­­­­­
Original
Message­­­­­
From:
Woock,
Steve
[
mailto:
steve.
woock@
weyerhaeuser.
com]
Sent:
Friday,
June
11,
2004
10:
00
AM
To:
'
kissell.
mary@
epa.
gov';
'
kphanks@
rti.
org';
'
nizich.
g@
epa.
gov'
Subject:
New
PCWP­
Boiler
MACTS
Overlap
Issue
Mary
Tom,
Katie,
and
Greg
­
I
talked
with
Mary
Tom
in
the
late
afternoon
Thursday
about
this.
She
asked
that
I
summarize
the
situation
and
email
you
all
as
soon
as
possible
today.

I've
put
the
information
in
the
attached
document
to
preserve
some
formatting.
I
will
try
to
reach
Katie
to
discuss
this
afternoon.

Thank
you
very
much
for
your
attention
to
this
question.

Steve
Woock
Stephen
E.
Woock
Federal
Regulatory
Affairs
Manager,
Weyerhaeuser
PO
Box
1391,
New
Bern,
NC
28563­
1391
steve.
woock@
weyerhaeuser.
com
ph
252­
633­
7351
June
11,
2004
Mary
Tom
Kissell
EPA
cc:
Katie
Hanks
RTI
Greg
Nizich
EPA
Mary
Tom:

We
are
working
with
a
state
to
permit
construction
activities
at
a
wood
products
facility.
Because
of
the
timing
of
the
work
with
respect
to
the
MACT
rule
promulgation,
the
state
plans
to
incorporate
provisions
from
both
of
the
signed
PCWP
NESHAP
and
the
signed
Industrial,
Commercial
and
Institutional
Boilers
and
Process
Heaters
NESHAP,
in
the
permit.
The
state
very
recently
has
taken
the
position
that
a
process
heater
routinely
exhausted
through
a
strand
dryer
for
additional
heat
recovery
is
subject
to
the
Boiler
and
Process
Heater
MACT
rule.
We
believe
EPA
intended
that
process
heaters
that
exhaust
through
dryers
are
included
in
the
floor
and
are
included
in
the
source
definition
of
the
PCWP
MACT,
as
indicated
in
the
proposed
and
final
rule
preambles
and
responses
to
comments.

Please
note
that
this
is
not
a
question
of
coverage
when
the
process
heater
exhaust
is
temporarily
bypassing
the
dryers,
which
has
been
raised
to
you
before
as
the
"
Boiler
Overlap"
question.

I
will
describe
the
situation
in
more
detail
below
for
your
review
and
I
will
followup
with
a
call
to
Katie
Hanks
and
Greg
Nizich
since
I
understand
you
are
soon
to
take
some
important
leave
from
work.

We
believe
the
state
is
mis­
interpreting
the
rule
and
this
would
set
an
incorrect
precedent
for
all
wood
products
facilities
just
as
you
all
are
preparing
the
rule
for
publication.
However,
after
reviewing
the
rule
language
in
the
Boiler
and
Process
Heater
MACT
and
PCWP
MACT
rules,
we
can
see
why
a
state
might
make
an
incorrect
interpretation
on
this.
I
will
provide
the
language
from
both
rules
that
leads
to
this
situation
and
a
suggestion
for
a
possible
remedy.
After
you
see
the
language,
you
may
consider,
as
we
do,
whether
this
is
an
inadvertent
error
that
might
be
remedied
in
the
rule
being
prepared
for
publication.

The
facility
will
have
two
direct­
fired
strand
dryers
that
are
heated
with
combustion
gases
from
two
suspension
burners
and
the
total
exhaust
from
a
wood
residue
fired
thermal
oil
heater.
The
hot
gases
from
the
wood
combustion
first
work
to
heat
oil.
The
remaining
heat
from
those
same
gases
then
is
used
by
mixing
the
exhaust
from
the
process
heater
with
the
heated
gases
from
the
suspension
burners
to
provide
heat
to
the
strand
dryers.
This
configuration
is
typical
in
the
industry
and
is
the
type
of
circumstance
we
understood
to
be
covered
under
the
PCWP
MACT
as
described
in
the
proposed
rule
preamble:
PCWP
proposed
rule,
68
FR
January
9,
2003
pg
1304
Column
1:
C.
Combustion
Related
NESHAP
Plywood
and
composite
wood
products
facilities
operate
combustion
units
such
as
boilers,
fuel
cells,
and
thermal
oil
heaters
that
supply
heat
to
process
units
such
as
dryers
and
presses
that
are
used
in
the
manufacture
of
PCWP.
When
the
combustion
unit
supplies
heat
by
directly
exhausting
the
combustion
gas
through
a
dryer,
the
dryer
is
considered
a
``
direct­
fired
dryer.''
Therefore,
the
HAP
emissions
from
a
direct­
fired
dryer
are
actually
a
combination
of
the
emissions
from
the
combustion
unit
exhausting
into
the
dryer
and
the
emissions
that
result
from
drying
the
wood.
Because
today's
proposed
rule
regulates
emissions
from
direct­
fired
dryers,
those
combustion
units
associated
with
direct­
fired
dryers
are
excluded
from
the
requirements
of
other
combustion­
related
NESHAP,
such
as
the
Industrial/
Commercial/
Institutional
Boilers
NESHAP
and
the
Process
Heaters
NESHAP.
However,
those
combustion
units
that
supply
heat
or
steam
to
indirect­
fired
dryers
or
presses
(
i.
e.,
combustion
unit
exhaust
does
not
contact
wood
particles
or
veneers),
and
those
thermal
oil
heaters
that
supply
hot
oil
for
presses
but
which
don't
exhaust
through
dryers
are
not
covered
by
today's
proposed
rule
and
would
be
subject
to
the
requirements
the
applicable
combustion
related
NESHAP.

The
state
staff
we
are
working
with
has
taken
the
position
that
the
exhaust
from
the
thermal
oil
heater
is
routinely
subject
to
the
Boiler
and
Process
Heater
MACT.
They
cite
that
the
primary
purpose
of
the
combustion
unit
is
to
heat
the
oil
that
is
used
to
provide
heat
in
other
parts
of
the
process
and
the
facility
buildings.
They
believe
the
heat
going
to
the
dryers
is
only
"
waste
heat"
and
therefore,
is
subject
to
the
Boiler
and
Process
Heater
MACT.
The
language
in
the
two
MACT
rules
may
contribute
to
their
thinking
since
the
coverage
anticipated
under
the
PCWP
MACT
for
the
exhausts
from
energy
sources
providing
heat
to
direct­
fired
dryers
is
not
explicitly
listed
in
the
PCWP
MACT
as
part
of
the
affected
PCWP
source
category,
whereas
the
Boiler
and
Process
Heater
MACT
requires
boilers
and
process
heaters
to
be
specifically
listed
in
the
affected
source
of
the
other
MACT
if
the
units
are
to
be
exempted
from
Boiler
and
Process
Heater
MACT
coverage.
Here
is
the
relevant
language
from
the
two
rules:

BOILER
MACT
§
63.7491
Are
any
boilers
or
process
heaters
not
subject
to
this
subpart?

The
types
of
boilers
and
process
heaters
listed
in
paragraphs
(
a)
through
(
o)
of
this
section
are
not
subject
to
this
subpart.
 
(
l)
Any
boiler
and
process
heater
specifically
listed
as
an
affected
source
in
another
standard(
s)
under
40
CFR
part
63.
PCWP
MACT
§
63.2232
What
parts
of
my
plant
does
this
subpart
cover?

(
a)
This
subpart
applies
to
each
new,
reconstructed,
or
existing
affected
source
at
a
PCWP
manufacturing
facility.

(
b)
The
affected
source
is
the
collection
of
dryers,
refiners,
blenders,
formers,
presses,
board
coolers,
and
other
process
units
associated
with
the
manufacturing
of
plywood
and
composite
wood
products.
The
affected
source
includes,
but
is
not
limited
to,
green
end
operations,
refining,
drying
operations,
resin
preparation,
blending
and
forming
operations,
pressing
and
board
cooling
operations,
and
miscellaneous
finishing
operations
(
such
as
sanding,
sawing,
patching,
edge
sealing,
and
other
finishing
operations
not
subject
to
other
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)).
The
affected
source
also
includes
onsite
storage
and
preparation
of
raw
materials
used
in
the
manufacture
of
plywood
and/
or
composite
wood
products,
such
as
resins;
onsite
wastewater
treatment
operations
specifically
associated
with
plywood
and
composite
wood
products
manufacturing;
and
miscellaneous
coating
operations
(
§
63.2292).
The
affected
source
includes
lumber
kilns
at
PCWP
manufacturing
facilities
and
at
any
other
kind
of
facility.

Although
dryers
and
drying
operations
are
listed
in
the
PCWP
MACT
rule,
the
energy
systems
are
not
explicitly
listed.
Also,
there
is
no
definition
for
drying
operations
that
might
include
the
energy
system.

Perhaps
the
most
direct
way
to
assure
that
the
PCWP
MACT
coverage
of
the
emissions
from
direct­
fired
dryers
includes
coverage
of
the
energy
systems
providing
direct
heat
to
the
dryers
and
thereby
avoid
overlap
with
Boiler
and
Process
Heater
MACT
is
to
add
some
appropriate
words
to
the
PCWP
affected
source
description.
Here
is
an
example,
with
changes
underlined:

(
b)
The
affected
source
is
the
collection
of
dryers,
refiners,
blenders,
formers,
presses,
board
coolers,
and
other
process
units
associated
with
the
manufacturing
of
plywood
and
composite
wood
products.
The
affected
source
includes,
but
is
not
limited
to,
green
end
operations,
refining,
drying
operations
including
any
energy
system
exhaust
routinely
providing
direct
heat
(
combustion
gases
coming
in
contact
with
product
components)
to
dryers,
resin
preparation,
blending
and
forming
operations,
pressing
and
board
cooling
operations,
and
miscellaneous
finishing
operations
(
such
as
sanding,
sawing,
patching,
edge
sealing,
and
other
finishing
operations
not
subject
to
other
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)).
The
affected
source
also
includes
onsite
storage
and
preparation
of
raw
materials
used
in
the
manufacture
of
plywood
and/
or
composite
wood
products,
such
as
resins;
onsite
wastewater
treatment
operations
specifically
associated
with
plywood
and
composite
wood
products
manufacturing;
and
miscellaneous
coating
operations
(
§
63.2292).
The
affected
source
includes
lumber
kilns
at
PCWP
manufacturing
facilities
and
at
any
other
kind
of
facility.

Per
your
request,
I
will
contact
Katie
and
Greg
to
follow­
up.
Thank
you
for
your
time.

­
Steve
Woock
Stephen
E.
Woock
Federal
Regulatory
Affairs
Manager,
Weyerhaeuser
PO
Box
1391,
New
Bern,
NC
28563­
1391
steve.
woock@
weyerhaeuser.
com
phone
252­
633­
7351
