From:
Rebecca
Nicholson
and
Katie
Hanks
To:
Mary
Tom
Kissell
Waste
and
Chemical
Processes
Group
(
WCPG),
C439­
03
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
November
8,
2004
Project:
Plywood
and
Composite
Wood
Products
NESHAP
Re:
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
I.
Purpose
The
EPA
participated
in
a
meeting
with
members
of
AF&
PA
and
other
representatives
of
the
PCWP
industry
on
October
29,
2004,
to
discuss
industry
questions
and
concerns
related
to
potential
amendments
to
the
final
Plywood
and
Composite
Wood
Products
(
PCWP)
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP).
The
list
of
participants
is
included
as
Attachment
1
and
the
agenda
prepared
for
the
meeting
is
included
in
Attachment
2.

II.
Discussion
A.
Update
on
Draft
Amendment
Proposal
The
meeting
began
with
introductions
and
an
update
by
EPA
on
the
status
of
the
amendment
proposal
under
development
for
the
PCWP
NESHAP.
The
majority
of
the
amendments
under
consideration
would
affect
Appendix
B
to
subpart
DDDD,
the
procedures
that
facilities
must
use
to
demonstrate
that
they
belong
in
the
delisted
low­
risk
subcategory,
and
in
particular,
the
procedures
for
determining
mass
emissions
from
individual
process
units
within
each
PCWP
affected
source.
An
EPA
representative
stated
that
EPA
staff
and
RTI
have
been
drafting
the
amendment
proposal
that
will
be
recommended
to
the
EPA
work
group
and
EPA
management.
The
amendment
package
must
first
undergo
formal
EPA
review
and
then
OMB
review
(
a
process
that
could
take
up
to
90
days).
Thus,
the
current
draft
of
the
amendment
proposal
could
change.
The
AF&
PA
representative
stated
that
the
industry
is
anxious
to
resolve
any
issues
because
member
companies
are
working
hard
to
determine
if
their
facilities
meet
the
2
low­
risk
criteria
before
the
July
2006
low­
risk
demonstration
submittal
date
(
which
is
less
than
2
years
away).
He
noted
that
most
of
the
PCWP
risk
demos
would
likely
be
submitted
to
EPA
just
prior
to
the
July
2006
deadline.

The
discussion
then
turned
to
a
draft
summary
of
the
amendments
under
consideration
(
provided
in
Attachment
3).
Except
as
discussed
below,
most
of
the
draft
amendments
listed
in
Attachment
3
were
self­
explanatory
and
did
not
require
lengthy
discussion.
An
EPA
representative
noted
the
table
item
in
Attachment
3
labeled
as
"
Appendix
B"
and
stated
that
EPA
is
considering
whether
to
add
a
requirement
to
Appendix
B
for
facilities
to
continually
consider
dose­
response
values
for
PCWP
hazardous
air
pollutants
(
HAP)
in
addition
to
the
13
HAP
listed
in
Appendix
B
(
as
promulgated).
Should
dose­
response
values
change
such
that
they
become
more
health
protective,
then
Appendix
B
(
following
amendment)
would
require
facilities
to
revisit
their
risk
analyses
to
ensure
they
remain
in
the
low­
risk
subcategory.
However,
specific
rule
language
for
this
amendment
has
not
yet
been
developed.
The
industry
representatives
objected
to
this
potential
amendment.
The
AF&
PA
representative
argued
that
once
whole
source
categories
are
delisted,
EPA
does
not
revisit
their
previous
delisting
decisions
every
time
a
doseresponse
value
changes.
An
EPA
representative
responded
that
EPA
could
relist
a
source
category
if
it
was
found
to
pose
more
risk
than
originally
thought,
and
stated
that
EPA
needs
to
establish
a
process
for
considering
the
potential
risk
posed
by
additional
PCWP
HAP
in
the
future
should
these
additional
HAP
be
deemed
more
potent.
The
Georgia­
Pacific
representative
stated
that,
while
facilities
ensure
continuous
compliance
with
permit
limits,
they
are
not
in
the
practice
of
staying
abreast
of
risk
benchmarks.
However,
an
EPA
representative
noted
that
facilities
becoming
part
of
the
PCWP
low­
risk
subcategory
are
already
required
to
track
changes
in
the
dose­
response
values
for
the
13
HAP
listed
in
Appendix
B
(
as
promulgated),
and
that
tracking
changes
in
dose­
response
values
for
an
additional
17
or
so
HAP
is
little
added
effort.
The
AF&
PA
representative
then
suggested
that
under
the
approach
used
by
EPA
in
selecting
the
13
HAP
included
in
the
promulgated
Appendix
B
(
i.
e.,
the
HAP
that
contribute
95
percent
of
the
risk),
as
additional
HAP
come
onto
the
list
of
significant
risk
contributors,
the
effects
of
other
HAP
would
diminish
such
that
some
of
the
13
HAP
could
be
removed
from
consideration
under
Appendix
B.

The
industry
representatives
supported
EPA's
draft
amendment
to
Appendix
B
section
5(
j),
that
would
allow
only
one
of
multiple
similar
process
units
at
a
plant
site
to
be
tested
(
e.
g.,
one
of
three
veneer
dryers
at
a
plant).
However,
the
industry
representatives
requested
that
EPA
take
this
amendment
a
step
further
and
allow
test
data
for
a
process
unit
at
one
plant
to
be
applied
to
similar
process
units
at
other
plants
within
the
same
company
(
and
perhaps
at
other
companies).
The
industry
representatives
stated
that
this
is
commonly
done
for
permitting
purposes.
They
stated
that
they
would
justify
how
the
process
units
at
multiple
plants
are
similar
(
e.
g.,
same
model
unit,
similar
parameters,
same
heating
method),
just
as
they
would
justify
that
process
units
at
the
same
plant
site
are
similar.
An
RTI
representative
asked
how
often
facilities
would
be
required
to
conduct
emissions
testing
under
their
title
V
permits.
Two
of
the
industry
representatives
replied
that
the
amount
of
time
between
performance
tests
varies
from
State
to
1K.
Hanks,
K.
Parrish,
and
D.
Randall,
RTI,
to
M.
Kissell,
EPA/
ESD.
Procedures
for
Determining
Emissions
from
Plywood
and
Composite
Wood
Products
Process
Units
for
Low­
risk
Demonstrations.
Draft
in
progress.

3
State,
but
that
3
to
5
years
between
tests
is
common
for
demonstrating
compliance
with
permit
limits.
One
of
the
industry
representatives
stated
that
EPA
needs
to
consider
the
role
of
emissions
tests
in
the
low­
risk
demonstration,
and
stated
that
the
purpose
of
the
emissions
test
was
to
obtain
a
permit
limit.
The
industry
representative
stated
that
his
company
intends
to
use
conservative
emissions
values
(
e.
g.,
emission
test
result
plus
as
much
of
a
safety
factor
as
possible
while
remaining
low­
risk)
to
ensure
that
they
establish
a
permit
limit
that
can
be
met
at
all
times.
The
industry
representative
also
noted
that
emissions
from
a
single
process
unit
can
vary
by
±
20
percent.

An
NCASI
representative
asked
if
a
facility
can
test
one
vent
of
a
process
unit
and
assume
that
the
data
collected
for
that
vent
are
similar
to
other
identical
vents
on
the
same
process
unit
(
e.
g.,
for
PCWP
presses
with
multiple
vents).
An
RTI
representative
acknowledged
that
this
has
been
done
in
the
past,
and
that
the
test
report
should
provide
appropriate
rationale
for
testing
only
one
vent
and
calculations
showing
how
the
results
from
one
vent
were
also
applied
to
other
vents
(
i.
e.,
if
there
are
two
identical
vents
then
the
mass
emission
rate
from
the
vent
tested
should
be
multiplied
by
two
to
represent
the
total
emissions
from
the
process
unit).

B.
Process
Unit
Emission
Testing
Prior
to
the
meeting,
the
industry
representatives
were
provided
with
a
draft
table
listing
the
PCWP
process
units
and
indicating
whether
emissions
testing
would
continue
to
be
required
or
if
emissions
estimation
is
under
consideration
for
the
draft
amendments
to
Appendix
B.
If
emissions
estimation
is
under
consideration,
then
the
draft
table
presents
the
emission
factors
or
emissions
estimation
methodology
that
would
be
allowed.
Attachment
4
presents
the
draft
summary
of
testing
or
emissions
estimation
procedures
(
for
possible
inclusion
as
Table
6
to
Appendix
B
to
subpart
DDDD).
During
the
meeting,
EPA
also
handed
out
draft
process
unit
definitions
(
provided
in
Attachment
5)
under
consideration
for
inclusion
in
Appendix
B.
To
begin
the
discussion
of
process
unit
emissions
testing,
an
RTI
representative
explained
how
the
list
of
process
units
in
the
draft
Table
6
was
selected,
the
approach
used
in
deciding
whether
to
continue
to
require
emissions
testing
or
allow
emissions
estimates,
the
emissions
estimation
approach
selected,
and
how
emission
factors
are
to
be
applied.
All
of
this
information
will
be
documented
in
a
memorandum
supporting
development
of
the
amendment
proposal.
1
Next,
the
industry
representatives
raised
several
questions
related
to
the
draft
Table
6
and
associated
draft
process
unit
definitions.
The
industry's
concerns
are
summarized
in
the
following
paragraphs.

The
industry
representatives
reiterated
the
difficulties
of
testing
lumber
kilns
(
i.
e.,
24­
hour
or
longer
batch
cycle,
oscillating
vents,
etc.).
They
noted
that
some
facilities
may
pursue
testing
of
lumber
kilns
because
they
would
have
difficulty
meeting
the
low­
risk
criteria
4
(
particularly
with
the
look­
up
table
or
lower
tiered
risk
analyses)
if
they
used
the
lumber
kiln
acrolein
emission
factor
suggested
by
EPA
for
inclusion
in
the
proposed
amendments.
The
industry
representatives
requested
that
EPA
allow
use
of
small­
scale
lumber
kiln
emissions
testing.
They
noted
that
small­
scale
kilns
have
been
tested
in
the
past,
and
that
test
results
from
small­
scale
lumber
kilns
were
comparable
to
those
from
full­
scale
kilns
(
as
shown
in
NCASI
technical
bulletin
845).
They
stated
that
several
universities
have
small­
scale
lumber
kilns
that
could
be
used
for
emissions
testing
under
controlled
conditions
including:
Mississippi
State
University
(
contact
is
Leonard
Ingram),
Oregon
State
University
(
contact
is
Michael
Milota),
and
North
Carolina
State
University
(
NCSU
­
Bill
DeWees
with
DEECO
has
been
in
contact
with
NCSU).
There
could
be
commercial
facilities
with
small­
scale
kilns
as
well.
In
small­
scale
kiln
testing
a
sample
of
lumber
from
a
facility
is
sent
to
the
small­
scale
kiln
where
it
is
dried
under
conditions
mirroring
those
of
the
facility's
full­
scale
kilns.
Emissions
and
gas
flow
rates
are
easier
to
measure
at
small­
scale
kilns
than
for
full­
scale
kilns.
The
industry
representatives
felt
that
small­
scale
kiln
testing
would
provide
more
accurate
results
than
application
of
the
default
emission
factors
selected
by
EPA
for
inclusion
in
Appendix
B.
The
industry
representatives
acknowledged
that
they
are
unaware
of
any
small­
scale
kilns
that
are
direct­
fired.
An
NCASI
representative
stated
that
NCASI
has
tested
the
emissions
from
a
two­
stage
green
sawdust
burner
and
found
that
the
emissions
were
relatively
free
of
HAP
metals.
[
Note:
Following
the
meeting
RTI
was
unable
to
locate
any
lumber
kiln
HAP
metals
data
in
technical
bulletin
845.]
An
RTI
representative
stated
that
while
the
idea
of
small­
scale
kiln
testing
is
promising,
EPA
would
need
to
consider
developing
or
referring
to
some
standard
procedures
for
small­
scale
kiln
testing
to
ensure
data
quality
(
e.
g.,
procedures
for
packaging
the
lumber
so
that
it
does
not
air
dry
in
route
to
the
small­
scale
kiln,
required
documentation
to
show
that
full­
scale
kiln
conditions
are
duplicated
in
the
small­
scale
kiln,
etc.).

The
industry
representatives
requested
that
EPA
not
require
emissions
testing
of
veneer
dryer
cooling
vents.
They
stated
that
veneer
dryers
typically
have
several
cooling
vents
per
dryer,
and
the
purpose
of
the
cooling
zone
of
veneer
dryers
was
to
blow
ambient
air
over
the
hot
sheets
of
veneer
to
cool
them.
An
NCASI
representative
explained
that
they
had
difficult
locating
veneer
dryers
with
testable
cooling
zones
and
that
NCASI
had
to
build
temporary
stacks
in
order
to
test
cooling
zones
during
their
29­
mill
sampling
program.
The
industry
representatives
noted
that
the
veneer
dryer
cooling
zones
have
very
low
HAP
emissions
compared
to
other
processes
at
plywood
plants
and
requested
that
EPA
select
a
worst­
case
value
from
the
available
emission
factors
for
inclusion
in
Appendix
B.

The
industry
representatives
questioned
the
process
unit
category
named
"
other
ancillary
processes
(
not
listed
elsewhere
in
this
table)
that
may
emit
HAP
listed
in
this
table"
in
the
draft
Table
6.
The
AF&
PA
representative
stated
that
there
is
no
evidence
that
process
units
other
than
those
listed
in
Table
6
contribute
to
the
risk
from
PCWP
facilities.
The
industry
representatives
were
concerned
that
the
meaning
of
"
other
ancillary
processes"
was
not
clear
and
could
be
interpreted
to
mean
that
they
must
test
insignificant
sources
of
emissions
(
e.
g.,
green
end
operations
such
as
green
material
storage
piles,
truck
dumps,
and
green
end
saws).
They
5
recommended
that
all
operations
that
are
not
part
of
the
manufacturing
process
and
do
not
involve
use
of
heat
or
resin
be
excluded
from
the
emissions
determination
requirements.
An
RTI
representative
explained
that
the
"
other
ancillary
processes"
category
was
included
in
the
draft
Table
6
to
ensure
that
no
process
units
(
e.
g.,
one­
of­
a­
kind
dryers,
hog
fuel
dryers,
and
other
processes
that
do
not
otherwise
meet
any
of
the
process
unit
definitions)
that
a
facility
knows
to
emit
Appendix
B
HAP
are
excluded
from
the
low­
risk
determination.
The
industry
representatives
agreed
that
there
could
be
some
unique
process
units,
but
strongly
encouraged
EPA
to
be
clear
about
which
operations
are
to
be
excluded
from
the
"
other
ancillary
processes"
category
or
to
set
an
emissions
cutoff
(
e.
g.,
X
tons
per
year)
below
which
ancillary
processes
need
not
be
considered.
The
industry
representatives
suggested
that
EPA
adopt
a
list
of
activities
that
would
not
be
expected
to
emit
Appendix
B
HAP
similar
to
a
list
of
insignificant
activities
used
for
permitting
purposes.
An
RTI
representative
stated
that
some
rationale
for
processes
included
on
the
"
insignificant
activities"
list
would
be
needed.

The
industry
representatives
questioned
EPA's
draft
definition
of
"
wastewater/
process
water
operation"
and
indicated
that
the
definition
was
overly
broad.
The
draft
Table
6
for
possible
inclusion
in
Appendix
B
states
that
engineering
emissions
such
as
estimates
generated
with
EPA's
WATER9
model
must
be
developed
for
"
wastewater/
process
water
operations."
An
RTI
representative
pointed
out
that
the
definition
originated
from
public
comments
on
the
proposed
rule.
The
industry
representatives
stated
that
many
of
the
units
mentioned
in
the
"
wastewater/
process
water
operation"
definition
would
have
insignificant
emissions
because
of
the
low­
vapor­
pressure
liquids
processed
and
recommended
that
EPA
revise
the
definition.
They
noted
that
subpart
Kb
contains
vapor
pressure
cutoffs
for
tanks.
They
indicated
that
log
storage
ponds
and
log
vats,
in
particular,
should
be
removed
from
the
definition.
One
industry
representative
suggested
that
EPA
lump
log
steaming
vats,
log
storage
ponds,
and
log
vats
into
one
definition
for
"
log
conditioning
process
units"
and
apply
the
available
log
steaming
vat
emission
factors
for
these
operations
(
even
though
the
log­
steaming
vat
emission
factors
would
likely
over­
estimate
emissions).
The
industry
representatives
indicated
that
they
would
provide
further
comments
on
the
definition
and
consideration
of
wastewater/
process
water
operations
for
purposes
of
the
low­
risk
demonstration.

For
atmospheric
refiners,
the
industry
representatives
suggested
that
EPA
separate
hardboard/
fiberboard
and
particleboard
atmospheric
refiners
for
purposes
of
the
draft
Table
6.
They
stated
that
the
hardboard/
fiberboard
atmospheric
refiner
tested
used
HAP­
containing
process
water
(
i.
e.,
white
water)
which
gave
it
different
emissions
characteristics
from
particleboard
refiners.
According
to
the
industry
representative,
particleboard
atmospheric
refiners
represent
the
majority
of
atmospheric
refiners
and
emit
no
HAP
except
for
methanol.
They
suggested
that
EPA
also
re­
consider
whether
it
is
worthwhile
to
test
benzene
emissions
from
atmospheric
refiners.

The
industry
representatives
also
requested
that
EPA
split
out
particleboard
and
medium
density
fiberboard
(
MDF)
blending
and
forming
operations
in
the
draft
Table
6.
They
contended
6
that
there
is
an
order
of
magnitude
difference
in
the
emissions
from
particleboard
and
MDF
blending
and
forming
operations.

With
regard
to
the
default
emission
estimates
for
resin
storage
tanks,
the
industry
representatives
thought
the
pound­
per­
hour
values
included
in
the
draft
Table
6
were
very
conservative
for
phenol
and
formaldehyde.
They
also
commented
that
the
TANKS
program
was
not
difficult
to
use.

As
promulgated,
Appendix
B
would
require
HAP
metals
emissions
testing
for
directfired
process
units.
The
industry
representatives
requested
that
EPA
exclude
natural
gas­
fired
process
units
from
the
HAP
metals
testing
requirement
based
on
the
fact
that
there
is
little
potential
for
HAP
metals
from
burning
of
natural
gas.
The
industry
representatives
noted
that
natural
gas­
fired
process
units
are
usually
limited
to
firing
only
natural
gas
by
their
permits.
They
further
requested
that
EPA
allow
a
fuel
analysis
(
similar
to
what
is
promulgated
in
the
Boilers
NESHAP)
instead
of
emissions
testing
for
the
process
units
direct­
fired
with
fuels
other
than
natural
gas.
Using
a
fuel
analysis,
a
worst­
case
sample
of
fuel
(
i.
e.,
wood)
would
be
tested
for
metal
content
and
then
it
would
be
assumed
that
all
of
the
metals
in
the
fuel
are
emitted.

The
industry
representatives
requested
that
EPA
revisit
their
decision
to
require
benzene
and
acrolein
emissions
testing
for
process
units
where
these
HAP
have
rarely
or
never
been
detected.
They
referred
to
the
white
paper
on
this
issue
that
they
had
submitted
previously,
and
argued
that
benzene
and
acrolein
emissions
would
not
be
expected
from
process
units
that
do
not
involve
combustion.
The
industry
representatives
stated
that
testing
for
benzene
and
acrolein
is
more
difficult
than
testing
for
the
other
Appendix
B
HAP.
They
stated
that
emissions
testing
contractors
are
very
uncomfortable
using
Fourier
Transform
Infrared
(
FTIR)
spectroscopy
for
benzene,
and
therefore,
the
industry
representatives
requested
that
EPA
allow
use
of
EPA
Method
18
for
benzene
measurement.
They
also
stated
that
the
FTIR
method
detection
limit
(
MDL)
for
acrolein
is
about
1.8
parts
per
million
(
ppm),
although
the
MDL
is
not
determined
until
the
raw
data
are
analyzed.
According
to
the
industry
representatives,
some
test
contractors
are
optimistic
that
they
can
get
below
a
1
ppm
acrolein
MDL,
however,
to
date
no
contractors
have
been
able
to
get
below
1
ppm.
The
industry
representatives
acknowledged
that
the
NCASI
Method
IM/
CAN/
WP­
99.02
could
get
below
1
ppm
for
both
benzene
and
acrolein.

C.
Health
Effects
of
Acetaldehyde
and
Acrolein
The
AF&
PA
representative
indicated
that
AF&
PA
is
currently
working
with
CIIT
Centers
for
Health
Research
(
CIIT)
on
new
studies
related
to
the
mode
of
action
of
acrolein
and
acetaldehyde.
The
studies
began
with
a
literature
review.
The
AF&
PA
representative
expects
to
know
by
mid­
December
whether
the
evidence
in
these
studies
is
strong
enough
to
proceed
with
additional
study.
The
AF&
PA
representative
acknowledged
that
third
party
review
must
be
completed
before
EPA
would
consider
other
dose­
response
values
for
acrolein
and
acetaldehyde.
An
EPA
representative
stated
that
it
would
be
challenging
for
industry
to
affect
any
change
on
the
7
dose­
response
values
for
acrolein
and
acetaldehyde
before
July
2006.
The
EPA
representative
stated
that
the
third
party
review
process
must
consist
of
a
peer
review
panel
(
i.
e.,
it
is
not
as
simple
as
publishing
a
scientific
journal
article),
and
that
all
studies
would
be
considered
in
the
Integrated
Risk
Information
System
(
IRIS)
process
when
and
if
EPA
decides
to
reevaluate
the
dose­
response
values.
Thus,
the
IRIS
review
process
takes
time.
The
EPA
representative
noted
that
the
reference
concentration
(
RfC)
for
acrolein,
in
particular,
includes
a
number
of
uncertainty
factors
due
to
data
gaps
and
that
the
IRIS
review
for
acrolein
is
ongoing.
He
recommended
that,
if
the
industry
has
any
new
data,
they
should
submit
it
very
soon
and
note
how
it
fits
into
the
context
of
the
existing
data
because
this
could
impact
how
the
existing
data
are
weighted
for
purposes
of
revising
the
RfC.
An
industry
representative
stated
that
the
industry
is
not
conducting
new
animal
studies,
but
plans
to
review
the
mode
of
action
documented
in
former
studies.
The
EPA
representative
suggested
that
the
industry
representatives
meet
with
EPA
(
including
EPA's
Office
of
Research
and
Development)
again
in
the
coming
months
to
discuss
the
scope
of
the
study.

D.
Industry's
Implementation
Questions
Next,
the
industry's
maximum
achievable
control
technology
(
MACT)
implementation
questions
were
briefly
discussed.
The
questions
submitted
by
the
industry
representatives
prior
to
the
meeting
(
with
AF&
PA's
suggested
responses)
are
provided
in
Attachment
6.
The
AF&
PA
suggested
responses
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
All
of
the
questions
were
not
discussed
or
resolved
during
the
meeting.
However,
EPA
remarks
made
in
response
to
some
of
the
questions
are
indicated
below.

With
regard
to
risk
assessment
question
1
(
Can
a
mill
mix
and
match
look­
up
table
and
site
specific
analyses,
that
is,
only
do
site
specific
modeling
for
endpoints
that
fail
the
screening
model?
For
example,
if
pass
cancer
on
look­
up
table
then
don't
need
to
model
cancer
in
site
specific
efforts
as
you
look
at
other
non­
cancer
chronic/
acute
affects.),
an
EPA
representative
stated
that
he
thought
this
was
allowed
under
Appendix
B
(
as
promulgated).
The
EPA
representative
noted
that
a
hybrid
tier
is
allowed
under
the
site­
specific
risk
assessment
guidance
(
Air
Toxics
Risk
Assessment
Guidance
reference
Library,
Volume
2)
referred
to
in
Appendix
B.
The
AF&
PA
representative
suggested
that
EPA
clarify
this
in
the
amendment
package.

The
EPA
representatives
stated
that
the
EPA
work
group
will
need
to
make
a
decision
regarding
risk
assessment
question
2
(
Can
mills
have
a
"
shield"
(
protection
from
application
of
MACT
for
three
years)
if
health
benchmark
changes
between
now
and
risk
assessment
submittal
even
if
no
application
has
been
submitted
to
EPA
but
the
mill
is
well
down
the
path
of
demonstrating
it
will
meet
the
low­
risk
subcategory?).
An
EPA
representative
stated
that
the
rule
addresses
how
to
handle
changes
in
health
benchmarks
after
a
facility
becomes
part
of
the
lowrisk
subcategory,
so
the
question
only
applies
to
the
time
period
between
submittal
of
the
low­
risk
demonstration
and
approval
of
the
facility
as
belonging
to
the
low­
risk
subcategory.
The
EPA
representatives
at
the
meeting
suggested
that
facilities
go
ahead
and
submit
their
low­
risk
demonstration
for
approval
with
the
former
benchmark
by
the
deadline,
and
then
if
they
pass
their
initial
low­
risk
demonstration,
submit
a
revised
demonstration
showing
the
effects
of
the
new
benchmark.
The
AF&
PA
representative
suggested
that
EPA
clarify
how
to
handle
this
situation
in
the
proposed
amendment
package.

With
regard
to
general
question
1
(
Do
lumber
kilns
need
to
file
a
Part
I
hammer
application
(
FR
45962
preamble)?),
an
EPA
representative
disagreed
with
AF&
PA's
suggestion
that
the
amendment
proposal
should
specify
that
the
initial
notification
could
be
used
in
place
of
a
Part
I
hammer
application.
The
EPA
representative
pointed
out
that
the
amendment
proposal
would
not
be
published
before
the
January
2005
initial
notification
due
date.

An
RTI
representative
clarified
for
general
question
7
(
§
63.2262(
h)
specifies
how
to
determine
the
control
efficiency
across
an
emission
control
system
during
the
initial
performance
test.
The
equation
for
determining
percent
reduction
contains
a
term
(
CE)
for
capture
efficiency.
The
text
says
that
the
CE
is
to
be
"
determined
for
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart."
However,
the
rule
is
silent
about
how
to
determine
the
CE
for
control
systems
on
processes
other
than
wood
product
presses
and
board
coolers,
e.
g.
for
a
credit
unit
in
emissions
averaging.
Are
we
to
assume
100
%
capture
efficiency
for
dryers
and
use
a
CE
of
1.0
in
the
equation?)
that
capture
efficiency
need
not
be
determined
for
credit­
generating
process
units
if
the
reduction
in
captured
emissions
provides
the
desired
credits.

E.
Other
Issues
Potential
permitting
issues
were
discussed.
One
industry
representative
believes
that
permitting
should
not
be
an
issue
and
that
facilities
would
simply
obtain
permit
limits,
typically
an
emission
limit
either
for
the
entire
facility
or
per
process
unit.
He
noted
that
most
PCWP
facilities
already
have
permit
limits
for
formaldehyde
and
methylene
diphenyl
diisocyanate
(
MDI),
if
applicable.
Another
industry
representative
stated
that
EPA
would
do
the
risk
review,
but
some
States
(
e.
g.,
South
Carolina)
may
also
want
to
do
their
own
review
of
the
risk
assessment.
There
is
public
review
process
when
permits
are
re­
opened
and
some
States
may
be
concerned
that
they
would
be
unable
to
answer
questions
if
they
do
not
review
the
risk
assessments
themselves;
however,
the
States
may
defer
to
EPA.
An
EPA
representative
noted
that
EPA
has
told
State
and
Territorial
Air
Pollution
Program
Administrators/
Association
of
Local
Air
Pollution
Control
Officials
(
STAPPA/
ALAPCO)
that
they
would
provide
outreach
materials
(
e.
g.,
risk
assessment
templates,
etc.),
and
that
some
States
are
waiting
to
see
how
the
litigation
is
resolved.

Due
to
time
constraints,
there
was
no
discussion
of
the
draft
low­
risk
demonstration
review
templates
submitted
by
industry.

Attachment
1
List
of
Participants
U.
S.
EPA
Dave
Guinnup,
OAQPS/
REAG
Kent
C.
Hustvedt,
OAQPS/
WCPG
Mary
Tom
Kissell,
OAQPS/
WCPG
Scott
Jenkins,
OAQPS/
REAG
PCWP
Industry
John
Bradfield,
Composite
Panel
Association
(
CPA)
Phil
Ferguson,
International
Paper
David
Harvey,
Louisiana­
Pacific
Corporation
Tim
Hunt,
American
Forest
and
Paper
Association
Lawrence
Otwell,
Georgia­
Pacific
Corporation
John
Pinkerton,
National
Council
for
Air
and
Stream
Improvement
(
NCASI)
David
Word,
NCASI
Stephen
Woock,
Weyerhaeuser
Research
Triangle
Institute
Katie
Hanks
Rebecca
Nicholson
Attachment
2
Draft
Agenda
EPA­
AF&
PA
PCWP
Implementation
October
29,
2004
Draft
Agenda
Introductions
Update
on
Supplemental
Rule
 
timing
and
content
Discussion
of
process
unit
emission
testing
Health
effects
testing
Implementation
questions:
1.
Risk
2.
General
Draft
Risk
Templates
 
feedback
[
if
time]

Next
Steps
Attachment
3
Draft
Summary
of
Proposed
Amendments
TABLE
1.
SUMMARY
OF
THE
PROPOSED
AMENDMENTS
Citation
Change
§
§
63.2232(
b)
and
63.2292
Revise
definition
of
"
affected
source"
to
include
combustion
unit
exhaust
streams
used
to
direct
fire
process
units.

§
63.2250(
a)
Revise
language
to
clarify
rule
applicability
during
unscheduled
startups
and
shutdowns.

§
63.2252
Add
section
to
exclude
affected
sources
with
no
process
units
subject
to
compliance
options
or
work
practice
requirements
(
e.
g.,
sawmills)
from
performance
testing,
monitoring,
SSM
plan,
recordkeeping,
and
reporting
requirements.

§
63.2262(
d)(
1)
Allow
testing
between
wet
control
device
and
HAP
control
device.

§
63.2292
Revise
definition
of
"
tube
dryer"
to
clarify
that
heat
is
applied.

§
63.2292
and
Appendix
B,
section
15
Move
definition
of
"
direct­
fired
process
unit"
from
Appendix
B
to
subpart
DDDD,
section
15
to
§
63.2292
of
subpart
DDDD.

Appendix
A,
section
10
Correct
misnumbering
of
sections
10.4
and
10.5.

Appendix
B
Revise
to
include
requirement
to
consider
other
PCWP
HAP
if
health
benchmarks
are
developed
or
become
more
health
protective.

Appendix
B,
section
4(
b)
introductory
text
and
4(
b)(
4)
Revise
to
include
new
paragraph
(
4)
stating
that
if
there
is
no
dose­
response
value
for
a
pollutant
(
e.
g.,
lead)
on
EPA's
website,
then
the
pollutant
need
not
be
included
in
the
risk
analysis.

Appendix
B,
sections
4(
a),
5(
a),
6(
a),
6(
b),
and
Equations
1
and
2,
Revised
terminology
to
refer
to
"
emission
point"
instead
of
"
process
unit"

Appendix
B,
section
5(
a)
and
Table
2A
Specify
whether
testing
or
emission
estimation
is
required
for
various
process
units.
Add
Table
2A
to
specify
emission
estimation
procedures
or
emissions
testing
requirements.

Appendix
B,
section
5(
f)(
2)
Allow
use
of
other
EPA
Method
29
laboratory
analysis
procedures
with
detection
limits
equal
to
or
lower
than
atomic
absorption
spectroscopy
(
AAS)
when
claiming
zero
for
non­
detect
HAP
metals
measurements.

Appendix
B,
section
5(
i)
Allow
use
of
previous
emission
test
results
(
e.
g.,
NCASI
IM/
CAN/
WP
99.01).

Appendix
B,
section
5(
j)
Allow
only
one
of
multiple
similar
process
units
to
be
tested
(
e.
g.,
one
of
three
veneer
dryers).

Appendix
B,
section
5(
k)
Specify
requirements
for
developing
emission
estimates
according
to
Table
2A
Table
1.
Continued
Appendix
B,
section
6(
a)
and
Table
2A
Revise
to
clarify
that
section
6(
a)
applies
when
emissions
estimation
or
testing
performed.

Appendix
B,
section
6(
a)
Add
equations
for
calculation
of
carcinogen
and
non­
carcinogen
weighted
average
stack
height
Appendix
B,
section
6(
b),
6(
c),
8(
b)(
1),
8(
b)(
3)
Revise
to
clarify
that
weighted
average
stack
height
calculations
must
be
used
Appendix
B,
section
8(
a)(
3)
Require
submittal
of
emissions
estimate
calculations
with
low­
risk
demonstration.

Appendix
B,
section
10(
c)
Revise
date
for
new
sources
to
conduct
emissions
tests
and
submit
demonstrations
of
eligibility
for
the
low­
risk
subcategory.

Appendix
B,
section
11(
b)
Revise
to
state
that
facilities
must
be
in
the
process
of
incorporating
parameters
that
defined
the
affected
source
as
part
of
the
low­
risk
subcategory
into
their
title
V
permit,
as
opposed
to
having
the
permit
revised
before
the
MACT
compliance
date.

Appendix
B,
section
15
Add
definitions
of
various
process
units
not
defined
in
subpart
DDDD
and
move
definition
of
"
direct­
fired
process
unit"
to
§
63.2292.

Appendix
B,
Table
2
Renumber
as
Table
2B.
Delete
footnote
1
related
to
benzene
and
acrolein
testing.

Appendix
B,
Table
2,
row
5
Allow
use
of
NCASI
IM/
CAN/
WP
99.02
for
benzene
testing.

Appendix
B,
Table
3
Change
column
heading
to
"
distance
to
property
boundary"

Appendix
B,
Tables
3
and
4
Delete
footnote
regarding
units
of
measure.
Attachment
4
Draft
Summary
of
Testing
or
Emissions
Estimation
Procedures
for
Amendment
to
Appendix
B
to
Subpart
DDDD
(
to
be
proposed)
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
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
units
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
Fiberboard
mat
dryer
(
heated
zones)
C
(
new)
test
test
test
test
test
NA
test
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
Process
unit
type
Subpart
DDDD
control
(
C)

or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
units
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
sections
none
test
test
test
test
test
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
Engineering
estimate
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
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
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
Process
unit
type
Subpart
DDDD
control
(
C)

or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
units
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
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
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
Process
unit
type
Subpart
DDDD
control
(
C)

or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
units
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
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
test
test
test
test
test
NA
NA
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
Process
unit
type
Subpart
DDDD
control
(
C)

or
work
practice
(
WP)
Acetaldehyde
Acrolein
Formaldehyde
Phenol
Benzene
MDI
HAP
metals
from
direct­
fired
process
units
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
Engineering
estimate
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
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.
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
DRAFT
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
Attachment
5
Draft
Process
Unit
Definitions
for
Amendment
to
Appendix
B
to
Subpart
DDDD
(
to
be
proposed)

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
steaming
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.
A
log
steaming
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.

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.

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
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,
log
vats,
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.
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
Attachment
6
Industry
Questions
PCWP
MACT
Implementation
Questions
 
Outstanding
October
2004
Risk
Assessment
Questions
1.
Can
a
mill
mix
and
match
look­
up
table
and
site
specific
analyses,
that
is,
only
do
site
specific
modeling
for
endpoints
that
fail
the
screening
model?
For
example,
if
pass
cancer
on
look­
up
table
then
don't
need
to
model
cancer
in
site
specific
efforts
as
you
look
at
other
non­
cancer
chronic/
acute
affects.

AF&
PA
Response:
Generally
yes.
However,
in
complex
terrain,
it
is
best
to
do
refined
modeling
given
inadequacies
of
look­
up
table.

2.
Can
mills
have
a
"
shield"
(
protection
from
application
of
MACT
for
three
years)
if
health
benchmark
changes
between
now
and
risk
assessment
submittal
even
if
no
application
has
been
submitted
to
EPA
but
mill
well
down
the
path
of
demonstrating
it
will
meet
the
low­
risk
subcategory?

AF&
PA
Response:
Yes,
a
mill
would
get
another
three
years
to
comply
if
a
benchmark
change
is
"
controlling"
on
the
outcome
of
the
low
risk
demonstration
(
were
it
not
for
the
change,
the
mill
would
be
considered
low
risk);
EPA
work
through
AF&
PA
and
affiliated
trades
to
notify
mills
if
health
benchmark
changes.
EPA
make
clear
this
policy.

3.
Is
EPA
willing
to
consider
an
alternative,
less
stringent
health
benchmark
(
i.
e.,
acrolein
or
acetaldehyde)
than
currently
in
the
OAQPS
list
even
if
the
change
occurs
just
before
the
two
year
deadline
or
between
7/
06
and
10/
07)?

AF&
PA
Response:
Yes,
EPA
willing
to
consider
the
latest
science
regardless
of
when
it
becomes
known
to
allow
a
mill
to
use
it
in
its
risk
assessment
demonstration.
EPA
make
clear
this
approach
in
supplemental
rule
and
provide
clear
process
for
mill
to
use
(
third­
party
review
of
science
required).

4.
How
does
a
new
facility
model
risk
when
they
are
not
up
and
running
to
measure
emissions?

AF&
PA
Response:
Mill
should
use
best
estimate
of
emissions/
risk
using
predicted
emissions
and
then
verify
once
started
(
no
different
than
any
new
source
requirements);
supplement
rule
should
clarify
EPA's
intent.
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
5.
If
have
previous
source
testing,
can
mill
use
the
emissions
information
in
risk
assessment
if
it
meets
conditions/
methods
in
rule?

AF&
PA
Response:
If
quality
of
data
gathered
meets
guidelines
then
EPA
willing
to
use
even
if
no
test
plan
or
early
notice
to
EPA;
clarify
in
supplemental
rule
to
explicitly
allow
if
any
uncertainty.

Following
questions
EPA
has
indicated
will
be
included
in
supplemental
rule;
confirm
with
EPA:

6.
Will
the
Title
V
language
be
amended
to
be
consistent
with
Boiler
MACT?

Response
heard
from
EPA:
Yes,
the
supplemental
rule
will
add
"
submitted
for
incorporation"
to
provide
shield
to
account
for
time
it
may
take
a
state
to
make
final
action
on
permit
conditions
related
to
risk;
traditionally
states
have
to
"
deem
complete"
application
under
Title
V
even
if
supplemental
information
requested.

7.
Will
the
stack
height
calculations
be
adjusted
to
be
a
toxicity­
weighted
average
like
in
Boiler
MACT?
Will
ground
level
emission
points
be
excluded
in
calculating
average
stack
heights?

Response
heard
from
EPA:
Yes,
although
weighting
may
be
different
for
different
endpoints;
to
be
added
to
supplemental
rule.

Lower
priority
question:

8.
What
weather
data
should
sources
use
in
modeling?

Response
heard
from
EPA:
Can
use
HEM
with
canned
meteorological
data
(
nearest
met
station);
however,
for
complex
terrain
may
want
to
use
met
data
that
matches
situation.
Mill
would
have
the
option
to
consult
with
EPA
for
advance
approval
(
meteorologists
in
air
quality
modeling
group;
Dave
Guinnup
to
follow­
up
on
possible
future
consultations.
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
General
(
non­
risk)
questions:

1.
Do
lumber
kilns
need
to
file
a
Part
I
hammer
application
(
FR
45962
preamble)?

AF&
PA
Response:
No,
the
standard
initial
notification
is
sufficient;
clarify
in
supplemental
rule.

2.
Must
a
mill
provide
notice
of
performance
testing
at
least
60
days
in
advance
and
referenced
63.2280(
c)?
63.2280(
c)
describes
requirements
for
performance
tests.
Appendix
B
does
not
described
the
HAP
emission
tests
as
performance
tests.
Does
EPA
expect
an
initial
notification
for
Appendix
B?

Response
heard
from
EPA:
No,
at
least
in
terms
of
emission
tests
for
risk
subcategory
demonstrations
[
Dave
Guinnup
at
Portland
meeting]

3.
What
is
the
first
substantive
compliance
date?
Is
it
timing
for
submittal
of
low
risk
demonstration
or
year
3
(
10/
07)?

AF&
PA
Response:
3
years
is
the
first
substantive
compliance
date;
confirmation
may
be
sufficient.

4.
If
using
Atomic
Absorption
for
metals
then
non­
detects
(
ND)
are
zero
according
to
the
rule;
however,
other
methods
(
ICP)
not
included
in
rule
so
how
should
ND
be
treated?

AF&
PA
Response:
Non­
detect
always
equal
zero
applies
regardless
of
method
(
not
limited
to
atomic
absorption)

5.
How
much
of
the
equipment
associated
with
a
press
(
loader
and
unloader)
needs
to
be
included
in
the
press
enclosure?

AF&
PA
Response:
Only
the
unloader
and
the
press
itself
are
included
in
the
definition
and
thus
need
to
be
covered
by
the
enclosure,
the
loader
does
not
need
to
be
included
in
the
enclosure.
Confirm
with
EPA
6.
If
mill
makes
a
modification
to
a
press
with
a
biofilter
then
might
be
forced
to
use
an
RTO
if
MACT
does
not
equal
BACT.
Can
a
biofilter
be
defined
as
BACT
to
avoid
use
of
RTOs
across
the
board?
MACT
has
been
declared
equal
to
BACT
in
many
cases
already
(
Huber
and
Plum
Creek
use
of
biofilters)

AF&
PA
Response:
Yes,
allow
biofilters
as
BACT.
EPA
needs
to
clarify
policy
7.
§
63.2262(
h)
specifies
how
to
determine
the
control
efficiency
across
an
emission
control
system
during
the
initial
performance
test.
The
equation
for
determining
percent
reduction
contains
a
term
(
CE)
for
capture
efficiency.
The
text
says
that
the
CE
is
to
be
"
determined
for
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart."
However,
the
rule
is
silent
about
how
to
determine
the
CE
for
control
systems
on
processes
other
than
wood
product
presses
and
board
coolers,
e.
g.
for
a
credit
unit
in
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
emissions
averaging.
Are
we
to
assume
100
%
capture
efficiency
for
dryers
and
use
a
CE
of
1.0
in
the
equation?

AF&
PA
Response:
Yes,
the
capture
efficiency
for
processes
other
than
for
reconstituted
wood
product
presses
and
board
coolers
should
be
assumed
to
be
100%
in
equation
1
of
§
63.2262(
h).
The
control
efficiency
calculations
used
to
determine
the
floor
for
the
MACT
rule
assumed
a
capture
efficiency
of
100%
for
all
dryers.

Several
places
in
the
final
rule
need
to
be
corrected
to
make
this
clear.

a)
From
page
46015,
63.2262
(
h):
CE
=
capture
efficiency,
percent
(
applicable
only
to
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart)

b)
From
page
46015,
63.2262
(
i):
CE
=
capture
efficiency,
percent
(
applicable
only
to
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart).

c)
From
page
460221,
63.2292:
Capture
device
means
a
hood,
enclosure,
or
other
means
of
collecting
emissions
into
a
duct
so
that
the
emissions
can
be
measured.
This
definition
is
applicable
only
to
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart.

d)
From
page
46021,
63.2292:
Capture
efficiency
means
the
fraction
(
expressed
as
a
percentage)
of
the
pollutants
from
an
emission
source
that
are
collected
by
a
capture
device.
This
definition
is
applicable
only
to
reconstituted
wood
product
presses
and
board
coolers
as
required
in
Table
4
to
this
subpart.

8.
§
63.2250(
a)
states
that
"
You
must
be
in
compliance
with
the
compliance
options,
....
in
this
subpart
at
all
times,
except..."
All
processes
exhibit
variability,
and
may
not
meet
the
compliance
options
for
every
moment.
For
example,
when
valves
change
on
an
RTO,
there
is
a
fraction
of
a
second
that
the
emissions
bypass
the
RTO
and
are
not
treated.
The
units
can
meet
the
90%
control
efficiency
over
an
hour
average,
but
not
every
second.
Similarly,
emissions
from
the
press
are
cyclic,
peaking
every
time
the
press
opens,
and
vary
with
product
thickness.
The
press
may
be
able
to
meet
the
production
based
compliance
option
(
PBCO)
over
an
hour
long
average,
but
not
every
second
of
operation.
It
may
meet
the
PBCO
for
an
average
mix
board
thicknesses,
but
not
for
some
individual
products.
The
rule
does
not
specify
what
the
averaging
period
should
be
for
either
PBCO
or
Add­
on
Control
Systems
Compliance
Options.
The
rule
does
specify
a
6
month
averaging
period
for
the
Emissions
Averaging
Compliance
Option.
What
averaging
period
should
be
used
for
the
Add­
on
Control
Systems
Compliance
Options
and
PBCO?
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
AF&
PA
Response:
A
one
week
average
period
should
be
allowed
so
mill
can
certify
compliance
at
all
times
when
using
PBCO
or
Add­
on
Control
compliance
options.
This
averaging
period
does
not
replace
the
3­
hr
averaging
period
for
operating
limits
or
the
initial
compliance
demonstrations.

9.
Appendix
B
specifies
FTIR
methods
to
measure
benzene
emissions
(
specifically
EPA
Method
320
and
ASTM
Method
D6348­
03).
These
methods
are
complicated
and
may
require
multiple
test
methods
when
method
320
is
not
appropriate
for
measuring
other
HAPs
(
specifically
acetaldehyde,
acrolein,
formaldehyde
and
phenol).
NCASI
has
updated
its
Method
IM/
CAN/
WP
99.02
for
selected
HAPs
at
wood
products
facilities
to
measure
benzene.
The
updated
method
is
designed
as
a
self­
validating
method.
Updated
QA/
QC
procedures
(
Section
6.10)
require
duplicate
sample
runs,
spiked
sample
runs
and
field
spike
samples.
Benzene
can
be
included
in
the
spike
solutions
as
are
the
other
compounds
of
interest.
In
Section
2
of
the
method
(
Applicability),
benzene
is
listed
in
Table
2.1
as
a
compound
that
"
the
method
is
applicable
to
determining
the
concentration
of...."
Considering
that
EPA
approved
the
method
for
the
other
HAPS,
there
is
no
reason
EPA
should
exclude
benzene.
Can
other
methods
such
as
the
updated
NCASI
Method
IM/
CAN/
WP
99.02
be
used
to
sample
for
benzene?
In
addition,
can
Method
18
also
be
used
to
measure
benzene
since
it
is
straightforward
to
use
in
identifying
a
single
compound
like
benzene?

AF&
PA
Response:
Yes,
the
updated
NCASI
method
and
Method
18
are
appropriate
to
measure
benzene
and
will
be
included
in
the
supplemental
rule.
Other
appropriate
methods
can
be
used,
subject
to
obtaining
approval
from
EPA
as
provided
in
the
MACT
General
Provisions
at
63.7(
e)(
2)
ii.

Following
questions
EPA
has
indicated
will
be
included
in
supplemental
rule:

10.
Can
the
piping
involved
in
pneumatic
transfer
of
fiber
following
a
single
stage
(
primary)
tube
dryer
be
considered
a
"
secondary
tube
dryer"?

Response
heard
from
EPA:
No,
supplemental
heat,
either
indirect
or
direct,
needs
to
be
added
to
the
air
stream
or
applied
to
the
pneumatic
transfer
tubing
before
a
system
can
be
classified
as
a
secondary
dryer.
Supplemental
rule
will
address.

11.
Does
initial
notification
need
to
include
units
without
control
obligations
(
like
lumber
kilns)?

Response
heard
from
EPA:
Yes,
will
clarify
in
supplemental
rule
and
implementation
brochure
12.
Are
all
shutdowns
and
start­
ups
exempt
from
the
rule
requirements
(
see
63.2250
(
a))?
Note:
The
AF&
PA
suggested
responses
in
this
attachment
do
not
necessarily
reflect
final
EPA
decisions
or
EPA
responses
to
the
questions.
Response
heard
from
EPA:
Yes,
however,
the
duration
of
"
scheduled"
shutdowns
and
start­
ups
should
be
minimized.
To
be
included
in
the
supplemental
rule.

Planned
clarification:
(
Square
brackets
denote
words
to
delete;
ALL
CAPS
denote
an
addition)

§
63.2250
What
are
the
general
requirements?
(
a)...
The
compliance
options,
operating
requirements,
and
work
practice
requirements
do
not
apply
during
times
when
the
process
unit(
s)
subject
to
the
compliance
options,
operating
requirements,
and
work
practice
requirements
are
not
operating,
or
during
[
scheduled]
startup
and
shutdown
periods,
and
during
malfunctions.
[
These]
SCHEDULED
startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary
for
these
events.

13.
Should
boilers
and
process
heaters
and
their
exhaust
be
part
of
the
PWCP
affected
source
to
avoid
duplicative
regulation
under
Boiler
MACT?

Response
heard
from
EPA:
Yes,
exhausts
from
boilers
and
process
heaters
will
be
added
to
the
affected
source
definition
in
the
supplemental
rule;
Boiler
MACT
exempts
units
that
are
specifically
identified
as
part
of
the
affected
source
of
another
MACT.

Low
priority
questions:

14.
Do
you
see
a
problem
with
the
testing
requirements
for
testing
at
the
functional
inlet
(
63.2262(
d)(
1))
relative
to
plants
at
which
separate
WESPs
serve
individual
dryers
and
then
the
emissions
are
combined
prior
to
the
RTO(
s)?
Read
strictly,
the
language
says
you
must
sample
at
the
functional
inlet
 
prior
to
the
WESP(
s).
Do
you
think
states
will
allow
you
to
test
at
the
RTO
inlet/
outlet
and
consider
the
RTO
inlet
the
functional
inlet?

Response
heard
from
EPA:
Yes,
allow
testing
at
functional
inlet
at
combined
units
or
across
RTO/
RCOs;
EPA
made
change
in
response
to
comments.

15.
What
is
the
definition
of
dry
basis
moisture
content?

Response
heard
from
EPA:
EPA
may
address
in
implementation
document
