June 11, 1999
Mr. Andy S. Counts
Dear Mr. Counts:
Your letter of May 14, 1999 with the subject of "Furniture Industry Emission Factors" brings attention to several items on which we feel we have previously reached agreement and provided documentation. If our regions or Raleigh staff is not consistently recognizing such information, we apologize. If you can identify specific situations where this is happening, it will assist us in minimizing miscommunications. We have been trying to move toward better publicity and centralization of our DAQ web pages as a place where both our staff and industry can find such documentation and better consistency. We are still making improvements in the web information, and will continue to do so, but you may wish to visit the site http://daq.state.nc.us/Offices/Planning/Attainment/est.html and check it out. I gave you a paper copy of the pertinent emission factor information from that site at our May 26 meeting. We welcome any suggestions for improvement of such information, and its delivery.
For the specific topics in your letter, please refer to the corresponding headers below.
Points made in my May 14, 1998 letter regarding your three steps, with additional caveats and conditions, still apply. For example, yield is (best) calculated on a plant by plant basis and can be done routinely using the information maintained by most facilities. We continue to caution and encourage you and the industry to be collecting information on condensed and other particles less than 2.5 micrometers in aerodynamic diameter. If monitoring now underway triggers areas of North Carolina into a classification of "non-attainment," an approach of using PM-10 estimates instead of more realistic PM-2.5 estimates may penalize the industry. Such practices will show the industry to be a larger contributor to the problem than it really is.
Fossil Fuel Boilers
Since the March and September letters, we have had discussions and have portions of the draft report from NCASI with other results showing estimates of kiln emissions (pine) around 3.8 lb./MDF, after conversion to an "actual mass" basis (vs. "as carbon"). We continue to accept the very gross historical assumption that 10% of the pine value applies to hardwoods due to lack of anything better. In short, we are currently accepting and using "3.1 and 0.3" for the CY 1998 inventory (as "best available information" for SYP and hardwoods, respectively), but expect to have a slightly higher value approved by the time next year's inventory (CY '99) is addressed. We invite you to join us in the review of new NCASI reports and underlying data, to assure that we use the best information for North Carolina estimates. We acknowledge in advance that we may tend to accept higher (than existing) values as generated by industry more readily than a lower proposed replacement. Ultimately, we expect the NCASI information to be the basis of a new update of EPA's AP-42, but do not expect that to be available for the near future.
Correction: After this letter was issued, it was determined that instead of 3.1, the number for kilns should have been cited as 3.4 which is consistent with other documents and citations. Noted to AFMA on 7/8/99 by Jim Southerland by e-mail.
It was a pleasure to meet with you on May 28 to discuss these and other matters related to your industry. We continue to strive to develop the best interface possible between our mandates regarding clean air in North Carolina and the understandable technical and economic pressures that industries such as furniture manufacturing have to face. We cannot change these mandates, but will continue to try to make implementation as fair and open as possible.
B. Keith Overcash, P.E.