers
chippers
atmospheric
refiners
log
vats
formers
lumber
kilns
blenders
storage
tanks
rotary
agricultural
fiber
dryers
wastewater
operations
agricultural
fiber
board
presses
stand­
alone
digesters
miscellaneous
coating
operations
(
including
group
1
miscellaneous
coating
operations)

We
believe
it
would
be
appropriate
to
allow
emissions
estimates
for
those
process
units
that
typically
are
not
configured
(
and
often
cannot
be
readily
configured)
for
emissions
testing,
except
as
otherwise
specified
below.
The
feasibility
of
testing
each
type
of
process
unit
is
discussed
below.

Miscellaneous
coating
operations.
Information
on
the
types
of
miscellaneous
coatings
used
at
PCWP
plants
was
collected
through
the
MACT
survey.
Available
information
on
the
content
of
coatings
applied
during
miscellaneous
coating
operations
(
as
defined
in
subpart
DDDD)
indicate
that
Appendix
B
HAP
are
not
emitted
from
these
coating
operations.
6,8
Therefore,
we
recommend
that
all
miscellaneous
coating
operations
be
excluded
from
consideration
under
Appendix
B.

Agri­
board
rotary
dryers
and
presses.
No
emissions
data
are
available
for
rotary
agricultural
fiber
dryers
and
agricultural
fiber
board
presses.
However,
MDI
resin
is
commonly
used
to
produce
agriboard,
so
some
MDI
could
be
emitted
from
agricultural
fiber
board
presses.
Furthermore,
if
agricultural
fiber
dryers
are
direct­
fired
(
as
is
common
for
rotary
dryers),
then
they
could
possibly
emit
HAP
metals
as
a
result
of
fuel
combustion.
We
are
not
aware
of
any
unusual
equipment
configurations
that
would
make
testing
difficult
for
rotary
agricultural
fiber
dryers
and
agricultural
fiber
board
presses.
Therefore,
we
recommend
that
Appendix
B
continue
to
require
emissions
testing
for
rotary
agricultural
fiber
dryers
and
agricultural
fiber
board
presses.

Atmospheric
refiners.
Atmospheric
refiners
are
used
by
medium
density
fiberboard
(
MDF),
hardboard,
fiberboard,
and
particleboard
plants.
We
recommend
that
emissions
testing
continue
to
be
conducted
for
atmospheric
refiners
because
these
units
are
amenable
to
emissions
7
testing.
Available
emissions
data
show
that
all
of
the
Appendix
B
organic
HAP
except
MDI
have
been
detected
in
atmospheric
refining
operations.
We
recommend
that
MDI
and
HAP
metals
testing
not
be
required
for
atmospheric
refining
operations.
MDI
is
not
used
in
atmospheric
refining
operations,
and
there
is
no
mechanism
for
HAP
metals
formation.

Hard­
to­
test
process
units.
Except
as
noted
above,
other
process
units
without
control
or
work
practice
requirements
in
subpart
DDDD
are
difficult
to
test.
These
hard­
to­
test
process
units
include:

softwood
plywood
presses
hardwood
plywood
presses
engineered
wood
products
presses
humidifiers
formers
blenders
sanders
saws
fiber
washers
chippers
log
vats
lumber
kilns
storage
tanks
wastewater
operations
stand­
alone
digesters
Some
of
these
process
units
are
vented
primarily
for
dust
control
and
reclaim
of
process
materials,
and
their
venting
systems
are
not
designed
for
flow
measurement
or
measurement
of
organic
gases.
Some
of
the
process
units
are
not
vented
(
i.
e.,
are
fugitive
emissions
sources)
or
are
only
partially
vented.
The
configuration
of
these
process
units,
in
terms
of
how
and
if
they
vent
to
the
atmosphere,
varies
significantly
from
plant
to
plant,
and
only
a
small
number
of
the
process
units
across
the
U.
S.
are
configured
for
emissions
testing.
2,9
Often,
the
emission
points
from
these
process
units
(
where
discernable
emission
points
exist)
are
not
configured
such
that
EPA
Method
1
and/
or
2
(
40
CFR
60,
Appendix
A)
criteria
for
selection
of
sampling
ports
and
measurement
of
gas
velocity
could
be
met.
Emissions
data
are
available
from
an
extensive
emissions
testing
program
where
testable
units
in
several
of
the
process
unit
groups
were
identified.
These
emissions
data
(
along
with
other
available
data
collected
during
NESHAP
development)
have
been
used
to
develop
emission
factors.
10
We
recommend
that
these
emission
factors
be
used
to
estimate
emissions
from
the
hard­
to­
test
process
units
for
purposes
of
the
PCWP
low­
risk
demonstrations.
Sections
IV.
A.
1
through
9
discuss
recommended
emission
factor
estimation
procedures.
Other
emissions
estimation
methods
are
recommended
for
hard­
to­
test
process
units
for
which
no
emission
factors
are
available
(
see
sections
IV.
B.
1
through
3).

d.
Other
process
units
not
listed
in
Table
1
of
the
final
preamble
A
MACT
determination
was
made
for
several
non­
traditional
PCWP
process
units
that
were
not
listed
in
Table
1
of
the
preamble
to
the
final
rule,
including
paddle­
type
particle
dryers,
bagasse
fiberboard
mat
dryers,
veneer
kilns,
particleboard
press
molds,
and
particleboard
extruders.
Of
these
process
units,
veneer
kilns,
particleboard
press
molds,
and
particleboard
extruders
are
likely
hard­
to­
test.
Emission
estimation
procedures
for
veneer
kilns,
particleboard
press
molds,
and
particleboard
extruders
are
discussed
in
sections
IV.
A.
11
through
12.
8
Paddle­
type
particle
dryers
and
bagasse
fiberboard
mat
dryers
are
expected
to
emit
some
HAP,
however,
no
emission
factors
are
available
for
these
process
units.
It
is
expected
that
these
units
could
be
configured
for
emissions
testing.
Therefore,
we
recommend
that
emissions
testing
be
required
for
paddle­
type
particle
dryers
and
bagasse
fiberboard
mat
dryers.

There
may
be
additional
ancillary
PCWP
processes
for
which
no
HAP
data
are
available
and
MACT
determinations
were
not
made
(
e.
g.,
log
storage
piles,
material
handling
operations).
No
information
is
available
to
conclude
that
there
are
Appendix
B
HAP
emissions
from
other
PCWP
processes
not
mentioned
elsewhere
in
this
memorandum.
Nevertheless,
in
the
event
that
there
may
be
an
additional
HAP
emission
source
within
the
PCWP
affected
source
that
the
facility
is
aware
of
but
has
not
been
accounted
for
by
EPA,
we
recommend
that
a
category
of
"
other
ancillary
processes
that
may
emit
Appendix
B
HAP
emissions"
be
added
to
Appendix
B
and
that
engineering
estimates
for
all
of
the
Appendix
B
HAP
be
required
for
such
processes.
To
prevent
unnecessarily
broad
interpretation
of
the
"
other
ancillary
processes
that
may
emit
Appendix
B
HAP
emissions"
category,
EPA
may
wish
to
consider
development
of
a
list
of
insignificant
activities
that
need
not
be
included
in
the
low­
risk
demonstration.
In
order
to
develop
such
a
list,
it
would
be
helpful
to
know
what
activities
States
consider
to
be
insignificant
for
HAP
emissions
and/
or
to
have
some
data
or
rationale
explaining
why
none
of
the
Appendix
B
HAP
would
be
expected
from
certain
activities.

B.
Testing
for
Benzene
and
Acrolein
1.
Use
of
NCASI
Method
IM/
CAN/
WP­
99.02
and
EPA
Method
18
for
benzene
testing
Stakeholders
requested
that
the
NCASI
Method
IM/
CAN/
WP­
99.02
be
listed
in
Appendix
B
to
subpart
DDDD
for
measurement
of
benzene
as
well
as
for
measurement
of
acetaldehyde,
acrolein,
formaldehyde,
and
phenol.
Following
proposal
of
the
PCWP
rule,
commenters
requested
that
EPA
replace
references
to
NCASI
Method
IM/
CAN/
WP­
99.01
in
subpart
DDDD
(
for
measurement
of
acetaldehyde,
acrolein,
formaldehyde,
methanol,
phenol,
and
propionaldehyde)
with
the
revised
version
of
the
same
method
(
NCASI
Method
IM/
CAN/
WP­
99.02).
The
EPA
reviewed
the
NCASI
Method
IM/
CAN/
WP­
99.02
for
applicability
with
respect
to
the
six
HAP
named
in
subpart
DDDD
and
concluded
that
NCASI
Method
IM/
CAN/
WP­
99.02
was
appropriate
for
measurement
of
these
six
HAP.
Prior
to
promulgation,
EPA
did
not
review
NCASI
Method
IM/
CAN/
WP­
99.02
with
respect
to
benzene,
and
therefore,
EPA
did
not
list
NCASI
Method
IM/
CAN/
WP­
99.02
in
Appendix
B
to
subpart
DDDD
as
an
applicable
method
for
measurement
of
benzene.
Upon
receipt
of
additional
information
and
further
review
of
the
method,
EPA
agreed
that
it
is
appropriate
for
measurement
of
benzene
and
plans
to
amend
Appendix
B
to
subpart
DDDD
to
allow
use
of
NCASI
Method
IM/
CAN/
WP­
99.02
for
benzene
measurement.
12
Stakeholders
also
requested
that
EPA
Method
18
(
40
CFR
part
60,
appendix
A)
be
included
in
Appendix
B
to
subpart
DDDD
for
benzene
measurement.
21
The
EPA
has
agreed
that
Method
18
is
appropriate
for
measurement
of
benzene
and
plans
to
amend
Appendix
B
to
subpart
DDDD
accordingly.
9
2.
Reducing
benzene
and
acrolein
testing
requirements
Appendix
B
allows
a
process
unit
to
be
excluded
from
the
testing
requirements
for
benzene
or
acrolein
for
purposes
of
the
low­
risk
demonstration
when
EPA
determines
it
will
not
emit
detectable
amounts
of
benzene
or
acrolien,
respectively.
Elsewhere
in
this
memorandum,
we
recommend
that
emissions
estimation
(
as
opposed
to
emissions
testing)
be
allowed
for
many
hardto
test
process
units.
If
all
of
the
available
benzene
and
acrolein
data
are
non­
detect
for
these
hard­
to­
test
units
(
as
is
generally
the
case),
then
consideration
of
benzene
and
acrolein
is
not
required
for
these
process
units
(
see
section
IV.
A
for
details).

The
discussion
of
benzene
and
acrolein
testing
in
this
section
is
limited
to
those
process
units
for
which
emission
testing
is
recommended.
Also,
as
noted
in
the
previous
sub­
section,
EPA
has
decided
to
propose
to
revise
Appendix
B
to
allow
benzene
measurement
with
NCASI
Method
IM/
CAN/
WP­
99.02.
Thus,
the
burden
associated
with
benzene
measurement
will
likely
be
reduced
somewhat
because
a
separate
test
method
would
no
longer
be
required.

Table
2
lists
the
process
unit
groups
with
recommended
Appendix
B
emission
testing
requirements
and
notes
whether
acrolein
or
benzene
have
been
detected
from
the
process
unit
group.
Benzene
and
acrolein
have
been
detected
on
a
few
occasions
from
most
of
the
process
unit
groups.
The
size
of
the
available
data
sets
vary
according
to
process
unit
type.
The
size
of
the
data
set
should
be
considered
when
deciding
if
acrolein
or
benzene
may
be
emitted
from
the
entire
population
of
each
type
of
process
unit
(
including
those
that
have
not
been
tested
previously).
For
example,
as
of
April
2000,
there
were
303
softwood
veneer
dryers
in
the
U.
S.;
however,
acrolein
and
benzene
data
are
available
for
the
heated
zones
of
only
22
softwood
veneer
dryers.
6
We
recommend
that
emissions
testing
for
benzene
and
acrolein
continue
to
be
required
for
all
of
the
process
units
listed
in
Table
2
for
the
following
reasons:

(
1)
Most
of
the
process
unit
groups
had
at
least
some
scattered
detects,
and
the
number
of
process
units
tested
was
much
lower
than
the
number
of
existing
process
units.
Thus,
the
available
data
do
not
allow
one
to
conclude
that
benzene
and
acrolein
would
not
be
emitted
for
a
given
process
unit
type.
Although
there
are
no
data
for
some
process
unit
types,
the
available
data
for
similar
process
units
indicate
that
benzene
and
acrolein
could
reasonably
be
expected
to
be
emitted
from
the
process
units.

(
2)
Unlike
the
hard­
to­
test
process
units
for
which
emissions
estimates
are
recommended,
the
process
units
listed
in
Table
2
are
amenable
to
emissions
testing.

(
3)
Requiring
testing
for
benzene
and
acrolein
is
not
likely
to
substantially
increase
the
overall
testing
burden
for
these
units.
The
process
units
listed
in
Table
2
would
be
tested
for
acetaldehyde,
formaldehyde,
and
phenol
under
subpart
DDDD
and/
or
the
low­
risk
demonstration.
Benzene
and
acrolein
can
be
measured
with
the
same
test
method
used
to
test
these
HAP
(
i.
e.,
NCASI
Method
IM/
CAN/
WP­
99.02).
10
Table
2.
Number
of
Process
Units
Tested
and
Number
of
Non­
detect
Test
Runs
for
Benzene
and
Acrolein
Process
unit
group
recommended
for
Appendix
B
testing
(
No.
nationwide
in
2000)
6
Control
(
C)
or
work
practice
(
WP)
under
subpart
DDDD
Acrolein
Benzene
Detected?
No.
Process
units
tested
No.
BDL
runs/

No.
total
runs
Detected?
No.
Process
units
tested
No.
BDL
runs/

No.
total
runs
Softwood
veneer
dryers
(
heated
zones)

(
303)
C/
WP

22
49/
60

22
61/
69
Primary
tube
dryers
(
71)
C

11
37/
40

11
37/
40
Secondary
tube
dryers
(
22)
C
ND
4
12/
12

4
11/
12
Rotary
strand
dryers
(
123)
C

18
1/
33

14
2/
24
Green
rotary
dryers
(
84)
C

10
13/
30

9
11/
30
Hardboard
ovens
(
20)
C

1
0/
3
ND
1
3/
3
Reconstituted
wood
products
presses
(
166)
C

15
60/
73

15
85/
86
Pressurized
refiners
(
43)
C

1
0/
3
ND
1
3/
3
Press
predryers
(
5)
C

1
0/
6
no
data
Fiberboard
mat
dryers
(
10)
C
(
new
only)

3
16/
33

3
27/
33
Reconstituted
wood
products
board
coolers
(
105)
C
(
new
only)

2
0/
5
ND
3
9/
9
Dry
rotary
dryers
(
58)
WP

6
8/
27

6
12/
27
Hardwood
veneer
dryers
(
heated
zones)

(
178)
WP
ND
4
36/
36
ND
5
42/
42
Atmospheric
refiners
(
73)

3
6/
9
ND
3
9/
9
Conveyor
strand
dryers,
all
zones
(
8)
C
(
zones
1­
2)
no
data
no
data
Veneer
redryers
(
heated
by
conventional
means)
(
unknown)
WP
no
data
no
data
Rotary
agricultural
fiber
dryers
(
3)
no
data
no
data
Process
unit
group
recommended
for
Appendix
B
testing
(
No.
nationwide
in
2000)
6
Control
(
C)
or
work
practice
(
WP)
under
subpart
DDDD
Acrolein
Benzene
Detected?
No.
Process
units
tested
No.
BDL
runs/

No.
total
runs
Detected?
No.
Process
units
tested
No.
BDL
runs/

No.
total
runs
11
Agricultural
fiber
board
presses
(
8)
no
data
no
data
Paddle­
type
particle
dryers
(
2)
no
data
no
data
Agricultural
fiberboard
mat
dryers
(
1)
no
data
no
data
Fiberboard
mat
dryer
(
cooling
zones)
(
10)
no
data
no
data
ND
=
Not
detected
in
any
test
runs
for
the
process
unit
group
BDL­
Below
the
test
method
detection
limit
12
C.
Testing
only
one
of
multiple
dryers
Stakeholders
suggested
that
only
one
of
multiple
identical
dryers
at
a
facility
would
need
to
be
tested
(
e.
g.,
only
one
of
three
identical
veneer
dryers)
and
that
the
emissions
data
from
the
one
dryer
tested
could
be
applied
to
the
other
identical
dryers.
This
change
would
decrease
the
number
of
emissions
tests
required
without
significantly
affecting
the
quality
of
the
emissions
determination.
To
evaluate
this
request,
emissions
data
gathered
at
nearly
the
same
time
from
multiple
similar
PCWP
process
units
at
a
plant
site
were
reviewed
(
see
Attachment
3).
The
process
units
were
considered
to
be
nearly
identical
if
they
were
similar
in
terms
of
function,
firing
method,
raw
materials
processed,
operating
temperature,
inlet/
outlet
furnish
moisture
content,
and
resin
type
processed.
Based
on
the
data
in
Attachment
3,
there
appears
to
be
little
variation
in
the
test
data
for
similar
process
units
at
the
same
plant
site
tested
at
nearly
the
same
time.
Most
of
the
data
for
similar
process
units
varied
by
a
factor
of
two
or
less.
The
greatest
variation
in
the
data
for
similar
process
units
was
by
a
factor
of
six.
Therefore,
we
recommend
that
application
of
test
results
from
one
process
unit
to
other
similar
process
units
at
the
same
plant
site
be
allowed
provided
that
certain
conditions
are
met.
To
help
evaluate
whether
process
units
are
"
similar,"
facilities
could
be
required
to
explain
in
their
test
reports
or
low­
risk
demonstrations
how
the
process
units
are
similar
in
terms
of
design,
function,
heating
method,
raw
materials
processed,
operating
temperature,
residence
time,
resin
type
processed,
and
any
other
parameters
that
may
affect
emissions.
There
are
likely
to
be
some
slight
variations
in
operating
parameters
(
e.
g.,
a
5­
10%
difference
in
temperature
set
point,
small
difference
in
furnish
moisture
content
between
core
and
face
dryers,
panel
thickness,
etc).
To
account
for
slight
variations
in
parameters,
EPA
could
require
facilities
to
explain
and
test
the
process
unit
that
would
be
expected
to
have
the
greatest
emissions
(
e.
g.,
the
unit
with
a
slightly
higher
temperature
set
point,
dryer
processing
higher
moisture
furnish,
press
processing
thicker
panels,
etc.)
Also,
if
the
process
units
have
different
throughput
rates,
then
facilities
would
need
to
convert
the
emission
test
results
to
terms
of
pounds
of
HAP
per
unit
throughput
prior
to
applying
the
emissions
test
data
to
other
similar
process
units.

The
stakeholders
also
suggested
that
only
one
of
multiple
identical
process
units
from
separate
facilities
within
the
same
company
would
need
to
be
tested.
Unlike
for
identical
process
units
at
the
same
plant,
we
have
not
identified
or
evaluated
any
emissions
data
for
identical
process
units
at
multiple
plants.
Due
to
uncontrollable
variations
in
raw
material,
the
variability
in
emissions
data
for
identical
process
units
is
likely
to
be
greater
if
the
process
units
are
located
at
different
sites
than
if
they
are
located
on
the
same
plant
site.
For
instance,
at
any
given
time,
identical
dryers
located
on
the
same
plant
site
generally
process
wood
from
the
same
source
(
e.
g.,
same
stand
of
trees,
or
same
sources
of
planer
shavings)
that
has
been
handled
in
the
same
manner
(
e.
g.,
same
amount
of
time
in
the
log
yard),
but
the
same
may
not
be
true
for
dryers
on
multiple
sites.
Also,
if
EPA
were
to
allow,
for
instance,
only
one
of
three
identical
veneer
dryers
at
a
plant
site
to
be
tested,
and
then
also
allow
the
emissions
data
for
this
dryer
to
be
applied
to
identical
dryers
at
two
other
sites
with
three
veneer
dryers
each,
then
it
is
possible
that
the
emissions
data
from
this
one
dryer
could
be
used
to
represent
emissions
from
eight
additional
dryers
that
were
not
tested.
Given
that
the
process
units
recommended
for
emissions
testing
are
not
hard­
to­
test
and
the
potential
for
increased
variability
in
emissions
from
plant
to
plant,
we
recommend
that
13
application
of
data
from
one
process
unit
at
one
plant
not
be
allowed
for
multiple
identical
process
units
at
other
plants.

D.
HAP
metals
testing
for
gas­
fired
process
units
Stakeholders
stated
that
HAP
metals
emissions
testing
is
not
necessary
for
direct­
fired
process
units
using
only
natural
gas.
The
vast
majority
of
PCWP
direct­
fired
process
units
are
fired
with
either
wood
or
natural
gas.
A
small
number
of
PCWP
direct­
fired
process
units
are
fired
with
other
fuels
(
e.
g.,
residual
or
distillate
oil,
propane).
Natural
gas,
or
less
commonly,
propane,
is
often
used
as
a
backup
or
auxiliary
fuel.
14
Although
it
is
possible
that
HAP
metals
emissions
could
originate
from
combustion
in
direct
wood­
fired
process
units,
measurable
emissions
of
HAP
metals
would
not
be
expected
from
process
units
fired
with
natural
gas
or
propane.
Therefore,
it
is
reasonable
to
exclude
process
units
direct­
fired
with
only
natural
gas
or
propane
from
the
HAP
metals
testing
requirements.
However,
it
is
possible
that
HAP
metals
could
be
emitted
from
process
units
direct­
fired
using
wood,
other
fuels,
or
a
combination
of
natural
gas
(
or
propane)
and
wood
or
other
fuels,
and
therefore,
HAP
metals
emissions
testing
is
recommended
for
these
units.
For
clarity,
the
definitions
of
"
natural
gas"
(
from
the
final
Oil
and
Natural
Gas
Production
and
Natural
Gas
Transmission
and
Storage
NESHAP,
64
FR
32610)
and
"
propane"
(
from
the
final
Stationary
Reciprocating
Internal
Combustion
Engines
NESHAP,
69
FR
33474)
are
recommended
for
inclusion
in
Appendix
B
to
subpart
DDDD.

IV.
Emission
Estimation
Procedures
for
Hard­
to­
Test
Process
Units
Emission
factors
for
PCWP
process
units
were
developed
using
available
emissions
test
data
from
nearly
100
test
reports
collected
through
EPA's
MACT
survey,
data
from
EPA's
Compilation
of
Air
Pollutant
Emission
Factors,
Volume
I:
Stationary
Point
and
Area
Sources
(
commonly
referred
to
as
AP­
42),
and
extensive
data
from
the
industry­
sponsored
test
program
performed
by
NCASI.
A
separate
memorandum
discusses
in
detail
how
the
emission
factors
were
developed.
10
Following
development,
these
emission
factors
were
incorporated
into
EPA's
AP­
42,
Chapter
10.
These
emission
factors
could
be
used
to
estimate
emissions
from
most
hard­
totest
process
units
for
purposes
of
completing
the
PCWP
low­
risk
demonstrations.
Attachment
4
presents
the
available
emission
factors
for
the
Appendix
B
organic
HAP
for
each
process
unit
group.
Other
emission
estimation
methods
are
needed
for
hard­
to­
test
process
units
for
which
no
emission
factors
exist.
Section
IV.
A
discusses
application
of
emission
factors
and
section
IV.
B
discusses
application
of
other
emission
estimation
procedures
for
the
hard­
to­
test
process
units.
Because
some
types
of
process
units
have
multiple
emission
points,
we
recommend
that
the
estimated
emissions
be
divided
evenly
across
the
number
of
emission
points
for
purposes
of
the
low­
risk
demonstration.

A.
Emission
factor
estimates
To
apply
emission
factors,
facilities
will
need
the
emission
factor
(
in
terms
of
pounds
of
HAP
per
process
unit
throughput)
and
the
process
unit
throughput.
None
of
the
hard­
to­
test
14
process
units
are
equipped
with
HAP
control
devices;
therefore,
control
efficiency
is
not
a
variable
that
needs
to
be
considered
for
the
hard­
to­
test
PCWP
process
units.
6
We
recommend
that
an
amendment
to
Appendix
B
to
subpart
DDDD
clearly
identify
the
emission
factors
that
are
to
be
used
in
low­
risk
demonstrations
to
streamline
completion
and
review
of
the
low­
risk
demonstrations.
Alternatively,
if
facilities
are
required
to
choose
their
own
emission
factors
(
from
AP­
42
or
elsewhere)
for
each
process
unit,
then
additional
time
will
be
required
for
EPA
to
verify
the
emission
factor
selected
for
each
process
unit.
It
is
also
recommended
that,
where
multiple
emission
factors
are
available
for
a
process
unit
group,
that
the
maximum
emission
factor
(
i.
e.,
the
emission
factor
resulting
from
the
highest
emission
test)
be
used
for
purposes
of
the
low­
risk
demonstration.
Use
of
the
maximum
emission
factor
builds
conservatism
into
the
emission
estimates
to
help
account
for
unit­
to­
unit
variability
and
ensure
protection
of
public
health.
Furthermore,
the
maximum
emission
factor
more
closely
represents
the
maximum
detected
emissions
at
any
process
unit
and
is
less
likely
to
have
been
lowered
by
use
of
values
equal
to
½
of
the
MDL
for
non­
detect
measurements.
[
For
example,
if
the
process
unit
data
set
used
to
develop
an
average
emission
factor
contains
6
units,
5
of
which
had
no
detects
during
their
3­
run
tests
while
the
6th
unit
had
all
3
runs
detectable,
then
the
average
emission
factor
would
be
based
on
15
values
of
½
MDL
and
3
detected
values.
However,
the
maximum
emission
factor
would
be
based
on
the
test
where
all
runs
were
detected,
and
therefore,
would
better
represent
the
maximum
detected
emissions
at
any
process
unit
in
the
group.]
As
shown
in
Attachment
5,
the
maximum
emission
factor
is
no
more
than
three
times
the
average
emission
factor
for
any
of
the
hard­
to­
test
process
unit
groups.
Facilities
approaching
the
limits
of
the
lowrisk
criteria
could
be
given
the
option
to
refine
their
analysis
of
HAP
emitted
by
reconfiguring
their
process
unit
(
if
possible)
and
conducting
emissions
testing.
Finally,
if
a
HAP
was
not
detected
in
any
emissions
test
run
conducted
for
a
process
unit
group,
then
we
recommend
that
emissions
for
the
particular
HAP
be
excluded
from
the
emission
estimation
requirements
because
the
available
emission
factors
are
based
on
values
equal
to
½
of
the
MDL
and
are
not
meaningful.
Engineering
estimates
are
recommended
in
some
cases
where
all
of
the
data
are
non­
detect,
but
the
available
data
sets
are
small
and
it
is
reasonable
to
believe
that
a
particular
HAP
could
be
emitted.

Process
unit
throughput
could
be
based
on
process
unit
capacity
or
actual
throughput.
Section
11
of
Appendix
B
to
subpart
DDDD
requires
facilities
to
incorporate
parameters
that
defined
the
affected
source
as
part
of
the
low­
risk
subcategory
(
including
production
rate)
as
federally
enforceable
limits
in
their
title
V
permits.
Furthermore,
according
to
section
13(
a)
of
Appendix
B
to
subpart
DDDD,
facilities
must
certify
with
their
ongoing
title
V
certification
that
the
basis
for
their
low­
risk
demonstration
has
not
changed
(
including
process
change
that
would
increase
HAP
emissions
such
as
a
production
rate
increase).
Given
these
requirements,
we
recommend
that
facilities
be
allowed
to
use
the
process
unit
throughput
that
they
wish
to
incorporate
into
their
title
V
permit
in
their
emissions
estimates
for
the
low­
risk
demonstration
(
as
opposed
to
process
unit
capacity).

The
following
sections
(
1
through
14)
discuss
the
emission
factors
available
for
each
of
the
hard­
to­
test
process
unit
groups.
With
the
exception
of
lumber
kilns
(
addressed
in
section
15
IV.
B.
1),
all
of
the
hard­
to­
test
process
units
described
below
are
heated
by
means
other
than
direct
firing
(
if
heated
at
all),
so
estimation
of
metals
emissions
is
not
necessary.
[
Note:
Table
6
in
Section
V
displays
the
numeric
emission
factors
selected.]

1.
Softwood
plywood
presses
Emissions
factors
covering
the
relevant
Appendix
B
HAP
(
acetaldehyde,
acrolein,
formaldehyde,
phenol,
and
benzene)
are
available
for
softwood
plywood
presses.
Softwood
plywood
is
not
made
using
MDI
resin;
therefore,
estimation
of
MDI
emissions
is
not
necessary.
All
of
the
emission
test
runs
were
below
the
test
method
detection
limit
(
BDL)
for
acrolein
and
benzene.
Since
there
are
no
meaningful
emission
factors
for
acrolein
and
benzene,
we
recommend
that
these
HAP
be
excluded
from
the
emission
estimation
requirements.
The
maximum
emission
factor
for
acetaldehyde,
formaldehyde,
and
phenol
was
selected.

2.
Hardwood
plywood
presses
Emissions
factors
are
available
for
hardwood
plywood
presses.
Hardwood
plywood
is
not
made
using
MDI
resin;
therefore
estimation
of
MDI
emissions
is
not
necessary.
All
of
the
emission
test
runs
were
BDL
for
acetaldehyde,
acrolein
and
benzene,
and
therefore,
no
meaningful
emission
factors
are
available.
The
maximum
emission
factors
for
formaldehyde
and
phenol
were
selected.

3.
Engineered
wood
products
(
EWP)
presses
Plants
manufacturing
engineered
wood
products
such
as
laminated
veneer
lumber
(
LVL),
parallel
strand
lumber
(
PSL),
and
laminated
strand
lumber
(
LSL)
use
microwave
or
RF
presses
to
press
billets,
which
are
much
thicker
than
panel
products.
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.
6
The
type
of
resin
used
by
EWP
plants
varies
according
to
the
product
manufactured.
In
some
cases,
more
than
one
type
of
resin
may
be
used
to
manufacture
the
same
product.
Phenol­
formaldehyde
(
PF)
resins
are
generally
used
in
manufacture
of
LVL
and
PSL.
Laminated
strand
lumber
is
manufactured
with
MDI
resin.
A
phenol­
resorcinolformaldehyde
(
PRF)
resin
is
typically
used
to
manufacture
glulam
and
I­
joists.
11
Emission
factors
are
available
for
LVL
presses.
The
maximum
LVL
press
emission
factors
were
also
applied
to
PSL
presses
because
no
emission
factors
are
available
for
PSL
presses.
Both
PSL
and
LVL
presses
use
PF
resin
to
press
a
veneer­
based
billet.
The
heating
methods
and
operating
temperatures
of
both
types
of
presses
are
also
similar.
Of
the
Appendix
B
organic
HAP,
only
acetaldehyde
and
formaldehyde
were
detected.
MDI
is
not
used
to
manufacture
LVL
and
PSL.

Emission
factors
are
also
available
for
I­
joist
curing
chambers.
The
emission
factors
are
based
on
an
I­
joist
curing
oven
used
to
cure
PRF
resin.
Only
formaldehyde
was
detected
at
the
I­
joist
curing
chamber
tested.
Therefore,
the
maximum
emission
factor
for
formaldehyde
was
16
selected
for
I­
joist
curing
chambers.
Because
no
data
are
available
for
potential
MDI
emissions
from
I­
joist
curing
chambers;
we
recommend
that
engineering
estimates
of
MDI
emissions
be
generated
when
MDI
is
used
to
produce
I­
joists.

Acrolein,
MDI,
and
formaldehyde
emission
factors
are
available
for
LSL
presses.
Acrolein
was
tested,
but
was
not
detected
in
LSL
press
emissions.
Oriented
strand
board
(
OSB)
press
emission
factors
were
reviewed
in
order
to
determine
if
the
other
Appendix
B
organic
HAP
(
phenol,
benzene,
and
acetaldehyde)
could
be
emitted
from
LSL
presses.
The
OSB
and
LSL
presses
operate
at
similar
temperatures.
Benzene
was
not
detected
in
emissions
from
other
engineered
wood
products
presses
or
OSB
presses,
and
therefore,
benzene
is
not
expected
to
be
emitted
from
LSL
presses.
The
emission
factors
for
OSB
presses
using
MDI
or
a
combination
of
PF
and
MDI
resin
indicate
that
acetaldehyde
and
phenol
are
emitted
in
detectable
quantities
from
OSB
presses.
Therefore,
it
is
reasonable
to
expect
that
acetaldehyde
and
phenol
could
be
emitted
from
LSL
presses.
We
recommend
that
engineering
estimates
be
used
to
estimate
acetaldehyde
and
phenol
emissions
form
LSL
presses.

4.
Humidifiers
Hardboard
plants
operate
humidifiers
to
stabilize
the
moisture
content
of
board
as
it
exits
from
the
hardboard
ovens.
One
set
of
emission
factors
is
available
for
a
hardboard
humidifier.
The
maximum
emission
factor
was
selected
for
the
Appendix
B
organic
HAP,
all
of
which
were
detected
during
emissions
testing.
Estimation
of
MDI
emissions
is
unnecessary
because
MDI
is
not
used
in
hardboard
manufacture.

5.
Blending
and
forming
operations
Rotary
blenders
are
used
to
manufacture
particleboard,
OSB,
and
MDF
(
at
MDF
plants
with
non­
blow­
line
blend
tube
dryers).
Blenders
are
used
to
mix
resin,
wax,
and
other
additives
with
dried
wood
material
prior
to
forming
of
the
loose
wood
mat.
Formers
are
used
in
the
production
of
reconstituted
wood
products.
Wet
forming
is
required
to
manufacture
fiberboard,
wet/
dry
process
hardboard,
and
wet/
wet
process
hardboard.
In
the
wet
forming
process,
the
slurry
of
water
and
fiber
is
metered
onto
a
wire
screen
where
the
water
drains
away.
Dry
forming
is
used
to
manufacture
particleboard,
MDF,
dry/
dry
process
hardboard,
and
OSB.
In
dry
forming,
material
from
the
blenders
is
usually
transferred
to
the
former
via
conveyor
belt,
which
may
or
may
not
be
fully
enclosed.
Blenders
and
formers
can
share
emission
points
to
collect
material
from
pneumatic
pick­
up
points
along
the
length
of
blender
conveyors
and
former.
Dust
collection
from
the
former
occurs
as
reject
material
is
drawn
from
the
sides
of
the
formed
wood
mat
or
from
hoses
on
flying
cutoff
saws.
Formers
are
not
enclosed.
Available
emission
factors
for
blenders
and
formers
are
divided
according
to
product
type,
resin
type,
and
whether
blowline
blending
is
used
(
for
MDF
plants).
Emission
factors
are
not
available
for
all
types
of
blending
and
forming
operations;
however,
some
of
the
available
emission
factors
can
be
applied
for
different
products.

No
emission
factors
specific
to
particleboard
blenders
and
formers
are
available.
However,
emission
factors
for
MDF
blenders
and
formers
are
applicable
to
particleboard
plants
17
because
urea­
formaldehyde
(
UF)
resin
is
used
for
both
particleboard
(
conventional
and
molded)
and
MDF
manufacture.
Emission
factors
are
available
for
an
MDF
blender,
a
blender/
former
combination,
and
a
former.
The
blender/
former
emission
factors
are
representative
of
plants
that
do
not
perform
blowline
blending.
The
former
emission
factors
are
representative
of
plants
that
perform
blowline
blending.
The
blender
emission
factors
are
representative
of
plants
that
use
rotary
blenders.
Acetaldehyde,
acrolein,
phenol,
and
benzene
were
not
detected
during
any
of
the
tests
used
to
develop
these
emission
factors.
Therefore,
we
recommend
that
acetaldehyde,
acrolein,
phenol,
and
benzene
be
excluded
from
the
emission
estimation
requirements.
The
maximum
formaldehyde
emission
factor
from
these
sets
of
factors
was
selected
for
purposes
of
estimating
emissions
from
particleboard
and
MDF
blending
and
forming
operations.
Particleboard
(
e.
g.,
agriboard)
and
MDF
plants
sometimes
use
MDI
resin.
Because
there
are
no
available
MDI
emission
factors
for
blending
and
forming
operations,
we
recommend
that
engineering
estimates
be
used
to
estimate
MDI
emissions
for
those
plants
that
use
MDI.

Emission
factors
are
available
from
one
OSB
blender
and
former
baghouse
system
tested
at
a
plant
using
a
combination
of
PF
and
MDI
resin.
The
emission
factors
are
based
on
press
throughput.
Acetaldehyde,
acrolein,
phenol,
and
benzene
were
not
detected
at
the
one
blender
aspiration
system
tested.
Given
that
PF
resin
is
used
in
OSB
manufacture,
and
there
are
phenol
emissions
from
other
PCWP
sources
(
e.
g.,
MDF
and
particleboard
sanders;
PF
not
used
in
these
products),
we
believe
that
phenol
emission
could
reasonably
be
expected
to
be
emitted
from
OSB
blenders,
even
though
none
was
detected
from
the
one
OSB
blender
tested.
Some
facilities
manufacture
OSB
using
only
PF
resin,
so
the
potential
for
phenol
emissions
from
their
blending
and
forming
operations
may
be
even
greater
than
for
the
one
OSB
blender
tested
that
used
a
blend
of
PF
and
MDI.
Thus,
we
recommend
that
engineering
estimates
of
phenol
emissions
be
required
for
OSB
blending
and
forming
operations.
The
OSB
blender/
former
emission
factors
do
not
include
an
MDI
emission
factor.
Because
there
is
a
possibility
that
MDI
may
be
emitted
from
blending
and
forming
operations,
we
recommend
that
engineering
estimates
be
required
for
OSB
blending
an
forming
operations
involving
MDI
use.

Wet
formers
are
employed
by
fiberboard,
wet/
wet
hardboard,
and
wet/
dry
hardboard
plants.
Emission
factors
are
available
for
a
fiberboard
former
(
asphalt
additive)
and
for
a
wet/
wet
hardboard
former
(
PF
resin).
The
emission
factors
for
the
fiberboard
former
can
also
be
applied
to
wet/
dry
hardboard
former
because
the
fiberboard
and
wet/
dry
hardboard
processes
are
similar
prior
to
the
pressing
step
in
the
wet/
dry
hardboard
process.
The
additives
used
in
the
wet/
dry
hardboard
process
(
linseed
oil,
asphalt,
and
wax)
more
closely
resemble
the
additives
used
to
produce
fiberboard
(
alum,
starch,
asphalt,
and
wax)
than
the
additives
used
to
produce
wet/
wet
hardboard
(
i.
e.,
PF
resin,
alum,
and
wax).
Emissions
of
acetaldehyde
and
formaldehyde
were
detected
at
the
fiberboard
former
tested,
so
the
emission
factors
resulting
from
these
tests
may
be
used.
The
other
Appendix
B
HAP
were
not
detected.
MDI
is
not
used
in
producing
fiberboard
or
hardboard.
Therefore,
emissions
estimates
for
fiberboard
and
wet/
dry
hardboard
formers
need
to
be
developed
for
acetaldehyde
and
formaldehyde
only.
Emissions
of
acetaldehyde,
formaldehyde,
and
phenol
were
detected
at
the
wet/
wet
hardboard
former
tested;
therefore,
emissions
of
these
three
HAP
need
to
be
estimated.
18
No
emission
factors
are
available
to
estimate
emissions
from
dry/
dry
process
hardboard
forming
operations.
Estimation
of
MDI
emissions
is
not
necessary
because
MDI
is
not
used
to
manufacture
hardboard.
Benzene
and
acrolein
emissions
have
not
been
detected
in
tests
performed
on
blending
and
forming
operations
used
to
produce
other
PCWP.
Therefore,
benzene
and
acrolein
emissions
also
are
not
expected
from
dry/
dry
hardboard
formers.
We
recommend
that
engineering
estimates
of
acetaldehyde,
formaldehyde,
and
phenol
be
performed
for
dry/
dry
hardboard
formers
because
these
HAP
have
been
detected
from
forming
operations
used
to
produce
other
PCWP.
With
one
exception,
all
dry/
dry
hardboard
plants
use
blow­
line
blending
instead
of
blenders.
Thus,
consideration
of
dry/
dry
process
hardboard
blender
emissions
is
not
necessary.
One
dry/
dry
hardboard
plant
has
rotary
blenders
followed
by
rotary
dryers.
This
plant
was
named
as
part
of
the
PCWP
low­
risk
subcategory
in
the
preamble
to
the
final
PCWP
rule.
Should
this
plant
choose
to
submit
a
low­
risk
demonstration,
it
could
use
engineering
estimates
of
its
blender
emissions.

6.
Sanders
and
saws
Sanders
are
used
to
finish
all
types
of
PCWP
panels.
Saws
are
used
throughout
PCWP
plants
to
cut
logs,
cut
formed
mats
before
they
enter
the
press,
and
to
trim
and
cut­
to­
size
pressed
PCWP.
Sawdust
from
saws
that
cut
unpressed
mats
is
collected
pneumatically
along
the
former
and
is
included
in
the
former
emission
points.
No
HAP
test
data
are
available
for
saws
used
to
cut
logs
(
e.
g.,
at
plywood
plants
where
logs
are
cut
to
8­
foot
lengths
prior
to
preconditioning
in
log
vats).
Sawing
of
logs
is
usually
performed
outside.
Appendix
B
HAP
emissions
from
log
sawing
are
expected
to
be
negligible
based
on
the
fact
that
no
Appendix
B
HAP
were
detected
in
log
chipping
operations.

Appendix
B
HAP
emission
factors
are
available
for
sanding
and
sawing
operations
used
in
the
finishing
end
of
some
PCWP
plants.
Emission
factors
are
available
for
an:
°
MDF
sander
°
Particleboard
sander
°
MDF
reclaim
saw
(
emission
factors
in
terms
of
lb
HAP
per
MSF
of
reclaimed/
trimmed
material;
MSF
reclaim
=
MSF
from
press
x
3%)
°
Hardwood
plywood
combined
dust
baghouse
(
trim
saw,
composer,
core
saw,
dry
hog,
hammermill,
and
sander)
°
Softwood
plywood
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
°
Softwood
plywood
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)

Data
were
also
available
for
two
OSB
fuel
holding
bins
that
contain
wood
residue
from
sanders
and
saws;
these
emission
factors
were
lower
than
the
other
emission
factors
available
for
sanders
and
saws.
Of
the
Appendix
B
organic
HAP,
only
acetaldehyde,
formaldehyde,
and
phenol
were
detected
at
some
of
the
sander
and
saw
emission
points.
The
configuration
of
finishing,
sanding,
and
sawing
operations
emission
points
at
PCWP
plants
varies
widely
from
plant
to
plant.
The
applicability
of
the
available
emission
factors
to
other
plants
is
questionable.
19
Panel
thickness
does
not
need
to
be
specified
for
sander
throughput
since
only
the
panel
surface
area
is
sanded.
In
the
absence
of
more
applicable
data,
the
maximum
of
the
sander
and
saw
emission
factors
for
each
detected
HAP
was
selected
for
all
PCWP
sanding
and
sawing
operations.
The
acetaldehyde
and
formaldehyde
emission
factors
for
sanders
were
based
on
the
softwood
plywood
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw).
The
phenol
emission
factor
for
sanders
was
based
on
the
particleboard
sander.
Both
the
softwood
plywood
and
particleboard
sanders
sand
the
top
and
bottom
of
the
board.
The
acetaldehyde
and
formaldehyde
emission
factors
for
saws
were
based
on
the
softwood
plywood
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander).
Although
the
softwood
plywood
sander
and
saw
factors
each
include
both
some
sander
and
saw
emission
points,
there
is
no
double
counting
because
the
emission
factors
were
derived
from
tests
on
separate
emission
points
at
one
plant
(
NCASI
mill
code
170).

The
phenol
emission
factor
for
finishing
saws
was
based
on
the
MDF
reclaim
saw
emission
factor,
which
was
in
terms
of
pounds
per
thousand
square
feet
(
lb/
MSF)
of
material
shaved
off
of
the
boards
by
the
saw.
This
material
is
called
"
reclaim."
At
the
plant
tested,
reclaim
was
measured
as
the
difference
in
the
surface
area
of
the
board
enterinig
and
exiting
the
saw.
On
average,
there
was
a
three
percent
difference
in
the
board
surface
area.
The
MDF
reclaim
saw
phenol
emission
factor
was
adjusted
by
3%
(
0.19
lb/
MSF
x
0.03
=
0.0057
lb/
MSF)
to
account
for
the
difference
in
reclaimed
(
trimmed)
material
and
press
throughput.
The
MDF
saw
emission
factor
is
in
terms
of
lb
phenol
per
MSF
press
throughput.
No
thickness
is
provided
for
the
MDF
saw
emission
factor.

No
data
are
available
for
potential
MDI
emissions
from
sanding
and
sawing
operations.
We
recommend
that
engineering
estimates
be
used
for
MDI
emissions
from
sanding
and
sawing
operations.

7.
Fiber
washers
Fiber
washers
were
present
at
some
fiberboard
and
wet/
dry
hardboard
plants.
Emission
factors
are
available
for
a
fiber
washer
at
a
fiberboard
plant.
The
maximum
emission
factor
was
selected
for
acetaldehyde
and
formaldehyde.
Estimation
of
MDI
emissions
is
unnecessary
because
MDI
is
not
used
in
hardboard
manufacture.
None
of
the
other
Appendix
B
organic
HAP
were
detected
during
emissions
testing.

8.
Chippers
Log
chippers
may
be
used
by
facilities
that
begin
their
manufacturing
process
with
wood
chips
(
e.
g.,
hardboard,
fiberboard,
or
MDF
facilities).
Emission
factors
are
available
for
a
hardboard
log
chipper.
None
of
the
relevant
Appendix
B
organic
HAP
were
detected
at
the
log
chipper.
Therefore,
we
recommend
that
no
emissions
estimates
be
required
for
log
chipping
operations.

Panel
trim
may
also
be
processed
through
a
chipper.
Emission
factors
are
available
for
a
softwood
veneer
dry­
trim
chipper
that
processes
trimmed
veneer
from
the
layup
line
and
for
a
20
softwood
plywood
dry
trim
chipper
that
processes
dry
trim
from
the
panel
saws.
These
emission
factors
are
in
terms
of
pounds
of
HAP
per
thousand
square
feet,
3/
8"
basis,
of
finished
board
production.
We
recommend
that
the
maximum
of
the
veneer
trim
and
panel
trim
chipper
emission
factors
be
applied
to
all
PCWP
trim
chipper
operations.
The
maximum
emission
factor
was
selected
for
acetaldehyde,
formaldehyde,
and
phenol.
Acrolein
and
benzene
were
not
detected
from
the
chippers,
so
we
recommend
that
no
estimates
of
acrolein
and
benzene
emissions
be
developed.
Phenol
emissions
were
detected
from
chipping
of
dry
veneer
even
though
it
did
not
contain
phenolic
resin,
however,
no
phenol
emissions
were
detected
from
chipping
of
the
softwood
plywood
trim,
which
did
contain
phenolic
resin.
Also,
MDF
and
particleboard
sanders
and
an
MDF
saw
exhibited
phenol
emissions
even
though
phenolic
resins
are
not
used
in
manufacture
of
MDF.
Thus,
it
appears
that
phenol
emissions
may
result
from
some
PCWP
process
equipment
even
if
phenolic
resin
is
not
used.
Although
MDI
is
not
used
in
veneer
or
plywood
manufacture,
it
can
be
used
to
produce
other
PCWP.
We
recommend
that
engineering
estimates
of
MDI
emissions
from
panel­
trim
chippers
be
performed
by
facilities
using
MDI
resin.

9.
Log
vats
Plywood
plants
typically
use
log
vats
to
heat
logs
before
they
are
peeled
or
sliced
into
veneer.
These
log
vats
use
hot
water
or
steam
to
heat
the
logs.
Hot
water
vats
are
often
open
to
the
atmosphere,
whereas
log
steaming
vats
are
enclosed.
Emission
factors
are
available
for
log
steaming
vats.
The
log
steaming
vat
emission
factors
are
expected
to
be
representative
of
hot
water
log
vats
because
both
types
of
vats
are
used
to
heat
the
log
cores
to
the
same
temperature
range.
These
emission
factors
are
in
terms
of
pounds
of
HAP
per
volume
of
wood
(
in
MSF
3/
8")
removed
from
the
vat
per
hour.
Of
the
relevant
Appendix
B
organic
HAP,
only
acetaldehyde
was
detected
in
the
log
vat
emissions.
Thus,
the
maximum
emission
factor
for
acetaldehyde
was
selected
for
log
vats.

10.
Stand­
alone
digesters
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
process
unit
while
maintaining
continuous
internal
pressure.
Other
plants
operate
stand­
alone
digesters
that
feed
into
one
or
more
atmospheric
refiners.
Most
standalone
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
process
units
(
i.
e.,
with
continuous
infeed
and
outfeed
of
wood
material),
while
stand­
alone
digesters
are
either
batch
or
continuous
units.
6
No
emission
factors
are
available
for
stand­
alone
digesters.
However,
a
set
of
emission
factors
is
available
for
a
pressurized
refiner
at
a
hardboard
plant.
Therefore
the
maximum
emission
factors
for
the
pressurized
refiner
were
selected
for
acetaldehyde,
acrolein,
21
formaldehyde,
and
phenol.
Benzene
was
not
detected
from
the
pressurized
refiner,
and
MDI
is
not
used
in
these
systems.
Because
pressurized
refiners
incorporate
both
the
digesting
and
refining
process,
it
is
likely
that
application
of
the
pressurized
refiner
emission
factors
to
standalone
digesters
would
reasonably
approximate
emissions
from
stand­
alone
digesters.

11.
Veneer
kilns
A
small
number
of
softwood
and
hardwood
plywood
plants
operate
veneer
kilns
instead
of
veneer
dryers.
No
emission
factors
are
available
for
veneer
kilns.
However,
emissions
for
veneer
kilns
may
be
estimated
by
applying
emission
factors
for
softwood
or
hardwood
veneer
dryers.
The
maximum
available
emission
factors
for
softwood
veneer
dryer
heated
zones,
cooling
sections,
and
fugitive
emissions
were
summed
to
arrive
at
an
emission
factor
for
softwood
veneer
kilns.
Likewise,
the
maximum
available
emission
factors
for
hardwood
veneer
dryer
heated
zones
and
cooling
sections
were
summed
to
arrive
at
an
emission
factor
for
hardwood
veneer
kilns.
Attachment
6
presents
the
summation
of
emission
factors
for
veneer
kilns.
Since
MDI
resin
is
not
used
in
veneer
production,
estimation
of
MDI
emissions
is
not
necessary.
Based
on
responses
to
the
MACT
survey,
all
of
the
veneer
kilns
in
the
U.
S.
are
indirect­
fired,
so
estimation
of
HAP
metals
emissions
is
not
necessary.

12.
Particleboard
press
molds
and
extruders
Unlike
conventional
particleboard
plants
that
operate
platen
presses
to
manufacture
panels,
molded
particleboard
plants
operate
either
extruders
for
forming
panels
or
single­
opening
press
molds
for
forming
shaped
particleboard
(
e.
g.,
paper
roll
cores,
pallets).
No
emission
factors
are
available
for
particleboard
press
molds
or
extruders.
However,
emission
factors
are
available
for
conventional
particleboard
presses
that
use
UF
resin.
Conventional
particleboard
presses,
press
molds,
and
extruders
operate
at
similar
temperatures
and
process
particleboard
containing
UF
resin.
The
maximum
conventional
particleboard
press
emission
factors
can
be
used
to
approximate
emissions
for
extruders
and
press
molds.
The
emission
factors
may
not
be
directly
applicable
to
extruders
and
press
molds,
but
it
is
the
only
information
available
to
use
in
estimating
emissions
from
these
sources.
It
will
be
necessary
for
press
mold
throughput
(
which
is
usually
reported
in
tons
instead
of
MSF
3/
4")
to
be
converted
to
volume
(
i.
e.,
MSF
3/
4")
using
the
product
density.
11,13,14
13.
Fiberboard
mat
dryer
fugitive
emissions,
softwood
veneer
dryer
fugitive
emissions,
and
veneer
dryer
cooling
zones
Emission
factors
are
available
for
fiberboard
mat
dryer
fugitive
emissions.
The
maximum
emission
factors
may
be
applied
for
acetaldehyde
and
formaldehyde.
Estimation
of
MDI
emissions
is
unnecessary
because
MDI
is
not
used
in
fiberboard
manufacture.
None
of
the
other
Appendix
B
organic
HAP
were
detected
during
emissions
testing.

Similarly,
emission
factors
are
available
for
softwood
veneer
dryer
fugitive
emissions.
The
emission
factors
for
acetaldehyde,
formaldehyde,
and
phenol
may
be
applied.
None
of
the
other
22
Appendix
B
organic
HAP
were
detected
during
emissions
testing.
Estimation
of
MDI
emissions
is
unnecessary.

Emission
factors
are
also
available
for
hardwood
and
softwood
veneer
dryer
cooling
zones.
Of
the
Appendix
B
organic
HAP,
acetaldehyde
and
formaldehyde
were
detected
in
the
exhaust
from
hardwood
veneer
dryer
cooling
zones.
Acetaldehyde,
formaldehyde,
and
phenol
were
detected
in
the
exhaust
from
softwood
veneer
dryer
cooling
zones.
Estimation
of
HAP
metals
and
MDI
emissions
is
unnecessary
from
veneer
dryer
cooling
zones
because
the
cooling
zones
circulate
ambient
air
over
the
hot
veneer
(
i.
e.,
no
combustion
exhaust
is
involved)
and
MDI
is
not
used
to
manufacture
veneer.

14.
Radio­
frequency
veneer
redryers
Acetaldehyde
and
formaldehyde
have
been
detected
from
RF
veneer
redryers.
None
of
the
other
Appendix
B
organic
HAP
have
been
detected,
and
MDI
is
not
applied
to
veneer.
Emission
factors
are
available
to
use
in
estimating
acetaldehyde
and
formaldehyde
emissions
from
RF
veneer
redryers.

B.
Other
Emission
Estimation
Techniques
There
are
some
common
types
of
hard­
to­
test
PCWP
processing
equipment
for
which
no
emission
factors
are
available,
including
resin
storage
tanks,
lumber
kilns,
and
wastewater/
process
water
operations.
This
section
describes
emission
estimation
procedures
that
may
be
used
for
PCWP
processes
that
currently
have
no
applicable
emission
factors.

1.
Lumber
kilns
Lumber
kilns
are
batch
units.
Lumber
is
loaded
into
the
kiln,
the
kiln
runs
through
the
drying
cycle,
and
the
dried
lumber
is
removed
from
the
kiln
when
the
drying
cycle
is
complete.
Softwood
lumber
kiln
drying
cycles
typically
last
around
24
hours,
while
hardwood
kiln
drying
cycles
can
last
from
several
days
to
weeks.
The
emissions
profile
from
lumber
kilns
depends
on
kiln
drying
time,
moisture
content
of
the
wood,
kiln
temperature,
and
air
flow
through
the
kiln.
The
amount
and
direction
of
air
that
is
vented
from
the
kiln
changes
in
response
to
kiln
process
parameters
such
as
relative
humidity,
dry
bulb
temperature,
and
wet
bulb
temperature.
Lumber
kilns
have
multiple
vents,
which
alternate
in
function.
During
any
given
time,
one
set
of
vents
allows
moisture
to
exhaust
from
the
kiln
while
the
other
set
of
vents
brings
in
dry
air.
After
some
time,
the
direction
of
air
circulation
within
the
kiln
is
changed,
and
the
kiln
vents
exchange
functions.
Because
of
these
changes
in
air
flow
patterns,
lumber
kiln
emission
streams
vary
in
flow
rate,
concentration,
and
mass
emission
rate
throughout
the
kiln
drying
cycle.
In
addition
to
emissions
from
lumber
kiln
vents,
considerable
amounts
of
fugitive
emissions
may
be
emitted
from
lumber
kilns
through
crevices
in
the
kiln
wall
and
around
doors.

It
is
difficult
to
measure
emissions
from
lumber
kilns
due
to
the
kiln
air
flow
design
and
fugitive
emissions.
Therefore,
little
emissions
test
data
is
available
for
use
in
developing
HAP
23
emission
factors
for
lumber
kilns.
Methods
for
quantifying
lumber
kiln
flow
rates
vary
from
test
to
test.
Most
of
the
emissions
test
data
that
is
available
contains
calculated
flow
rates
or
other
assumptions
that
bring
the
validity
of
the
data
into
question.
Most
of
the
available
emissions
data
for
lumber
kilns
is
for
total
hydrocarbon
(
THC)
emissions
from
softwood
lumber
kilns.
A
few
tests
have
been
conducted
on
both
small
and
large­
scale
lumber
kilns
to
determine
emissions
of
HAP
(
generally
formaldehyde
and
methanol)
from
softwood
lumber
kilns.

Emission
factors
for
lumber
kilns
were
not
included
in
EPA's
emission
factor
data
base
developed
for
MACT.
10
However,
a
discussion
of
available
data
(
as
of
June
2000)
for
lumber
kilns
was
presented
in
Appendix
D
of
the
baseline
emission
memo.
11
Additional
literature
was
reviewed,
including
NCASI
Technical
Bulletin
(
TB)
845
and
two
technical
papers.
15,16,17
For
purposes
of
conservatively
estimating
lumber
kilns
emissions,
the
maximum
emission
factors
for
the
Appendix
B
HAP
presented
in
the
literature
reviewed
may
be
used.
Table
3
lists
each
emission
factor,
the
process
unit
tested,
and
the
reference.
No
HAP
metals
data
are
available
for
direct­
fired
lumber
kilns.
We
recommend
that
engineering
estimates
of
HAP
metals
emission
be
developed
for
direct­
fired
lumber
kilns.

Another
approach
to
determining
emissions
from
lumber
kilns
may
be
through
use
of
small­
scale
kilns.
While
emissions
testing
of
full­
scale
lumber
kilns
has
proven
to
be
very
difficult,
studies
have
shown
that
testing
of
small­
scale
lumber
kilns
can
be
used
to
reasonably
approximate
emissions
from
full­
scale
lumber
kilns
if
representative
lumber
samples
are
dried
and
the
venting
characteristics
of
the
small­
scale
kiln
mimic
those
of
the
full­
scale
kiln.
15,18
Several
U.
S.
universities
and
private
laboratories
operate
small­
scale
kilns.
To
approximate
emissions
from
full­
scale
kilns,
a
representative
sample
of
lumber
is
taken
from
the
full­
scale
kiln
facility,
packaged
to
prevent
moisture
loss,
and
shipped
to
the
location
of
the
small­
scale
kiln
where
the
full­
scale
kiln's
drying
cycle
(
e.
g.,
time
and
temperatures)
is
mirrored
during
emissions
testing.
Small­
scale
kilns
are
designed
for
more
accurate
air
flow
measurement
and
are
less
costly
to
test.
In
order
to
allow
a
small­
scale
kiln
approach,
it
may
be
necessary
to
develop
regulatory
text
(
or
incorporate
by
reference
appropriate
material)
to
provide
standard
procedures
for
selecting
a
representative
small­
scale
kiln,
submitting
lumber
samples,
and
conducting
small­
scale
kiln
emissions
testing.
A
separate
memorandum
provides
examples
of
factors
that
need
to
be
considered
when
developing
a
small­
scale
kiln
emission
testing
program.
19
24
Table
3.
Maximum
available
lumber
kiln
emission
factors.

Appendix
B
HAP
Emission
factor
lb/
MBF
Kiln
tested
Test
method
Reference
Acetaldehyde
0.065
Oregon
State
University
(
OSU)
small­
scale
indirect­
fired
kiln,
southern
pine
NICM
NCASI
TB
845
Acrolein
0.009
OSU
small­
scale
indirect­
fired
kiln,
southern
pine
NICM
NCASI
TB
845
Formaldehyde
0.034
Direct­
fired
softwood
kiln
(
fullscale
TO­
5
NCASI
data
base
Phenol
0.010
Direct­
fired
softwood
kiln
(
fullscale
TO­
8
NCASI
data
base
Benzene
not
detected
­
North
Carolina
State
University,
indirect­
fired,
southern
pine
­
Indirect­
fired,
southern
pine,
fullscale
kiln
­
OSU
small­
scale
indirect­
fired
kiln,
southern
pine
NICM
NCASI
TB
845
MDI
NA
(
MDI
not
used
to
produce
kilndried
lumber)

HAP
metals
for
direct­
fired
kilns
no
data
OSU=
Oregon
State
University,
NCSU
=
North
Carolina
State
University
NCASI
­
National
Council
for
Air
and
Stream
Improvement,
TB
=
Technical
Bulletin
NICM
=
NCASI
Impinger/
Cannister
Method
MDI
=
methylene
diphenyl
diisocyanate
2.
Resin
tanks
Resin
storage
tanks
are
located
at
most
PCWP
plants.
The
tanks
contain
UF,
PF,
MDI,
or
other
types
of
resins
or
additives
(
e.
g.,
wax,
scavenger).
These
resins
exhibit
low
vapor
pressures
and
low
volatility.
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.
The
MACT
survey
also
requested
information
on
potential
HAP
emissions
from
resin
tanks.
Only
about
35
percent
of
survey
respondents
provided
information
on
HAP
emissions
from
resin
tanks,
and
these
estimates
varied
by
four
orders
of
magnitude
(
e.
g.,
1.3E­
5
to
7.6E­
1
tpy
for
formaldehyde).
The
maximum
emissions
reported
for
any
single
tank
are
summarized
in
Table
4.
The
tank
emission
estimates
reported
in
the
survey
responses
were
likely
generated
using
TANKS
software.
14
One
conservative
approach
to
estimating
resin
tank
emissions
for
purposes
of
the
low­
risk
demonstration
would
be
to
multiply
the
maximum
emission
estimates
from
Table
4
below
by
the
25
number
of
tanks
at
the
facility.
This
approach
may
be
ideal
for
facilities
who
do
not
have
the
necessary
data
readily
available
to
use
TANKS
software.
Application
of
the
values
in
Table
4
would
depend
on
tank
content
(
e.
g.,
MDI
would
only
be
estimated
for
MDI­
containing
tanks,
formaldehyde
for
UF
and
PF
tanks,
and
phenol
for
PF
tanks).
Facilities
who
wish
to
refine
their
analysis
of
tank
emissions
could
obtain
the
necessary
inputs
for
the
TANKS
software
and
run
the
software
to
generate
more
site­
specific
estimates.
The
TANKS
software
may
be
obtained
from
EPA's
Technology
Transfer
Network
(
ttn).

Table
4.
Worst­
case
Appendix
B
HAP
emissions
from
resin
storage
tanks
Pollutant
Emissionsa
(
tpy
per
tank)
Emissionsb
(
lb/
hr
per
tank)
c
Formaldehyde
0.76
0.19
Phenol
0.70
0.18
MDI
0.005
0.0013
a
Maximum
reported
uncontrolled
emissions
for
each
HAP
from
any
individual
storage
tank.
14
b
Emissions
(
tpy)
divided
by
typical
plant
operating
hours
(
8,000
hr/
yr).
11
b
lb/
hr
=
pounds
per
hour
3.
Wastewater/
process
water
operations
Wastewater
operations
(
e.
g.,
lagoons,
clarifiers,
settling
ponds,
tanks,
etc.)
are
used
for
handling
process
waters
or
wastewaters,
which
may
contain
traces
of
HAP.
Water
is
used
for
many
purposes
at
PCWP
plants,
including
hardboard
process
operations,
equipment
washing
(
e.
g.,
the
glue
line,
blender,
dryers,
regenerative
thermal
oxidizers,
etc.),
and
in
control
devices
(
i.
e.,
wet
ESP's
and
scrubbers).
After
use,
the
water
is
generally
conveyed
to
a
holding
pond
or
tank
where
some
of
the
water
evaporates,
and
some
may
be
recirculated
for
reuse
in
the
process
or
a
control
device.
Some
water
may
also
be
discharged
to
a
wastewater
treatment
system,
including
onsite
land
application
via
spraying.
An
attempt
was
made
to
gather
information
on
potential
emissions
from
PCWP
water
operations
with
the
MACT
survey.
However,
HAP
concentration
data
were
provided
for
only
23
of
the
241
wastewater
operations
for
which
flow
rates
were
provided.
It
is
not
known
how
the
potential
emissions
from
PCWP
water
operations
could
vary
from
facility
to
facility
because
there
are
various
sources
of
water,
and
there
is
a
wide
range
of
water
flow
rates
and
handling
methods.
Although
potential
HAP
emissions
from
PCWP
water
operations
are
believed
to
be
low,
the
available
data
do
not
provide
sufficient
information
for
specifying
an
emission
factor
that
could
be
applied
to
all
PCWP
facilities.
More
site­
specific
information
is
needed
for
the
low­
risk
demonstration.
Air
emissions
of
HAP
metals
from
PCWP
wastewater
operations
are
not
expected
given
the
low
volatility
of
metals
at
typical
wastewater
temperatures.

The
following
subsections
(
a
through
d)
discuss
three
methods
for
estimating
emissions
wastewater/
process
water
operations
and
other
considerations.
All
three
of
the
methods
for
estimating
emissions
necessitate
sampling
of
the
wastewater/
process
water
to
determine
the
concentration
of
Appendix
B
HAP.
The
worst­
case
Appendix
B
HAP
concentration
in
the
26
wastewater/
process
water
is
of
interest
for
purposes
of
the
low­
risk
demonstration.
Potential
methods
for
analyzing
water
samples
are
listed
in
Attachment
7.
Potential
regulatory
language
that
specifies
procedures
for
identifying
sample
locations,
collecting
and
handling
samples,
using
non­
detect
measurements,
and
validating
methods
that
differ
from
approved
EPA
methods
is
also
presented
in
Attachment
7.
As
for
air
samples,
we
recommend
that
the
concentration
of
HAP
in
the
water
sample
be
assumed
to
be
zero
if
all
of
the
water
samples
in
a
test
result
in
a
non­
detect
reading,
and
the
MDL
is
less
than
or
equal
to
1
ppmw.
Otherwise,
we
recommend
that
nondetect
data
be
treated
as
one­
half
of
the
MDL.
This
would
deter
facilities
from
attempting
to
measure
water
concentrations
using
methods
or
equipment
with
low
sensitivity
in
order
to
purposely
obtain
non­
detect
measurements,
and
would
also
prevent
facilities
from
having
to
assume
the
MDL
for
HAP
that
are
not
present
(
or
are
present
in
very
low
concentrations)
in
water
stream.

a.
Option
1:
WATER9
modeling
One
method
for
estimating
wastewater/
process
water
emissions
would
be
through
the
application
of
EPA's
WATER9
model
(
available
at
http://
www.
epa.
gov/
ttn/
chief/
software/
index.
html).
WATER9
uses
analytical
expressions
and
a
data
base
of
organic
compounds
to
provide
separate
emission
estimates
for
each
individual
compound
that
is
identified
as
a
constituent
of
the
wastewater/
process
water.
The
emission
estimates
are
based
upon
the
properties
of
the
compound
and
its
concentration.
To
obtain
these
emission
estimates,
the
facility
would
have
to
collect
and
analyze
water
samples
from
inlet
streams
to
provide
their
concentrations
of
Appendix
B
HAP.
WATER9
may
be
used
to
estimate
air
emissions
from
common
wastewater
management
and
treatment
units
including:
drains,
sumps,
weirs,
open
drains,
j
traps,
manhole
covers,
trenches,
buried
conduits
(
sewers),
junction
boxes,
pump
stations,
clarifiers,
trickling
filters,
aerated
impoundments,
quiescent
impoundments,
cooling
towers,
activated
sludge
units,
storage
tanks,
wastewater
separators,
and
settling
ponds.
Impoundments
(
e.
g.,
settling
ponds)
and
wastewater
storage
tanks
are
most
commonly
found
at
PCWP
facilities.

b.
Option
2:
Mass
transfer
calculations
(
similar
to
those
in
WATER9)

Another
approach
for
estimating
HAP
emissions
from
water
operations
would
be
to
have
the
rule
specify
both
the
appropriate
mass
transfer
relationships
to
use
and
the
specific
water
operations
for
which
emissions
must
be
estimated.
If
the
collection
and
conveyance
system
consists
of
hard­
piping,
then
emissions
only
need
to
be
estimated
for
open
water
tanks
and
ponds,
including
those
that
are
part
of
zero­
discharge
systems
as
well
as
those
that
precede
discharge
to
a
treatment
unit.
The
applicable
equations
to
estimate
emission
from
open
ponds
and
tanks
are
presented
in
Attachment
8
and
summarized
below.
In
Appendix
B
to
subpart
DDDD,
the
ponds
and
tanks
could
be
classified
as
"
water
management
units"
with
the
following
definition:

"
water
management
unit
means
each
uncovered
tank
or
pond
that
receives
water
from
process
operations
including
but
not
limited
to
hardboard
operations,
washing
of
process
or
control
equipment,
or
as
discharge
from
a
wet
control
device.
The
tank
or
pond
may
be
a
final
disposal
unit,
an
equalization
basin
or
holding
unit
in
a
once­
through
system
27
E
KACL
=
(
Eq.
1)

1
1
K
k
RT
k
H
L
G
=
+
(
Eq.
2)
prior
to
wastewater
treatment,
or
a
holding
unit
for
water
that
is
recirculated
for
process
uses
or
in
a
control
device.
A
water
management
unit
is
a
process
unit."

The
appropriate
mass
transfer
relationships
for
estimating
emissions
from
water
management
units
are
the
same
as
those
used
in
the
WATER9
model.
The
basic
relationship
describing
mass
transfer
of
a
volatile
constituent
from
an
open
liquid
surface
to
the
air
is:

where:
E
=
air
emissions
from
the
liquid
surface,
g/
s
K
=
overall
mass
transfer
coefficient,
m/
s
A
=
liquid
surface
area,
m2
C
L
=
concentration
of
individual
HAP
in
the
water,
g/
m3
The
overall
mass
transfer
coefficient
(
K)
is
estimated
from
a
two­
phase
resistance
model
that
is
based
on
the
liquid­
phase
mass
transfer
coefficient
(
k
L
in
m/
s),
the
gas­
phase
mass
transfer
coefficient
(
k
G
in
m/
s),
and
Henry's
law
constant.
The
two
resistances
act
in
series,
and
the
overall
resistance
is
expressed
as:

where:

K
=
overall
mass
transfer
coefficient,
m/
s
k
L
=
liquid­
phase
mass
transfer
coefficient,
m/
s
k
G
=
gas­
phase
mass
transfer
coefficient,
m/
s
R
=
universal
gas
constant
(
8.21
x
10­
5
atm°
m3/
gmol°
K)
T
=
temperature
of
the
air,
K
H
=
Henry's
law
constant
for
the
HAP,
atm°
m3/
gmol
Several
empirical
models
that
are
used
in
WATER9
to
estimate
the
gas­
phase
and
liquidphase
mass
transfer
coefficients
are
presented
in
Attachment
8.20
An
identical
model
is
codified
in
Appendix
C
to
40
CFR
Part
63,
in
Forms
VII
and
VIII.
The
models
are
functions
of
numerous
pond
or
tank
characteristics
and
properties
of
the
HAP
that
are
present
in
the
water.
The
appropriate
model
also
depends
on
whether
the
water
in
the
pond
or
tank
is
agitated,
the
wind
speed,
and
the
fetch­
to­
depth
ratio
for
the
pond
or
tank
(
fetch
is
the
linear
distance
across
the
liquid
surface
in
the
direction
of
wind
flow).
This
discussion
assumes
that
biological
activity
in
the
pond
or
tank
is
negligible.
This
is
a
worst­
case
assumption
because
a
pond
or
tank
in
which
biodegradation
is
occurring
will
have
lower
emissions
(
although
it
may
not
make
much
difference
28
over
the
short,
one­
hour,
periods
that
are
of
interest
for
the
risk
demonstration).
For
an
aerated
pond
or
tank,
note
that
separate
overall
mass
transfer
coefficients
must
be
developed
using
Equation
2
for
both
the
aerated
and
quiescent
zones
in
the
tank
or
pond.
These
overall
mass
transfer
coefficients
for
each
zone
are
calculated
using
the
appropriate
equations
for
the
gas­
phase
and
liquid­
phase
mass
transfer
coefficients
provided
in
Attachment
8.
A
single
overall
coefficient
for
use
in
Equation
1
is
calculated
by
determining
a
weighted
average
of
the
overall
coefficients
for
the
two
zones
based
on
the
relative
surface
areas
of
the
two
zones
in
the
tank
or
pond.
Additional
information
regarding
the
development
of
these
models
can
be
found
in
the
companion
document
for
WATER9.20
Attachment
8
provides
an
example
calculation
based
on
the
equations
presented
in
Attachment
8
(
which
are
essentially
identical
to
those
contained
in
Forms
VII
and
VIII
of
Appendix
C
to
40
CFR
Part
63).

Both
the
WATER9
modeling
approach
discussed
in
subsection
"
a"
above,
and
the
mass
transfer
calculation
approach
discussed
in
this
subsection
require
the
Henry's
law
constant
(
H)
and
diffusivities
in
water
(
D
w)
and
air
(
D
a)
of
each
HAP
at
the
appropriate
temperature.
WATER9
contains
a
database
with
the
values
for
these
parameters
at
25

C,
and
it
automatically
calculates
the
correct
values
to
use
when
the
user
specifies
a
different
temperature.
The
same
data
and
adjustment
procedures
can
be
used
in
the
equations
that
are
presented
in
Attachment
8,
or
the
appropriate
values
can
be
obtained
from
chemical
reference
manuals.
Attachment
8
tabulates
the
WATER9
values
for
H,
D
w,
and
D
a
at
25

C
for
each
of
the
six
organic
HAP
in
Appendix
B
to
subpart
DDDD.
Attachment
8
also
presents
the
equations
that
WATER9
uses
to
make
the
temperature
corrections.
Other
variables
in
the
equations
are
parameters
that
must
be
determined
for
each
plant
on
a
site­
specific
basis.
The
values
for
these
parameters
also
would
need
to
be
established
at
the
"
worst­
case"
levels
that
result
in
the
maximum
hourly
emissions
for
the
water
management
unit.
Other
site­
specific
parameters
needed
in
the
calculations
include
the
air
and
water
temperatures,
wind
speed,
dimensions
of
the
pond
or
tank,
power
to
aerators,
impeller
diameter,
and
impeller
rotational
speed.

c.
Option
3:
Assume
evaporation
and
discharge
rate
are
equivalent
A
third
approach
for
estimating
HAP
emissions
from
water
operations
would
be
to
assume
that
the
HAP
evaporation
rate
equals
the
rate
at
which
it
is
discharged
to
the
water
management
unit.
Under
this
approach,
the
flow
rates
and
HAP
concentrations
would
need
to
be
determined
for
all
of
the
streams
that
discharge
to
the
water
management
unit.
The
worst­
case
would
be
if
all
of
the
streams
could
discharge
simultaneously.
If
this
is
not
physically
possible
due
to
some
type
of
processing
or
water
collection
system
constraint,
then
the
worst­
case
would
be
for
the
combination
of
streams
with
the
highest
hourly
discharge
rate
of
each
HAP
that
could
realistically
occur.
If
the
collection
system
is
not
hard­
piped,
then
the
concentration
measurements
should
be
made
at
the
inlet
to
the
collection
system;
if
the
collection
system
is
hard­
piped,
then
the
samples
could
be
taken
anywhere
in
the
collection
system.
This
approach
would
also
be
applicable
for
estimating
emissions
from
the
spraying
associated
with
treatment
by
land
application
(
i.
e.,
the
worst­
case
estimate
would
be
to
determine
the
maximum
hourly
HAP
load
to
the
spray
head(
s),
and
assume
all
of
it
volatilizes).
29
d.
Other
considerations
MDI.
It
is
possible
that
MDI
emissions
from
water
management
units
are
so
low
that
the
risk
from
such
emissions
will
be
infinitesimal
at
all
facilities
in
the
industry.
As
shown
in
Attachment
8,
the
Henry's
law
constant
and
diffusivities
in
air
and
water
are
all
extremely
low.
In
addition,
the
MDI
concentration
in
the
water
management
unit
is
likely
to
be
low
because
there
may
be
few
ways
in
which
MDI
would
be
expected
to
enter
the
water
stream.
Potential
sources
of
MDI
in
water
streams
could
include
MDI
blender
wash
water
or
wash
water
from
RTO's
on
presses
that
process
board
containing
MDI
resin
(
although
it
is
likely
that
most
of
the
MDI
is
combusted
rather
than
residing
in
the
RTO).
As
a
result,
it
might
be
productive
to
conduct
a
preliminary
risk
assessment
using
conservative
assumptions
to
determine
the
maximum
risk
that
might
be
expected
for
MDI
emissions
from
water
management
units.
However,
in
the
absence
of
information
on
potential
MDI
concentrations
in
water
streams
and
a
study
documenting
that
MDI
is
likely
to
pose
no
risk
from
any
facility,
each
facility
with
MDI
in
water
streams
should
include
MDI
emissions
from
water
management
units
in
their
low­
risk
determinations.

Sampling
location.
If
water
streams
are
not
hard­
piped
from
the
process
discharge
point
to
the
pond
or
tank,
then
depending
on
HAP
concentrations
and
system
characteristics,
emissions
from
the
collection
and
conveyance
system
could
be
significant
relative
to
the
emissions
from
the
pond
or
tank.
This
is
especially
true
for
more
volatile
HAP
such
as
acetaldehyde,
acrolein,
and
benzene,
all
of
which
have
much
higher
Henry's
law
constants
than
formaldehyde,
phenol,
and
MDI.
Thus,
for
acetaldehyde,
acrolein,
and
benzene,
option
1
or
3
should
be
used
instead
of
option
2
to
estimate
emissions
from
both
the
collection
system
and
the
holding
pond
or
tank
unless
the
collection
system
is
constructed
of
hard­
piping.
If
the
only
Appendix
B
HAP
in
the
pond
or
tank
are
formaldehyde,
phenol,
and/
or
MDI,
then
emissions
from
the
collection
system
can
be
ignored,
and
only
the
emissions
from
the
holding
pond
or
tank
need
to
be
estimated
using
any
of
the
options.

As
mentioned
previously,
the
worst­
case
Appendix
B
HAP
concentration
in
the
wastewater/
process
water
is
of
interest
for
purposes
of
the
low­
risk
demonstration.
One
way
to
determine
the
worst­
case
HAP
concentration
for
option
2
would
be
to
collect
and
analyze
water
samples
from
all
of
the
inlet
streams
and
very
conservatively
assume
that
the
maximum
concentration
in
any
individual
inlet
stream
represents
the
maximum
concentration
in
the
wastewater/
process
water
operation.
Because
this
approach
would
clearly
overstate
the
maximum
emissions,
Appendix
B
to
Subpart
DDDD
could
also
allow
facilities
to
develop
their
own
site­
specific
approach
to
selecting
appropriate
sampling
locations.
Facilities
selecting
their
own
sampling
locations
would
need
to
identify
the
number
of
locations
at
which
samples
would
be
collected,
indicate
what
fraction
of
the
surface
area
is
represented
by
each
sample,
and
provide
supporting
rationale.
Part
of
the
supporting
rationale
would
include
a
description
of
the
design
and
operation
of
the
water
management
unit
including,
but
not
limited
to,
the
dimensions
of
the
unit,
inlet
and
outlet
locations,
and
mixing
methods.
Potential
regulatory
language
regarding
selection
of
sampling
location
is
included
in
Attachment
7.
30
V.
Summary
of
Recommended
Procedures
for
Determining
HAP
Emissions
In
section
III.
A.
2,
we
recommended
that
emissions
from
each
type
of
process
unit
(
that
could
potentially
emit
any
of
the
HAP
listed
in
Appendix
B)
be
considered
in
the
low­
risk
demonstration
through
emissions
testing
or
estimation,
as
appropriate,
depending
of
the
feasibility
of
emission
testing.
We
recommended
emissions
testing
for
process
units
that
are
feasible
to
test.
Emissions
estimation
is
recommended
for
process
units
that
are
hard­
to­
test
(
i.
e.,
generally
are
not
configured
and
cannot
readily
be
configured
from
emissions
testing).
Table
5
presents
a
summary
of
process
units
according
to
feasibility
of
emissions
testing
and
recommended
approach
to
determining
emissions
for
purposes
of
the
low­
risk
demonstration.

Section
III.
B
addressed
issues
related
to
benzene
and
acrolein
emission
testing.
The
EPA
has
decided
that
it
is
appropriate
to
allow
use
of
NCASI
Method
IM/
CAN/
WP­
99.02
and
EPA
Method
18
for
measurement
of
benzene.
We
recommended
that
benzene
and
acrolein
testing
be
required
for
all
of
the
process
units
that
must
be
tested
for
the
other
Appendix
B
organic
HAP
(
i.
e.,
process
units
that
can
feasibly
be
tested)
for
the
following
reasons:
(
1)
the
available
data
do
not
allow
one
to
conclude
that
benzene
and
acrolein
would
not
be
emitted
for
a
given
process
unit
type;
(
2)
the
process
units
are
not
hard­
to­
test;
and
(
3)
testing
for
benzene
and
acrolein
would
not
substantially
increase
the
overall
testing
burden.

In
section
III.
C,
we
recommended
that
application
of
test
results
from
one
process
unit
to
other
similar
process
units
at
the
same
plant
site
be
allowed
provided
that
facilities
explain
in
their
test
reports
or
low­
risk
demonstrations
how
the
process
units
are
similar
in
terms
of
design,
function,
heating
method,
raw
materials
processed,
operating
temperature,
residence
time,
resin
type
processed,
and
any
other
parameters
that
may
affect
emissions.
To
account
for
slight
variations
in
parameters,
EPA
could
require
facilities
to
explain
and
test
the
process
unit
that
would
be
expected
to
exhibit
greater
emissions.
We
also
recommended
that
application
of
data
from
one
process
unit
at
one
plant
not
be
allowed
for
multiple
identical
process
units
at
other
plants.

In
section
III.
D,
we
recommended
that
process
units
direct­
fired
with
only
natural
gas
or
propane
be
excluded
from
the
HAP
metals
testing
requirements
for
direct­
fired
units.
However,
we
recommended
that
EPA
continue
to
require
HAP
metals
testing
for
process
units
direct­
fired
using
wood,
other
fuels,
or
a
combination
of
natural
gas
(
or
propane)
and
wood
or
other
fuels.

In
section
IV,
we
discussed
emission
estimation
procedures
that
may
be
used
to
estimate
emissions
from
hard­
to­
test
process
units.
In
section
IV.
A,
we
recommended
that
the
estimated
emissions
be
divided
evenly
across
the
number
of
emission
points
for
purposes
of
the
low­
risk
demonstration.
Emission
factor
estimates
were
recommended
for
process
units
with
available
emission
factors.
The
maximum
available
emission
factor
was
selected
for
each
process
unit
and
pollutant
combination.
With
a
few
exceptions,
we
recommended
that
emissions
of
a
particular
HAP
be
excluded
from
the
low­
risk
demonstration
for
hard­
to­
test
process
units
if
all
of
the
available
emission
factors
were
based
on
values
½
of
the
MDL
(
i.
e.,
if
all
of
the
test
data
for
a
HAP
was
non­
detect
for
a
certain
process
unit
group).
Engineering
estimates
were
recommended
31
if
no
emission
factors
are
available
for
HAP
that
could
reasonably
be
expected
to
be
emitted
from
a
given
process
unit.
In
section
IV.
B,
emission
techniques
were
specified
for
hard­
to­
test
process
units
with
no
available
emission
factors
(
i.
e.,
lumber
kilns,
resin
tanks,
and
wastewater/
process
water
operations).

In
summary,
Table
6
lists
each
process
unit
and
Appendix
B
pollutant
and
presents
the
procedures
recommended
in
this
memorandum
for
determining
Appendix
B
HAP
emissions
from
each
type
of
PCWP
process
unit
for
purposes
of
the
low­
risk
demonstration.
A
table
similar
to
Table
6
could
be
incorporated
into
Appendix
B
to
subpart
DDDD
through
an
amendment.
32
Table
5.
Overview
of
Appendix
B
requirements
for
determining
emissions
from
PCWP
process
units
Type
of
process
unit
Feasibility
of
emissions
testing
Appendix
B
requirement
for
emissions
determination
Agricultural
fiber
board
presses
Agricultural
fiberboard
mat
dryers
Atmospheric
refiners
Conveyor
strand
dryers
(
all
zones)
Dry
rotary
dryers
Fiberboard
mat
dryers
(
heated
and
cooling
zones)
Green
rotary
dryers
Hardboard
ovens
Hardwood
veneer
dryers
(
heated
zones)
Paddle­
type
particle
dryers
Press
predryers
Pressurized
refiners
Primary
tube
dryers
Reconstituted
wood
product
presses
Reconstituted
wood
product
board
coolers
Rotary
strand
dryers
Rotary
agricultural
fiber
dryers
Secondary
tube
dryers
Softwood
veneer
dryers
(
heated
zones)
Veneer
redryers
(
heated
by
conventional
means)
Feasible
to
test
Emissions
testing
is
required
for
the
following
organic
HAP:
acetaldehyde,
acrolein,
formaldehyde,
phenol,
and
benzene.
In
addition,
MDI
testing
is
required
for
process
units
processing
material
containing
MDI
resin.
Testing
for
HAP
metals
(
arsenic,
beryllium,
cadmium,
chromium,
lead,
manganese,
and
nickel)
is
required
for
direct­
fired
process
units
(
except
for
units
directfired
with
only
natural
gas
or
propane).

Blending
and
forming
operations
Engineered
wood
products
presses
Fiber
washers
Fiberboard
mat
dryers
(
fugitive
emissions)
Finishing
sanders
Finishing
saws
Hardwood
plywood
presses
Hardwood
veneer
dryers
(
cooling
zones)
Humidifiers
Log
vats
Lumber
kilns
Panel­
trim
chippers
Particleboard
press
molds
Particleboard
extruders
Radio­
frequency
veneer
redryers
Resin
tanks
Softwood
veneer
dryers
(
cooling
zones)
Softwood
plywood
presses
Stand­
alone
digesters
Veneer
kilns
Wastewater/
process
water
operations
Hard­
to­
test
Emissions
estimates
according
to
method
specified
in
Appendix
B
Log
chipping
Miscellaneous
coating
operations
Softwood
veneer
dryer
(
fugitive
emissions)
Hard­
to­
test
Not
applicable
(
Appendix
B
HAP
not
emitted)

Other
ancillary
processes
that
emit
Appendix
B
HAP
emissions
Hard­
to­
test
Emissions
estimates
(
engineering
estimate)

Note:
Different
terms
for
some
of
the
process
unit
types
may
be
incorporated
into
Appendix
B.
For
example,
engineered
wood
products
presses
had
to
be
subdivided
for
application
of
emission
factors.
Attachment
2
supplies
sugested
process
unit
definitions.
33
Table
6.
Summary
of
recommended
testing
or
emissions
estimation
procedures
for
process
units
to
be
included
in
Appendix
B
to
subpart
DDDD.

Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
Agricultural
fiber
board
presses
none
test
test
test
test
test
test
if
board
contains
MDI
resin
NA
Agricultural
fiberboard
mat
dryers
none
test
test
test
test
test
NA
test
Atmospheric
refiners
none
test
test
test
test
test
NA
NA
Blending
and
forming
operations
­
OSB
none
NA
NA
0.0036
lb/
MSF
3/
8"
press
throughput
engineering
estimate
NA
engineering
estimate
if
MDI
resin
used
NA
Blending
and
forming
operations
­
particleboard
and
MDF
none
NA
NA
0.060
lb/
ODT
NA
NA
engineering
estimate
if
MDI
resin
used
NA
Conveyor
strand
dryers
C
test
test
test
test
test
NA
NA
Dry
forming
­

hardboard
none
engineering
estimate
NA
engineering
estimate
engineering
estimate
NA
NA
NA
Dry
rotary
dryers
WP
test
test
test
test
test
NA
test
Fiber
washers
none
0.015
lb/
ODT
NA
0.0026
lb/
ODT
NA
NA
NA
NA
Fiberboard
mat
dryer
(
fugitive
emissions)
none
0.0055
lb/
MSF
½
"
NA
0.031
lb/
MSF
½
"
NA
NA
NA
NA
Table
6,
continued
Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
34
Fiberboard
mat
dryer
(
heated
zones)
C
(
new)
test
test
test
test
test
NA
test
Finishing
saws
none
0.00092
lb/
MSF
3/
8"
NA
0.00034
lb/
MSF
3/
8"
0.0057
lb/
MSF
NA
engineering
estimate
if
MDI
resin
used
NA
Finishing
sanders
none
0.0028
lb/
MSF
3/
8"
NA
0.0042
lb/
MSF
0.015
lb/
MSF
NA
engineering
estimate
if
MDI
resin
used
NA
Green
rotary
dryers
C
test
test
test
test
test
NA
test
Hardboard
ovens
C
test
test
test
test
test
NA
test
Hardwood
veneer
dryers
(
heated
zones)
WP
test
test
test
test
test
NA
test
Hardwood
veneer
dryer,
cooling
zones
none
0.058
lb/
MSF
3/
8"
NA
0.013
lb/
MSF
3/
8"
NA
NA
NA
NA
Hardwood
plywood
presses
none
NA
NA
0.0088
lb/
MSF
3/
8"
0.016
lb/
MSF
3/
8"
NA
NA
NA
Hardwood
veneer
kilns
none
0.067
lb/
MSF
3/
8"
NA
0.016
lb/
MSF
3/
8"
0.0053
lb/
MSF
3/
8"
NA
NA
NA
Humidifiers
none
0.0018
lb/
MSF
1/
8"
0.0087
lb/
MSF
1/
8"
0.0010
lb/
MSF
1/
8"
0.00057
lb/
MSF
1/
8"
0.0000062
lb/
MSF
1/
8"
NA
NA
Table
6,
continued
Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
35
I­
joist
curing
chambers
none
NA
NA
0.00018
lb/
MLF
NA
NA
engineering
estimate
if
MDI
resin
used
NA
Log
steaming
vats
none
0.0047
lb/
MSF
3/
8"
removed
from
vat
per
hour
NA
NA
NA
NA
NA
NA
LSL
presses
none
engineering
estimate
NA
0.029
lb/
1000
ft3
engineering
estimate
NA
0.18
lb/
1000
ft3
NA
Lumber
kilns
none
0.065
lb/
MBF
0.009
lb/
MBF
0.034
lb/
MBF
0.010
lb/
MBF
NA
NA
Engineering
estimate
LVL
presses
none
0.29
lb/
1000
ft3
NA
0.79
lb/
1000
ft3
NA
NA
NA
NA
Paddle­
type
particleboard
dryers
none
test
test
test
test
test
NA
test
Panel­
trim
chippers
none
0.00081
lb/
MSF
3/
8"

finished
board
production
NA
0.00034
lb/
MSF
3/
8"

finished
board
production
0.0019
lb/
MSF
3/
8"
finished
board
production
NA
NA
NA
Particleboard
press
molds
and
particleboard
extruders
none
0.034
lb/
MSF
3/
4"
0.0087
lb/
MSF
3/
4"
0.64
lb/
MSF
3/
4"
0.024
lb/
MSF
3/
4"
0.0073
lb/
MSF
3/
4"
NA
NA
Table
6,
continued
Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
36
Press
predryers
C
test
test
test
test
test
NA
test
Pressurized
refiners
C
test
test
test
test
test
NA
NA
Primary
tube
dryers
C
test
test
test
test
test
test
if
processing
furnish
with
MDI
resin
added
prior
to
drying
test
Radio­
frequency
veneer
redryers
none
0.0029
lb/
MSF
3/
8"
NA
0.00065
lb/
MSF
3/
8"
NA
NA
NA
NA
Reconstituted
wood
products
presses
C
test
test
test
test
test
test
if
board
contains
MDI
resin
NA
Reconstituted
wood
product
board
coolers
C
(
new)
test
test
test
test
test
test
if
board
contains
MDI
resin
NA
Resin
storage
tanks
none
NA
NA
0.19
lb/
hr
per
tank
for
tanks
with
resin
containing
formaldehyde
OR
model
using
TANKS
softwarea
0.18
lb/
hr
per
tank
for
tanks
with
resin
containing
phenol
OR
model
using
TANKS
softwarea
NA
0.0013
lb/
hr
per
tank
for
tanks
with
MDI
resin
OR
model
using
TANKS
softwarea
NA
Table
6,
continued
Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
37
Rotary
strand
dryers
C
test
test
test
test
test
NA
test
Rotary
agricultural
fiber
dryers
none
test
test
test
test
test
NA
test
Secondary
tube
dryers
C
test
test
test
test
test
test
if
processing
furnish
with
MDI
resin
added
prior
to
drying
test
Softwood
plywood
presses
none
0.012
lb/
MSF
3/
8"
NA
0.0054
lb/
MSF
3/
8"
0.0022
lb/
MSF
3/
8"
NA
NA
NA
Softwood
veneer
dryers
(
heated
zones)
C/
WP
test
test
test
test
test
NA
test
Softwood
veneer
dryers
(
cooling
zones)
none
0.012
lb/
MSF
3/
8"
NA
0.0028
lb/
MSF
3/
8"
0.011
lb/
MSF
3/
8"
NA
NA
NA
Softwood
veneer
kilns
none
0.097
lb/
MSF
3/
8"
0.012
lb/
MSF
3/
8"
0.10
lb/
MSF
3/
8"
0.020
lb/
MSF
3/
8"
0.0078
lb/
MSF
3/
8"
NA
NA
Stand­
alone
digesters
none
0.030
lb/
ODT
0.0024
lb/
ODT
0.0045
lb/
ODT
0.0012
lb/
ODT
NA
NA
NA
Veneer
redryers
(
heated
by
conventional
means)
WP
test
test
test
test
test
NA
test
Table
6,
continued
Process
unit
type
Subpart
DDDD
control
(
C)
or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
unitsb
38
Wastewater/
process
water
operations
none
engineering
estimate
(
such
as
WATER9a
or
other
method)
engineering
estimate
(
such
as
WATER9a
or
other
method)
engineering
estimate
(
such
as
WATER9a
or
other
method)
engineering
estimate
(
such
as
WATER9a
or
other
method)
engineering
estimate
(
such
as
WATER9a
or
other
method)
engineering
estimate
(
such
as
WATER9a
or
other
method)
if
MDI
resin
used
NA
Wet
forming
­

fiberboard
and
hardboard
(
without
PF
resin)
none
0.0075
lb/
MSF
½
"
NA
0.0036
lb/
MSF
½
"
NA
NA
NA
NA
Wet
forming
­

hardboard
(
PF
resin)
none
0.0067
lb/
ODT
NA
0.00039
lb/
ODT
0.00075
lb/
ODT
NA
NA
NA
Miscellaneous
coating
operations,
log
chipping,
and
softwood
veneer
dryer
fugitive
emissions
none
NA
NA
NA
NA
NA
NA
NA
Other
ancillary
processes
(
not
listed
elsewhere
in
this
table)

that
may
emit
HAP
listed
in
this
table
none
engineering
estimate
engineering
estimate
engineering
estimate
engineering
estimate
engineering
estimate
engineering
estimate
engineering
estimate
test:
Emissions
testing
must
be
conducted
for
the
process
unit
and
pollutant
according
to
the
test
methods
specified
in
Table
2B
to
Appendix
B
to
subpart
DDDD.

NA:
Not
applicable.
No
emission
estimates
or
emissions
testing
is
required
for
purposes
of
the
low­
risk
demonstration.
Table
6,
continued
39
lb/
MSF:
Pounds
of
HAP
per
thousand
square
feet
of
board
of
the
inches
thickness
specified
(
e.
g.,
lb/
MSF
3/
4
=
pounds
of
HAP
per
thousand
square
feet
of
3/
4­
inch
board).
See
equation
in
§
63.2262(
j)
of
subpart
DDDD
to
convert
from
one
thickness
basis
to
another.

lb/
ODT:
Pounds
of
HAP
per
oven
dried
ton
of
wood
material
a
TANKS
and
WATER9
software
is
available
at
http://
www.
epa.
gov/
ttn/
chief/
software/
index.
html
b
Excludes
direct­
fired
process
units
fired
with
only
natural
gas
or
propane.
40
References:

1.
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products;
Effluent
Limitations
Guidelines
and
Standards
for
the
Timber
Products
Point
Source
Category;
List
of
Hazardous
Air
Pollutants,
Lesser
Quantity
Designations,
Source
Category
List.
69
FR
45944.
July
30,
2004.

2.
T.
Hunt,
AF&
PA,
to
M.
Kissell,
K.
Hustvedt,
S.
Jenkins,
and
D.
Guinnup,
EPA/
ESD.
June
3,
2004.
E­
mail
transmitting
white
paper
containing
the
industry's
recommendations
regarding
process
unit
testing
and
alternatives
to
demonstrate
eligibility
for
the
low­
risk
subcategory.

3.
Memorandum
from
K.
Hanks,
RTI,
to
M.
Kissell,
EPA/
ESD.
April
27,
2004.
Meeting
Minutes
for
the
March
29,
2004
Conference
Call
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA),
the
American
Forest
and
Paper
Association
(
AF&
PA),
and
Representatives
of
the
PCWP
Industry.

4.
Memorandum
from
K.
Hanks,
RTI,
to
M.
Kissell,
EPA/
ESD.
April
12,
2004.
Meeting
Minutes
for
the
April
1,
2004
Conference
Call
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA),
the
American
Forest
and
Paper
Association
(
AF&
PA),
and
Representatives
of
the
PCWP
Industry
5.
T.
Hunt,
AF&
PA,
to
M.
Kissell,
K.
Hustvedt,
and
D.
Guinnup,
EPA/
ESD.
February
19,
2004.
E­
mail
transmitting
white
paper
containing
industry's
suggestions
regarding
testing
of
process
units
for
benzene
and
acrolein
process
when
demonstrating
eligibility
for
the
low­
risk
subcategory.

6.
Memorandum
from
K.
Hanks,
B.
Nicholson,
and
K.
Parrish,
RTI,
to
M.
Kissell,
EPA/
ESD.
December
15,
2003.
Determination
of
MACT
floors
and
MACT
for
the
Final
Plywood
and
Composite
Wood
Products
Industry
NESHAP.

7.
U.
S.
EPA,
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plywood
and
Composite
Wood
Products,
Background
Information
for
Final
Standard,
Summary
of
Public
Comments
and
Responses.
February
2004.

8.
Memorandum
from
K.
Hanks,
RTI,
to
M.
Kissell,
EPA/
ESD.
November
7,
2003.
Estimates
of
Ancillary
Plywood
and
Composite
Wood
Products
Process
Emissions
for
Use
in
Risk
Modeling.

9.
National
Council
for
Air
and
Stream
Improvement.
An
Evaluation
of
Credit­
Generating
Emission
Sources
for
Use
in
the
Emissions
Averaging
Compliance
Option
Under
the
Wood
Products
NESHAP.
Technical
Bulletin
No.
869.
December
2003.
41
10.
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.

11.
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.

12.
D.
Word
to
G.
McAlister,
EPA/
ESD.
June
22,
2004.
Email
transmitting
information
related
to
quality
assurance
data
benzene
measured
using
NCASI
IM/
CAN/
WP
99.02.

13.
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.

14.
Memorandum
from
D.
Bullock,
K.
Hanks,
and
B.
Nicholson,
MRI
to
M.
Kissell,
EPA/
ESD.
April
28,
2000.
Summary
of
Responses
to
the
1998
EPA
Information
Collection
Request
(
MACT
Survey)
­­
General
Survey.

15.
National
Council
for
Air
and
Stream
Improvement.
A
Comparative
Study
of
VOC
Emissions
from
Small­
scale
and
Full­
scale
Lumber
Kilns
Drying
Southern
Pine.
Technical
Bulletin
No.
845.
May
2002.

16.
Milota,
M.,
Oregon
State
University.
Drying
Emissions
and
Environmental
Regulations.
Presented
at
the
Forest
Products
Society
Conference
Quality
Drying:
The
Key
to
Profitable
Manufacturing,
September
23­
25,
2002,
Montreal,
Quebec,
Canada.

17.
Milota,
M.,
Oregon
State
University.
HAP
and
VOC
Emissions
From
White
Fir
Lumber
Dried
at
High
and
Conventional
Temperatures.
Forest
Products
Journal,
March
2003.

18.
M.
Lavery
and
M.
Milota,
Oregon
State
University.
VOC
Emissions
from
Douglas­
Fir:
Comparing
a
Commercial
and
a
Laboratory
Kiln.
Forest
Products
Journal,
Vol
50,
No.
7/
8.
March
1999.

19.
Memorandum
from
K.
Hanks,
RTI
to
M.
Kissell,
EPA/
ESD.
February
21,
2005.
Considerations
for
a
Small­
scale
Kiln
Emission
Testing
Program.

20.
U.
S.
EPA,
Air
Emissions
Models
for
Waste
and
Wastewater.
EPA­
453/
R­
94­
080A.
November
1994.

21.
Memorandum
from
R.
Nicholson
and
K.
Hanks,
RTI
to
M.
Kissell,
EPA/
ESD.
November
8,
2004.
Meeting
Minutes
for
the
October
29,
2004
Meeting
Between
the
U.
S.
Environmental
Protection
Agency
(
EPA),
the
American
Forest
and
Paper
Association
(
AF&
PA),
and
Representatives
of
the
PCWP
Industry.
ATTACHMENT
1
Table
1
of
the
Preamble
to
the
Final
Rule
TABLE
1
OF
THE
PREAMBLE
TO
THE
FINAL
PCWP
RULE
TABLE
1.
PROCESS
UNITS
THAT
ARE
SUBJECT
TO
THE
FINAL
CONTROL
REQUIREMENTS
For
the
following
process
units...
Does
today's
final
rule
include
control
requirements
for...

Existing
affected
sources?
New
affected
sources?

Softwood
veneer
dryersa;
primary
tube
dryers;
secondary
tube
dryers;
rotary
strand
dryers;
conveyor
strand
dryers;
green
rotary
dryers;
hardboard
ovens;
reconstituted
wood
product
presses;
and
pressurized
refiners
Yes
Yes
Press
predryers;
fiberboard
mat
dryers;
and
board
coolers
No
Yes
Dry
rotary
dryersa;
veneer
redryersa;
softwood
plywood
presses;
hardwood
plywood
presses;
engineered
wood
products
presses;
hardwood
veneer
dryersa;
humidifiers;
atmospheric
refiners;
formers;
blenders;
rotary
agricultural
fiber
dryers;
agricultural
fiber
board
presses;
sanders;
saws;
fiber
washers;
chippers;
log
vats;
lumber
kilns;
storage
tanks;
wastewater
operations;
miscellaneous
coating
operations
(
including
group
1
miscellaneous
coating
operationsa);
and
stand­
alone
digesters
No
No
aThese
process
units
have
work
practice
requirements
in
today's
final
rule
in
addition
to
or
instead
of
control
requirements.
Group
1
miscellaneous
coating
operations
include
application
of
edge
seals,
nail
lines,
logo
(
or
other
information)
paint,
shelving
edge
fillers,
trademark/
grade­
stamp
inks,
and
wood
putty
patches
to
PCWP
(
except
kiln­
dried
lumber)
on
the
same
site
where
the
PCWP
are
manufactured.
Group
1
miscellaneous
coating
operations
also
include
application
of
synthetic
patches
to
plywood
at
new
affected
sources.
ATTACHMENT
2
Suggested
Process
Unit
Definitions
Agricultural
fiber
board
press
means
a
press
used
in
the
production
of
an
agricultural
fiber
based
composite
wood
product.
An
agricultural
fiber
board
press
is
a
process
unit.

Agricultural
fiberboard
mat
dryer
means
a
dryer
used
to
reduce
the
moisture
of
wet­
formed
agricultural
fiber
mats
by
operation
at
elevated
temperature.
An
agricultural
fiberboard
mat
dryer
is
a
process
unit.

Atmospheric
refiner
means
a
piece
of
equipment
operated
under
atmospheric
pressure
for
refining
(
rubbing
or
grinding)
the
wood
material
into
fibers
or
particles.
Atmospheric
refiners
are
operated
with
continuous
infeed
and
outfeed
of
wood
material
and
atmospheric
pressures
throughout
the
refining
process.
An
atmospheric
refiner
is
a
process
unit.

Blending
and
forming
operations
means
the
process
of
mixing
adhesive
and
other
additives
with
the
(
wood)
furnish
of
the
composite
panel
and
making
a
mat
of
resinated
fiber,
particles,
or
strands
to
be
compressed
into
a
reconstituted
wood
product
such
as
particleboard,
oriented
strandboard,
or
medium
density
fiberboard.
Blending
and
forming
operations
are
process
units.

Fiber
washer
means
a
unit
in
which
water­
soluble
components
of
wood
(
hemicellulose
and
sugars)
that
have
been
produced
during
digesting
and
refining
are
removed
from
the
wood
fiber.
Typically
wet
fiber
leaving
a
refiner
is
further
diluted
with
water
and
then
passed
over
a
filter,
leaving
the
cleaned
fiber
on
the
surface.
A
fiber
washer
is
a
process
unit.

Finishing
sander
means
a
piece
of
equipment
that
uses
an
abrasive
drum,
belt,
or
pad
to
impart
smoothness
to
the
surface
of
a
plywood
or
composite
wood
product
panel
and
to
reduce
the
panel
to
the
prescribed
thickness.
A
finishing
sander
is
a
process
unit.

Finishing
saw
means
a
piece
of
equipment
used
to
trim
or
cut
finished
plywood
and
composite
wood
products
panels
to
a
certain
size.
A
finishing
saw
is
a
process
unit.

Hardwood
plywood
press
means
a
hot
press
which,
through
heat
and
pressure,
bonds
assembled
hardwood
veneers
(
including
multiple
plies
of
veneer
and/
or
a
substrate)
and
resin
into
a
hardwood
plywood
panel.
A
hardwood
plywood
press
is
a
process
unit.

Hardwood
veneer
kiln
means
an
enclosed
dryer
operated
in
batch
cycles
at
elevated
temperature
to
reduce
the
moisture
content
from
stacked
hardwood
veneer.
A
hardwood
veneer
kiln
is
a
process
unit.

Humidifier
means
a
process
unit
used
to
increase
the
moisture
content
of
hardboard
following
pressing
or
after
post­
baking.
Typically,
water
vapor
saturated
air
is
blown
over
the
hardboard
surfaces
in
a
closed
cabinet.
A
humidifier
is
a
process
unit.

I­
joist
curing
chamber
means
an
oven
or
a
room
surrounded
by
a
solid
wall
or
heavy
plastic
flaps
that
uses
heat,
infrared,
or
radio­
frequency
techniques
to
cure
the
adhesive.
An
I­
joist
curing
chamber
is
a
process
unit.
Log
chipping
means
the
production
of
wood
chips
from
logs.

Log
vat
means
a
process
unit
that
raises
the
temperature
of
the
logs
inside
by
applying
a
heated
substance,
usually
hot
water
and
steam,
to
the
outside
of
the
logs
by
spraying
or
soaking.
A
log
vat
is
a
process
unit.

LSL
press
means
a
composite
wood
product
press
that
presses
a
loose
mat
of
resinated
strands
into
a
billet
by
simultaneous
application
of
heat
and
pressure
and
forms
laminated
strand
lumber.
An
LSL
press
is
a
process
unit.

LVL
press
means
a
composite
wood
product
press
that
presses
resinated
stacks
of
veneers
into
a
solid
billet
by
simultaneous
application
of
heat
and
pressure
and
forms
laminated
veneer
lumber
or
parallel
strand
lumber.
An
LVL
press
is
a
process
unit.

Natural
gas
means
a
naturally
occurring
mixture
of
hydrocarbon
and
non­
hydrocarbon
gases
found
in
geologic
formations
beneath
the
earth's
surface.
The
principal
hydrocarbon
constituent
is
methane.

Paddle­
type
particleboard
dryer
means
a
dryer
that
uses
elevated
temperature
to
remove
moisture
from
particles
and
paddles
to
advance
materials
through
the
dryer.
This
type
of
dryer
removes
moisture
absorbed
by
particles
due
to
high
ambient
temperature.
A
paddle­
type
particleboard
dryer
is
a
process
unit.

Panel­
trim
chipper
means
a
piece
of
equipment
that
accepts
the
discarded
pieces
of
veneer
or
pressed
plywood
and
composite
wood
products
panels
that
are
removed
by
finishing
saws
and
reduces
these
pieces
to
small
elements.
A
panel­
trim
chipper
is
a
process
unit.

Particleboard
extruder
means
a
heated
die
oriented
either
horizontally
or
vertically
through
which
resinated
particles
are
continuously
forced
to
form
extruded
particleboard
products.
A
particleboard
extruder
is
a
process
unit.

Particleboard
press
mold
means
a
press
that
consists
of
molds
that
apply
heat
and
pressure
to
form
molded
or
shaped
particleboard
products.
A
particleboard
press
mold
is
a
process
unit.

Propane
means
a
colorless
gas
derived
from
petroleum
and
natural
gas,
with
the
molecular
structure
C3H8.

Radio­
frequency
veneer
redryer
means
a
dryer
heated
by
radio­
frequency
waves
that
is
used
to
redry
veneer
that
has
been
previously
dried.
A
radio­
frequency
veneer
redryer
is
a
process
unit.

Resin
storage
tank
means
any
storage
tank,
container,
or
vessel
connected
to
plywood
and
composite
wood
product
production
that
contains
resin
additives.
A
resin
storage
tank
is
a
process
unit.
Rotary
agricultural
fiber
dryer
means
a
rotary
dryer
operated
at
elevated
temperature
and
used
to
reduce
the
moisture
of
agricultural
fiber.
A
rotary
agricultural
fiber
dryer
is
a
process
unit.

Softwood
plywood
press
means
a
hot
press
which,
through
heat
and
pressure,
bonds
assembled
softwood
veneer
plies
and
resin
into
a
softwood
plywood
panel.
A
softwood
plywood
press
is
a
process
unit.

Softwood
veneer
kiln
means
an
enclosed
dryer
operated
in
batch
cycles
at
elevated
temperature
to
reduce
the
moisture
content
from
stacked
softwood
veneer.
A
softwood
veneer
kiln
is
a
process
unit.

Stand­
alone
digester
means
a
pressure
vessel
used
to
heat
and
soften
wood
chips
(
usually
by
steaming)
before
the
chips
are
sent
to
a
separate
process
unit
for
refining
into
fiber.
A
stand­
alone
digester
is
a
process
unit.

Wastewater/
process
water
operation
means
equipment
that
stores,
transfer,
or
processes
water
in
plywood
or
composite
wood
product
facilities
for
reuse
or
disposal.
Wastewater/
process
water
operations
includes
but
is
not
limited
to
pumps,
holding
ponds
and
tanks,
cooling
and
heating
operations,
settling
systems,
filtration
systems,
aeration
systems,
clarifiers,
pH
adjustment
systems,
log
storage
ponds,
pollution
control
device
water
(
including
wash
water),
vacuum
distillation
systems,
sludge
drying
and
disposal
systems,
spray
irrigation
fields,
and
connections
to
POTW
facilities.
Wastewater/
process
water
operations
are
process
units.
ATTACHMENT
3
Comparison
of
Selected
HAP
Data
from
Similar
Process
Units
on
the
Same
Site
Shaded
rows
indicate
that
one
or
both
of
the
units
had
all
non­
detect
measurements
for
the
pollutant.
Therefore,
a
comparison
between
the
two
units
could
not
be
made.

Softwood
Plywood
Softwood
Plywood
Hot
Board
Press,
Unpowered
Vent
Above
No.
1
Board
Press
Softwood
Plywood
Hot
Board
Press,
Powered
Vent
Above
No.
2
Board
Press
Difference
is
a
factor
of...

Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MSF
3/
8"
Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MSF
3/
8"
lb/
hr
EF
194­
1PB1
acetaldehyde
1
0.46448581
0.012153016
0.00082734
194­
2PB1
acetaldehyde
1
0.472162201
0.0712776
0.005080149
6
6
194­
1PB1
acrolein
3
0.14440155
0.004835673
0.000375947
194­
2PB1
acrolein
3
0.134470272
0.026037815
0.001940698
5
5
194­
1PB1
benzene
3
0.044935273
0.002097932
0.000166345
194­
2PB1
benzene
3
0.038813141
0.010472174
0.000776091
5
5
194­
1PB1
formaldehyde
3
0.06452301
0.001158353
9.01062E­
05
194­
2PB1
formaldehyde
0
0.748626676
0.077121794
0.005433552
194­
1PB1
methanol
0
42.21742058
0.805872903
0.060465713
194­
2PB1
methanol
0
29.2907602
3.237752642
0.245075359
4
4
194­
1PB1
phenol
3
0.173311705
0.009742617
0.000756299
194­
2PB1
phenol
3
0.162273289
0.052748018
0.003933065
5
5
194­
1PB1
propionaldehyde
3
0.156943298
0.005444923
0.000423008
194­
2PB1
propionaldehyde
3
0.146531724
0.029395615
0.002191383
5
5
194­
1PB1
THC
as
carbon
0
213.8162995
1.529139198
0.108983943
194­
2PB1
THC
as
carbon
0
121.6809338
5.038749275
0.371976595
3
3
Note:
The
two
presses
are
similar
in
design
and
operation;
however,
the
press
vent
fan
was
not
operating
during
testing
of
the
No.
1
press.
It
is
common
for
plywood
plants
to
turn
off
press
vent
fans
during
winter
months.

Softwood
Veneer
Dryer,
No.
2
Combined
Vent
Softwood
Veneer
Dryer,
No.
3
Combined
Vent
Difference
is
a
factor
of...

Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MSF
3/
8"
Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MSF
3/
8"
lb/
hr
EF
170­
2DV3
acetaldehyde
0
4.986850046
0.207141187
0.014777546
170­
3DV3
acetaldehyde
0
4.594664188
0.217047936
0.020057348
1
1
170­
2DV3
acrolein
3
0.145967739
0.007730051
0.000555108
170­
3DV3
acrolein
3
0.137141817
0.008252651
0.000746565
1
1
170­
2DV3
benzene
3
0.043713345
0.003234073
0.000230178
170­
3DV3
benzene
3
0.038217993
0.003205574
0.000289046
1
1
170­
2DV3
formaldehyde
0
3.307519969
0.094966505
0.00662101
170­
3DV3
formaldehyde
0
2.149834815
0.06880423
0.006847769
1
1
170­
2DV3
methanol
0
11.72177747
0.357249181
0.024774387
170­
3DV3
methanol
0
16.50106713
0.563826277
0.053555672
2
2
170­
2DV3
phenol
3
0.17568827
0.015615904
0.001122127
170­
3DV3
phenol
2
0.245063977
0.024819513
0.002100491
170­
2DV3
propionaldehyde
3
0.158861043
0.008715177
0.000626045
170­
3DV3
propionaldehyde
3
0.149615168
0.009327549
0.000843892
1
1
170­
2DV3
THC
as
carbon
0
170­
3DV3
THC
as
carbon
0
NA
NA
Shaded
rows
indicate
that
one
or
both
of
the
units
had
all
non­
detect
measurements
for
the
pollutant.
Therefore,
a
comparison
between
the
two
units
could
not
be
made.

Particleboard
Face
Dryer,
Face
Dryer
Exhaust
Core
Dryer,
Core
Dryer
Exhaust
Difference
is
a
factor
of...

Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
lb/
hr
EF
010­
1DR1
acetaldehyde
3
0.245693
0.034367
0.00346968
010­
3DR1
acetaldehyde
1
0.339660414
0.063538179
0.00597121
010­
1DR1
acrolein
3
0.168769
0.030043
0.00303345
010­
3DR1
acrolein
3
0.138595029
0.032929559
0.003041719
1
1
010­
1DR1
benzene
3
0.038567
0.009566
0.00096683
010­
3DR1
benzene
3
0.036373043
0.012040173
0.001114467
1
1
010­
1DR1
formaldehyde
1
0.730361
0.066318
0.00698802
010­
3DR1
formaldehyde
1
0.201909989
0.025797667
0.002440519
3
3
010­
1DR1
methanol
1
0.953652
0.095366
0.00980276
010­
3DR1
methanol
0
0.731112968
0.099331013
0.009148015
1
1
010­
1DR1
phenol
3
0.206613
0.061744
0.0062339
010­
3DR1
phenol
3
0.168306139
0.067131034
0.006200116
1
1
010­
1DR1
propionaldehyde
3
0.185186
0.034154
0.00344838
010­
3DR1
propionaldehyde
3
0.151484246
0.037288973
0.003444183
1
1
010­
1DR1
THC
as
carbon
0
303.2183
11.24008
1.14800631
010­
3DR1
THC
as
carbon
0
369.8208801
18.8026253
1.717294871
2
1
Single
Pass
Rotary
Dryer,
No.
1
Dryer
Exhaust
at
Inlet
to
Sand
Filter
Single
Pass
Rotary
Dryer,
No.
2
Dryer
Exhaust
at
Inlet
to
Sand
Filter
Difference
is
a
factor
of...

Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
Unit
code
Compound
Name
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
lb/
hr
EF
156­
1DR2
acetaldehyde
0
6.298317
0.266576
0.03846574
156­
2DR2
acetaldehyde
0
3.644912777
0.123389764
0.017715837
2
2
156­
1DR2
acrolein
0
1.148655
0.060765
0.0085498
156­
2DR2
acrolein
0
0.675011417
0.031308427
0.004597277
2
2
156­
1DR2
benzene
0
0.266292
0.020069
0.00291395
156­
2DR2
benzene
0
0.283215933
0.018086038
0.002619596
1
1
156­
1DR2
formaldehyde
0
28.6228
0.831995
0.1211222
156­
2DR2
formaldehyde
0
39.69079318
0.905533725
0.128615158
1
1
156­
1DR2
methanol
0
13.93286
0.437496
0.06483169
156­
2DR2
methanol
0
6.240498153
0.154039528
0.022075515
3
3
156­
1DR2
phenol
2
0.325332
0.029131
0.00417624
156­
2DR2
phenol
2
2.204286224
0.140484013
0.019465307
5
5
156­
1DR2
propionaldehyde
1
0.444226
0.024437
0.00345657
156­
2DR2
propionaldehyde
2
0.269174036
0.011915715
0.001705231
2
2
156­
1DR2
THC
as
carbon
NA
156­
2DR2
THC
as
carbon
0
681.7146792
6.892782535
1.003151632
NA
NA
Shaded
rows
indicate
that
one
or
both
of
the
units
had
all
non­
detect
measurements
for
the
pollutant.
Therefore,
a
comparison
between
the
two
units
could
not
be
made.

MDF
Mill
132,
Core
Primary
Tube
Dryer,
Cyclone
No.
1
Exhaust
Mill
132,
Core
Primary
Tube
Dryer,
Cyclone
No.
2
Exhaust
Difference
is
a
factor
of...

Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
lb/
hr
EF
132­
3DT2
acetaldehyde
1
0.6901488
0.20420389
0.01318659
132­
4DT2
acetaldehyde
3
0.405977268
0.123873621
0.00799863
132­
3DT2
acrolein
3
0.2865889
0.10814606
0.00698264
132­
4DT2
acrolein
3
0.282530507
0.109713022
0.007084261
1
1
132­
3DT2
benzene
3
0.0810327
0.04259064
0.00275002
132­
4DT2
benzene
3
0.073584126
0.039820816
0.002571239
1
1
132­
3DT2
HCHO
0
67.497084
13.605031
0.87874812
132­
4DT2
HCHO
0
69.03227911
14.39266599
0.928902276
1
1
132­
3DT2
methanol
0
16.810945
3.61984076
0.2337382
132­
4DT2
methanol
0
19.85027718
4.398330743
0.283980461
1
1
132­
3DT2
phenol
2
0.3765141
0.23862014
0.01540593
132­
4DT2
phenol
3
0.343261366
0.223766707
0.01444881
132­
3DT2
propionaldehyde
3
0.3125076
0.12217724
0.00788858
132­
4DT2
propionaldehyde
3
0.308876653
0.124265059
0.0080239
1
1
132­
3DT2
THC
as
Carbon
0
554.36610
44.7336775
2.88857857
132­
4DT2
THC
as
Carbon
0
551.631776
45.85477023
2.960983019
1
1
Mill
132,
Face
Primary
Tube
Dryer,
Cyclone
No.
1
Exhaust
Mill
132,
Face
Primary
Tube
Dryer,
Cyclone
No.
2
Exhaust
Difference
is
a
factor
of...

Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
ODT
lb/
hr
EF
132­
1DT2
acetaldehyde
0
0.6218759
0.20244813
0.01300321
132­
2DT2
acetaldehyde
1
0.455371432
0.144821482
0.009289757
1
1
132­
1DT2
acrolein
3
0.2805112
0.11527821
0.00736218
132­
2DT2
acrolein
3
0.285060456
0.115723838
0.007385353
1
1
132­
1DT2
benzene
3
0.0784615
0.0451317
0.00288426
132­
2DT2
benzene
3
0.075501674
0.042656442
0.00272596
1
1
132­
1DT2
HCHO
0
51.674414
11.3204262
0.72010307
132­
2DT2
HCHO
0
53.9323635
11.69498515
0.742915164
1
1
132­
1DT2
methanol
0
12.950132
3.04499093
0.1949183
132­
2DT2
methanol
0
11.88362891
2.75839531
0.175613018
1
1
132­
1DT2
phenol
3
0.3392376
0.2339648
0.01494136
132­
2DT2
phenol
1
0.367392989
0.250827118
0.015976969
132­
1DT2
propionaldehyde
3
0.3059878
0.13025985
0.0083188
132­
2DT2
propionaldehyde
3
0.31148382
0.131011819
0.008360668
1
1
132­
1DT2
THC
as
Carbon
0
555.17772
49.0744696
3.13485248
132­
2DT2
THC
as
Carbon
0
565.4347952
49.14980447
3.133594959
1
1
Shaded
rows
indicate
that
one
or
both
of
the
units
had
all
non­
detect
measurements
for
the
pollutant.
Therefore,
a
comparison
between
the
two
units
could
not
be
made.

LVL
Mill
411,
LVL
Line,
LVL
Hot
Press
No.
1
Mill
411,
LVL
Line,
LVL
Hot
Press
No.
2
Difference
is
a
factor
of...

Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MCF
Unit
Code
Pollutant
No.

ND
Avg,
ppm
Avg,
lb/
hr
Avg,
lb/
MCF
lb/
hr
EF
411­
1PB1
acetaldehyde
3
3.8E­
01
0.15028807
1.11324493
411­
2PB1
acetaldehyde
3
4.1E­
01
0.137131383
1.015788024
1
1
411­
1PB1
acrolein
3
2.7E­
01
0.13419039
0.99400292
411­
2PB1
acrolein
3
2.9E­
01
0.122281785
0.905790997
1
1
411­
1PB1
benzene
3
7.6E­
02
0.05237325
0.38795002
411­
2PB1
benzene
3
7.9E­
02
0.047183691
0.349508821
1
1
411­
1PB1
HCHO
3
1.2E­
01
0.03312057
0.24533756
411­
2PB1
HCHO
2
1.5E­
01
0.034446123
0.255156466
411­
1PB1
methanol
0
1.5E+
00
0.42582331
3.15424673
411­
2PB1
methanol
0
1.9E+
00
0.47469556
3.516263404
1
1
411­
1PB1
phenol
3
3.3E­
01
0.27240528
2.01781687
411­
2PB1
phenol
3
3.5E­
01
0.248420623
1.840152765
1
1
411­
1PB1
propionaldehyde
3
2.9E­
01
0.15164512
1.12329718
411­
2PB1
propionaldehyde
3
3.1E­
01
0.138238298
1.02398739
1
1
411­
1PB1
THC
as
Carbon
0
1.4E+
01
1.5070702
11.1634829
411­
2PB1
THC
as
Carbon
0
2.1E+
01
1.949153907
14.43817709
1
1
ATTACHMENT
4
Available
Appendix
B
HAP
Emission
Factors
for
Process
Unit
Groups
Sort
EF
for
App
B
amendment.
xls
Acetaldehyde
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
FB,
atmospheric
refiner
and
dump
chest,
softwood
Acetaldehyde
1
1
3
0
NONE
2.7E­
03
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
Acetaldehyde
2
2
6
6
NONE
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
blender
HB
log
chipper,
hardwood
Acetaldehyde
1
1
2
2
NONE
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;
process
rate
=
finished
board
production)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;
process
rate
=

finished
board
production)
Acetaldehyde
1
1
3
2
NONE
8.1E­
04
lb/
MSF
3/
8
chipper
I­
Joist
curing
chamber
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
Acetaldehyde
1
1
6
5
NONE
2.9E­
01
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
Acetaldehyde
1
1
3
0
NONE
1.5E­
02
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
Acetaldehyde
2
1
18
8
NONE
1.4E­
03
4.4E­
03
2.9E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
Acetaldehyde
1
1
9
6
NONE
9.7E­
04
lb/
MSF
1/
2
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
Acetaldehyde
1
1
6
0
NONE
5.3E­
02
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­
12%

asphalt
binder
Acetaldehyde
2
1
12
11
NONE
5.0E­
03
5.5E­
03
5.2E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
(
fugitive)

FB,
former,
wet,
6­
12%
asphalt
Acetaldehyde
1
1
9
5
NONE
7.5E­
03
lb/
MSF
1/
2
former
HB
former,
wet,
PF
resin
Acetaldehyde
3
1
9
0
NONE
4.4E­
03
6.7E­
03
5.8E­
03
lb/
ODT
former
MDF
former
with
blowline
blend,
UF
resin
Acetaldehyde
2
2
6
6
NONE
BDL
lb/
ODT
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Acetaldehyde
2
1
6
6
NONE
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
Acetaldehyde
6
8
18
0
NONE
5.2E­
03
1.2E­
01
5.9E­
02
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
Acetaldehyde
4
2
15
0
NONE
7.0E­
02
8.1E­
02
7.5E­
02
lb/
ODT
green
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
Acetaldehyde
6
4
21
4
NONE
3.5E­
03
3.2E­
02
1.3E­
02
lb/
ODT
dry
rotary
dryer
HB,
tempering
oven,
direct
natural
gas­
fired
Acetaldehyde
1
1
3
0
NONE
7.6E­
02
lb/
MSF
1/
8
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
Acetaldehyde
7
4
21
12
NONE
1.7E­
02
5.8E­
02
3.2E­
02
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
Acetaldehyde
4
6
12
12
NONE
BDL
lb/
MSF
3/
8
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
Acetaldehyde
1
1
6
0
NONE
5.2E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
Acetaldehyde
7
4
36
7
NONE
2.4E­
03
9.4E­
03
4.3E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
Acetaldehyde
1
1
3
0
NONE
1.8E­
03
lb/
MSF
1/
8
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
Acetaldehyde
1
1
3
0
NONE
4.7E­
03
lb/
MSF
3/
8
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
Acetaldehyde
1
1
6
0
NONE
1.1E­
01
lb/
MSF
1/
2
press
predryer
PB
veneer
press,
UF
resin
Acetaldehyde
1
1
3
0
NONE
9.9E­
05
lb/
MSF
3/
4
press­
other
HB
pressurized
digester/
refiner,
hardwood
Acetaldehyde
1
1
3
0
NONE
3.0E­
02
lb/
ODT
pressurized
refiner
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Acetaldehyde
8/
24/
2004
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
Acetaldehyde
1
1
3
0
NONE
9.6E­
03
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
Acetaldehyde
2
4
6
0
NONE
8.0E­
02
1.3E­
01
1.1E­
01
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
Acetaldehyde
2
1
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
hardwood
Acetaldehyde
2
2
6
0
NONE
7.1E­
03
1.9E­
02
1.3E­
02
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
Acetaldehyde
6
5
24
8
NONE
7.0E­
03
4.8E­
02
2.0E­
02
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
Acetaldehyde
2
1
4
4
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
Acetaldehyde
1
1
2
0
NONE
1.0E­
03
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
Acetaldehyde
3
3
9
4
NONE
1.3E­
03
5.7E­
03
3.6E­
03
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
Hardboard,
press,
linseed
oil
binder
Acetaldehyde
1
1
3
0
NONE
3.6E­
02
lb/
MSF
1/
8
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
Acetaldehyde
4
2
21
10
NONE
7.0E­
03
2.3E­
02
1.6E­
02
lb/
MSF
1/
8
reconstituted
wood
product
press
MDF,
press,
UF
resin
Acetaldehyde
4
4
23
20
NONE
5.1E­
03
2.8E­
02
1.4E­
02
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
press,
PF
resin
Acetaldehyde
1
1
3
1
NONE
5.2E­
03
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
Acetaldehyde
4
4
12
5
NONE
6.5E­
03
1.8E­
02
1.0E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
PB,
press,
UF
resin
Acetaldehyde
8
7
35
17
NONE
2.5E­
03
3.4E­
02
1.1E­
02
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
rotary,
direct
wood­
fired,
hardwood
Acetaldehyde
1
2
3
0
NONE
6.2E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,

40­
60%
hardwood)
Acetaldehyde
2
4
6
0
NONE
9.0E­
02
1.3E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
Acetaldehyde
6
10
18
0
NONE
5.8E­
02
1.4E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
MDF
sander
Acetaldehyde
3
3
12
12
NONE
BDL
lb/
MSF
sander
PB
sander
Acetaldehyde
1
1
2
2
NONE
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
Acetaldehyde
1
1
3
1
NONE
2.8E­
03
lb/
MSF
3/
8
sander
LVL
I­
Beam
Saw
Acetaldehyde
1
1
2
2
NONE
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]

material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
Acetaldehyde
1
1
3
2
NONE
9.2E­
04
lb/
MSF
3/
8
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
Acetaldehyde
2
2
6
6
NONE
BDL
lb/
ODT
secondary
tube
dryer
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
Acetaldehyde
2
2
6
5
NONE
1.4E­
03
5.6E­
03
3.5E­
03
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
Acetaldehyde
6
9
18
7
NONE
8.3E­
04
1.2E­
02
4.2E­
03
lb/
MSF
3/
8
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
Acetaldehyde
2
2
6
0
NONE
3.8E­
02
8.5E­
02
6.2E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
Acetaldehyde
19
20
63
7
NONE
1.3E­
03
5.8E­
02
1.7E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
Acetaldehyde
1
1
9
8
NONE
3.4E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
Acetaldehyde
8
8
44
41
NONE
1.7E­
03
1.2E­
02
4.6E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
Acetaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
Acetaldehyde
2
2
6
3
NONE
1.4E­
04
2.9E­
03
1.5E­
03
lb/
MSF
3/
8
veneer
redryer
(
RF)
Sort
EF
for
App
B
amendment.
xls
Acrolein
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
FB,
atmospheric
refiner
and
dump
chest,
softwood
Acrolein
1
1
3
0
NONE
3.0E­
04
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
Acrolein
2
2
6
6
NONE
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
Acrolein
1
1
3
3
NONE
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
blender
HB
log
chipper,
hardwood
Acrolein
1
1
2
2
NONE
BDL
lb/
ODT
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;
process
rate
=

finished
board
production)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;
process
rate
=

finished
board
production)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
LSL,
press,
MDI
resin
Acrolein
1
1
3
3
NONE
BDL
lb/
1000
ft3
engineered
wood
products
press
I­
Joist
curing
chamber
Acrolein
1
1
3
3
NONE
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
Acrolein
3
3
12
12
NONE
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
Acrolein
1
1
3
3
NONE
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
Acrolein
1
1
9
6
NONE
5.7E­
04
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
Acrolein
2
1
18
10
NONE
8.2E­
04
1.6E­
03
1.2E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
Acrolein
1
1
6
0
NONE
3.7E­
02
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­
12%
asphalt
binder
Acrolein
2
1
12
12
NONE
BDL
lb/
MSF
1/
2
fiberboard
mat
dryer
(
fugitive)

MDF
former
with
blowline
blend,
UF
resin
Acrolein
2
2
6
6
NONE
BDL
lb/
ODT
former
HB
former,
wet,
PF
resin
Acrolein
3
1
9
9
NONE
BDL
lb/
ODT
former
FB,
former,
wet,
6­
12%
asphalt
Acrolein
1
1
9
9
NONE
BDL
lb/
MSF
1/
2
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
Acrolein
1
1
3
3
NONE
BDL
lb/
ODT
former,
blender
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
Acrolein
2
1
6
0
NONE
2.2E­
02
2.4E­
02
2.3E­
02
lb/
ODT
green
rotary
dryer
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Acrolein
2
1
6
6
NONE
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
Acrolein
6
8
18
7
NONE
8.1E­
04
2.3E­
02
1.1E­
02
lb/
ODT
green
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
Acrolein
8
6
27
8
NONE
4.1E­
04
7.7E­
03
3.5E­
03
lb/
ODT
dry
rotary
dryer
HB,
tempering
oven,
direct
natural
gas­
fired
Acrolein
1
1
3
0
NONE
2.4E­
02
lb/
MSF
1/
8
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
Acrolein
7
4
21
21
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
Acrolein
4
6
12
12
NONE
BDL
lb/
MSF
3/
8
hardwood
plywood
press
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
Acrolein
7
4
36
36
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
Acrolein
1
1
3
0
NONE
8.7E­
03
lb/
MSF
1/
8
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
Acrolein
1
1
6
0
NONE
2.9E­
02
lb/
MSF
1/
2
press
predryer
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Acrolein
8/
24/
2004
HB
pressurized
digester/
refiner,
hardwood
Acrolein
1
1
3
0
NONE
2.4E­
03
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
Acrolein
1
1
3
0
NONE
4.1E­
03
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
Acrolein
2
1
4
4
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
Acrolein
2
1
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
Acrolein
2
4
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
Acrolein
5
4
21
21
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
Acrolein
1
1
2
0
NONE
2.2E­
04
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
Acrolein
1
1
3
0
NONE
3.6E­
04
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
Hardboard,
press,
linseed
oil
binder
Acrolein
1
1
3
0
NONE
5.7E­
03
lb/
MSF
1/
8
reconstituted
wood
product
press
MDF,
press,
UF
resin
Acrolein
1
1
2
0
NONE
1.2E­
03
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
press,
PF
resin
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
Acrolein
4
4
12
12
NONE
BDL
lb/
MSF
3/
8
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
Acrolein
4
2
21
21
NONE
BDL
lb/
MSF
1/
8
reconstituted
wood
product
press
PB,
press,
UF
resin
Acrolein
7
6
32
24
NONE
1.3E­
03
8.7E­
03
4.2E­
03
lb/
MSF
3/
4
reconstituted
wood
product
press
LSL,
rotary,
direct
wood­
fired,
hardwood
Acrolein
2
2
6
0
NONE
1.2E­
03
1.1E­
02
6.2E­
03
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
hardwood
Acrolein
1
2
3
0
NONE
2.0E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­

60%
hardwood)
Acrolein
2
4
6
0
NONE
3.2E­
02
3.4E­
02
3.3E­
02
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
Acrolein
6
10
18
1
NONE
2.8E­
02
1.1E­
01
7.2E­
02
lb/
ODT
rotary
strand
dryer
PB
sander
Acrolein
1
1
2
2
NONE
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
sander
MDF
sander
Acrolein
3
3
12
12
NONE
BDL
lb/
MSF
sander
LVL
I­
Beam
Saw
Acrolein
1
1
2
2
NONE
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]

material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
saw
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
Acrolein
2
2
6
6
NONE
BDL
lb/
ODT
secondary
tube
dryer
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
Acrolein
2
2
6
6
NONE
BDL
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
Acrolein
6
9
18
18
NONE
BDL
lb/
MSF
3/
8
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
Acrolein
2
2
6
0
NONE
6.4E­
03
1.2E­
02
9.0E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
Acrolein
17
20
54
49
NONE
4.6E­
04
2.2E­
03
1.3E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
Acrolein
1
1
9
9
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
Acrolein
8
8
44
44
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
Acrolein
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
Acrolein
2
2
6
6
NONE
BDL
lb/
MSF
3/
8
veneer
redryer
(
RF)
Sort
EF
for
App
B
amendment.
xls
Formaldehyde
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
PB
steam
muffler
vent
(
vacuum
pump)
Formaldehyde
1
1
3
0
NONE
1.9E+
00
lb/
MSF
3/
4
???

FB,
atmospheric
refiner
and
dump
chest,
softwood
Formaldehyde
1
1
3
0
NONE
6.1E­
04
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
Formaldehyde
2
2
6
6
NONE
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
Formaldehyde
1
1
3
0
NONE
1.0E­
02
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
Formaldehyde
1
1
3
0
NONE
3.6E­
03
lb/
MSF
3/
8
blender
HB
log
chipper,
hardwood
Formaldehyde
1
1
2
2
NONE
BDL
lb/
ODT
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;
process
rate
=

finished
board
production)
Formaldehyde
1
1
3
2
NONE
3.4E­
04
lb/
MSF
3/
8
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;
process
rate
=
finished
board
production)
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
OSB,
conveyer,
indirect
heated,
hardwood
(
heated
zones)
Formaldehyde
1
1
3
0
NONE
2.4E­
03
lb/
ODT
conveyor
strand
dryer
LSL,
conveyer,
indirect
heated,
hardwood
Formaldehyde
2
4
6
6
NONE
BDL
lb/
ODT
conveyor
strand
dryer
PB,
rotary,
indirect
heated
with
auxiliary
natural
gas,
softwood
Formaldehyde
4
4
12
0
NONE
3.2E­
02
6.4E­
02
4.7E­
02
lb/
ODT
dry
rotary
dryer
LSL,
press,
MDI
resin
Formaldehyde
1
1
3
0
NONE
2.9E­
02
lb/
1000
ft3
engineered
wood
products
press
I­
Joist
curing
chamber
Formaldehyde
1
1
3
0
NONE
1.8E­
04
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
Formaldehyde
5
4
18
9
NONE
9.4E­
02
7.9E­
01
2.9E­
01
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
Formaldehyde
1
1
3
0
NONE
2.6E­
03
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
Formaldehyde
1
1
9
0
NONE
9.3E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
Formaldehyde
2
1
18
0
NONE
9.3E­
03
1.7E­
02
1.3E­
02
lb/
MSF
1/
2
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
Formaldehyde
1
1
6
0
NONE
5.9E­
02
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­
12%

asphalt
binder
Formaldehyde
2
1
12
1
NONE
7.8E­
03
3.1E­
02
1.9E­
02
lb/
MSF
1/
2
fiberboard
mat
dryer
(
fugitive)

MDF
former
with
blowline
blend,
UF
resin
Formaldehyde
2
2
6
3
NONE
1.3E­
03
8.9E­
03
5.1E­
03
lb/
ODT
former
HB
former,
wet,
PF
resin
Formaldehyde
3
1
9
3
NONE
9.2E­
05
3.9E­
04
2.6E­
04
lb/
ODT
former
FB,
former,
wet,
6­
12%
asphalt
Formaldehyde
1
1
9
5
NONE
3.6E­
03
lb/
MSF
1/
2
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
Formaldehyde
1
1
3
0
NONE
6.0E­
02
lb/
ODT
former,
blender
PB,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Formaldehyde
1
1
3
0
NONE
4.2E­
03
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
Formaldehyde
8
5
27
0
NONE
8.6E­
03
2.7E­
01
1.4E­
01
lb/
ODT
green
rotary
dryer
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Formaldehyde
2
1
6
1
NONE
4.4E­
03
1.1E­
02
7.6E­
03
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
Formaldehyde
6
8
18
1
NONE
3.8E­
03
2.0E­
01
9.6E­
02
lb/
ODT
green
rotary
dryer
PB,
rotary,
direct
natural
gas­
fired,
softwood
Formaldehyde
1
1
3
0
NONE
8.6E­
03
lb/
ODT
dry
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
Formaldehyde
10
11
33
2
NONE
2.4E­
03
1.2E­
01
2.5E­
02
lb/
ODT
dry
rotary
dryer
PB,
rotary,
direct
natural
gas­
fired,
hardwood
Formaldehyde
1
1
3
0
NONE
2.8E­
02
lb/
ODT
dry
rotary
dryer
HB,
tempering
oven,
direct
natural
gas­
fired
Formaldehyde
1
1
3
0
NONE
4.3E­
03
lb/
MSF
1/
8
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
Formaldehyde
7
4
21
19
NONE
2.7E­
03
1.3E­
02
6.5E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
Formaldehyde
4
6
12
3
NONE
1.3E­
03
8.8E­
03
4.7E­
03
lb/
MSF
3/
8
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
Formaldehyde
1
1
6
2
NONE
2.5E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
Formaldehyde
7
4
36
8
NONE
4.2E­
04
2.1E­
03
1.1E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Formaldehyde
8/
24/
2004
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
Formaldehyde
1
1
3
2
NONE
3.0E­
04
lb/
MSF
3/
8
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
Formaldehyde
1
1
3
0
NONE
1.0E­
03
lb/
MSF
1/
8
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
Formaldehyde
1
1
6
0
NONE
6.5E­
03
lb/
MSF
1/
2
press
predryer
PB
veneer
press,
UF
resin
Formaldehyde
1
1
3
0
NONE
6.2E­
03
lb/
MSF
3/
4
press­
other
HB
pressurized
digester/
refiner,
hardwood
Formaldehyde
1
1
3
0
NONE
4.5E­
03
lb/
ODT
pressurized
refiner
MDF,
tube,
direct
wood­
fired,
blowline
blend,
UF,
softwood
Formaldehyde
4
4
11
0
NONE
4.2E­
01
1.3E+
00
8.6E­
01
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
Formaldehyde
12
8
42
0
NONE
8.2E­
02
1.8E+
00
6.6E­
01
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
hardwood
Formaldehyde
2
2
6
0
NONE
2.5E­
01
2.6E­
01
2.6E­
01
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
Formaldehyde
1
1
3
0
NONE
1.1E+
00
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
Formaldehyde
2
4
6
0
NONE
2.5E­
01
2.6E­
01
2.6E­
01
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
Formaldehyde
2
1
4
1
NONE
7.5E­
02
9.4E­
02
8.5E­
02
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
Formaldehyde
2
1
6
4
NONE
3.2E­
03
1.4E­
02
8.5E­
03
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
Formaldehyde
3
3
8
1
NONE
2.4E­
03
1.1E­
01
4.2E­
02
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
Formaldehyde
4
4
12
3
NONE
1.2E­
03
2.6E­
02
1.5E­
02
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
Hardboard,
press,
PF
resin
Formaldehyde
4
2
21
0
NONE
1.0E­
02
2.6E­
02
1.4E­
02
lb/
MSF
1/
8
reconstituted
wood
product
press
Hardboard,
press,
linseed
oil
binder
Formaldehyde
1
1
3
0
NONE
1.8E­
02
lb/
MSF
1/
8
reconstituted
wood
product
press
MDF,
press,
UF
resin
Formaldehyde
11
11
43
0
NONE
2.7E­
02
1.1E+
00
4.8E­
01
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
press,
MDI
resin
Formaldehyde
2
2
6
0
NONE
2.8E­
02
1.0E­
01
6.4E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF
resin
Formaldehyde
2
2
6
0
NONE
1.5E­
02
7.3E­
02
4.4E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
Formaldehyde
22
15
66
0
NONE
7.5E­
05
1.5E­
01
5.6E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
dry
PF
resin
Formaldehyde
1
1
3
0
NONE
1.4E­
01
lb/
MSF
3/
8
reconstituted
wood
product
press
PB,
press,
UF
resin
Formaldehyde
18
12
136
1
NONE
6.9E­
03
6.4E­
01
2.3E­
01
lb/
MSF
3/
4
reconstituted
wood
product
press
LSL,
rotary,
direct
wood­
fired,
hardwood
Formaldehyde
2
2
6
0
NONE
5.9E­
02
1.3E­
01
9.6E­
02
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
Formaldehyde
30
26
89
0
NONE
3.5E­
03
5.5E­
01
1.3E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
hardwood
Formaldehyde
22
15
66
0
NONE
1.3E­
04
5.7E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,

40­
60%
hardwood)
Formaldehyde
2
4
6
0
NONE
2.7E­
01
4.1E­
01
3.4E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
natural
gas­
fired,
hardwood
Formaldehyde
1
2
3
0
NONE
3.6E­
02
lb/
ODT
rotary
strand
dryer
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
Formaldehyde
1
1
3
0
NONE
1.8E­
03
lb/
MSF
3/
8
sander
PB
sander
Formaldehyde
1
1
2
2
NONE
BDL
lb/
MSF
sander
MDF
sander
Formaldehyde
3
3
12
4
NONE
6.2E­
04
4.2E­
03
2.7E­
03
lb/
MSF
sander
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
Formaldehyde
1
1
3
1
NONE
3.4E­
04
lb/
MSF
3/
8
saw
LVL
I­
Beam
Saw
Formaldehyde
1
1
2
2
NONE
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]

material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
reclaim
saw
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
Formaldehyde
2
2
6
2
NONE
7.9E­
03
3.4E­
02
2.1E­
02
lb/
ODT
secondary
tube
dryer
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
Formaldehyde
2
2
6
3
NONE
5.3E­
03
2.8E­
02
1.7E­
02
lb/
ODT
secondary
tube
dryer
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Formaldehyde
8/
24/
2004
Softwood
Plywood,
press,
PF
resin
Formaldehyde
8
11
23
8
NONE
9.0E­
05
5.4E­
03
1.9E­
03
lb/
MSF
3/
8
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
Formaldehyde
4
3
12
0
NONE
2.7E­
02
8.7E­
02
6.4E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
wood­
fired,
softwood
(
heated
zones)
Formaldehyde
4
2
8
0
NONE
2.1E­
02
8.6E­
02
4.5E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
Formaldehyde
19
20
63
1
NONE
2.6E­
03
9.9E­
02
1.4E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
Formaldehyde
1
1
9
8
NONE
1.5E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
Formaldehyde
8
8
44
39
NONE
4.6E­
04
2.8E­
03
1.3E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
Formaldehyde
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
Formaldehyde
2
2
6
3
NONE
3.8E­
05
6.5E­
04
3.5E­
04
lb/
MSF
3/
8
veneer
redryer
(
RF)
Sort
EF
for
App
B
amendment.
xls
Phenol
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
FB,
atmospheric
refiner
and
dump
chest,
softwood
Phenol
1
1
3
3
NONE
BDL
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
Phenol
1
1
3
2
NONE
4.5E­
03
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
Phenol
1
1
3
3
NONE
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
blender
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;
process
rate
=

finished
board
production)
Phenol
1
1
3
1
NONE
1.9E­
03
lb/
MSF
3/
8
chipper
HB
log
chipper,
hardwood
Phenol
1
1
2
2
NONE
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;
process
rate
=

finished
board
production)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
I­
Joist
curing
chamber
Phenol
1
1
3
3
NONE
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
Phenol
3
3
12
12
NONE
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
Phenol
1
1
3
3
NONE
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
Phenol
1
1
9
8
NONE
1.2E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
Phenol
2
1
18
14
NONE
1.4E­
03
1.4E­
03
1.4E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
Phenol
1
1
6
0
NONE
1.9E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­
12%

asphalt
binder
Phenol
2
1
12
12
NONE
BDL
lb/
MSF
1/
2
fiberboard
mat
dryer
(
fugitive)

HB
former,
wet,
PF
resin
Phenol
3
1
9
0
NONE
6.9E­
04
7.5E­
04
7.1E­
04
lb/
ODT
former
MDF
former
with
blowline
blend,
UF
resin
Phenol
2
2
6
6
NONE
BDL
lb/
ODT
former
FB,
former,
wet,
6­
12%
asphalt
Phenol
1
1
9
9
NONE
BDL
lb/
MSF
1/
2
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
Phenol
1
1
3
3
NONE
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Phenol
1
1
6
6
NONE
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
Phenol
2
1
9
6
NONE
8.7E­
03
4.7E­
02
2.8E­
02
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
Phenol
5
7
15
11
NONE
2.1E­
03
1.8E­
02
7.9E­
03
lb/
ODT
green
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
Phenol
6
5
21
17
NONE
2.4E­
03
1.2E­
02
6.6E­
03
lb/
ODT
dry
rotary
dryer
HB,
tempering
oven,
direct
natural
gas­
fired
Phenol
1
1
3
0
NONE
1.9E­
03
lb/
MSF
1/
8
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
Phenol
7
4
21
21
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
Phenol
4
6
12
6
NONE
7.9E­
03
1.6E­
02
1.1E­
02
lb/
MSF
3/
8
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
Phenol
1
1
6
6
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
Phenol
7
4
36
34
NONE
1.3E­
03
5.3E­
03
3.0E­
03
lb/
MSF
3/
8
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
Phenol
1
1
3
0
NONE
5.7E­
04
lb/
MSF
1/
8
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
log
vat
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Phenol
8/
24/
2004
HB
pressurized
digester/
refiner,
hardwood
Phenol
1
1
3
0
NONE
1.2E­
03
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
Phenol
1
1
3
0
NONE
5.6E­
02
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
Phenol
2
4
6
0
NONE
6.6E­
02
1.0E­
01
8.3E­
02
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
Phenol
2
1
4
4
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
Phenol
2
1
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
Phenol
5
4
21
15
NONE
8.2E­
03
4.5E­
02
2.3E­
02
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
Phenol
2
2
6
5
NONE
4.1E­
03
9.1E­
03
6.6E­
03
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
OSB,
press,
PF
resin
Phenol
2
2
6
0
NONE
7.1E­
02
7.3E­
02
7.2E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
Hardboard,
press,
linseed
oil
binder
Phenol
1
1
3
2
NONE
3.9E­
03
lb/
MSF
1/
8
reconstituted
wood
product
press
MDF,
press,
UF
resin
Phenol
2
2
9
7
NONE
2.4E­
02
3.1E­
02
2.7E­
02
lb/
MSF
3/
4
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
Phenol
4
2
21
11
NONE
5.6E­
03
1.5E­
02
1.0E­
02
lb/
MSF
1/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
Phenol
10
7
30
12
NONE
5.8E­
06
2.8E­
02
1.5E­
02
lb/
MSF
3/
8
reconstituted
wood
product
press
PB,
press,
UF
resin
Phenol
5
4
26
18
NONE
6.4E­
03
2.4E­
02
1.1E­
02
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
rotary,
direct
wood­
fired,
hardwood
Phenol
1
2
3
0
NONE
2.8E­
02
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
Phenol
6
10
18
10
NONE
7.8E­
03
2.6E­
02
1.5E­
02
lb/
ODT
rotary
strand
dryer
PB
sander
Phenol
1
1
2
1
NONE
1.5E­
02
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
sander
MDF
sander
Phenol
3
3
12
9
NONE
4.2E­
03
1.1E­
02
6.9E­
03
lb/
MSF
sander
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]

material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
Phenol
1
1
3
1
NONE
1.9E­
01
lb/
MSF
reclaim
saw
LVL
I­
Beam
Saw
Phenol
1
1
2
2
NONE
BDL
lb/
MLF
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
Phenol
2
2
6
4
NONE
2.5E­
02
5.3E­
02
3.9E­
02
lb/
ODT
secondary
tube
dryer
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
Phenol
2
2
6
6
NONE
BDL
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
Phenol
4
7
12
11
NONE
7.6E­
04
2.2E­
03
1.4E­
03
lb/
MSF
3/
8
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
Phenol
2
2
6
2
NONE
4.1E­
03
7.8E­
03
6.0E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
Phenol
19
20
63
44
NONE
1.1E­
03
9.3E­
03
3.4E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
Phenol
1
1
9
5
NONE
1.0E­
02
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
Phenol
7
7
38
37
NONE
3.1E­
03
1.1E­
02
6.2E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
Phenol
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
Phenol
2
2
6
6
NONE
BDL
lb/
MSF
3/
8
veneer
redryer
(
RF)
Sort
EF
for
App
B
amendment.
xls
Benzene
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
FB,
atmospheric
refiner
and
dump
chest,
softwood
Benzene
1
1
3
3
NONE
BDL
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
Benzene
2
2
6
6
NONE
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
Benzene
1
1
3
3
NONE
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
blender
HB
log
chipper,
hardwood
Benzene
1
1
2
2
NONE
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;
process
rate
=

finished
board
production)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;
process
rate
=

finished
board
production)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
chipper
I­
Joist
curing
chamber
Benzene
1
1
3
3
NONE
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
Benzene
3
3
12
12
NONE
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
Benzene
1
1
3
3
NONE
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
Benzene
2
1
18
18
NONE
BDL
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
Benzene
1
1
9
9
NONE
BDL
lb/
MSF
1/
2
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
Benzene
1
1
6
0
NONE
2.1E­
03
lb/
MSF
1/
2
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­
12%

asphalt
binder
Benzene
2
1
12
12
NONE
BDL
lb/
MSF
1/
2
fiberboard
mat
dryer
(
fugitive)

FB,
former,
wet,
6­
12%
asphalt
Benzene
1
1
9
9
NONE
BDL
lb/
MSF
1/
2
former
HB
former,
wet,
PF
resin
Benzene
3
1
9
9
NONE
BDL
lb/
ODT
former
MDF
former
with
blowline
blend,
UF
resin
Benzene
2
2
6
6
NONE
BDL
lb/
ODT
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
Benzene
1
1
3
3
NONE
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
Benzene
2
1
6
6
NONE
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
Benzene
5
7
15
5
NONE
3.9E­
04
7.5E­
03
4.7E­
03
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
Benzene
2
1
9
0
NONE
7.3E­
03
7.9E­
03
7.6E­
03
lb/
ODT
green
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
Benzene
8
6
27
12
NONE
1.1E­
04
2.8E­
03
9.9E­
04
lb/
ODT
dry
rotary
dryer
HB,
tempering
oven,
direct
natural
gas­
fired
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
1/
8
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
Benzene
7
4
21
21
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
Benzene
4
6
12
12
NONE
BDL
lb/
MSF
3/
8
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
Benzene
1
1
6
6
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
Benzene
7
4
36
36
NONE
BDL
lb/
MSF
3/
8
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
Benzene
1
1
3
1
NONE
6.2E­
06
lb/
MSF
1/
8
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
log
vat
HB
pressurized
digester/
refiner,
hardwood
Benzene
1
1
3
3
NONE
BDL
lb/
ODT
pressurized
refiner
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
Sort
EF
for
App
B
amendment.
xls
Benzene
8/
24/
2004
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
Benzene
1
1
3
0
NONE
8.8E­
05
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
Benzene
2
4
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
Benzene
2
1
6
6
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
Benzene
5
4
21
21
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
Benzene
2
1
4
4
NONE
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
Benzene
2
2
6
6
NONE
BDL
lb/
MSF
3/
4
reconstituted
wood
product
board
cooler
Hardboard,
press,
linseed
oil
binder
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
1/
8
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
Benzene
4
2
21
21
NONE
BDL
lb/
MSF
1/
8
reconstituted
wood
product
press
MDF,
press,
UF
resin
Benzene
3
3
21
21
NONE
BDL
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
press,
PF
resin
benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
Benzene
4
4
12
12
NONE
BDL
lb/
MSF
3/
8
reconstituted
wood
product
press
PB,
press,
UF
resin
Benzene
5
4
26
25
NONE
8.6E­
04
7.3E­
03
3.0E­
03
lb/
MSF
3/
4
reconstituted
wood
product
press
OSB,
rotary,
direct
wood­
fired,
hardwood
Benzene
2
4
6
0
NONE
1.6E­
03
1.9E­
02
1.0E­
02
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
Benzene
6
10
18
2
NONE
3.7E­
03
9.8E­
03
6.7E­
03
lb/
ODT
rotary
strand
dryer
MDF
sander
Benzene
3
3
12
12
NONE
BDL
lb/
MSF
sander
PB
sander
Benzene
1
1
2
2
NONE
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
sander
LVL
I­
Beam
Saw
Benzene
1
1
2
2
NONE
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]

material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
Benzene
2
2
6
6
NONE
BDL
lb/
ODT
secondary
tube
dryer
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
Benzene
2
2
6
5
NONE
5.1E­
04
9.4E­
04
7.3E­
04
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
Benzene
6
9
18
18
NONE
BDL
lb/
MSF
3/
8
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
Benzene
2
2
6
0
NONE
3.6E­
03
7.8E­
03
5.7E­
03
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
Benzene
19
20
63
61
NONE
1.8E­
04
5.2E­
03
5.9E­
04
lb/
MSF
3/
8
softwood
veneer
dryer
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
Benzene
1
1
9
9
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
Benzene
8
8
44
44
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
Benzene
1
1
3
3
NONE
BDL
lb/
MSF
3/
8
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
Benzene
2
2
6
6
NONE
BDL
lb/
MSF
3/
8
veneer
redryer
(
RF)
Sort
EF
for
App
B
amendment.
xls
MDI
8/
24/
2004
Em.
Fact.
Process
Unit
Description
Pollutant
No.
of
tests
No.
of
process
units
No.
of
runs
No.
of
BDL
runs
APCD
Emission
factor
EF
units
MACT
floor
process
unit
group
Min
Max
Avg
LSL,
press,
MDI
resin
MDI
2
1
9
0
NONE
4.2E­
03
1.8E­
01
9.0E­
02
lb/
1000
ft3
engineered
wood
products
press
OSB,
press,
MDI
resin
MDI
1
1
3
0
NONE
2.1E­
03
lb/
MSF
3/
8
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
MDI
6
3
18
3
NONE
1.8E­
05
5.0E­
03
1.1E­
03
lb/
MSF
3/
8
reconstituted
wood
product
press
ATTACHMENT
5
Demonstration
That
Maximum
Available
Emission
Factor
Does
Not
Exceed
Three
Times
the
Average
Emission
Factor
for
Hard­
to­
test
Process
Units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

Pollutant:
Acetaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
FB,
atmospheric
refiner
and
dump
chest,
softwood
1
1
3
0
2.7E­
03
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
2
2
6
6
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
1
1
3
3
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
1
1
3
3
BDL
lb/
MSF
3/
8"
blender
HB
log
chipper,
hardwood
1
1
2
2
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;

process
rate
=
finished
board
production)
1
1
3
2
8.1E­
04
lb/
MSF
3/
8"
chipper
I­
Joist
curing
chamber
1
1
3
3
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
1
1
6
5
2.9E­
01
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
1
1
3
0
1.5E­
02
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
2
1
18
8
1.4E­
03
4.4E­
03
2.9E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
1.5
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
1
1
9
6
9.7E­
04
lb/
MSF
1/
2"
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
1
1
6
0
5.3E­
02
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­

12%
asphalt
binder
2
1
12
11
5.0E­
03
5.5E­
03
5.2E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
(
fugitive)
1.0
FB,
former,
wet,
6­
12%
asphalt
1
1
9
5
7.5E­
03
lb/
MSF
1/
2"
former
HB
former,
wet,
PF
resin
3
1
9
0
4.4E­
03
6.7E­
03
5.8E­
03
lb/
ODT
former
1.2
MDF
former
with
blowline
blend,
UF
resin
2
2
6
6
BDL
lb/
ODT
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
1
1
3
3
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
2
1
6
6
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­
60%
hardwood)
6
8
18
0
5.2E­
03
1.2E­
01
5.9E­
02
lb/
ODT
green
rotary
dryer
2.1
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
4
2
15
0
7.0E­
02
8.1E­
02
7.5E­
02
lb/
ODT
green
rotary
dryer
1.1
PB,
rotary,
direct
wood­
fired,
softwood
6
4
21
4
3.5E­
03
3.2E­
02
1.3E­
02
lb/
ODT
dry
rotary
dryer
2.4
HB,
tempering
oven,
direct
natural
gas­
fired
1
1
3
0
7.6E­
02
lb/
MSF
1/
8"
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
7
4
21
12
1.7E­
02
5.8E­
02
3.2E­
02
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)
1.8
HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
1
1
3
3
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
4
6
12
12
BDL
lb/
MSF
3/
8"
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
1
1
6
0
5.2E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
7
4
36
7
2.4E­
03
9.4E­
03
4.3E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
2.2
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
saw
Pollutant:
Acetaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

HB,
humidification
kiln,
indirect
heated
1
1
3
0
1.8E­
03
lb/
MSF
1/
8"
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
1
1
3
0
4.7E­
03
lb/
MSF
3/
8"
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
1
1
6
0
1.1E­
01
lb/
MSF
1/
2"
press
predryer
PB
veneer
press,
UF
resin
1
1
3
0
9.9E­
05
lb/
MSF
3/
4"
press­
other
HB
pressurized
digester/
refiner,
hardwood
1
1
3
0
3.0E­
02
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
1
1
3
0
9.6E­
03
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
2
4
6
0
8.0E­
02
1.3E­
01
1.1E­
01
lb/
ODT
primary
tube
dryer
1.3
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,

hardwood
2
1
6
6
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
hardwood
2
2
6
0
7.1E­
03
1.9E­
02
1.3E­
02
lb/
ODT
primary
tube
dryer
1.5
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
6
5
24
8
7.0E­
03
4.8E­
02
2.0E­
02
lb/
ODT
primary
tube
dryer
2.4
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
2
1
4
4
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
1
1
2
0
1.0E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
3
3
9
4
1.3E­
03
5.7E­
03
3.6E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
1.6
Hardboard,
press,
linseed
oil
binder
1
1
3
0
3.6E­
02
lb/
MSF
1/
8"
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
4
2
21
10
7.0E­
03
2.3E­
02
1.6E­
02
lb/
MSF
1/
8"
reconstituted
wood
product
press
1.5
MDF,
press,
UF
resin
4
4
23
20
5.1E­
03
2.8E­
02
1.4E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.0
OSB,
press,
PF
resin
1
1
3
1
5.2E­
03
lb/
MSF
3/
8"
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
4
4
12
5
6.5E­
03
1.8E­
02
1.0E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
1.7
PB,
press,
UF
resin
8
7
35
17
2.5E­
03
3.4E­
02
1.1E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
press
3.1
OSB,
rotary,
direct
wood­
fired,
hardwood
1
2
3
0
6.2E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
2
4
6
0
9.0E­
02
1.3E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
1.2
OSB,
rotary,
direct
wood­
fired,
softwood
6
10
18
0
5.8E­
02
1.4E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
1.2
MDF
sander
3
3
12
12
BDL
lb/
MSF
sander
PB
sander
1
1
2
2
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
1
1
3
1
2.8E­
03
lb/
MSF
3/
8"
sander
LVL
I­
Beam
Saw
1
1
2
2
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]
material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
1
1
3
3
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
1
1
3
2
9.2E­
04
lb/
MSF
3/
8"
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
2
2
6
6
BDL
lb/
ODT
secondary
tube
dryer
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
2
2
6
5
1.4E­
03
5.6E­
03
3.5E­
03
lb/
ODT
secondary
tube
dryer
1.6
Softwood
Plywood,
press,
PF
resin
6
9
18
7
8.3E­
04
1.2E­
02
4.2E­
03
lb/
MSF
3/
8"
softwood
plywood
press
2.8
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
2
2
6
0
3.8E­
02
8.5E­
02
6.2E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
1.4
Pollutant:
Acetaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
19
20
63
7
1.3E­
03
5.8E­
02
1.7E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
3.4
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
1
1
9
8
3.4E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
8
8
44
41
1.7E­
03
1.2E­
02
4.6E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)
2.6
SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
1
1
3
3
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
2
2
6
3
1.4E­
04
2.9E­
03
1.5E­
03
lb/
MSF
3/
8"
veneer
redryer
(
RF)
1.9
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

Pollutant:
Acrolein
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
FB,
atmospheric
refiner
and
dump
chest,
softwood
1
1
3
0
3.0E­
04
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
2
2
6
6
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
1
1
3
3
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
1
1
3
3
BDL
lb/
MSF
3/
8"
blender
HB
log
chipper,
hardwood
1
1
2
2
BDL
lb/
ODT
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
LSL,
press,
MDI
resin
1
1
3
3
BDL
lb/
1000
ft
3
engineered
wood
products
press
I­
Joist
curing
chamber
1
1
3
3
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
3
3
12
12
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
1
1
3
3
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
1
1
9
6
5.7E­
04
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
2
1
18
10
8.2E­
04
1.6E­
03
1.2E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
1.3
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
1
1
6
0
3.7E­
02
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­

12%
asphalt
binder
2
1
12
12
BDL
lb/
MSF
1/
2"
fiberboard
mat
dryer
(
fugitive)

MDF
former
with
blowline
blend,
UF
resin
2
2
6
6
BDL
lb/
ODT
former
HB
former,
wet,
PF
resin
3
1
9
9
BDL
lb/
ODT
former
FB,
former,
wet,
6­
12%
asphalt
1
1
9
9
BDL
lb/
MSF
1/
2"
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
1
1
3
3
BDL
lb/
ODT
former,
blender
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
2
1
6
0
2.2E­
02
2.4E­
02
2.3E­
02
lb/
ODT
green
rotary
dryer
1.0
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
2
1
6
6
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­
60%
hardwood)
6
8
18
7
8.1E­
04
2.3E­
02
1.1E­
02
lb/
ODT
green
rotary
dryer
2.0
PB,
rotary,
direct
wood­
fired,
softwood
8
6
27
8
4.1E­
04
7.7E­
03
3.5E­
03
lb/
ODT
dry
rotary
dryer
2.2
HB,
tempering
oven,
direct
natural
gas­
fired
1
1
3
0
2.4E­
02
lb/
MSF
1/
8"
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
7
4
21
21
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
1
1
3
3
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
4
6
12
12
BDL
lb/
MSF
3/
8"
hardwood
plywood
press
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
7
4
36
36
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
1
1
3
0
8.7E­
03
lb/
MSF
1/
8"
humidifier
Pollutant:
Acrolein
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
1
1
3
3
BDL
lb/
MSF
3/
8"
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
1
1
6
0
2.9E­
02
lb/
MSF
1/
2"
press
predryer
HB
pressurized
digester/
refiner,
hardwood
1
1
3
0
2.4E­
03
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
1
1
3
0
4.1E­
03
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
2
1
4
4
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
2
1
6
6
BDL
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
2
4
6
6
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
5
4
21
21
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
1
1
2
0
2.2E­
04
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
1
1
3
0
3.6E­
04
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
Hardboard,
press,
linseed
oil
binder
1
1
3
0
5.7E­
03
lb/
MSF
1/
8"
reconstituted
wood
product
press
MDF,
press,
UF
resin
1
1
2
0
1.2E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
press
OSB,
press,
PF
resin
1
1
3
3
BDL
lb/
MSF
3/
8"
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
4
4
12
12
BDL
lb/
MSF
3/
8"
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
4
2
21
21
BDL
lb/
MSF
1/
8"
reconstituted
wood
product
press
PB,
press,
UF
resin
7
6
32
24
1.3E­
03
8.7E­
03
4.2E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.1
LSL,
rotary,
direct
wood­
fired,
hardwood
2
2
6
0
1.2E­
03
1.1E­
02
6.2E­
03
lb/
ODT
rotary
strand
dryer
1.8
OSB,
rotary,
direct
wood­
fired,
hardwood
1
2
3
0
2.0E­
01
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
2
4
6
0
3.2E­
02
3.4E­
02
3.3E­
02
lb/
ODT
rotary
strand
dryer
1.0
OSB,
rotary,
direct
wood­
fired,
softwood
6
10
18
1
2.8E­
02
1.1E­
01
7.2E­
02
lb/
ODT
rotary
strand
dryer
1.5
PB
sander
1
1
2
2
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
1
1
3
3
BDL
lb/
MSF
3/
8"
sander
MDF
sander
3
3
12
12
BDL
lb/
MSF
sander
LVL
I­
Beam
Saw
1
1
2
2
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]
material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
1
1
3
3
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
1
1
3
3
BDL
lb/
MSF
3/
8"
saw
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
2
2
6
6
BDL
lb/
ODT
secondary
tube
dryer
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
2
2
6
6
BDL
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
6
9
18
18
BDL
lb/
MSF
3/
8"
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
2
2
6
0
6.4E­
03
1.2E­
02
9.0E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
1.3
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
17
20
54
49
4.6E­
04
2.2E­
03
1.3E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
1.7
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
1
1
9
9
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
8
8
44
44
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
1
1
3
3
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
2
2
6
6
BDL
lb/
MSF
3/
8"
veneer
redryer
(
RF)
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

Pollutant:
Benzene
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
FB,
atmospheric
refiner
and
dump
chest,
softwood
1
1
3
3
BDL
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
2
2
6
6
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
1
1
3
3
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
1
1
3
3
BDL
lb/
MSF
3/
8"
blender
HB
log
chipper,
hardwood
1
1
2
2
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
I­
Joist
curing
chamber
1
1
3
3
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
3
3
12
12
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
1
1
3
3
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
2
1
18
18
BDL
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
1
1
9
9
BDL
lb/
MSF
1/
2"
fiberboard
mat
dryer
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
1
1
6
0
2.1E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­

12%
asphalt
binder
2
1
12
12
BDL
lb/
MSF
1/
2"
fiberboard
mat
dryer
(
fugitive)

FB,
former,
wet,
6­
12%
asphalt
1
1
9
9
BDL
lb/
MSF
1/
2"
former
HB
former,
wet,
PF
resin
3
1
9
9
BDL
lb/
ODT
former
MDF
former
with
blowline
blend,
UF
resin
2
2
6
6
BDL
lb/
ODT
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
1
1
3
3
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
2
1
6
6
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­
60%
hardwood)
5
7
15
5
3.9E­
04
7.5E­
03
4.7E­
03
lb/
ODT
green
rotary
dryer
1.6
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
2
1
9
0
7.3E­
03
7.9E­
03
7.6E­
03
lb/
ODT
green
rotary
dryer
1.0
PB,
rotary,
direct
wood­
fired,
softwood
8
6
27
12
1.1E­
04
2.8E­
03
9.9E­
04
lb/
ODT
dry
rotary
dryer
2.8
HB,
tempering
oven,
direct
natural
gas­
fired
1
1
3
3
BDL
lb/
MSF
1/
8"
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
7
4
21
21
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
1
1
3
3
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
4
6
12
12
BDL
lb/
MSF
3/
8"
hardwood
plywood
press
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
1
1
6
6
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
7
4
36
36
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
saw
Pollutant:
Benzene
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

HB,
humidification
kiln,
indirect
heated
1
1
3
1
6.2E­
06
lb/
MSF
1/
8"
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
1
1
3
3
BDL
lb/
MSF
3/
8"
log
vat
HB
pressurized
digester/
refiner,
hardwood
1
1
3
3
BDL
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
1
1
3
0
8.8E­
05
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
2
4
6
6
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
2
1
6
6
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
5
4
21
21
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
2
1
4
4
BDL
lb/
ODT
primary
tube
dryer
MDF
board
cooler,
UF
resin
1
1
3
3
BDL
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
2
2
6
6
BDL
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
Hardboard,
press,
linseed
oil
binder
1
1
3
3
BDL
lb/
MSF
1/
8"
reconstituted
wood
product
press
Hardboard,
press,
PF
resin
4
2
21
21
BDL
lb/
MSF
1/
8"
reconstituted
wood
product
press
MDF,
press,
UF
resin
3
3
21
21
BDL
lb/
MSF
3/
4"
reconstituted
wood
product
press
OSB,
press,
PF
resin
1
1
3
3
BDL
lb/
MSF
3/
8"
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
4
4
12
12
BDL
lb/
MSF
3/
8"
reconstituted
wood
product
press
PB,
press,
UF
resin
5
4
26
25
8.6E­
04
7.3E­
03
3.0E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.4
OSB,
rotary,
direct
wood­
fired,
hardwood
2
4
6
0
1.6E­
03
1.9E­
02
1.0E­
02
lb/
ODT
rotary
strand
dryer
1.8
OSB,
rotary,
direct
wood­
fired,
softwood
6
10
18
2
3.7E­
03
9.8E­
03
6.7E­
03
lb/
ODT
rotary
strand
dryer
1.5
MDF
sander
3
3
12
12
BDL
lb/
MSF
sander
PB
sander
1
1
2
2
BDL
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
1
1
3
3
BDL
lb/
MSF
3/
8"
sander
LVL
I­
Beam
Saw
1
1
2
2
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]
material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
1
1
3
3
BDL
lb/
MSF
reclaim
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
1
1
3
3
BDL
lb/
MSF
3/
8"
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
2
2
6
6
BDL
lb/
ODT
secondary
tube
dryer
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
2
2
6
5
5.1E­
04
9.4E­
04
7.3E­
04
lb/
ODT
secondary
tube
dryer
1.3
Softwood
Plywood,
press,
PF
resin
6
9
18
18
BDL
lb/
MSF
3/
8"
softwood
plywood
press
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
2
2
6
0
3.6E­
03
7.8E­
03
5.7E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
1.4
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
19
20
63
61
1.8E­
04
5.2E­
03
5.9E­
04
lb/
MSF
3/
8"
softwood
veneer
dryer
8.9
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
1
1
9
9
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
8
8
44
44
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
1
1
3
3
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
2
2
6
6
BDL
lb/
MSF
3/
8"
veneer
redryer
(
RF)
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

Pollutant:
Formaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
PB
steam
muffler
vent
(
vacuum
pump)
1
1
3
0
1.9E+
00
lb/
MSF
3/
4"
???

FB,
atmospheric
refiner
and
dump
chest,
softwood
1
1
3
0
6.1E­
04
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
2
2
6
6
BDL
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
1
1
3
0
1.0E­
02
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
1
1
3
0
3.6E­
03
lb/
MSF
3/
8"
blender
HB
log
chipper,
hardwood
1
1
2
2
BDL
lb/
ODT
chipper
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;

process
rate
=
finished
board
production)
1
1
3
2
3.4E­
04
lb/
MSF
3/
8"
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
OSB,
conveyer,
indirect
heated,
hardwood
(
heated
zones)
1
1
3
0
2.4E­
03
lb/
ODT
conveyor
strand
dryer
LSL,
conveyer,
indirect
heated,
hardwood
2
4
6
6
BDL
lb/
ODT
conveyor
strand
dryer
PB,
rotary,
indirect
heated
with
auxiliary
natural
gas,
softwood
4
4
12
0
3.2E­
02
6.4E­
02
4.7E­
02
lb/
ODT
dry
rotary
dryer
1.4
LSL,
press,
MDI
resin
1
1
3
0
2.9E­
02
lb/
1000
ft
3
engineered
wood
products
press
I­
Joist
curing
chamber
1
1
3
0
1.8E­
04
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
5
4
18
9
9.4E­
02
7.9E­
01
2.9E­
01
lb/
1000
ft3
engineered
wood
products
press
2.7
FB,
washer,
softwood
1
1
3
0
2.6E­
03
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
1
1
9
0
9.3E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
2
1
18
0
9.3E­
03
1.7E­
02
1.3E­
02
lb/
MSF
1/
2"
fiberboard
mat
dryer
1.3
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
1
1
6
0
5.9E­
02
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­

12%
asphalt
binder
2
1
12
1
7.8E­
03
3.1E­
02
1.9E­
02
lb/
MSF
1/
2"
fiberboard
mat
dryer
(
fugitive)
1.6
MDF
former
with
blowline
blend,
UF
resin
2
2
6
3
1.3E­
03
8.9E­
03
5.1E­
03
lb/
ODT
former
1.8
HB
former,
wet,
PF
resin
3
1
9
3
9.2E­
05
3.9E­
04
2.6E­
04
lb/
ODT
former
1.5
FB,
former,
wet,
6­
12%
asphalt
1
1
9
5
3.6E­
03
lb/
MSF
1/
2"
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
1
1
3
0
6.0E­
02
lb/
ODT
former,
blender
PB,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
1
1
3
0
4.2E­
03
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
8
5
27
0
8.6E­
03
2.7E­
01
1.4E­
01
lb/
ODT
green
rotary
dryer
2.0
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
2
1
6
1
4.4E­
03
1.1E­
02
7.6E­
03
lb/
ODT
green
rotary
dryer
1.4
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­
60%
hardwood)
6
8
18
1
3.8E­
03
2.0E­
01
9.6E­
02
lb/
ODT
green
rotary
dryer
2.0
PB,
rotary,
direct
natural
gas­
fired,
softwood
1
1
3
0
8.6E­
03
lb/
ODT
dry
rotary
dryer
PB,
rotary,
direct
wood­
fired,
softwood
10
11
33
2
2.4E­
03
1.2E­
01
2.5E­
02
lb/
ODT
dry
rotary
dryer
5.0
PB,
rotary,
direct
natural
gas­
fired,
hardwood
1
1
3
0
2.8E­
02
lb/
ODT
dry
rotary
dryer
Pollutant:
Formaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

HB,
tempering
oven,
direct
natural
gas­
fired
1
1
3
0
4.3E­
03
lb/
MSF
1/
8"
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
7
4
21
19
2.7E­
03
1.3E­
02
6.5E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)
2.1
HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
1
1
3
3
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
4
6
12
3
1.3E­
03
8.8E­
03
4.7E­
03
lb/
MSF
3/
8"
hardwood
plywood
press
1.9
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
1
1
6
2
2.5E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
7
4
36
8
4.2E­
04
2.1E­
03
1.1E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
1.9
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
1
1
3
2
3.0E­
04
lb/
MSF
3/
8"
holding
bin,
saw
HB,
humidification
kiln,
indirect
heated
1
1
3
0
1.0E­
03
lb/
MSF
1/
8"
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
1
1
3
3
BDL
lb/
MSF
3/
8"
log
vat
HB,
press
preheater,
softwood,
linseed
oil
binder
1
1
6
0
6.5E­
03
lb/
MSF
1/
2"
press
predryer
PB
veneer
press,
UF
resin
1
1
3
0
6.2E­
03
lb/
MSF
3/
4"
press­
other
HB
pressurized
digester/
refiner,
hardwood
1
1
3
0
4.5E­
03
lb/
ODT
pressurized
refiner
MDF,
tube,
direct
wood­
fired,
blowline
blend,
UF,
softwood
4
4
11
0
4.2E­
01
1.3E+
00
8.6E­
01
lb/
ODT
primary
tube
dryer
1.5
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
12
8
42
0
8.2E­
02
1.8E+
00
6.6E­
01
lb/
ODT
primary
tube
dryer
2.7
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
hardwood
2
2
6
0
2.5E­
01
2.6E­
01
2.6E­
01
lb/
ODT
primary
tube
dryer
1.0
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
1
1
3
0
1.1E+
00
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
2
4
6
0
2.5E­
01
2.6E­
01
2.6E­
01
lb/
ODT
primary
tube
dryer
1.0
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
2
1
4
1
7.5E­
02
9.4E­
02
8.5E­
02
lb/
ODT
primary
tube
dryer
1.1
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
2
1
6
4
3.2E­
03
1.4E­
02
8.5E­
03
lb/
ODT
primary
tube
dryer
1.6
MDF
board
cooler,
UF
resin
3
3
8
1
2.4E­
03
1.1E­
01
4.2E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
2.7
PB
board
cooler,
UF
resin
4
4
12
3
1.2E­
03
2.6E­
02
1.5E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
1.8
Hardboard,
press,
PF
resin
4
2
21
0
1.0E­
02
2.6E­
02
1.4E­
02
lb/
MSF
1/
8"
reconstituted
wood
product
press
1.8
Hardboard,
press,
linseed
oil
binder
1
1
3
0
1.8E­
02
lb/
MSF
1/
8"
reconstituted
wood
product
press
MDF,
press,
UF
resin
11
11
43
0
2.7E­
02
1.1E+
00
4.8E­
01
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.3
OSB,
press,
MDI
resin
2
2
6
0
2.8E­
02
1.0E­
01
6.4E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
1.6
OSB,
press,
PF
resin
2
2
6
0
1.5E­
02
7.3E­
02
4.4E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
1.7
OSB,
press,
PF/
MDI
resin
22
15
66
0
7.5E­
05
1.5E­
01
5.6E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
2.7
OSB,
press,
dry
PF
resin
1
1
3
0
1.4E­
01
lb/
MSF
3/
8"
reconstituted
wood
product
press
PB,
press,
UF
resin
18
12
136
1
6.9E­
03
6.4E­
01
2.3E­
01
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.7
LSL,
rotary,
direct
wood­
fired,
hardwood
2
2
6
0
5.9E­
02
1.3E­
01
9.6E­
02
lb/
ODT
rotary
strand
dryer
1.4
OSB,
rotary,
direct
wood­
fired,
softwood
30
26
89
0
3.5E­
03
5.5E­
01
1.3E­
01
lb/
ODT
rotary
strand
dryer
4.2
OSB,
rotary,
direct
wood­
fired,
hardwood
22
15
66
0
1.3E­
04
5.7E­
01
1.1E­
01
lb/
ODT
rotary
strand
dryer
5.0
Pollutant:
Formaldehyde
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

OSB,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%

softwood,
40­
60%
hardwood)
2
4
6
0
2.7E­
01
4.1E­
01
3.4E­
01
lb/
ODT
rotary
strand
dryer
1.2
OSB,
rotary,
direct
natural
gas­
fired,
hardwood
1
2
3
0
3.6E­
02
lb/
ODT
rotary
strand
dryer
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
1
1
3
0
1.8E­
03
lb/
MSF
3/
8"
sander
PB
sander
1
1
2
2
BDL
lb/
MSF
sander
MDF
sander
3
3
12
4
6.2E­
04
4.2E­
03
2.7E­
03
lb/
MSF
sander
1.5
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
1
1
3
1
3.4E­
04
lb/
MSF
3/
8"
saw
LVL
I­
Beam
Saw
1
1
2
2
BDL
lb/
MLF
saw
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]
material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
1
1
3
3
BDL
lb/
MSF
reclaim
saw
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
2
2
6
2
7.9E­
03
3.4E­
02
2.1E­
02
lb/
ODT
secondary
tube
dryer
1.6
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
2
2
6
3
5.3E­
03
2.8E­
02
1.7E­
02
lb/
ODT
secondary
tube
dryer
1.7
Softwood
Plywood,
press,
PF
resin
8
11
23
8
9.0E­
05
5.4E­
03
1.9E­
03
lb/
MSF
3/
8"
softwood
plywood
press
2.9
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
4
3
12
0
2.7E­
02
8.7E­
02
6.4E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
1.4
SPW,
veneer,
direct
wood­
fired,
softwood
(
heated
zones)
4
2
8
0
2.1E­
02
8.6E­
02
4.5E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
1.9
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
19
20
63
1
2.6E­
03
9.9E­
02
1.4E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
7.1
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
1
1
9
8
1.5E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
8
8
44
39
4.6E­
04
2.8E­
03
1.3E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)
2.2
SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
1
1
3
3
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
2
2
6
3
3.8E­
05
6.5E­
04
3.5E­
04
lb/
MSF
3/
8"
veneer
redryer
(
RF)
1.9
Pollutant:
MDI
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
LSL,
press,
MDI
resin
2
1
9
0
4.2E­
03
1.8E­
01
9.0E­
02
lb/
1000
ft
3
engineered
wood
products
press
2.0
OSB,
press,
MDI
resin
1
1
3
0
2.1E­
03
lb/
MSF
3/
8"
reconstituted
wood
product
press
OSB,
press,
PF/
MDI
resin
6
3
18
3
1.8E­
05
5.0E­
03
1.1E­
03
lb/
MSF
3/
8"
reconstituted
wood
product
press
4.4
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

Pollutant:
Phenol
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
FB,
atmospheric
refiner
and
dump
chest,
softwood
1
1
3
3
BDL
lb/
ODT
atmospheric
refiner
PB
flaker/
refiner/
hammermill
1
1
3
2
4.5E­
03
lb/
ODT
atmospheric
refiner,
etc
MDF
paddle
blender,
UF
resin
1
1
3
3
BDL
lb/
ODT
blender
OSB
blender
(
PF
&
MDI
resin)
1
1
3
3
BDL
lb/
MSF
3/
8"
blender
SV
dry
trim
chipper
(
chips
trimmed
veneer
from
layup
line;

process
rate
=
finished
board
production)
1
1
3
1
1.9E­
03
lb/
MSF
3/
8"
chipper
HB
log
chipper,
hardwood
1
1
2
2
BDL
lb/
ODT
chipper
SPW
dry
trim
chipper
(
chips
dry
trim
from
SPW
panel
saws;

process
rate
=
finished
board
production)
1
1
3
3
BDL
lb/
MSF
3/
8"
chipper
I­
Joist
curing
chamber
1
1
3
3
BDL
lb/
MLF
engineered
wood
products
press
LVL,
press,
PF
resin
3
3
12
12
BDL
lb/
1000
ft3
engineered
wood
products
press
FB,
washer,
softwood
1
1
3
3
BDL
lb/
ODT
fiber
washer
FB,
board
dryer,
indirect
heated,
softwood,
starch
binder
(
heated
zones)
1
1
9
8
1.2E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer,
indirect
heated,
softwood,
6­
12%
asphalt
binder
(
heated
zones)
2
1
18
14
1.4E­
03
1.4E­
03
1.4E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
1.0
HB,
board
dryer,
direct
natural
gas­
fired,
softwood,
linseed
oil
binder
(
heated
zones)
1
1
6
0
1.9E­
03
lb/
MSF
1/
2"
fiberboard
mat
dryer
FB,
board
dryer
fugitive
emissions,
indirect
heated,
softwood,
6­

12%
asphalt
binder
2
1
12
12
BDL
lb/
MSF
1/
2"
fiberboard
mat
dryer
(
fugitive)

HB
former,
wet,
PF
resin
3
1
9
0
6.9E­
04
7.5E­
04
7.1E­
04
lb/
ODT
former
1.1
MDF
former
with
blowline
blend,
UF
resin
2
2
6
6
BDL
lb/
ODT
former
FB,
former,
wet,
6­
12%
asphalt
1
1
9
9
BDL
lb/
MSF
1/
2"
former
MDF
former
without
blowline
blend,
UF
resin
(
includes
blender
emissions)
1
1
3
3
BDL
lb/
ODT
former,
blender
MDF,
green
dryer,
rotary,
direct
natural
gas­
fired,
softwood
1
1
6
6
BDL
lb/
ODT
green
rotary
dryer
PB,
green
dryer,
rotary,
direct
wood­
fired,
softwood
2
1
9
6
8.7E­
03
4.7E­
02
2.8E­
02
lb/
ODT
green
rotary
dryer
1.7
PB,
green
dryer,
rotary,
direct
wood­
fired,
mixed
wood
species
(
40­
60%
softwood,
40­
60%
hardwood)
5
7
15
11
2.1E­
03
1.8E­
02
7.9E­
03
lb/
ODT
green
rotary
dryer
2.2
PB,
rotary,
direct
wood­
fired,
softwood
6
5
21
17
2.4E­
03
1.2E­
02
6.6E­
03
lb/
ODT
dry
rotary
dryer
1.8
HB,
tempering
oven,
direct
natural
gas­
fired
1
1
3
0
1.9E­
03
lb/
MSF
1/
8"
hardboard
oven
HPW,
veneer,
indirect
heated,
hardwood
(
cooling
section)
7
4
21
21
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

HPW,
veneer,
direct
wood­
fired,
hardwood
(
cooling
section)
1
1
3
3
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
(
cooling)

Hardwood
Plywood,
press,
UF
resin
4
6
12
6
7.9E­
03
1.6E­
02
1.1E­
02
lb/
MSF
3/
8"
hardwood
plywood
press
1.5
HPW,
veneer,
direct
wood­
fired,
hardwood
(
heated
zones)
1
1
6
6
BDL
lb/
MSF
3/
8"
hardwood
veneer
dryer
HPW,
veneer,
indirect
heated,
hardwood
(
heated
zones)
7
4
36
34
1.3E­
03
5.3E­
03
3.0E­
03
lb/
MSF
3/
8"
hardwood
veneer
dryer
1.7
OSB
sanderdust
metering
bin
(
holds
fuel
for
dryer
and
thermal
oil
heater
suspension
burners)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
sander
OSB
raw
fuel
bin
(
holds
fines
from
screens
and
saws)
1
1
3
3
BDL
lb/
MSF
3/
8"
holding
bin,
saw
Pollutant:
Phenol
APCD:
None
No.
of
tests
No.
of
proces
s
units
No.
of
runs
No.
of
runs
BDL
Emission
factor
EF
MACT
floor
process
unit
group
(
terms
from
Table
1
in
preamble)
Difference
in
max
and
avg
EF's
(
max/
avg)

*

Em.
Fact.
Process
Unit
Description
Min
Max
Avg
units
*
Values
for
process
units
that
are
not
hard­
to­
test
are
shaded.

HB,
humidification
kiln,
indirect
heated
1
1
3
0
5.7E­
04
lb/
MSF
1/
8"
humidifier
SPW
log
steaming
vat
(
process
rate
=
volume
of
wood
removed
from
vat
per
hour)
1
1
3
3
BDL
lb/
MSF
3/
8"
log
vat
HB
pressurized
digester/
refiner,
hardwood
1
1
3
0
1.2E­
03
lb/
ODT
pressurized
refiner
HB,
tube,
direct
natural
gas­
fired,
blowline
blend,
PF,
hardwood
1
1
3
0
5.6E­
02
lb/
ODT
primary
tube
dryer
HB,
tube,
direct
wood­
fired,
blowline
blend,
PF,
hardwood
2
4
6
0
6.6E­
02
1.0E­
01
8.3E­
02
lb/
ODT
primary
tube
dryer
1.2
MDF,
tube,
indirect­
heated,
non­
blowline
blend,
softwood
2
1
4
4
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
direct
natural
gas­
fired,
non­
blowline
blend,
hardwood
2
1
6
6
BDL
lb/
ODT
primary
tube
dryer
MDF,
tube,
indirect
heated,
blowline
blend,
UF,
softwood
5
4
21
15
8.2E­
03
4.5E­
02
2.3E­
02
lb/
ODT
primary
tube
dryer
2.0
MDF
board
cooler,
UF
resin
1
1
3
3
BDL
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
PB
board
cooler,
UF
resin
2
2
6
5
4.1E­
03
9.1E­
03
6.6E­
03
lb/
MSF
3/
4"
reconstituted
wood
product
board
cooler
1.4
OSB,
press,
PF
resin
2
2
6
0
7.1E­
02
7.3E­
02
7.2E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
1.0
Hardboard,
press,
linseed
oil
binder
1
1
3
2
3.9E­
03
lb/
MSF
1/
8"
reconstituted
wood
product
press
MDF,
press,
UF
resin
2
2
9
7
2.4E­
02
3.1E­
02
2.7E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
press
1.1
Hardboard,
press,
PF
resin
4
2
21
11
5.6E­
03
1.5E­
02
1.0E­
02
lb/
MSF
1/
8"
reconstituted
wood
product
press
1.4
OSB,
press,
PF/
MDI
resin
10
7
30
12
5.8E­
06
2.8E­
02
1.5E­
02
lb/
MSF
3/
8"
reconstituted
wood
product
press
1.9
PB,
press,
UF
resin
5
4
26
18
6.4E­
03
2.4E­
02
1.1E­
02
lb/
MSF
3/
4"
reconstituted
wood
product
press
2.2
OSB,
rotary,
direct
wood­
fired,
hardwood
1
2
3
0
2.8E­
02
lb/
ODT
rotary
strand
dryer
OSB,
rotary,
direct
wood­
fired,
softwood
6
10
18
10
7.8E­
03
2.6E­
02
1.5E­
02
lb/
ODT
rotary
strand
dryer
1.7
PB
sander
1
1
2
1
1.5E­
02
lb/
MSF
sander
SPW
sander
(
8­
drum
sander,
1­
drum
sander,
&
specialty
saw)
1
1
3
3
BDL
lb/
MSF
3/
8"
sander
MDF
sander
3
3
12
9
4.2E­
03
1.1E­
02
6.9E­
03
lb/
MSF
sander
1.6
MDF
saw
(
reclaim
saw;
emission
factors
in
lb/
MSF
of
reclaimed
[
trimmed]
material)
MSF
reclaim
(
trim)
=
MSF
from
press
x
3%)
1
1
3
1
1.9E­
01
lb/
MSF
reclaim
saw
LVL
I­
Beam
Saw
1
1
2
2
BDL
lb/
MLF
saw
SPW
skinner
&
equalizer
saws
(
3
saws,
hog,
and
sander)
1
1
3
3
BDL
lb/
MSF
3/
8"
saw
HB,
second
stage
tube
dryer,
indirect
heated,
hardwood
2
2
6
4
2.5E­
02
5.3E­
02
3.9E­
02
lb/
ODT
secondary
tube
dryer
1.3
MDF,
second
stage
tube
dryer,
indirect
heated,
softwood
2
2
6
6
BDL
lb/
ODT
secondary
tube
dryer
Softwood
Plywood,
press,
PF
resin
4
7
12
11
7.6E­
04
2.2E­
03
1.4E­
03
lb/
MSF
3/
8"
softwood
plywood
press
1.6
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
heated
zones)
2
2
6
2
4.1E­
03
7.8E­
03
6.0E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
1.3
SPW,
veneer,
indirect
heated,
softwood
(
heated
zones)
19
20
63
44
1.1E­
03
9.3E­
03
3.4E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
2.7
SPW,
veneer,
direct
natural
gas­
fired,
softwood
(
cooling
section)
1
1
9
5
1.0E­
02
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)

SPW,
veneer,
indirect
heated,
softwood
(
cooling
section)
7
7
38
37
3.1E­
03
1.1E­
02
6.2E­
03
lb/
MSF
3/
8"
softwood
veneer
dryer
(
cooling)
1.7
SPW,
veneer
dryer
fugitive
emissions,
indirect
heated,
softwood
1
1
3
3
BDL
lb/
MSF
3/
8"
softwood
veneer
dryer
(
fugitive)

SPW,
veneer,
RF
heated,
softwood
2
2
6
6
BDL
lb/
MSF
3/
8"
veneer
redryer
(
RF)
ATTACHMENT
6
Derivation
of
Emission
Factors
for
Veneer
Kilns
Emission
factors
for
hardwood
and
softwood
veneer
kilns
Maximum
available
emission
factor
for
Appendix
B
HAP
(
lb/
MSF
3/
8")

Process
unit
Acetaldehyde
Acrolein
Formaldehyd
e
Phenol
Benzene
MDI
HAP
metalsa
Softwood
veneer
dryer,
heated
zones
0.085411
0.011547
0.099475
0.009337
0.00779
NA
NA
Softwood
veneer
dryer,
cooling
0.011732
BDL
0.002774
0.010688
BDL
NA
NA
Softwood
veneer
dryer,
fugitives
BDL
BDL
BDL
BDL
BDL
NA
NA
Total
for
softwood
veneer
dryer
to
apply
0.097143
0.011547
0.102249
0.020025
0.00779
NA
NA
for
softwood
veneer
kilns
Hardwood
veneer
dryer,
heated
zones
0.009362
BDL
0.00248
0.005263
BDL
NA
NA
Hardwood
veneer
dryer,
cooling
0.057681
BDL
0.013488
BDL
BDL
NA
NA
Total
for
hardwood
veneer
dryer
to
apply
0.067043
NA
0.015968
0.005263
NA
NA
NA
for
hardwood
veneer
kilns
There
are
no
known
direct­
fired
veneer
kilns.
ATTACHMENT
7
Potential
Methods
for
Determining
Concentration
of
Appendix
B
Organic
HAP
in
PCWP
Wastewater/
Process
Water
Streams
Potential
Methods
for
Determining
Concentration
of
Appendix
B
Organic
HAP
in
PCWP
Wastewater/
Process
Water
Streams
Appendix
B
HAP
Methods
mentioning
these
HAPa,
b
Acetaldehyde
NCASI
Method
DI/
HAPS
99.01
Acrolein
SW­
846
Method
8260B
Method
603,
40
CFR
part
136,
appendix
A
Method
624,
40
CFR
part
136,
appendix
A
(
extension
of
method)
Method
1624,
40
CFR
part
136,
appendix
A
Benzene
SW­
846
Method
8260B
Method
602,
40
CFR
part
136,
appendix
A
Method
624,
40
CFR
part
136,
appendix
A
Method
1624,
40
CFR
part
136,
appendix
A
Formaldehyde
ASTM
method
D6303,
Standard
Test
Method
for
Formaldehyde
in
Water
Phenol
NCASI
Method
CP­
86.02
Method
625,
40
CFR
part
136,
appendix
A
Method
1625,
40
CFR
part
136,
appendix
A
MDI
No
method
found
a
Method
305,
40
CFR
part
60,
appendix
A
may
be
an
option
for
speciation
of
the
Appendix
B
organic
HAP.
However,
the
method
does
not
contain
a
list
of
analytes.
b
The
non­
CFR
methods
(
NCASI,
ASTM,
and
SW­
846)
would
have
to
be
incorporated
by
reference.

Other
methods
scanned
for
applicability
that
do
not
appear
to
apply:
Method
25D,
40
CFR
part
60,
appendix
A
(
Measures
volatile
organics
but
does
not
speciate)
Appendix
C
to
40
CFR
part
63
(
Determines
fraction
biodegraded)

In
addition
to
specifying
applicable
methods,
Appendix
B
to
subpart
DDDD
would
also
need
to
include
language
to
specify
procedures
for
number
of
samples,
locating
sampling
points,
sample
collection
and
handling,
and
validation
of
methods.
Potential
language
that
could
be
included
in
Appendix
B
to
subpart
DDDD
could
be
based
on
that
in
§
63.144
of
the
HON,
with
edits
as
follows:

§
_
___________

(
a)
To
measure
the
organic
HAP
listed
in
Table
1
to
this
Appendix
in
a
water
management
unit,
you
must
comply
with
the
requirements
of
this
paragraph.
(
1)
Sample
location.
If
you
use
HAP
concentrations
from
the
collection
system
in
your
low­
risk
determination,
select
sampling
locations
as
specified
in
paragraph
(
a)(
1)(
i)
of
this
section.
If
you
use
HAP
concentrations
from
the
water
management
unit
in
your
low­
risk
determination,
select
sampling
locations
as
specified
in
paragraph
(
a)(
1)(
ii)
of
this
section.
(
i)
Collection
system.
If
your
collection
system
consists
of
hard­
piping,
or
your
water
stream
contains
only
formaldehyde,
phenol,
and/
or
MDI,
then
you
may
take
samples
at
any
point
in
the
system.
If
your
collection
system
is
not
hard­
piped,
and
your
water
stream
contains
benzene,
acetaldehyde,
or
acrolein,
then
you
must
collect
samples
at
the
inlet
to
the
collection
system
(
i.
e.,
where
discharged
from
a
process
unit).
(
ii)
Water
management
unit.
You
must
select
one
or
more
water
sample
locations
that
will
represent
the
maximum
concentrations
in
the
water
management
unit
of
each
of
the
HAP
listed
in
Table
1
to
this
Appendix.
You
must
provide
justification
for
your
selection
along
with
a
detailed
description
of
the
design
and
operation
of
your
water
management
unit
and
the
conveyance
system
from
process
units.
The
description
must
include,
but
is
not
limited
to,
dimensions
of
the
water
management
unit,
locations
of
inlet
and
outlet
streams,
and
mixing
methods.
(
2)
Methods
You
may
use
any
of
the
methods
specified
in
Table
__.
(
i)
If
you
use
Method
624
or
625
of
40
CFR
part
136,
you
must
comply
with
the
sampling
protocol
requirements
specified
in
paragraph
(
a)(
3)
of
this
section.
If
these
methods
are
used
to
analyze
one
or
more
compounds
that
are
not
on
the
method's
published
list
of
approved
compounds,
the
Alternative
Test
Procedure
specified
in
40
CFR
136.4
and
136.5
must
be
followed.
For
Method
625,
make
corrections
to
the
compounds
for
which
the
analysis
is
being
conducted
based
on
the
accuracy
as
recovery
factors
in
Table
7
of
the
Method.
(
ii)
If
you
use
Method
1624
or
1625
of
40
CFR
part
136,
appendix
A,
you
must
comply
with
the
sampling
protocol
requirements
specified
in
paragraph
(
a)(
3)
of
this
section.
If
you
use
these
methods
to
analyze
one
or
more
compounds
that
are
not
on
the
method's
published
list
of
approved
compounds,
you
must
follow
the
Alternative
Test
Procedure
specified
in
40
CFR
136.4
and
136.5.
(
iii)
If
you
use
Method
8260
in
SW­
846,
you
must
maintain
a
formal
quality
assurance
program
consistent
with
Section
8
of
Method
8260.
This
program
must
include
the
elements
related
to
measuring
the
concentrations
of
volatile
compounds
that
are
specified
in
paragraphs
(
a)(
2)(
iii)(
A)
through
(
C)
of
this
section.
(
A)
Documentation
of
site­
specific
procedures
to
minimize
the
loss
of
compounds
due
to
volatilization,
biodegradation,
reaction,
or
sorption
during
the
sample
collection,
storage,
and
preparation
steps.
(
B)
Documentation
of
specific
quality
assurance
procedures
followed
during
sampling,
sample
preparation,
sample
introduction,
and
analysis.
(
C)
Measurement
of
the
average
accuracy
and
precision
of
the
specific
procedures,
including
field
duplicates
and
field
spiking
of
the
material
source
before
or
during
sampling
with
compounds
having
similar
chemical
characteristics
to
the
target
analytes.
(
iv)
If
you
use
other
EPA
test
methods,
you
must
use
the
procedures
specified
in
the
method
and
comply
with
the
requirements
specified
in
paragraph
(
a)(
4)
and
either
paragraph
(
a)(
5)(
i)
of
(
ii)
of
this
section.
(
v)
If
you
use
a
Method
other
than
an
EPA
method,
you
must
use
the
procedures
in
the
method
and
comply
with
the
requirements
specified
in
paragraphs
(
a)(
4)
and
(
a)(
5)(
i)
of
this
section.
(
3)
Non­
detect
measurements.
If
all
of
the
water
samples
in
a
test
result
in
a
non­
detect
reading,
and
the
method
detection
limit
is
less
than
or
equal
to
1
ppmw,
then
you
may
assume
the
concentration
to
be
zero.
Otherwise,
non­
detect
readings
must
be
assumed
to
be
one­
half
of
the
method
detection
limit.
(
4)
Sampling
plan.
If
you
are
expressly
referred
to
this
paragraph
by
provisions
of
this
Appendix,
you
must
prepare
a
sampling
plan.
Water
samples
must
be
collected
using
sampling
procedures
which
minimize
loss
of
organic
compounds
during
sample
collection
and
analysis
and
maintain
sample
integrity.
The
sampling
plan
must
include
procedures
for
determining
recovery
efficiency
of
the
relevant
organic
HAP
listed
in
Table
1
to
this
Appendix.
An
example
of
an
acceptable
sampling
plan
would
be
one
that
incorporates
similar
sampling
and
sample
handling
requirements
to
those
of
Method
25D
of
40
CFR
part
60,
appendix
A.
You
must
maintain
the
sampling
plan
at
your
facility.
(
5)
Validation
of
methods.
You
must
validate
EPA
methods
other
than
Methods
624,
625,
1624,
and
1625
using
the
procedures
specified
in
paragraph
(
a)(
5)(
i)
or
(
ii)
of
this
section.
You
must
validate
other
methods
as
specified
in
paragraph
(
a)(
5)(
i)
of
this
section.
(
i)
Validation
of
EPA
methods
and
other
methods.
The
method
used
to
measure
organic
HAP
in
the
water
must
be
validated
according
to
section
5.1
or
5.3,
and
the
corresponding
calculations
in
section
6.1
or
6.3,
of
Method
301
of
appendix
A
to
40
CFR
part
63.
The
data
are
acceptable
if
they
meet
the
criteria
specified
in
section
6.1.5
or
6.3.3
of
Method
301
of
appendix
A
to
40
CFR
part
63.
If
correction
is
required
under
section
6.3.3
of
Method
301
of
appendix
A
to
40
CFR
part
63,
the
data
are
acceptable
if
the
correction
factor
is
within
the
range
0.7
to
1.30.
Other
sections
of
method
301
of
appendix
A
to
40
CFR
part
63
are
not
required.
(
ii)
Validation
of
EPA
methods.
Follow
the
procedures
as
specified
in
"
Alternative
Validation
Procedure
for
EPA
Waste
Methods"
40
CFR
part
63,
appendix
D.
ATTACHMENT
8
Equations
for
Estimating
Mass
Transfer
Coefficients,
Tabulated
Properties
of
Organic
HAP
Listed
in
Appendix
B
to
subpart
DDDD,
and
Example
Calculation
of
Mass
Transfer
Coefficients
and
Worst­
case
Emissions
Table
A8­
1.
Equations
for
estimating
mass
transfer
coefficients
If...
Use
the
following
equation(
s)
to
estimate
mass
transfer
coefficients...

°
liquid
is
quiescent,
and
°
U10
<
3.25
m/
s
k
2.78x10
D
D
L
6
w
ether
2/
3
=






 

°
liquid
is
quiescent,
°
U10
>
3.25
m/
s,
and
°
14
<
F/
D
<
51.2
k
(
2.605x10
)
F
D
1.277x10
(
U
)
D
D
L
9
7
10
2
w
ether
2/
3
=






+



	









 
 

°
liquid
is
quiescent,
°
U10
>
3.25
m/
s,
and
°
F/
D
>
51.2
(
)(
)
k
2.611x10
U
D
D
L
10
2
w
ether
2/
3
=



	



 
7
°
liquid
is
quiescent,
°
U10
>
3.25,
°
U*
>
0.3,
and
°
F/
D
<
14
k
1.0x10
(
34.1x10
)(
U
)(
Sc
)
L
6
4
*

L
0.5
=
+ 
 
 

U
(
0.01)(
U
)(
6.1
(
0.63)(
U
))
*
10
10
0.5
=
+

Sc
(
)(
D
)
L
L
L
w
=
µ
 
°
liquid
is
quiescent,
°
U10
>
3.25,
°
U*
<
0.3,
and
°
F/
D
<
14
k
1.0x10
(
144x10
)(
U
)
(
Sc
)
L
6
4
*
2.2
L
0.5
=
+ 
 
 

U*
and
ScL
defined
as
above
°
liquid
is
quiescent,
and
°
any
U10
and
F/
D
k
(
0.00482)(
U
)
(
Sc
)
(
d
)
G
10
0.78
G
0.67
e
0.11
=
 
 

Sc
(
)(
D
)
G
G
G
a
=
µ
 
µ
G
7
4
(
4.568
10
)(
T)
1.7209
10
=
×
+
×
 
 

d
(
4)(
A)
e
0.5
=






 
°
liquid
is
mechanically
aerated
k
(
0.00822)(
J)(
POWR)(
O
)(
1.024)
(
MW
)

(
A
)(
/
62.37)
D
D
L
t
Tw
20
L
t
W
O2
0.5
=












 

 
L
*

k
(
1.35x10
)(
R
)
(
p)
(
Sc
)
(
F
)
(
D
)(
MW
)
/
d
G
7
e
1.42
0.4
G
0.5
r
0.21
a
a
=
 
 
If...
Use
the
following
equation(
s)
to
estimate
mass
transfer
coefficients...

R
(
d)
(
w)(
)
e
2
G
G
=
 
µ
p
(
0.85)(
POWR)(
550)(
g
)

(
N
)(
)(
d
)
(
w)
c
a
*
5
3
=
 
L
*

Sc
(
)(
D
)
G
G
G
a
=
µ
 
F
(
d
)(
w)

g
r
*
2
c
=

The
terms
in
the
above
equations
are
defined
as
follows:

kL
=
liquid­
phase
mass
transfer
coefficient,
m/
s
Dw
=
diffusivity
of
individual
HAP
in
water,
cm2/
s
Dether
=
diffusivity
of
ether
in
water,
8.5
x
10­
6
cm2/
s
at
25oC
DO2
=
diffusivity
of
oxygen
in
water,
2.4
x
10­
5
cm2/
s
at
25oC
F
=
fetch
(
linear
distance
across
the
liquid
surface
in
the
direction
of
wind
flow),
m
D
=
depth
of
liquid
in
pond
or
tank,
m
U10
=
windspeed
at
10
m
above
the
liquid
surface,
m/
s
U*
=
friction
velocity,
m/
s
ScL
=
Schmidt
number
on
liquid
side,
dimensionless
µ
L
=
viscosity
of
water,
0.008904
g/
cm°
s
at
25

C
 L
=
density
of
water,
1
g/
cm3
(
at
0

C
to
30

C)

 L
*
=
density
of
water,
62.37
lb/
ft3
(
at
0

C
to
30

C)
ScG
=
Schmidt
number
on
gas
side,
dimensionless
µ
G
=
viscosity
of
air,
1.84x10­
4
g/
cm°
s
at
25

C
 G
=
density
of
air,
1.2x10­
3
g/
cm3
at
25

C
Da
=
diffusivity
of
individual
HAP
in
air,
cm2/
s
de
=
effective
diameter
of
tank
or
pond,
m
A
=
liquid
surface
area
of
tank
or
pond,
m2
J
=
oxygen
transfer
rating
of
surface
aerator,
typically
3.0
lb
O2/
hp/
hr
POWR
=
total
power
to
aerators,
hp
(
sum
of
power
to
each
aerator
for
multiple
aerators)
T
=
temperature
of
the
air,

C
Tw
=
temperature
of
water,

C
MWL
=
molecular
weight
of
water,
18
g/
gmol
MWa
=
molecular
weight
of
air,
29
g/
gmol
At
=
agitated
surface
area,
ft2
Ot
=
oxygen
transfer
correction
factor,
use
0.83
Re
=
impeller
Reynold's
number,
rad
p
=
power
number
Na
=
number
of
aerators
d
=
impeller
diameter,
cm
d*
=
impeller
diameter,
ft
w
=
rotational
speed
of
impeller,
rad/
s
0.85
=
typical
efficiency
of
aerator
motor
gc
=
gravitation
constant,
32.17
lbm°
ft/
s2/
lbf
Fr
=
Froude
number
Table
A8­
2.
Properties
of
Organic
HAP
at
25oCa
HAP
Diffusivity
of
HAP
in
water,
cm2/
s
Diffusivity
of
HAP
in
air,
cm2/
s
Henry's
law
constant,
atm°
m3/
mol
Acetaldehyde
1.41x10­
5
0.124
9.99x10­
5
Acrolein
1.22x10­
5
0.105
1.351x10­
4
Benzene
9.8x10­
6
0.088
5.55x10­
3
Formaldehyde
1.98x10­
5
0.178
3.226x10­
7
MDI
1x10­
5
0.001
4.86x10­
8
Phenol
9.1x10­
6
0.082
7.088x10­
7
a
Calculate
diffusivity
of
HAP
in
water
at
other
temperatures
as
follows:
D
T2
=
(
D
298)(
T
2/
298)

Calculate
diffusivity
of
HAP
in
air
at
other
temperatures
as
follows:
D
T2
=
(
D
298)(
T
2/
298)
1.75
In
WATER9,
the
Henry's
law
constant
at
another
temperature
is
estimated
by
multiplying
the
value
at
25

C
by
the
ratio
of
the
vapor
pressure
at
the
actual
temperature
to
the
vapor
pressure
at
25

C.
When
the
Antoine's
equation
is
used
to
calculate
the
vapor
pressures,
the
ratios
can
be
simplified
as
follows
for
each
of
the
HAP:

For
acetaldehyde:
H
T2
=
(
9.99x10­
5)(
e^(
11.629­
3,684.2/(
291.809
+
T
2)))

For
acrolein:
H
T2
=
(
1.351x10­
4)(
e^(
10.995­
2,987.2/(
246.691
+
T
2)))

For
benzene:
H
T2
=
(
5.55x10­
3)(
e^(
11.345­
2,788.5/(
220.8
+
T
2)))

For
formaldehyde:
H
T2
=
(
3.22x10­
7)(
e^(
8.305­
2,234.9/(
244.1
+
T
2)))

For
MDI:
no
change
with
temperature
For
phenol:
H
T2
=
(
7.088x10­
7)(
e^(
17.47­
3,492.5/(
174.95
+
T
2)))
Example
Calculation
of
Emissions
from
a
Water
Management
Unit
Determine
the
worst­
case
emissions
from
the
water
management
unit
with
the
characteristics
listed
in
Table
A8­
3.
This
example
considers
only
one
influent
stream
to
illustrate
the
procedure.
Similar
calculations
would
be
required
for
other
inlet
streams
that
have
the
maximum
concentrations
of
any
of
the
other
organic
HAP
listed
in
appendix
B
to
subpart
DDDD.

Table
A8­
3.
Site­
specific
parameters
Parameter
Value
and
units
Surface
impoundment
characteristics
Surface
area
(
A)
1,500
m2
(
16,146
ft2)

Median
depth
(
D)
1.8
m
(
5.9
ft)

Volume
2,700
m3
(
95,349
ft3)

Temperature
of
water
(
T
w)
25

C
(
298

K)

Source
of
influent
stream
WESP
blowdown
HAP
in
influent
stream
acetaldehyde
Maximum
HAP
concentration
(
C
L)
8
ppmw
(
8
g/
m3)

Aeration
characteristics
Number
of
aerators
(
N
a)
5
Motor
power
15
hp
Impeller
diameter
(
d
or
d*)
61
cm
(
2.0
ft)

Rotational
speed
of
impeller
(
w)
126
rad/
s
Meteorological
conditions
Maximum
air
temperature
(
T)
25

C
(
298

K)

Wind
speed
(
U
10)
4.47
m/
s
Table
A8­
4.
Standard
parameter
values
Parameter
Values
and
units
Water
properties
(
at
25oC)

Molecular
weight
(
MW
L)
18
g/
gmol
Density
(
 L)
1
g/
cm
3
(
62
lb/
ft3)

Viscosity
(
µ
L
)
0.008904
g/
cm°
s
Air
properties
(
at
25oC)

Molecular
weight
(
MW
G)
29
g/
gmol
Density
(
 G)
0.0012
g/
cm3
Viscosity
(
µ
G
)
1.84
x
10­
4
g/
cm°
s
Acetaldehyde
properties
(
at
25oC)

Henry's
law
constant
(
H)
9.99
x
10­
5
atm°
m3/
gmol
Diffusivity
in
air
(
D
a)
0.124
cm2/
s
Diffusivity
in
water
(
D
w)
1.41
x
10­
5
cm2/
s
Aeration
parameters
(
typical
values)

Oxygen
transfer
rating
(
J)
3.0
lb
O
2/
hp/
h
Oxygen
transfer
correction
factor
(
O
t
)
0.83
Efficiency
of
aerator
motor
0.85
Step
1:
Determine
the
fraction
of
the
surface
area
that
is
aerated
(
turbulent)

The
extent
of
turbulence
must
be
estimated
for
each
pond
or
tank
based
on
information
such
as
the
number,
size,
and
placement
of
aerators.
Based
on
information
in
a
reference
cited
in
reference
18,
five
aerators
with
15­
hp
motors
and
61­
cm
diameter
impellers
turning
at
126
rad/
s
would
agitate
a
volume
of
441
m3
(
15,590
ft3).
Dividing
this
volume
by
the
average
depth
of
the
pond
in
this
example
results
in
an
agitated
surface
area
of
245
m2
(
2,637
ft2).
The
balance
of
the
surface
area
(
1,255
m2)
is
quiescent.

Step
2:
Determine
the
fetch
(
F)
and
the
fetch­
to­
depth
ratio
(
F/
D)
for
the
pond
Assuming
the
pond
is
relatively
circular,
the
fetch
will
be
equal
to
the
diameter
of
the
pond:
F
A
m
=






=
×






=
4
4
1500
44
0
5
0
5
 
 
.

.
,

The
fetch­
to­
depth
ratio
(
F/
D)
for
this
pond
is
24
(
44
m
divided
by
1.8
m).

Step
3:
Calculate
the
liquid­
phase
mass
transfer
coefficient
(
k
L)
for
the
quiescent
portion
of
the
pond
Since
the
wind
speed
is
greater
than
3.25
m/
s
and
the
fetch­
to­
depth
ratio
is
between
14
and
51.2,
the
second
equation
in
Table
A8­
1
should
be
used
to
calculate
k
L.
All
of
the
necessary
data
have
been
calculated
above
or
are
listed
in
Tables
A8­
3
and
A8­
4:

k
x
F
D
x
U
D
D
x
x
x
x
x
m
s
L
w
ether
=






+



	









=






+



	









=
 
 

 
 
 

 

 
(
.
)
.
(
)

(
.
)
.
.
(.)
.

.

.
/
/

/
2
605
10
1277
10
2
605
10
44
18
1277
10
4
47
141
10
85
10
535
10
9
7
10
2
2
3
9
7
2
5
6
2
3
6
Step
4:
Calculate
the
gas­
phase
mass
transfer
coefficient
(
k
G)
for
the
quiescent
portion
of
the
pond
According
to
Table
A8­
1,
the
sixth
equation
should
be
used
to
calculate
k
G.
Terms
in
this
equation
that
must
be
calculated
first
are
the
Schmidt
number
(
Sc
G)
and
the
effective
diameter
of
the
pond,
and
the
viscosity
of
the
air
can
be
calculated
for
use
in
calculating
the
Schmidt
number:

µ
µ
 
G
G
G
G
a
T
g
cm
s
Sc
D
=
×
+
×
=
×
+
×
=
×
 

=

=
×
×
=
 
 

 
 

 

 

 
(
.
)(
)
.

(
.
)(
)
.

.
/

(
)(
)

.

(
.
)(
.
)

.
4
568
10
17209
10
4
568
10
25
17209
10
184
10
184
10
12
10
0124
124
7
4
7
4
4
4
3
d
A
m
e
=






=






=
(
)(
)

(
)(
,
)

.
.

.
4
4
1500
437
0
5
0
5
 
 
k
J
POWR
O
MW
A
D
D
m
s
L
t
Tw
L
t
L
W
O
=












=
×






×
×






=
×
 

 
 

 

 
(
.
)(
)(
)(
)(
.
)
(
)

(
)(
/
.
)

(
.
)(
)(
)(
.
)(
.
)
(
)

(
,
)(
.
/
.
)
.

.

.
/
*
.

.
0
00822
1024
62
37
0
00822
3
5
15
0
83
1024
18
2
637
62
37
62
37
141
10
2
4
10
904
10
20
0
5
25
20
5
5
0
5
3
2
 
The
gas­
phase
mass
transfer
coefficient
(
k
G)
can
now
be
calculated
as
follows:

k
U
Sc
d
m
s
G
G
e
=

=
=
×
 
 

 
 

 
(
.
)(
)
(
)
(
)

(
.
)(
.
)
(
.
)
(
.
)

.
/
.
.
.

.
.
.
0
00482
0
00482
4
47
124
437
888
10
10
0
78
0
67
0
11
0
78
0
67
0
11
3
Step
5:
Calculate
the
overall
mass
transfer
coefficient
(
K
q)
for
the
quiescent
zone
1
1
1
535
10
821
10
298
888
10
9
99
10
4
66
10
6
5
3
5
6
K
k
RT
k
H
K
ms
L
G
q
=
+

=
×
+
×
×
×
=
×
 
 

 
 

 
.
(
.
)(
)

(
.
)(
.
)

.
/

Step
6:
Calculate
the
liquid­
phase
mass
transfer
coefficient
(
k
L)
for
the
turbulent
zone
Step
7:
Calculate
the
gas­
phase
mass
transfer
coefficient
(
k
G)
for
the
turbulent
zone
According
to
Table
A8­
1,
the
equation
for
estimating
the
gas­
phase
mass
transfer
coefficient
(
k
G)
for
the
turbulent
zone
depends
on
the
Reynold's
number
(
R
e),
power
number
(
p),
Schmidt
number
(
Sc
G),
and
Froude
number
(
F
r).
These
values
are
calculated
as
follows
using
the
data
in
Tables
A8­
3
and
A8­
4.
R
d
w
e
G
G
=

=
×
×
=
×
 

 
(
)
(
)(
)

(
)
(
)(
.
)

.
.
2
2
3
4
6
61
126
12
10
184
10
306
10
 
µ
p
POWR
g
N
d
w
c
a
L
=

=
×
=
×
 
(
.
)(
)(
550)(
)

(
)(
)(
)
(
)

(
.
)(
5
)(
550)(
.
)

(
5)(
.
)(
)
(
)

.
*
*
085
085
15
3217
62
37
2
126
565
10
5
3
5
3
5
 
Fr
d
w
g
c
=

=

=
(
)(
)

(
)(
)

.
*
2
2
2
126
32
17
987
The
Reynold's
number:

The
power
number:

The
Schmidt
number:

Sc
D
G
G
G
a
=

=
×
×
=
 

 
µ
 
(
)(
)

.

(
.
)(
.
)

.
184
10
12
10
0124
124
4
3
The
Froude
number:
k
R
pSc
Fr
DMWd
m
s
G
e
G
a
a
=
×
=
×
×
×
=
×
 
 

 
 
 

 
(
.
)(
)
(
)
(
)
(
)
(
)(
)
/

(
.
)(
.
)
(
.
)
(
.
)
(
)
(
.
)(
)
/

.
/
.
.
.
.

.
.
.
.
135
10
135
10
306
10
5
65
10
124
987
0124
29
61
675
10
7
1
42
0
4
0
5
0
21
7
6
1
42
5
0
4
0
5
0
21
2
1
1
1
9
04
10
821
10
298
6
75
10
9
99
10
2
67
10
3
5
2
5
4
K
k
RT
k
H
K
ms
L
G
turb
=
+

=
×
+
×
×
×
=
×
 
 

 
 

 
.
(
.
)(
)

(
.
)(
.
)

.
/

K
m
s
=
×
+
×
+
=
×
 
 

 
(
.
)(
,
)
(
.
)(
)

,

.
/
4
66
10
1
255
2
67
10
245
1
255
245
475
10
6
4
5
E
KAC
g
s
L
=

=
×
=
 
(
.
)(
,
)(
)

.
/
4
75
10
1500
8
057
5
And,
now
the
gas­
phase
mass
transfer
coefficient
(
k
G):

Step
8:
Calculate
the
overall
mass
transfer
coefficient
(
K
turb)
for
the
turbulent
zone
Step
9:
Calculate
the
overall
mass
transfer
coefficient
(
K)
for
the
combined
quiescent
and
turbulent
zones
The
combined
mass
transfer
coefficient
(
K)
is
based
on
the
mass
transfer
coefficients
for
the
two
zones
(
K
q
and
K
turb),
weighted
by
the
surface
area
of
each
zone:

Step
10:
Calculate
the
worst­
case
emissions
rate
