June 11, 1999

Mr. Andy S. Counts
Director of Environmental Affairs
American Furniture Manufacturers Association (AFMA)
223 South Wrenn Street
PO Box HP-7
High Point, North Carolina 27261

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.

Woodworking Operations
My letter of May 27, 1998 (responding to your letter of March 31, 1998) specifically addressed this issue and was sent to our regional staff as well. I repeated this in my September 3, 1998 letter to you. The information is also included in the July 15, 1998 draft of Estimating Emissions From Generation and Combustion of "Waste" Wood, which is posted on the web page above. Regions and the related task force have reviewed this latter document and we have advised staff to go ahead and use it with caution, though it is still marked "draft." It is so marked primarily because it is incomplete and needs further refinement. Any comments you may have on this document would be valuable to us.

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
My March 1998 letter to you addressed this issue. No changes in agreement have occurred.

Finishing Operations
My March 1998 letter to you (and elaborated upon in my September 3, 1998 letter) addressed this issue and we are still in general agreement.

Gluing Operations
My March 1998 letter to you addressed this issue and we continue to be in general agreement, with the inclusion of emphasis on the formaldehyde caveats.

Kilns
My March 1998 letter to you addressed this issue, and my September 3, 1998 letter further refined and updated the status more specifically. In those letters we indicated that the "2.1 or 0.21" levels were much too low for SLP and that validated industry-provided tests had shown that a much higher value was warranted. In my September letter I said that "In view of these several points, the DAQ agrees that the industry's use of 2.11/0.21 in the 1997 (emphasis added) inventory should not be modified while we compile and jointly review this and any other additional similar research information. We encourage AFMA to jointly review the new information from NCASI prior to adopting new factors for future inventory and permit purposes. If the NCASI information is not forthcoming by the end of the calendar year, to allow for its use in the CY 1998 inventories and permit applications submitted during that time, we will view the 3.4 lb./MDF number supplied and adopted by the aforementioned wood products company as the appropriate guide ('best available information') for pine. For hardwoods, a 10% of pine assumption will still be acceptable, absent test data to the contrary." The documented value from tests that we are comfortable with as the lower limit is 3.1 lb./MDF.

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.

Summary
Given the documentation referenced and restatement of previous points, I believe we should be clear. We agree that we must continue to work to improve communications and, in fact, DAQ now has a specific internal focus group working to suggest ways we can improve our communications. We also realize that there will likely never be a time when everyone is in total agreement. In the meanwhile, we request that you and your member companies continue to review the information placed on the DAQ web page and adopt this as a point of focus to identify agreements or disagreements. We will do likewise with our regional staff. Jim Southerland is trying to arrange a meeting in the next few weeks between DAQ staff, NCASI staff, and your office, to explore how we can best review and use the data and results from NCASI's extensive work on kilns. This is in accordance with your request. We will continue to address common concerns as rapidly as resources and time allow.

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.

Sincerely,

B. Keith Overcash, P.E.
Deputy Director

/jhs

cc:
DAQ Regional Supervisors
Laura Butler, P.E., DAQ
Lee Daniel, DAQ
Tony Pendola, P.E., DENR
Jim Southerland, QEP, DAQ
Alan McConnell, Kilpatrick Stockton LLP

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