Development of a New Test Method Using Sulfur Hexafluoride Tracer Gas to Determine the Capture Efficiency of Hoods or Enclosures Around Hot Presses Used in Wood Products Panel Manufacturing, 2003 Environmental Conference Proceedings

The information provided to and used by the US EPA to determine the control “floor” for the currently proposed Plywood & Composite Wood Panels MACT Standard includes some presses with enclosures and pollution controlled devices. These press enclosures are believed to generally conform to the requirements of EPA Method 204, however, it is not clear that these installations have been rigorously examined or if ventilation rates are adequate to maintain an acceptable workplace environment. Additionally, the majority of the enclosures included to define the “floor” determination were installed around conventional multiple-opening and short continuous presses. New generation, long continuous presses (i.e., 90 to 120 feet long) are not included in the ‘floor” determination. The regulation as currently proposed with sole reliance on Method 204 will unduly increase costs, stifle innovation, and force some installations to contend with a clearly inapplicable provision.