From:
Katie
Hanks
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
April
12,
2004
Project:
Plywood
and
Composite
Wood
Products
NESHAP
Re:
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
I.
Purpose
The
EPA
participated
in
a
conference
call
with
members
of
AF&
PA
and
other
representatives
of
the
PCWP
industry
on
April
1,
2004,
to
discuss
industry
questions
and
concerns
related
to
the
final
Plywood
and
Composite
Wood
Products
(
PCWP)
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
which
was
signed
on
February
27,
2004.
The
list
of
participants
is
included
as
Attachment
1.

II.
Discussion
A.
Appendix
B
Emission
Testing
Issues
The
industry
representatives
stated
that,
at
a
later
date,
they
would
more
formally
propose
to
EPA
a
simple
approach
to
narrow
the
scope
of
the
emissions
testing
requirements
in
Appendix
B
to
subpart
DDDD
(
the
final
PCWP
rule).
As
promulgated,
Appendix
B
requires
emissions
testing
of
all
process
units
for
purposes
of
demonstrating
that
the
facility
is
part
of
the
low­
risk
subcategory.
The
industry's
suggested
approach
would
not
require
emissions
testing
of
fugitive
emission
sources
(
e.
g.,
storage
piles,
conveyors,
raw
material
storage
operations,
log
decks,
etc.).
The
industry
representatives
claimed
that
the
fugitive
emissions
from
these
sources
would
likely
include
methanol
as
the
only
HAP
and
methanol
is
not
one
of
the
13
HAP
of
concern
listed
in
Appendix
B.
However,
there
are
some
fugitive
emission
sources
at
PCWP
plants
that
emit
HAP
listed
in
Appendix
B.
For
fugitive
emission
sources
emitting
HAP
listed
in
Appendix
B,
the
industry
representatives
suggested
that
emission
estimation
methods
could
be
used
as
opposed
to
stack
testing.
For
example,
water
sampling
and
emission
estimation
could
be
done
for
wastewater
treatment
operations.
The
industry
representatives
stated
that
they
would
send
EPA
a
list
of
fugitive
emission
sources.
The
industry
representatives
acknowledged
that
2
some
miscellaneous
process
units
may
be
configured
such
that
they
produce
fugitive
emissions
at
some
facilities,
while
the
same
types
of
process
units
may
be
point
sources
at
other
facilities.
The
configuration
of
miscellaneous
process
units
varies
from
facility
to
facility.

The
industry
representatives
also
suggested
that
there
is
no
reason
to
believe
that
Appendix
B
HAP
are
emitted
from
sources
where
no
heat
is
applied
and
there
is
no
uncured
resin
in
the
wood
material.
The
RTI
representative
noted
that
saws
and
sanders
have
exhibited
Appendix
B
HAP
emissions
(
e.
g.,
acetaldehyde,
formaldehyde,
phenol),
and
these
are
sources
with
no
heat
application
and
no
uncured
resin.
The
NCASI
representative
stated
that
some
saws
and
sanders
emit
HAP
while
others
do
not,
and
typically,
HAP
emissions
are
below
the
test
method
detection
limit
(
MDL)
for
saws
and
sanders.
The
industry
representatives
cited
the
1
part
per
million
(
ppm)
criteria
in
section
5(
f)
of
Appendix
B
as
justification
for
not
requiring
emission
testing
of
sources
that
often
emit
less
than
1
ppm
of
HAP.
The
RTI
representative
clarified
that
section
5(
f)
states
that
facilities
may
treat
non­
detect
organic
HAP
measurements
of
less
that
1
ppm
as
zero
if
all
test
runs
are
below
the
MDL,
and
that
section
5(
f)
does
not
mean
that
all
emission
points
with
detected
HAP
measurements
of
below
1
ppm
can
be
disregarded.

The
industry
representatives
stated
that
they
would
like
to
estimate
emissions
from
lumber
kilns
and
plywood
presses
because
of
the
technical
difficulty
capturing
emissions
from
these
process
units.
In
addition,
the
industry
representatives
suggested
that
only
one
of
multiple
dryers
at
a
facility
be
tested
(
e.
g.,
only
one
of
three
veneer
dryers).
The
RTI
representative
suggested
that
there
would
need
to
be
some
explanation
of
how
the
dryers
were
identical
(
e.
g.,
the
dryers
had
the
same
firing
method,
dry
the
same
wood
type
at
the
same
temperature,
etc.).
In
addition,
one
industry
representative
suggested
that
EPA
allow
facilities
to
measure
HAP
concentration
without
determining
the
associated
flow
rate
if
the
concentration
is
less
than
1
ppm
for
certain
miscellaneous
process
units.
The
industry
representative
stated
that
many
processes
do
not
have
stacks
that
meet
the
EPA
Method
1­
2
flow
measurement
criteria
as
currently
configured,
and
installing
such
stacks
would
be
expensive.
If
the
HAP
concentration
was
detected,
then
the
facility
would
install
the
stack
necessary
to
meet
EPA
Methods
1­
2.
Another
industry
representative
asked
if
emission
testing
conducted
previously
(
e.
g.,
NCASI
testing)
could
be
used.
The
EPA
representatives
stated
that
they
would
consider
the
industry's
questions
and
suggestions
related
to
emissions
testing
for
Appendix
B,
and
asked
the
industry
representatives
to
send
a
list
of
their
concerns.

B.
Appendix
B
Exposure
Estimation
Issues
The
industry
representatives
noted
that
lead
was
listed
in
Appendix
B
Table
1
as
a
HAP
for
which
chronic
inhalation
carcinogenic
effects
must
be
considered.
However,
there
currently
is
no
established
unit
risk
estimate
(
URE)
on
the
EPA
website
cited
in
Appendix
B
for
lead.
An
EPA
representative
explained
that
a
lead
URE
was
posted
on
the
EPA
website
at
the
time
when
EPA
started
their
risk
analysis
for
the
PCWP
industry.
However,
the
lead
URE
was
later
removed
from
the
website
due
to
uncertanties.
The
EPA
representatives
stated
that
if
there
is
no
dose­
response
value
on
the
EPA
website,
then
the
pollutant
does
not
need
to
be
included
in
the
facility's
risk
demonstration.

The
industry
representatives
also
asked
what
type
of
justification
would
be
needed
to
use
a
dose­
response
value
other
than
an
EPA
Integrated
Risk
Information
System
(
IRIS)
value.
An
EPA
representative
noted
that
Appendix
B
specifies
that
the
dose­
response
values
on
EPA's
3
website
are
to
be
used,
and
that
these
values
are
not
limited
to
IRIS
values.
The
Latham
&
Watkins
representative
noted
that
Appendix
B
section
4
says
that
facilities
"
should"
use
the
values
on
the
EPA
website,
and
stated
that
the
dose­
response
values
posted
on
the
EPA
website
cannot
be
dictated
in
a
rulemaking
because
they
have
not
undergone
public
notice
and
comment.
The
EPA
representatives
stated
that
they
would
need
to
discuss
this
issue
internally
before
providing
a
response.

The
industry
representatives
then
inquired
about
the
meaning
of
the
footnote
at
the
end
of
Appendix
B
Table
4
(
noncarcinogen
lookup
table)
which
says,
"
HI=
1.
However,
EPA
may
require
a
more
stringent
level
in
specific
cases,
which
will
correspondingly
render
the
emission
rates
in
the
table
more
stringent."
The
EPA
representatives
stated
that
they
would
get
back
to
the
industry
representatives
on
this
issue.
An
EPA
representative
indicated
that
the
lookup
tables
should
also
refer
to
the
property
boundary
instead
of
the
"
distance
to
nearest
residence"
and
that
this
conforming
change
would
be
made
prior
to
publication.

Another
industry
representative
questioned
the
calculation
of
average
stack
height
and
indicated
that
if
all
fugitive
emission
sources
at
a
plant
are
included
in
the
calculation,
then
the
average
stack
height
would
be
near
zero.
An
EPA
representative
stated
that
EPA
was
inclined
to
exclude
ground
level
fugitive
emission
sources
from
the
average
stack
height
calculation.
However,
the
emissions
from
ground
level
emission
sources
would
be
considered
in
the
risk
analysis.
The
industry
representative
stated
that
this
approach
sounds
reasonable,
and
pointed
out
the
lumber
kilns
are
near
ground
level.
He
also
stated
that
veneer
dryer
cooling
sections
are
merely
blowing
air.

C.
Appendix
B
Title
V
Permit
Timing
Issues
The
industry
representatives
noted
that
Appendix
B
would
require
enforceable
limits
to
be
incorporated
into
title
V
permits
within
2
years.
However,
this
could
be
an
issue
because
States
are
not
always
timely
with
title
V
permit
changes.
The
industry
representatives
suggested
that
both
the
PCWP
and
Boilers
risk
appendices
require
only
that
the
permit
revisions
be
submitted
to
the
permitting
agency
within
the
2
year
time
frame.

The
industry
representatives
asked
if
EPA
would
review
a
template
low­
risk
demonstration
developed
by
the
industry.
The
industry
representatives
noted
that
the
upcoming
risk
assessment
guidelines
would
be
lengthy
and
difficult
for
smaller
facilities
to
digest.
The
EPA
representatives
agreed
that
a
template
low­
risk
demonstration
would
be
useful.

Another
industry
representative
suggested
that
section
10(
c)
of
Appendix
B
seems
to
eliminate
new
sources
from
eligibility
for
the
low­
risk
subcategory
option.

The
EPA
representatives
indicated
that
they
would
be
sending
information
to
the
eight
facilities
named
as
part
of
the
low­
risk
subcategory
in
the
final
PCWP
preamble
to
assist
them
with
their
title
V
permit
revisions.

D.
Subpart
DDDD
Definition
of
Flame
Zone
The
industry
representatives
acknowledged
that
EPA
had
changed
the
final
rule
to
allow
combustion
units
with
less
than
44
megawatts
(
MW)
capacity
that
accept
process
exhaust
into
the
flame
zone
to
be
exempt
from
the
emission
testing
and
monitoring
requirements.
One
industry
representative
stated
that
the
definition
of
"
flame
zone"
in
the
final
PCWP
rule
appears
to
have
been
lifted
from
other
MACT
rules
where
the
flame
zone
is
better
defined
(
e.
g.,
for
liquid
fuel
combustion
units).
However,
the
flame
zone
for
PCWP
combustion
units
(
e.
g.,
spreader­
stoker
units)
is
not
well­
defined
and
the
process
exhaust
would
almost
have
to
enter
into
the
unit
with
the
fuel.
The
industry
representative
explained
that
solid
fuel
burners
inject
small
volumes
of
air
with
the
fuel
and
larger
volumes
of
air
as
undergrate
air.
In
addition,
there
is
a
small
amount
of
overfire
air
(
secondary
air
needed
to
complete
the
combustion
process).
In
order
to
inject
process
exhaust
somewhere
else,
the
fire
walls
of
the
combustor
would
have
to
be
breeched.
Spreaderstoker
units
are
just
one
type
of
PCWP
combustion
unit.
Other
types
of
PCWP
combustion
units
include
Wellons
units,
suspension
burners,
and
fluidized
beds.
The
industry
representatives
questioned
the
justification
for
the
definition
of
"
flame
zone"
used
in
other
rules
(
e.
g.,
the
time
and
temperature
requirements).
An
EPA
representative
stated
that
EPA
would
need
to
consider
the
PCWP
combustion
units
and
determine
how
they
differ
from
the
combustion
units
for
which
the
definition
of
"
flame
zone"
was
originally
written
and
determine
how
the
PCWP
combustion
units
would
meet
the
underlying
requirements.

E.
Subpart
DDDD
Sampling
Location
for
Combined
Control
Devices
One
industry
representative
noted
that
the
final
rule
specifies
that
the
sampling
location
for
combined
control
devices
(
e.
g.,
wet
electrostatic
precipitator
(
WESP)
followed
by
a
regenerative
thermal
oxidizer
(
RTO))
is
the
functional
inlet
of
the
control
devices
(
e.
g.,
before
the
WESP).
The
industry
representative
stated
that
in
some
instances
there
my
be
no
good
location
to
sample
prior
to
the
WESP,
and
asked
EPA
to
also
allow
sampling
across
the
RTO
alone.
The
RTI
representative
acknowledged
the
concern
and
noted
that
the
sampling
location
specified
in
the
final
rule
was
a
change
made
in
response
to
industry
comments.

An
industry
representative
asked
EPA
when
the
final
rule
may
be
published
in
the
Federal
Register.
An
EPA
representative
stated
that
EPA
had
not
yet
received
the
galley
proofs
of
the
Federal
Register
notice
to
review
so
the
publication
date
could
be
anywhere
from
weeks
to
months
away.
Some
minor
editorial,
formatting,
and/
or
conforming
changes
may
be
made
to
the
final
Federal
Register
notice.
However,
no
substantive
changes
will
be
made
and
no
delays
in
publication
are
expected.
Attachment
1
List
of
Participants
U.
S.
EPA
Mary
Tom
Kissell,
OAQPS
Ken
Hustvedt,
OAQPS
Scott
Jenkins,
OAQPS
Gary
McAlister,
OAQPS
Robert
Fegley,
ORD
PCWP
Industry
John
Bradfield,
Composite
Panel
Association
Victor
Dallons,
Weyerhaeuser
Phil
Ferguson,
International
Paper
David
Harvey,
Louisiana­
Pacific
Corporation
Don
Hejna,
Potlatch
Corporation
Tim
Hunt,
American
Forest
and
Paper
Association
Rob
Kaufman,
Georgia­
Pacific
Corporation
Claudia
O'Brien,
Latham
and
Watkins,
Counsel
for
American
Forest
and
Paper
Association
John
Orynawka,
Temple­
Inland
Corporation
Lori
Chalker,
Temple­
Inland
Corporation
Lawrence
Otwell,
Georgia­
Pacific
Corporation
David
Word,
National
Council
for
Air
and
Stream
Improvement
Paul
Vasquez,
Georgia­
Pacific
Corporation
Louis
Wagner,
American
Fiberboard
Association
Stephen
Woock,
Weyerhaeuser
Gary
Gramp,
Hardwood
Plywood
and
Veneer
Association
Russell
Frye,
Collier
Shannon
Scott,
Counsel
for
Louisiana­
Pacific
Corporation
Glynn
Rountree,
American
Forest
and
Paper
Association
George
Ellis,
International
Paper
John
Pinkerton,
National
Council
for
Air
and
Stream
Improvement
Tom
Crawshaw,
Masonite
Corporation
Russell
Strader,
Boise
Cascade
Corporation
Research
Triangle
Institute
Katie
Hanks
