From:
Katie
Hanks
To:
Mary
Tom
Kissell
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
April
27,
2004
Project:
Plywood
and
Composite
Wood
Products
NESHAP
Re:
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
I.
Purpose
The
EPA
participated
in
a
conference
call
with
members
of
AF&
PA
and
other
representatives
of
the
PCWP
industry
on
March
29,
2004,
to
discuss
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.
Specifically,
the
industry
representatives
expressed
their
concerns
with
the
emission
testing
requirements
in
Appendix
B
to
subpart
DDDD
(
the
final
PCWP
rule).
Appendix
B
specifies
the
procedures
facilities
must
use
if
they
wish
to
demonstrate
eligibility
for
the
lowrisk
subcategory.

II.
Discussion
The
industry
representatives
noted
that
Appendix
B
requires
emission
testing
of
all
process
units
for
the
following
organic
HAP:
acetaldehyde,
acrolein,
benzene,
formaldehyde,
and
phenol.
They
stated
that
there
is
some
ambiguity
in
the
term
"
process
unit."
The
term
"
process
unit"
is
used
broadly
in
some
instances
in
the
final
PCWP
preamble,
but
is
used
more
specifically
2
in
the
final
PCWP
rule
language.
In
addition,
there
is
a
footnote
in
Appendix
B
which
states,
"
If
EPA
approves
that
your
process
unit
will
not
emit
detectable
amounts
of
benzene
or
acrolein,
that
unit
may
be
excluded
from
the
testing
requirement
in
this
table."
This
footnote
seems
to
indicate
that
EPA
intends
to
work
with
industry
to
specify
which
process
units
must
be
tested
for
acrolein
and
benzene.
The
industry
representatives
stated
that
preparations
for
emissions
testing
would
need
to
be
under
way
soon
(
i.
e.,
preliminary
engineering
within
the
year),
and
that
testing
every
process
unit
for
acetaldehyde,
formaldehyde,
and
phenol
would
be
tremendously
resource
intensive.
Some
of
these
HAP
would
not
be
expected
from
every
process
unit,
and
there
is
technical
difficulty
associated
with
emission
testing
for
some
process
units.
Furthermore,
the
industry
representative
indicated
that
acrolein
and
acetaldehyde
are
risk
drivers
for
noncarcinogenic
effects.
The
industry
representatives
stated
that
EPA
should
also
consider
only
those
process
units
with
significant
levels
of
Appendix
B
organic
HAP.
Given
these
concerns,
the
industry
representatives
asked
if
EPA
could
clarify
the
final
PCWP
rule
before
it
is
published
in
the
Federal
Register.
The
EPA
representatives
stated
that
they
would
like
to
understand
better
the
industry's
specific
concerns.

The
industry
representatives
asked
if
EPA
clearly
intended
to
define
"
process
unit"

broadly.
The
EPA
representatives
stated
that
they
did
intend
to
define
"
process
unit"
broadly
so
that
emissions
from
all
process
units
must
be
considered
in
PCWP
low­
risk
demonstrations
performed
according
to
Appendix
B.

The
industry
representatives
stated
that
the
footnote
regarding
acrolein
and
benzene
could
be
interpreted
two
ways:
(
1)
that
process
units
with
no
detectable
acrolein
and
benzene
need
not
be
tested
for
any
of
the
Appendix
B
HAP,
or
(
2)
process
units
with
no
detectable
acrolein
and
benzene
need
not
be
tested
for
acrolein
and
benzene
(
but
must
be
tested
for
the
other
Appendix
B
HAP).
The
industry
representatives
suggested
that
the
footnote
be
clarified,
or
that
a
clarification
be
included
in
Appendix
B
section
5.
The
purpose
of
the
clarification
would
be
to
exempt
from
Appendix
B
emissions
testing
the
process
units
where
the
Appendix
B
HAP
are
not
expected
to
be
emitted.
The
industry
representatives
asked
of
EPA
could
clarify
the
final
rule
before
it
is
published
in
the
Federal
Register,
and
stated
that
they
would
prefer
to
see
the
rule
clarified
now
rather
than
later
through
a
direct
final
rule
amendment.
3
The
industry
representatives
stated
that
they
do
not
have
a
single
recommendation
for
narrowing
the
scope
of
Appendix
B
emissions
testing,
but
did
have
some
general
ideas.
The
EPA
representatives
stated
that
developing
an
emission
estimation
methodology
for
the
hard­
to­
test
process
units
would
be
preferred
rather
than
dropping
process
units
from
consideration
under
Appendix
B.
The
industry
representatives
stated
that
the
NCASI
emission
testing
data
and
AP­
42
data
that
have
been
compiled
for
the
PCWP
industry
could
be
the
basis
for
an
emission
estimation
method
(
i.
e.,
emission
factor
calculations
for
miscellaneous
process
units).
The
EPA
representatives
stated
that
they
would
like
specific
suggestions
from
the
industry,
including
identification
of
the
process
units
that
are
difficult
to
test
and
applicable
emission
estimation
methods
for
these
process
units.
One
industry
representative
stated
that
the
process
units
that
are
hard
to
test
will
vary
from
plant
to
plant
because
of
different
plant
configurations.
Another
industry
representative
stated
that
EPA
should
also
consider
the
contribution
to
facility­
wide
HAP
emissions
from
each
type
of
process
unit
(
i.
e.,
some
miscellaneous
process
units
may
emit
only
small
amounts
of
HAP).
The
industry
representatives
identified
lumber
kilns
as
hard­
to­
test
units
because
they
have
many
vents
and
the
testing
period
would
have
to
be
24
to
36
hours
due
to
the
batch
nature
of
the
process.
Also,
softwood
plywood
presses
would
require
a
temporary
total
enclosure
(
TTE)
for
testing
because
they
are
configured
with
roof
cupolas.
Other
types
of
operations
that
the
industry
representatives
would
prefer
not
to
test
include
(
but
are
not
limited
to)
wastewater
operations,
chippers,
saws,
tanks,
refiners,
adhesive
preparation
units,

maintenance
activities,
wood
fuel
storage,
log
decks,
conveyors,
and
stand
alone
digesters.
The
industry
representatives
agreed
to
provide
EPA
with
some
specific
suggestions
at
a
later
date.

The
industry
representatives
also
asked
how
they
should
include
ground­
level
emission
sources
in
the
average
stack
height
calculation.
They
argued
that
90
percent
of
the
emissions
from
the
facility
would
be
from
dryers
and
presses,
and
that
they
were
hoping
to
exclude
sources
that
contribute
a
negligible
amount
of
HAP
from
the
risk
analysis
required
in
Appendix
B
(
rather
than
estimating
emissions
from
these
sources).
The
industry
representatives
pointed
out
that
many
of
their
miscellaneous
processes
are
fugitive
emission
sources,
and
that
the
testing
procedures
in
Appendix
B
cannot
be
applied
to
fugitive
sources.
An
EPA
representative
suggested
again
that
emission
estimation
procedures
would
be
preferable
for
these
types
of
sources.
4
The
industry
representatives
stated
that
timing
is
critical,
and
that
changes
to
Appendix
B
would
need
to
be
made
quickly,
preferably
before
publication
in
the
Federal
Register,
so
facilities
can
proceed
with
their
emissions
testing
programs
well
before
the
MACT
compliance
date.
The
EPA
representatives
stated
that
they
could
not
address
timing
of
changes
during
the
meeting.
However,
EPA
could
investigate
and
make
decisions
on
specific
changes
that
may
be
needed
so
that
these
changes
can
be
incorporated
at
a
later
date.
Significant
changes
to
the
signed
version
of
the
final
rule
may
not
be
appropriate.

The
industry
representatives
asked
how
the
HAP
listed
in
Appendix
B
were
selected,
and
if
it
was
possible
to
determine
which
process
units
had
these
HAP
as
risk
drivers.
The
EPA
representatives
stated
that
the
HAP
listed
in
Appendix
B
selected
because
they
were
determined
to
drive
risk.
The
emission
estimates
used
as
risk
inputs
were
facility
total
HAP
emissions,
and
not
emissions
by
process
unit.
Risk
drivers
were
identified
as
HAP
that
contributed
more
than
5
percent
of
the
risk
at
any
facility.

The
RTI
representative
pointed
out
that
the
same
test
method
could
be
used
for
most
of
the
appendix
B
organic
HAP,
and
asked
if
the
cost
savings
would
be
significant
if
the
number
of
pollutants
tested
at
each
process
unit
was
reduced.
An
industry
representative
stated
that
the
sampling
cost
changes
significantly
with
additional
HAP,
especially
acetaldehyde,
acrolein,
and
benzene
because
these
HAP
require
rather
sophisticated
measurement
techniques.
The
industry
representatives
stated
that
reducing
the
number
of
process
units
to
be
tested
would
likely
do
more
to
reduce
emission
testing
costs
than
reducing
the
number
of
pollutants
measured
for
each
type
of
process
unit
(
although
the
later
also
reduces
costs
significantly).

The
industry
representatives
asked
why
emission
factors
could
not
be
used
instead
of
emission
testing
for
purposes
of
Appendix
B,
especially
for
facilities
that
can
demonstrate
that
they
are
well
below
the
low­
risk
criteria
using
emission
estimates.
They
noted
that
the
production­
based
compliance
options
(
PBCO)
were
based
on
emission
factors.
The
RTI
representative
noted
that
emission
factors
from
individual
emission
tests
(
as
opposed
to
average
emission
factors)
were
used
in
developing
the
PBCO,
and
that
the
process
units
with
PBCO
(
i.
e.,

dryers,
presses)
are
generally
the
types
of
process
units
for
which
more
emissions
test
data
are
available.
Variability
and
representativeness
can
be
issues
with
emission
factors,
especially
when
only
one
or
two
emissions
tests
have
been
conducted.
Few
emission
tests
have
been
conducted
5
for
most
types
of
miscellaneous
process
units,
and
the
configuration
of
these
process
units
can
vary
from
facility
to
facility.
For
example,
for
some
miscellaneous
process
units
there
may
be
only
be
one
emission
factor
based
on
one
test
where
the
process
unit
throughput
was
difficult
to
determine.
The
EPA
representative
reminded
the
industry
representatives
that
the
purpose
of
the
procedures
in
Appendix
B
is
to
ensure
that
low­
risk
facilities
do
not
pose
a
risk
to
the
public.

Another
industry
representative
stated
that
to
build
an
information
base
to
assist
with
this
type
of
decision­
making
would
be
a
big
effort
and
could
not
be
done
in
a
short
amount
of
time.
The
industry
representatives
stated
that
they
did
not
want
the
emission
testing
procedures
for
the
lowrisk
demonstration
to
be
so
impossible
that
they
discourage
use
of
the
low­
risk
provisions.

In
closing,
the
industry
representatives
asked
for
an
update
on
when
the
final
rule
may
be
published
in
the
Federal
Register.
The
EPA
representatives
stated
that
they
had
not
yet
reviewed
the
galley
proofs
and
did
not
know
when
the
final
rule
would
be
published.
Attachment
1
List
of
Participants
U.
S.
EPA
Mary
Tom
Kissell,
OAQPS
Scott
Jenkins,
OAQPS
Gary
McAlister,
OAQPS
PCWP
Industry
Phil
Ferguson,
International
Paper
David
Harvey,
Louisiana­
Pacific
Corporation
Tim
Hunt,
American
Forest
and
Paper
Association
Claudia
O'Brien,
Latham
and
Watkins,
Counsel
for
American
Forest
and
Paper
Association
David
Word,
National
Council
for
Air
and
Stream
Improvement
Research
Triangle
Institute
Katie
Hanks
