EPA Region 10 HAP and VOC Emission Factors for Lumber Drying, November 2019
This spreadsheet calculates and compiles hazardous air pollutant (HAP) and volatile organic compound (VOC) emission factors (EF) in units of pounds of
pollutant per thousand board feet of lumber dried (Ib/mbf) that are preferred by EPA Region 10 for estimating emissions from indirect steam-heated batch
lumber drying kilns. The EFs are based on actual lab-scale emission test data when available. When no suitable HAP or VOC test data is available for a
species of wood (e.g western red cedar, engelmann spruce, larch and western white pine), EFs for similar species are substituted. When there are more
than one similar species, the highest of the EF for the similar species is substituted. When test data is available for some individual HAP (methanol,
formaldehyde, acetaldehyde, propionaldehyde and acrolein) or VOC compounds (ethanol and acetic acid) but not others, data substitution for that species
of wood is not performed so as to maintain the integrity of the WPP1 VOC EF calculation. Only douglas fir and ponderosa pine EF are supported by full
suite of test data for all seven aforementioned compounds.
A summary of the EFs for each species of wood is included on this sheet. The sheets that follow present the original test data as well as the calculations for
creating each EF. There are two sheets per lumber species: one for HAPs and one for VOCs. The methanol, formaldehyde and VOC EF are temperature
dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. Because
acetaldehyde, propionaldehyde and acrolein emissions across different species are not consistently dependent upon maximum drying temperature, EF are
calculated by averaging test results. Whereas HAP EF are derived in the HAP sheets, EF for individual VOC ethanol and acetic acid are derived in the
VOC sheets for douglas fir and ponderosa pine (only wood species undergoing testing for these two VOC compounds).
Species
WPP1 VOC12
Methanol2
Formaldehyde2
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
Non-Resinous Softwood Species
Western True Firs3
0.00817X- 1.02133
0.00465X - 0.73360
0.00016X-0.02764
0.0550
no data
no data
Western Hemlock
0.00369X- 0.39197
0.00249X - 0.39750
0.000046X - 0.007622
0.0677
0.0004
0.0012
Western Red Cedar
0.00817X- 1.02133
0.00465X - 0.73360
0.00016X-0.02764
0.0677
0.0004
0.0012
Resinous Softwood Species (Non-Pine Family)
Douglas Fir
0.01460X- 1.77130
0.00114x-0.16090
0.000028X - 0.003800
0.0275
0.0003
0.0005
Engelmann Spruce
0.1769
0.00088X-0.13526
0.000042X - 0.006529
0.0201
0.0002
0.0005
Larch
0.01460X- 1.77130
0.00114x-0.16090
0.000028X - 0.003800
0.0275
0.0003
0.0005
Resinous Softwood Species (Pine Family)
Lodgepole Pine
1.1352
0.0550
0.0030
no data
no data
no data
Ponderosa Pine
0.02083X- 1.30029
0.00137X-0.18979
0.000074X-0.010457
0.0340
0.0010
0.0026
Western White Pine
0.02083X- 1.30029
0.00137X-0.18979
0.000074X-0.010457
0.0340
0.0010
0.0026
1 VOC emissions approximated consistent with EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 (WPP1 VOC). WPP1
VOC underestimates emissions when the mass-to-carbon ratio of unidentified VOC exceeds that of propane. Ethanol and acetic acid are examples of
compounds that contribute to lumber drying VOC emissions (for some species more than others), and both have mass-to-carbon ratios exceeding that of
propane. Contribution of ethanol and acetic acid to VOC emissions has been quantified here when emissions testing data is available.
2 Because WPP1 VOC, methanol and formaldehyde emissions are dependent upon maximum drying temperature, a best-fit linear equation with dependent
variable maximum temperature of heated air entering the lumber has been generated to model emissions, with a couple of exceptions. For engelmann
spruce and lodgepole pine, a single VOC EF (based upon high-temperature drying) has been generated due to lack of sufficient test data to build a best-fit
linear equation.
3 Western true firs consist of the following seven species classified in the same Abies genus: bristlecone fir, California red fir, grand fir, noble fir, pacific
silver fir, subalpine fir and white fir.
Page 1 of 49
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Hazardous Air Pollutant Emission Factors for Drying Western True Fir Lumber
This sheet presents lab-scale HAP test data and calculations used to create HAP EF for drying western true fir lumber in an indirect steam-heated batch kiln. Western true fir consists of the following seven species classified in the same Abies genus:
bristlecone fir, California red fir, grand fir, noble fir, pacific silver fir, subalpine fir and white fir. The methanol and formaldehyde EF are temperature dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the
heated air entering the lumber. The acetaldehyde EF reflects the results of a single test. No EF are presented for either propionaldehyde or acrolein as EPA Region 10 is not aware of any test data for those HAP.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of
VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Western True Fir HAP Emission Test Data by Drying Temperature1
Maximum Dry Bulb
Temperature (°F)
Methanol
(lb/mbf)
Formaldehyde
(lb/mbf)
Acetaldehyde
(lb/mbf)
Propionaldehyde
(lb/mbf)
Acrolein
(lb/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
HAP Sample
Collection Technique
Reference
180
0.096
0.0022
no data
no data
no data
2x6
122.0/15
42.6
NCASI Method
IM/CAN/WP-99.01
without cannisters.
3, 4, 5, 12, 14
180
0.148
0.0034
no data
no data
no data
2x6
133.2/15
46.9
225
no data
no data
0.0550
no data
no data
2x4
170/13
54
Dinitrophenylhydrazine
coated cartridges.
7
240
0.42
0.0156
no data
no data
no data
2x6
126.3/15
24
NCASI chilled impinger
method.
5
240
0.419
0.0163
no data
no data
no data
2x6
119.0/15
24
1 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of the two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water/weight wood) x 100
Step Two: Adjust Western True Fir HAP Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
180
0.0875
0.0016
no data
no data
no data
180
0.1348
0.0025
no data
no data
no data
225
no data
no data
0.0550
no data
no data
240
0.3827
0.0115
no data
no data
no data
240
0.3818
0.0120
no data
no data
no data
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "lb/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Full-Scale Kiln
0.205
0.0155
0.039
0.001
OSU Kiln
0.225
0.0210
0.065
0.003
Step Three: Calculate Western True Fir HAP Emission Factors
Methanol1
Formaldehyde1
Acetaldehyde2
Propionaldehyde
Acrolein
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
0.00465X- 0.73360
0.00016x- 0.02764
0.0550
no data
no data
Acrolein
0.006
0.009
1 Because methanol and formaldehyde emissions are dependent upon drying temperature, best-fit linear equations model emissions with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
2 The acetaldehyde EF reflects the results of a single test.
Page 2 of 49
-------
-Q
£
0.45
0.40
0.35
0.30
0.25
0.20
0.15
0.10
0.05
0.00
y = 0.00465x-0.73360
R2 = 0.98422
~
170
190
210
230
250
Dry Bulb Temperatures (°F)
Page 3 of 49
y = 0.00016x-0.02764
= 0.99440
~
170
190
210
230
250
Dry Bulb Temperatures (°F)
-------
Volatile Organic Compound Emission Factors for Drying Western True Fir Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying western true fir lumber in an indirect steam-heated batch kiln. Western true fir consists of the following seven species classified in the same Abies genus: bristlecone fir,
California red fir, grand fir, noble fir, pacific silver fir, subalpine fir and white fir. RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are VOC and known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The
missed pollutant compounds (some HAP and some non-HAP) are accounted for through separate testing. RM25A test data is adjusted to fully account for three known pollutant compounds that are VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds.
This technique is consistent with EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 (WPP1 VOC) except that the RM25A results are adjusted to account for not only methanol and formaldehyde but also for acetaldehyde in this case.
More specifically, ten separate drying-temperature-specific VOC emission rates (upon which a best-fit linear equation will be established) are calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol and formaldehyde emission rates are calculated for each
temperature at which RM25A testing was performed using temperature-dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The temperature-independent acetaldehyde emission rate reflects the result of a single test. EPA Region 10 is not
aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by the RM25A test method (based on known flame ionization detector response factors) is subtracted from the RM25A measured emission rate. The remaining "unspeciated" RM25A emission rate is adjusted to
represent propane rather than carbon and then added to the speciated VOC emission rate to provide the "total" temperature-specific VOC emission rate. The resultant VOC EF is a 10-point best-fit linear equation with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Note that reporting the unspeciated VOC as propane (mass-to-carbon ratio of 1.22 and a response factor of 1) may underestimate the actual mass of VOC for certain wood species because VOC compounds like ethanol and acetic acid with higher mass-to-carbon ratios (1.92 and 2.5, respectively) and lower response factors
(0.66 and 0.575, respectively) can be a significant portion of the total VOC. Based upon the mass-to-carbon ratios and response factors noted above, 1 Ib/mbf ethanol is reported as 0.4194 Ib/mbf propane and 1 Ib/mbf acetic acid is reported as 0.2806 Ib/mbf propane through the use of EPA Reference Method 25A unless
compound-specific sampling and analysis is performed. The contribution of ethanol and acetic acid has been quantified through sampling and analysis for douglas fir and ponderosa pine. For douglas fir, ethanol's contribution over three tests was measured to be 0, 1.4 and 5.4 percent of WPP1 VOC, and acetic acid's
contribution over the same three tests was measured to be 37, 20 and 13 percent of WPP1 VOC. For ponderosa pine, ethanol's contribution over one test was measured to be 32 percent of WPP1 VOC, and acetic acid's contribution over the same test was measured to be 6.4 percent. Without western true fir lumber drying
test data for ethanol and acetic acid, EPA assumes propane adequately represents the mix of unspeciated VOC.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying
Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
180
0.26
2x6
106.3/15
36.6
JUM 3-200
3, 4
180
0.27
2x6
113.6/15
43.2
180
0.22
2x6
122.0/15
42.6
JUM 3-200
3, 4, 5, 12
180
0.25
2x6
133.2/15
46.9
190
0.63
2x4
138.1 /15
70
JUM VE-7
2
190
0.50
2x4
138.1 /15
75
200
0.53
2x4
96.1 /15
47
225
0.39
2x4
170/13
54
JUM VE-7
7
240
0.62
2x6
126.3/15
25
JUM 3-200
5
240
0.6
2x6
119.0/15
25
1 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of the two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water / weight wood) x 100
Step Two: Adjust Western True Fir VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Method 25A VOC
Temperature (°F)
as Carbon (Ib/mbf)
180
0.22
180
0.22
180
0.18
180
0.21
190
0.52
190
0.42
200
0.44
225
0.39
240
0.52
240
0.50
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "Ib/mbf documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
Full-Scale Kiln
OSU Kiln
NCASI TB No. 845 - Emission Rate (Ib/mbf)
RM25A VOC as carbon
3.53333
4.25000
Step Three: Calculate/Compile Western True Fir Speciated HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC
Maximum Dry Bulb
Methanol2
Formaldehyde3
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.1034
0.0012
190
0.1499
0.0028
200
0.1964
0.0044
0.0550
no data
no data
225
0.3127
0.0084
240
0.3824
0.0108
Testing1
1 See western true fir HAP sheet for lab-scale test data and calculations.
Page 4 of 49
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2 Methanol EF = 0.00465x - 0.73360; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
3 Formaldehyde EF = 0.00016x - 0.02764; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Four: Compile True Fir Speciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing
Maximum Dry Bulb
Ethanol
Acetic Acid
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
180
190
200
no data
no data
225
240
Step Five: Convert Western True Fir Speciated HAP and Non-HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RFX) X (SCX) X [(MWC) / (MWX)] X [(#CX) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Speciated Compounds
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.0279
0
0.0429
190
0.0405
0
0.0555
200
0.0530
0
0.0150
no data
no data
no data
no data
0.0680
225
0.0844
0
SUM
0.0994
240
0.1032
0
i—\
0.1182
Element and Compound Information
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Number of Oxygen
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
C3H4O
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3h8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in
units of "ppm."
Step Six: Subtract Speciated HAP and Non-HAP Compounds from Western True Fir RM25A VOC Emission Factors and Convert Result to "as Propane"
FROM STEP TWO
FROM STEP FIVE
Method 25A VOC
Method 25A VOC
Speciated Compounds
as Carbon without
Maximum Dry Bulb
as Carbon
as Carbon
Speciated Compounds
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.22
0.0429
0.1733
180
0.22
0.0429
0.1816
180
0.18
0.0429
0.1400
180
0.21
0.0429
0.1649
190
0.52
0.0555
0.4683
190
0.42
0.0555
0.3602
200
0.44
0.0680
0.3726
225
0.39
0.0994
0.2906
240
0.52
MINUS
0.1182
EQUALS
0.3972
240
0.50
0.1182
0.3806
Propane
Mass
Conversion
Factor
X 1.2238 =
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
0.2120
0.2222
0.1713
0.2018
0.5731
0.4408
0.4560
0.3557
0.4861
0.4658
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFc3hs) X [(MWc3hs) / (MWC)] X [(#Cc) / (#Cc3hs)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
MWC3h8 equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
Page 5 of 49
-------
#CC3h8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)], equals 1.2238 and can be referred to as the "propane mass conversion factor."
Page 6 of 49
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Step Seven: Calculate WPP1 VOC by Adding Speciated HAP and Non-HAP Compounds to Western True Fir RM25A VOC Emission Factors "as Propane"
WPP1 VOC = Method 25A VOC as propane without speciated compounds + X speciated compounds expressed as the entire mass of compound
FROM STEP SIX
Method 25A VOC
as Propane without
Maximum Dry Bulb
Speciated Compounds
Temperature (°F)
(Ib/mbf)
180
0.2120
180
0.2222
180
0.1713
180
0.2018
190
0.5731
190
0.4408
200
0.4560
225
0.3557
240
0.4861
240
0.4658
PLUS
¦=>
FROM STEP THREE
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.1034
0.0012
0.1034
0.0012
0.1034
0.0012
0.1034
0.0012
0.1499
0.0028
0.0550
no data
no data
0.1499
0.0028
0.1964
0.0044
0.3127
0.0084
0.3824
0.0108
0.3824
0.0108
Step Eight: Generate Western True Fir Best-Fit Linear Equation with Dependent Variable Maximum Drying Temperature of Heated Air Entering the Lumber to Model WPP1 VOC Emissions
WPP1 VOC (Ib/mbf): 0.00817x - 1.02133 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber
FROM STEP FOUR
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
no data
no data
EQUALS
>=>
WPP1 VOC
(Ib/mbf)
0.3716
0.3818
0.3309
0.3614
0.7808
0.6485
0.7118
0.7317
0.9343
0.9140
.a
£
u
O
>
Q.
Q.
1.0
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2
0.1
0.0
y = 0.00817x- 1.02133
R2 = 0.748^7^
<
~
~
<
1
170
190
210
230
250
Dry Bulb Temperatures (°F)
Page 7 of 49
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Hazardous Air Pollutant Emission Factors for Drying Western Hemlock Lumber
This sheet presents lab-scale test data and calculations used to create HAP EF for drying western hemlock lumber in an indirect steam-heated batch kiln. The methanol and formaldehyde EF are temperature dependent best-fit linear equations.
The temperature variable reflects the maximum temperature of the heated air entering the lumber. The acetaldehyde, propionaldehyde and acrolein EF are calculated by averaging test results.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study
of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Western Hemlock HAP Emission Test Data by Drying Temperature1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Lumber
Moisture Content2 (%)
Time to Final Moisture
HAP Sample
Reference
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
Dimensions
(Initial / Final)
Content (hours)
Collection Technique
180
0.083
0.0013
no data
no data
no data
2x4
102.3/14.7
49.5
NCASI Method 98.01
14, 15
180
0.075
0.0014
0.078
0.002
0.0012
2x4
102.3/14.7
49.5
NCASI Method 105
14, 15, 18
180
0.094
0.0015
0.141
0.0008
0.0012
2x4 or 2x6
93.5/17.5
no data
NCASI Method 105
18
180
0.052
0.0007
no data
no data
no data
2x4
88.8/15
46.2
NCASI Method CI//WP-
98.01
13
180
0.0312
0.00082
no data
no data
no data
2x4
56.8/15
38.35
NCASI Method CI//WP-
8, 11, 14
180
0.0304
0.00082
no data
no data
no data
2x4
51.1 /15
35.75
98.01
200
0.098
0.0015
no data
no data
no data
2x6
81.0/15
45.2
NCASI Method CI//WP-
98.01
200
0.175
0.0016
no data
no data
no data
2x6
73.7/15
36.5
11, 14
200
0.154
0.0018
no data
no data
no data
2x6
100.1 /15
47.4
200
0.044
0.0008
0.133
0.0008
0.0024
2x4 or 2x6
83.9/15.0
no data
NCASI Method 105
14, 18
200
0.077
0.0014
0.128
0.001
0.0011
2x4 or 2x6
98.6/15.0
no data
200
0.057
0.0014
no data
no data
no data
2x4
76.0/15
30.25
NCASI Method CI//WP-
98.01
9, 11, 14
215
0.138
0.0043
no data
no data
0.0027
2x4
119.7/15
38
no data
6, 11, 14
225
0.189
0.0035
no data
no data
no data
2x6
82/15
31.3
NCASI Method CI//WP-
98.01
225
0.167
0.0034
no data
no data
no data
2x6
77.4/15
28.6
11, 14
225
0.24
0.004
no data
no data
no data
2x6
101.7/15
33.5
235
0.187
0.0045
0.084
0.0014
0.0019
2x4 or 2x6
76.2/15.0
no data
NCASI Method 105
18
1 All data was generated by testing conducted on the smaller of the two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water/weight wood) x 100
Page 8 of 49
-------
Step Two: Adjust Western Hemlcock HAP Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.0756
0.0010
no data
no data
no data
180
0.0683
0.0010
0.0468
0.0007
0.0008
180
0.0856
0.0011
0.0846
0.0003
0.0008
180
0.0474
0.0005
no data
no data
no data
180
0.0284
0.0006
no data
no data
no data
180
0.0277
0.0006
no data
no data
no data
200
0.0893
0.0011
no data
no data
no data
200
0.1594
0.0012
no data
no data
no data
200
0.1403
0.0013
no data
no data
no data
200
0.0401
0.0006
0.0798
0.0003
0.0016
200
0.0702
0.0010
0.0768
0.0003
0.0007
200
0.0519
0.0010
no data
no data
no data
215
0.1257
0.0032
no data
no data
0.0018
225
0.1722
0.0026
no data
no data
no data
225
0.1522
0.0025
no data
no data
no data
225
0.2187
0.0030
no data
no data
no data
235
0.1704
0.0033
0.0504
0.0005
0.0013
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "Ib/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "Ib/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "Ib/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (Ib/mbf)
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Full-Scale Kiln
0.205
0.0155
0.039
0.001
OSU Kiln
0.225
0.0210
0.065
0.003
Step Three: Calculate Western Hemlock HAP Emission Factors
Methanol1
Formaldehyde1
Acetaldehyde2
Propionaldehyde2
Acrolein2
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.00249X-0.39750
0.000046X- 0.007622
0.0677
0.0004
0.0012
Acrolein
0.006
0.009
1 Because methanol and formaldehyde emissions are dependent upon maximum drying temperature, best-fit linear equations model emissions with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumbei
2 Because acetaldehyde, propionaldehyde and acrolein emissions across different species are not consistently dependent upon maximum drying temperature, EF are calculated by averaging test results.
Page 9 of 49
-------
Dry Bulb Temperatures (°F)
Page 10 of 49
Dry Bulb Temperatures (°F)
-------
Page 11 of 49
-------
Volatile Organic Compound Emission Factors for Drying Western Hemlock Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying western hemlock lumber in an indirect steam-heated batch kiln. RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are VOC and
known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The missed pollutant compounds (some HAP and some non-HAP) are accounted for through separate testing. RM25A test data is adjusted to fully account for five known pollutant compounds that are
VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds. This technique is consistent with EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 (WPP1 VOC) except that the RM25A results are adjusted to account for not
only methanol and formaldehyde but also for acetaldehyde, propionaldehyde and acrolein in this case.
More specifically, twenty-three separate drying-temperature-specific VOC emission rates (upon which a best-fit linear equation will be established) are calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol and formaldehyde emission rates are calculated for
each temperature at which RM25A testing was performed using temperature-dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The temperature-independent acetaldehyde, propionaldehyde and acrolein emission rates reflect the average of
all test results independent of the temperature of heated air entering the lumber. EPA Region 10 is not aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by the RM25A test method (based on known flame ionization detector response factors) is subtracted from
the RM25A measured emission rate. The remaining "unspeciated" RM25A emission rate is adjusted to represent propane rather than carbon and then added to the speciated VOC emission rate to provide the "total" temperature-specific VOC emission rate. The resultant VOC EF is a 23-point best-fit linear equation with
dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Note that reporting the unspeciated VOC as propane (mass-to-carbon ratio of 1.22 and a response factor of 1) may underestimate the actual mass of VOC for certain wood species because VOC compounds like ethanol and acetic acid with higher mass-to-carbon ratios (1.92 and 2.5, respectively) and lower response factors
(0.66 and 0.575, respectively) can be a significant portion of the total VOC. Based upon the mass-to-carbon ratios and response factors noted above, 1 Ib/mbf ethanol is reported as 0.4194 Ib/mbf propane and 1 Ib/mbf acetic acid is reported as 0.2806 Ib/mbf propane through the use of EPA Reference Method 25A unless
compound-specific sampling and analysis is performed. The contribution of ethanol and acetic acid has been quantified through sampling and analysis for douglas fir and ponderosa pine. For douglas fir, ethanol's contribution over three tests was measured to be 0, 1.4 and 5.4 percent of WPP1 VOC, and acetic acid's
contribution over the same three tests was measured to be 37, 20 and 13 percent of WPP1 VOC. For ponderosa pine, ethanol's contribution over one test was measured to be 32 percent of WPP1 VOC, and acetic acid's contribution over the same test was measured to be 6.4 percent. Without western hemlock lumber drying
test data for ethanol and acetic acid, EPA assumes propane adequately represents the mix of unspeciated VOC.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying
Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Western Hemlock RM25A VOC Emission Test Data by Drying Temperature1'2
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
Lumber
Dimensions
Moisture Content3 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
180
2x6
126.6/15
66.5
no data
11
180
om
2x6
139.3/15
67.9
180
as
2x6
127.8/15
65.7
180
2x6
132.7/15
67
180
0.17
2x4
114.8/15
45
no data
11
180
0.07
2x4
103.1 /15
40.7
180
0.12
2x4
98.0/15
37.5
180
0.4
2x4
115.7/15
52.9
180
0.236
2x4 or 2x6
93.5/17.5
no data
JUM VE-7
18
180
0.142
2x4
102.3/14.7
49.5
JUM VE-7
15, 18
180
0.18
2x4
88.8/15
46.2
JUM VE-7
13
180
0.198
2x4
56.8/15
38.35
JUM 3-200
8, 11
180
0.122
2x4
51.1 /15
35.75
200
0.24
2x4
112.8/15
40
JUM VE-7
2
200
0.2
2x6
81.0/15
45.2
no data
11
200
0.15
2x6
73.7/15
36.5
200
0.3
2x6
100.1 /15
47.4
200
0.204
2x4
76.0/15
30.25
JUM 3-200
9, 11
200
0.214
2x4 or 2x6
83.9/15.0
no data
JUM VE-7
18
200
0.239
2x4 or 2x6
98.6/15.0
no data
215
0.34
2x4
112.9/15
32.7
no data
11
215
0.34
2x4
119.7/15
38
JUM 3-200
6, 11
225
0.28
2x6
82/15
31.3
no data
11
225
0.27
2x6
77.4/15
28.6
225
0.31
2x6
101.7/15
33.5
235
0.247
2x4 or 2x6
81.6/15.0
no data
JUM VE-7
18
235
0.226
2x4 or 2x6
76.2/15.0
no data
1 Blue highlight denotes data not considered by EPA Region 10 in 2012. The four test runs not considered here were obtained from a single "sample" and appeared to use a much
longer drying cycle than would be in common use in the Pacific Northwest. Therefore, these highlighted values were not used in the EF derivation.
2 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of the
two small-scale kilns at OSU.
3 Dry basis. Moisture content = (weight of water / weight wood) x 100
Page 12 of 49
-------
Step Two: Adjust Western Hemlock VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Method 25A VOC
Temperature (°F)
as Carbon (Ib/mbf)
180
0.141
180
0.058
180
0.100
180
0.333
180
0.196
180
0.118
180
0.150
180
0.165
180
0.101
200
0.24
200
0.166
200
0.125
200
0.249
200
0.170
200
0.178
200
0.199
215
0.283
215
0.283
225
0.233
225
0.224
225
0.258
235
0.205
235
0.188
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "Ib/mbf" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (Ib/mbf)
RM25A VOC as carbon
Full-Scale Kiln 3.53333
OSU Kiln 4.25000
Step Three: Calculate/Compile Western Hemlock Speciated HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing*!1
Maximum Dry Bulb
Methanol2
Formaldehyde3
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.0507
0.0007
200
0.1005
0.0016
215
0.1379
0.0023
0.0677
0.0004
0.0012
225
0.1628
0.0027
235
0.1877
0.0032
1 See western hemlock HAP sheet for lab-scale test data and calculations.
2 Methanol EF = 0.00249x- 0.39750; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
3 Formaldehyde EF = 0.000046x- 0.007622; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Four: Compile Western Hemlock Speciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing
Maximum Dry Bulb
Ethanol
Acetic Acid
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
180
200
215
no data
no data
225
235
Page 13 of 49
-------
Step Five: Convert Western Hemlock Speciated HAP and Non-HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RF*) X (SC*) X [(MWC) / (MW*)] X [(#Cx) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.0137
0
200
0.0271
0
215
0.0372
0
0.0185
0.0002
0.0005
no data
no data
225
0.0439
0
235
0.0506
0
Element and Compound Information
Speciated Compounds
as Carbon
(Ib/mbf)
0.0328
0.0462
0.0563
0.0630
0.0698
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Number of Oxygen
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
c3h4o
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3H8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in units
of "ppm."
Step Six: Subtract Speciated HAP and Non-HAP Compounds from Western Hemlock RM25A VOC Emission Factors and Convert Result to "as Pro
FROM STEP TWO
FROM STEP FIVE
Method 25A VOC
Maximum Dry Bulb
Temperature
(°F)
Method 25A VOC
as Carbon
(Ib/mbf)
Speciated Compounds
as Carbon
(Ib/mbf)
as Carbon without
Speciated Compounds
(Ib/mbf)
180
0.1413
0.0328
0.1085
180
0.0582
0.0328
0.0254
180
0.0998
0.0328
0.0670
180
0.3325
0.0328
0.2998
180
0.1962
0.0328
0.1634
180
0.118
0.0328
0.0853
180
0.150
0.0328
0.1169
180
0.165
0.0328
0.1318
180
0.101
0.0328
0.0686
200
0.240
0.0462
0.1938
200
0.166
0.0462
0.1200
200
0.125
0.0462
0.0785
200
0.249
0.0462
0.2032
200
0.170
0.0462
0.1234
200
0.178
0.0462
0.1317
200
0.199
0.0462
0.1525
215
0.283
0.0563
0.2264
215
0.283
0.0563
0.2264
225
0.233
0.0630
0.1697
225
0.224
0.0630
0.1614
225
0.258
0.0630
0.1947
235
0.205
MINUS
0.0698
EQUALS
0.1356
235
0.188
c^>
0.0698
0.1181
pane
Propane
Mass
Conversion
Factor
X 1.2238 =
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
0.1328
0.0311
0.0820
0.3668
0.2000
0.1043
0.1430
0.1613
0.0840
0.2371
0.1469
0.0960
0.2486
0.1510
0.1611
0.1866
0.2770
0.2770
0.2077
0.1976
0.2383
0.1659
0.1446
Page 14 of 49
-------
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFC3H8) X [(MWC3h8) / (MWC)] X [(#Cc) / (#CC3H8)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
MWC3h8 equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
#CC3H8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)], equals 1.2238 and can be referred to as the "propane mass conversion factor."
WPP1 VOC = Method 25A VOC as propane without speciated compounds + £ speciated compounds expressed as the entire mass of compound
FROM STEP SIX
Method 25A VOC
as Propane without
FROM STEP THREE
Maximum Dry Bulb
Speciated Compounds
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
180
0.1328
0.0507
0.0007
180
0.0311
0.0507
0.0007
180
0.0820
0.0507
0.0007
180
0.3668
0.0507
0.0007
180
0.2000
0.0507
0.0007
180
0.1043
0.0507
0.0007
180
0.1430
0.0507
0.0007
180
0.1613
0.0507
0.0007
180
0.0840
0.0507
0.0007
200
0.2371
0.1005
0.0016
200
0.1469
0.1005
0.0016
200
0.0960
0.1005
0.0016
0.0677
0.0004
0.0012
200
0.2486
0.1005
0.0016
200
0.1510
0.1005
0.0016
200
0.1611
0.1005
0.0016
200
0.1866
0.1005
0.0016
215
0.2770
0.1379
0.0023
215
0.2770
0.1379
0.0023
225
0.2077
0.1628
0.0027
225
0.1976
0.1628
0.0027
225
0.2383
0.1628
0.0027
235
0.1659
PLUS
0.1877
0.0032
235
0.1446
0.1877
0.0032
PLUS
Step Seven: Generate Western Hemlock Best-Fit Linear Equation with Dependent Variable Maximum Drying Temperature of Heated Air Entering the Lumber to Model WPP1 VOC Emissions
WPP1 VOC (Ib/mbf): 0.00369x - 0.39197 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber
FROM STEP FOUR
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
no data
no data
EQUALS
WPP1 VOC
(Ib/mbf)
0.2534
0.1505
0.2014
0.4863
0.3194
0.2238
0.2624
0.2808
0.2034
0.4064
0.3161
0.2653
0.4179
0.3202
0.3304
0.3558
0.4836
0.4836
0.4392
0.4290
0.4697
0.4223
0.4010
Dry Bulb Temperatures (°F)
Page 15 of 49
-------
Hazardous Air Pollutant Emission Factors for Drying Western Red Cedar Lumber
This sheet presents the HAP EF for drying western red cedar lumber. EPA Region 10 is not aware of any HAP emission
testing of western red cedar. When no test data is available for any HAP, data for a similar species is substituted as noted.
When there are more than one similar species, the highest of the EF for the similar species is substituted.
In the absence of western red cedar test data, western true fir test data has been substituted for methanol and
formaldehyde and western hemlock test data has been substituted for acetaldehyde, propionaldehyde and acrolein.
Western red cedar is similar to western true firs and western hemlock in that all species are non-resinous softwood species
in the scientific classification order Pinales. For methanol and formaldehyde, western true fir EF are greater. For
acetaldehyde, western hemlock EF is greater. EPA Region 10 is not aware of any western true fir test data for either
propionaldehye or acrolein. See the western true fir and western hemlock HAP sheets for lab-scale test data and
calculations.
Western Red Cedar (Western True Firs and Western Hemlock Substitution) HAP Emission Factors
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.00465X- 0.73360
0.00016x- 0.02764
0.0677
0.0004
0.0012
Page 16 of 49
-------
Volatile Organic Compound Emission Factors for Drying Western Red Cedar Lumber
This sheet presents the VOC EF for drying western red cedar lumber. EPA Region 10 is aware of two tests being conducted while drying western red cedar
lumber, and both were conducted at 160°F. Because VOC emissions increase with maximum drying temperature, employing an EF based upon testing at
160°F would underreport emissions when drying at maximum drying temperatures greater than 160°F. A temperature of 160°F is not a particularly high
drying temperature. When little or no test data is available, data for a similar species is substituted as noted. When there are more than one similar species,
the highest of the EF for the similar species is substituted.
Given the limited western red cedar test data, western true fir test data has been substituted. Western red cedar is similar to western true firs and western
hemlock in that all species are non-resinous softwood species in the scientific classification order Pinales. Western true fir VOC emissions are greater than
western hemlock VOC emissions. See the western true fir and western hemlock VOC sheets for lab-scale test data and calculations.
Western Red Cedar (Western True Firs Substitution) WPP1 VOC Emission Factor
WPP1 VOC (Ib/mbf): 0.00817x - 1.02133 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumt
Page 17 of 49
-------
Hazardous Air Pollutant Emission Factors for Drying Douglas Fir Lumber
This sheet presents lab-scale test data and calculations used to create HAP EF for drying douglas fir lumber in an indirect steam-heated batch kiln. The methanol and formaldehyde EF are temperature dependent best-fit linear equations. The
temperature variable reflects the maximum temperature of the heated air entering the lumber. The acetaldehyde, propionaldehyde and acrolein EF are calculated by averaging test results.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study
of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Douglas Fir HAP Emission Test Data by Drying Temperature1
Maximum Dry Bulb
Temperature (°F)
Methanol
(Ib/mbf)
Formaldehyde
(Ib/mbf)
Acetaldehyde
(Ib/mbf)
Propionaldehyde
(Ib/mbf)
Acrolein
(Ib/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
HAP Sample
Collection Technique
Reference
145
0.013
0.001
0.057
0.005
0.000
2x4
49.6/15
39.7
NCASI ISS/FP-A105.01
Link to June 8.
2012 Exterior
Wood Test Report
160
0.025
0.0008
no data
no data
no data
2x6
37.3/15
23.5
NCASI Method
IM/CAN/WP-99.01
without cannisters.
3, 4, 12, 14
160
0.023
0.0008
no data
no data
no data
2x6
44.9/15
28.5
160
0.026
0.0017
no data
no data
no data
2x6
40.3/15
27.1
160
0.018
0.0011
no data
no data
no data
2x6
31.9/15
25.2
170
0.015
0.0005
no data
no data
no data
2x4
79.9/15
40.5
NCASI Method CI//WP-
98.01
13
170
0.026
0.0008
no data
no data
no data
2x4
56.9/15
27.5
NCASI Method 98.01
15
170
0.024
0.0008
0.03
0.0004
0.0005
2x4
56.9/15
27.5
NCASI Method 105
15, 18
175
0.019
0.001
0.006
0.0001
0.0004
2x4
32.5/15
17.8
NCASI ISS/FP-A105.01
Link to Mav 23.
2013 Sierra Pacific
Industries -
Centralia Test
ReDort
175
0.084
0.0016
0.042
0.0002
0.0008
4x5
39.5/15
150
NCASI ISS/FP-A105.01
Link to March 24,
2015 Columbia
Vista Test Report
180
0.050
0.0023
0.050
0.0005
0.0009
2x4
43.7/15
48
NCASI Method 105
18, 22
180
0.084
0.0019
0.061
0.0003
0.0007
4x4
44.7/15
111
NCASI Method 105
19
200
0.068
0.0018
0.043
0.0005
0.0009
2x4
64.3/15
60
NCASI Method 105
14, 18, 22
200
0.069
0.0019
0.071
0.0006
0.0004
2x4
59.5/15
56
200
0.080
0.003
0.037
0.0006
0.0017
2x4
69.3/15
20.8
NCASI ISS/FP-A105.01
Link to February
10. 2012 HamDton
Lumber - Morton
Test Report
220
no data
no data
0.030
no data
no data
2x4
73/12
46
Dinitrophenylhydrazine
coated cartridges.
7
220
no data
no data
0.022
no data
no data
2x4
73/15
46
235
0.117
0.0043
0.067
0.0008
0.0012
2x4 or 2x6
47.7/15
19
NCASI Method 105
18, 21
1 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of the two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water/weight wood) x 100
Page 18 of 49
-------
Step Two: Adjust Douglas Fir HAP Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
145
0.012
0.0007
0.034
0.0017
0.0000
160
0.023
0.0006
no data
no data
no data
160
0.021
0.0006
no data
no data
no data
160
0.024
0.0013
no data
no data
no data
160
0.016
0.0008
no data
no data
no data
170
0.014
0.0004
no data
no data
no data
170
0.024
0.0006
no data
no data
no data
170
0.022
0.0006
0.018
0.0001
0.0003
175
0.017
0.0007
0.004
0.0000
0.0003
175
0.077
0.0012
0.025
0.0001
0.0005
180
0.046
0.0017
0.030
0.0002
0.0006
180
0.077
0.0014
0.037
0.0001
0.0005
200
0.062
0.0013
0.026
0.0002
0.0006
200
0.063
0.0014
0.043
0.0002
0.0003
200
0.073
0.0022
0.022
0.0002
0.0011
220
no data
no data
0.030
no data
no data
220
no data
no data
0.022
no data
no data
235
0.107
0.0032
0.040
0.0003
0.0008
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "lb/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
Methanol Formaldehyde Acetaldehyde Propionaldehyde Acrolein
Full-Scale Kiln 0.205 0.0155 0.039 0.001 0.006
OSU Kiln 0.225 0.0210 0.065 0.003 0.009
Step Three: Calculate Douglas Fir HAP Emission Factors
Methanol1
Formaldehyde1
Acetaldehyde2
Propionaldehyde2
Acrolein2
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
0.00114x-0.16090
0.000028X- 0.003800
0.0275
0.0003
0.0005
1 Because methanol and formaldehyde emissions are dependent upon drying temperature, best-fit linear equations model emissions with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
2 Because acetaldehyde, propionaldehyde and acrolein emissions across different species are not consistently dependent upon maximum drying temperature, EF are calculated by averaging test results.
Page 19 of 49
-------
Dry Bulb Temperatures (°F)
Page 20 of 49
0.0035
0.0030
-Q
£ 0.0025
•
"S 0.0015
2
ro
£ 0.0010
0.0005
0.0000
y = 0.000028X - 0.0
03800
R2 = 0.71351?
I
<
~
<
~
<
i
~
I
~ ^
~
~
140
160
180 200
Dry Bulb Temperatures (°F)
220
240
-------
Volatile Organic Compound Emission Factors for Drying Douglas Fir Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying douglas fir lumber in an indirect steam-heated batch kiln. RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are VOC and
known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The missed pollutant compounds (some HAP and some non-HAP) are accounted for through separate testing. RM25A test data is adjusted to fully account for seven known pollutant compounds that
are VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds. This technique is consistent with EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 (WPP1 VOC) except that the RM25A results are adjusted to account
for not only methanol and formaldehyde but also for acetaldehyde, propionaldehyde, acrolein, ethanol and acetic acid in this case.
More specifically, twenty-one separate drying-temperature-specific VOC emission rates (upon which a best-fit linear equation will be established) are calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol, formaldehyde and ethanol emission rates are
calculated for each temperature at which RM25A testing was performed using temperature-dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The temperature-independent acetaldehyde, propionaldehyde, acrolein and acetic acid emission
rates reflect the average of all test results independent of the temperature of heated air entering the lumber. EPA Region 10 is not aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by the RM25A test method (based on known flame ionization detector
response factors) is subtracted from the RM25A measured emission rate. The remaining "unspeciated" RM25A emission rate is adjusted to represent propane rather than carbon and then added to the speciated VOC emission rate to provide the "total" temperature-specific VOC emission rate. The resultant VOC EF is a 21-
point best-fit linear equation with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying
Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
StegOne^ComgMeDouglasFirRM25AVOCEmissionTestDatabyDryingTemgerature^
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
145
0.24
2x4
49.6/15
39.7
JUM VE-7
Link to June 8, 2012
Exterior Wood Test
Report
160
0.51
2x6
37.3/15
23.5
JUM 3-200
3, 4, 12
160
0.55
2x6
44.9/15
28.5
160
0.45
2x6
40.3/15
27.1
160
0.46
2x6
31.9/15
25.2
170
0.65
2x4
79.9/15
40.5
JUM VE-7
13
170
0.24
2x4
56.9/15
27.5
JUM VE-7
15, 18
175
0.185
2x4
32.5/15
17.8
JUM VE-7
Link to Mav 23, 2013
Sierra Pacific Industries -
Centralia Test Report
175
0.86
4x5
39.5/15
150
JUM VE-7
Link to March 24, 2015
Columbia Vista Test
Report
180
0.942
2x4
38.9/15
63
JUM VE-7
2
180
0.669
2x4
44.9/15
42
180
0.21
2x4
56.3/15
27
180
0.575
2x4 or 2x6
43.7/15
no data
JUM VE-7
18
180
0.39
4x4
29.8/19
67.5
JUM 3-200
10
180
0.845
4x4
44.7/15
111
JUM VE-7
19
200
0.707
2x4 or 2x6
64.3/15
no data
JUM VE-7
18
200
0.879
2x4 or 2x6
59.5/15
no data
200
0.66
2x4
69.3/15
20.8
JUM VE-7
Link to February 10,
2012 Hampton Lumber-
Morton Test Report
220
1.2
2x4
73/12
46
JUM VE-7
7
220
1.3
2x4
73/15
46
235
1.206
2x4 or 2x6
47.7/15
19
JUM VE-7
18, 21
1 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of
the two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water / weight wood) x 100.
Page 21 of 49
-------
Step Two: Adjust Douglas Fir VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Method 25A VOC
Temperature (°F)
as Carbon (lb/mbf)
145
0.200
160
0.424
160
0.457
160
0.374
160
0.382
170
0.540
170
0.200
175
0.154
175
0.715
180
0.942
180
0.669
180
0.21
180
0.478
180
0.324
180
0.703
200
0.588
200
0.731
200
0.549
220
1.2
220
1.3
235
1.003
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "lb/mbf documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "lb/mbf measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "lb/mbf measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
RM25A VOC as carbon
Full-Scale Kiln 3.53333
OSU Kiln 4.25000
Step Three: Calculate/Compile Douglas FirSpeciated HAP Emission Factors at Maximum Drvint
Maximum Dry Bulb
Methanol2
Formaldehyde3
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
145
0.0044
0.0003
160
0.0215
0.0007
170
0.0329
0.0010
175
0.0386
0.0011
0.0275
0.0003
0.0005
180
0.0443
0.0012
200
0.0671
0.0018
220
0.0899
0.0024
235
0.1070
0.0028
Temperatures Observed during RM25A VOC Testing1
1 See douglas fir HAP sheet for lab-scale test data and calculations.
2 Methanol EF = 0.00114x - 0.16090; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
3 Formaldehyde EF = 0.000028x - 0.003800; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Four: Compile Douglas Fir Speciated Non-HAP Emission Test Data by Drying Temperature
Maximum Dry Bulb
Temperature (°F)
Ethanol
(lb/mbf)
Acetic Acid
(lb/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
VOC Sample
Collection Technique
Reference
145
0.0000
0.166
2x4
49.6/15
39.7
NCASI ISS/FP-A105.01
Link to June 8, 2012
Exterior Wood Test
ReDort
175
0.0010
0.094
2x4
32.5/15
17.8
NCASI ISS/FP-A105.01
Link to Mav 23, 2013
Sierra Pacific Industries -
Centralia Test Report
175
0.0230
0.242
4x6
39.5/15
150
NCASI ISS/FP-A105.01
Link to March 24, 2015
Columbia Vista Test
Report
200
0.0610
0.142
2x4
69.3/15
20.8
NCASI ISS/FP-A105.01
Link to February 10,
2012 HamDton Lumber-
Morton Test ReDort
1 Dry basis. Moisture content = (weight of water / weight wood) x 100
Page 22 of 49
-------
Step Five: Calculate Douglas FirSpeciated Non-HAP Emission Factors
Ethanol1
(Ib/mbf)
Acetic Acid2
(Ib/mbf)
0.00107X-0.16537
0.1610
1 Because ethanol emissions are dependent upon drying temperature, a best-fit linear equation models emissions with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
2 Because acetic acid emissions are independent of drying temperature, EF is calculated by averaging test results.
Step Six: Calculate/Compile Douglas FirSpeciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing
Maximum Dry Bulb
Ethanol1
Acetic Acid
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
145
0
160
0.00583
170
0.01653
175
0.02188
0.1610
180
0.02723
200
0.04863
220
0.07003
235
0.08608
1 Ethanol EF = 0.00107x - 0.16537; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Seven: Convert Douglas FirSpeciated HAP and Non-HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RFX) X (SCX) X [(MWC) / (MWX)] X [(#CX) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
145
0.0012
0
0
160
0.0058
0
0.0020
170
0.0089
0
0.0057
175
0.0104
0
0.0075
0.0001
0.0002
0.0075
0.0370
180
0.0120
0
0.0094
200
0.0181
0
0.0167
220
0.0243
0
0.0241
235
0.0289
0
0.0296
SUM
"=>
Speciated Compounds
as Carbon
(Ib/mbf)
0.0461
0.0527
0.0594
0.0628
0.0662
0.0797
0.0932
0.1034
Page 23 of 49
-------
Element and Compound Information
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Number of Oxygen
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
C3H4O
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3H8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in units of "ppm."
Step Eight: Subtract Speciated HAP and Non-HAP Compounds from Douglas Fir VOC Emission Factors and Convert Result to "as Propane"
FROM STEP TWO
FROM STEP SIX
Method 25A VOC
Maximum Dry Bulb
Method 25A VOC
Speciated Compounds
as Carbon without
Temperature
as Carbon
as Carbon
Speciated Compounds
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
145
0.1995
0.0461
0.1535
160
0.4240
0.0527
0.3713
160
0.4573
0.0527
0.4046
160
0.3741
0.0527
0.3214
160
0.3824
0.0527
0.3298
170
0.5404
0.0594
0.4810
170
0.1995
0.0594
0.1401
175
0.1538
0.0628
0.0910
175
0.7150
0.0628
0.6522
180
0.9420
0.0662
0.8758
180
0.6690
0.0662
0.6028
180
0.2100
0.0662
0.1438
180
0.4780
0.0662
0.4118
180
0.3242
0.0662
0.2580
180
0.7025
0.0662
0.6363
200
0.5878
0.0797
0.5081
200
0.7308
0.0797
0.6511
200
0.5487
0.0797
0.4690
220
1.2000
0.0932
1.1068
220
1.3000
MINUS
0.0932
EQUALS
1.2068
235
1.0026
0.1034
0.8993
Propane
Mass
Conversion
Factor
X 1.2238 =
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
0.1878
0.4544
0.4951
0.3934
0.4035
0.5886
0.1714
0.1114
0.7981
1.0718
0.7377
0.1760
0.5040
0.3158
0.7787
0.6218
0.7968
0.5739
1.3544
1.4768
1.1005
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
MWC3H8 equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
#CC3H8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFc3H8) X [(MWcshs) / (MWC)] X [(#Cc) / (#Cc3H8)L equals 1.2238 and can be referred to as the "propane mass conversion factor."
Page 24 of 49
-------
Step Nine: Calculate WPP1 VOC by Adding Speciated HAP and Non-HAP Compounds to Douglas Fir VOC Emission Factors "as Propane"
WPP1 VOC = Method 25A VOC as propane without speciated compounds + X speciated compounds expressed as the entire mass of compound
FROM STEP EIGHT
Method 25A VOC
as Propane without
Maximum Dry Bulb
Speciated Compounds
Temperature (°F)
(Ib/mbf)
145
0.1878
160
0.4544
160
0.4951
160
0.3934
160
0.4035
170
0.5886
170
0.1714
175
0.1114
175
0.7981
180
1.0718
180
0.7377
180
0.1760
180
0.5040
180
0.3158
180
0.7787
200
0.6218
200
0.7968
200
0.5739
220
1.3544
220
1.4768
235
1.1005
PLUS
FROM STEP THREE
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.0044
0.0003
0.0215
0.0007
0.0215
0.0007
0.0215
0.0007
0.0215
0.0007
0.0329
0.0010
0.0329
0.0010
0.0386
0.0011
0.0386
0.0011
0.0443
0.0012
0.0443
0.0012
0.0275
0.0003
0.0005
0.0443
0.0012
0.0443
0.0012
0.0443
0.0012
0.0443
0.0012
0.0671
0.0018
0.0671
0.0018
0.0671
0.0018
0.0899
0.0024
0.0899
0.0024
0.1070
0.0028
PLUS
Step Ten: Generate Douglas Fir Best-Fit Linear Eguation with Dependent Variable Maximum Drying Temperature to Model WPP1 VOC Emissions
WPP1 VOC (Ib/mbf): 0.01460x - 1.77130 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber
FROM STEP SIX
Ethanol
Acetic Acid
(Ib/mbf)
(Ib/mbf)
0
0.0058
0.0058
0.0058
0.0058
0.0165
0.0165
0.0219
0.0219
0.0272
0.0272
0.1610
0.0272
0.0272
0.0272
0.0272
0.0486
0.0486
0.0486
0.0700
0.0700
0.0861
EQUALS
WPP1 VOC
(Ib/mbf)
0.3818
0.6717
0.7124
0.6107
0.6209
0.8283
0.4111
0.3622
1.0490
1.3339
0.9998
0.4381
0.7661
0.5779
1.0408
0.9286
1.1036
0.8808
1.7060
1.8284
1.4857
2.0
1.8
1.6
1.4
_Q 1.2
1.0
0.8
0.6
0.4
0.2
0.0
Si
£
u
O
>
Q.
Q.
*
~
y = 0.0146
Dx - 1.77130
~
R2 = 0
.62865
~
<
~
~ 1
( ^
~
~ —-
~
~
~
* ~
140
160
180 200
Dry Bulb Temperatures (°F)
220
240
Page 25 of 49
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Hazardous Air Pollutant Emission Factors for Drying Engelmann Spruce Lumber
This sheet presents lab-scale test data and calculations used to create HAP EF for engelmann spruce lumber in an indirect steam-heated batch kiln. EPA Region 10 is not aware of any HAP emission testing of englemann spruce. When actual
test data is not available, data for a similar species is substituted as noted. When there are more than one similar species, the highest of the EF for the similar species is substituted. In the absence of engelmann spruce test data, white spruce test
data has been substituted. The two wood species are similar in that both are resinous softwood species in the scientific classification genus Picea.
The methanol and formaldehyde EF are temperature dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The acetaldehyde, propionaldehyde and acrolein EF are
calculated by averaging test results.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study
of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Maximum Dry Bulb
Temperature (°F)
Methanol
(lb/mbf)
Formaldehyde
(lb/mbf)
Acetaldehyde
(lb/mbf)
Propionaldehyde
(lb/mbf)
Acrolein
(lb/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
HAP Sample
Collection Technique
Reference
180
0.025
0.0013
0.036
0.0003
0.0005
2x4 or 2x6
33.5/15
no data
NCASI Method 105
18
235
0.078
0.0044
0.031
0.0007
0.001
2x4 or 2x6
32.7/15
no data
1 Dry basis. Moisture content = (weight of water/weight wood) x 100
Step Two: Adjust Enaelmann Spruce (White Spruce Substitution) HAP Emission Test Data to Account for Bias in Underlvina Small-Scale Kiln to Represent Full-Scale Kiln Emissions
Maximum Dry Bulb
Temperature (°F)
Methanol
(lb/mbf)
Formaldehyde
(lb/mbf)
Acetaldehyde
(lb/mbf)
Propionaldehyde
(lb/mbf)
Acrolein
(lb/mbf)
180
0.023
0.0010
0.022
0.0001
0.0003
235
0.071
0.0032
0.019
0.0002
0.0007
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "lb/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Full-Scale Kiln
0.205
0.0155
0.039
0.001
OSU Kiln
0.225
0.0210
0.065
0.003
Step Three: Calculate Enaelmann Spruce (White Spruce Substitution) HAP Emission Factors
Methanol1
Formaldehyde1
Acetaldehyde2
Propionaldehyde2
Acrolein2
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
0.00088X-0.13526
0.000042X- 0.006529
0.0201
0.0002
0.0005
Acrolein
0.006
0.009
1 Because methanol and formaldehyde emissions are dependent upon drying temperature, best-fit linear equations model emissions with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
2 Because acetaldehyde, propionaldehyde and acrolein emissions across different species are not consistently dependent upon maximum drying temperature, EF are calculated by averaging test results.
Page 26 of 49
-------
Dry Bulb Temperatures (°F)
Page 27 of 49
0.0035
^ 0.0030
-Q
0.0025
£
'Z 0.0020
¦a
>•
"S 0.0015
2
£ 0.0010
i-
O
"" 0.0005
0.0000
/ = 0.000042x - 0.00651
9
R2 = 1.000000
<1
F
160
180 200 220
Dry Bulb Temperatures (°F)
240
-------
Volatile Organic Compound Emission Factors for Drying Engelmann Spruce Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying white spruce lumber in an indirect steam-heated batch kiln. EPA Region 10 is not aware of any HAP or VOC emission testing of englemann spruce. When actual test
data is not available, data for a similar species is substituted as noted. When there are more than one similar species, the highest of the EF for the similar species is substituted. In the absence of engelmann spruce test data, white spruce test data has been substituted. The two wood species are similar in that both are
resinous softwood species in the scientific classification genus Picea. Although only one RM25A VOC test was performed while drying white spruce, it was performed while drying lumber at a relatively high maximum temperature of 235°F. Because emissions increase with maximum drying temperature, employing an
EF based upon testing at 235°F would overreport emissions when drying at maximum drying temperatures less than than 235°F.
RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are VOC and known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The missed pollutant compounds (some HAP and some non-HAP) are accounted
for through separate testing. RM25A test data is adjusted to fully account for five known pollutant compounds that are VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds. This technique is consistent with EPA's Interim VOC Measurement
Protocol for the Wood Products Industry - July 2007 (WPP1 VOC) except that the RM25A results are adjusted to account for not only methanol and formaldehyde but also for acetaldehyde, propionaldehyde and acrolein in this case.
More specifically, one VOC emission rate is calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol and formaldehyde emission rates are calculated for each temperature at which RM25A testing was performed using temperature-dependent best-fit
linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The temperature-independent acetaldehyde, propionaldehyde and acrolein emission rates reflect the average of all test results independent of the temperature of heated air entering the lumber. EPA
Region 10 is not aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by the RM25A test method (based on known flame ionization detector response factors) is subtracted from the RM25A measured emission rate. The remaining "unspeciated" RM25A
emission rate is adjusted to represent propane rather than carbon and then added to the speciated VOC emission rate to provide the "total" temperature-specific VOC emission rate.
Note that reporting the unspeciated VOC as propane (mass-to-carbon ratio of 1.22 and a response factor of 1) may underestimate the actual mass of VOC for certain wood species because VOC compounds like ethanol and acetic acid with higher mass-to-carbon ratios (1.92 and 2.5, respectively) and lower response
factors (0.66 and 0.575, respectively) can be a significant portion of the total VOC. Based upon the mass-to-carbon ratios and response factors noted above, 1 Ib/mbf ethanol is reported as 0.4194 Ib/mbf propane and 1 Ib/mbf acetic acid is reported as 0.2806 Ib/mbf propane through the use of EPA Reference Method
25A unless compound-specific sampling and analysis is performed. The contribution of ethanol and acetic acid has been quantified through sampling and analysis for douglas fir and ponderosa pine. For douglas fir, ethanol's contribution over three tests was measured to be 0, 1.4 and 5.4 percent of WPP1 VOC, and
acetic acid's contribution over the same three tests was measured to be 37, 20 and 13 percent of WPP1 VOC. For ponderosa pine, ethanol's contribution over one test was measured to be 32 percent of WPP1 VOC, and acetic acid's contribution over the same test was measured to be 6.4 percent. Without white
spruce lumber drying test data for ethanol and acetic acid, EPA assumes propane adequately represents the mix of unspeciated VOC.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying
Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Engelmann Spruce (White Spruce Substitution) RM25A VOC Emission Test Data by Drying Temperature
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
235
0.11
2x4 or 2x6
32.7/15
no data
JUM VE-7
18
1 Dry basis. Moisture content = (weight of water / weight wood) x 100
Step Two: Adjust Engelmann Spruce (White Spruce Substitution) VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
235
0.09
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "Ib/mbf documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (Ib/mbf)
RM25A VOC as carbon
Full-Scale Kiln 3.53333
OSU Kiln 4.25000
Step Three: Calculate/Compile Engelmann Spruce (White Spruce Substitution) Speciated HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
235
0.0715
0.0033
0.0201
0.0002
0.0005
1 See engelmann spruce HAP sheet for lab-scale test data and calculations.
2 Methanol EF = 0.00088x- 0.13526; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
3 Formaldehyde EF = 0.000042x- 0.006529; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Four: Compile Eng
elmann Spruce (White S
oruce Substitution) Speciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing
Maximum Dry Bulb
Temperature (°F)
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
235
no data
no data
Step Five: Convert Engelmann Spruce (White Spruce Substitution) Speciated HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RF><) X (SCx) X [(MWC) / (MW*)] X [(#Cx) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Page 28 of 49
-------
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
235
0.0193
0
0.0055
0.0001
0.0002
no data
no data
Element and Compound Information
Speciated Compounds
as Carbon
(Ib/mbf)
0.0251
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Number of Oxygen
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
c3h4o
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3h8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in units
of "ppm."
Step Six: Subtract Speciated HAP and Non-HAP Compounds from Enaelmann Spruce (White Spruce Substitution) VOC Emission Factors and Convert Result to "as Propane"
FROM STEP TWO
Maximum Dry Bulb
Method 25A VOC
Temperature
as Carbon
(°F)
(Ib/mbf)
235
0.0915
MINUS
>=>
FROM STEP FIVE
Speciated Compounds
as Carbon
(Ib/mbf)
0.0251
EQUALS
Method 25A VOC
as Carbon without
Speciated Compounds
(Ib/mbf)
0.0664
Propane
Mass
Conversion
X 1.2238 =
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
0.0812
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFC3H8) X [(MWC3h8) / (MWC)] X [(#Cc) / (#CC3H8)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
MWC3h8 equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
#CC3H8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFC3H8) X [(MWC3h8) / (MWC)] X [(#Cc) / (#CC3H8)], equals 1.2238 and can be referred to as the "propane mass conversion factor."
Step Seven: Calculate WPP1 VOC by Adding Speciated HAP and Non-HAP Compounds to Enaelmann Spruce (White Spruce Substitution) VOC Emission Factors "as Propane"
WPP1 VOC = Method 25A VOC as propane without speciated compounds + £ speciated compounds expressed as the entire mass of compound
FROM STEP SIX
Method 25A VOC
as Propane without
Maximum Dry Bulb
Speciated Compounds
Temperature (°F)
(Ib/mbf)
235
0.0812
PLUS
FROM STEP THREE
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.0715
0.0033
0.0201
0.0002
0.0005
PLUS
¦=>
FROM STEP FOUR
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
no data
no data
EQUALS
WPP1 VOC
(Ib/mbf)
0.1769
Page 29 of 49
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Hazardous Air Pollutant Emission Factors for Drying Larch Lumber
This sheet presents the HAP EF for drying larch lumber. EPA Region 10 is not aware of any HAP emission testing of larch.
Consistent with other species, when actual test data is not available, data for a similar species is substituted as noted.
When there are more than one similar species, the highest of the EF for the similar species is substituted.
In the absence of larch test data, douglas fir test data has been substituted. Larch is similar to douglas fir, engelmann
spruce, white spruce, lodgepole pine, ponderosa pine and western white pine in that all seven species are resinous
softwood species in the scientific classification order Pinaceae, but larch does not share a common genus with any of these
species. It appears to be most similar to douglas fir, engelmann spruce and white spruce in that the four species have small,
sparse resin canals as opposed to the large numerous resin canals of the pines. See
http://www.faculty.sfasu.edu/mcbroommatth/lectures/wood_science/lab_2_resin_canal_species.pdf. While the white spruce
EF for formaldehyde is greater than that of douglas fir at high drying temperatures, the opposite is true at low drying
temperatures. The douglas fir EF equation for formaldehyde is based upon seven tests while the white spurce EF equation
is based upon two. All other HAP EF are greater for douglas fir at all drying temperatures. Under the circumstances, EPA
Region 10 has decided to substitue the douglas fir formaldehyde EF equation. See the white spruce (appearing under
engelmann spruce tab) and douglas fir HAP sheets for lab-scale test data and calculations.
Larch (Douglas Fir Substitution) HAP Emission Factors
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.00114x- 0.16090
0.000028X-0.003800
0.0275
0.0003
0.0005
Page 30 of 49
-------
Volatile Organic Compound Emission Factors for Drying Larch Lumber
This sheet presents the VOC EF for drying larch lumber. EPA Region 10 is not aware of any VOC emission testing of larch. When actual test data is not
available, data for a similar species is substituted as noted. When there are more than one similar species, the highest of the EF for the similar species is
substituted.
In the absence of larch test data, douglas fir test data has been substituted. Larch is similar to douglas fir, engelmann spruce, white spruce, lodgepole pine,
ponderosa pine and western white pine in that all seven species are resinous softwood species in the scientific classification order Pinaceae, but larch does
not share a common genus with any of these species. It appears to be most similar to douglas fir, engelmann spruce and white spruce in that the four
species have small, sparse resin canals as opposed to the large numerous resin canals of the pines. See
http://www.faculty.sfasu.edu/mcbroommatth/lectures/wood_science/lab_2_resin_canal_species.pdf. Because the douglas fir EF is greater than that of white
spruce (and EPA Region 10 is not aware of any VOC test data for engelmann spruce), the douglas fir EF has been substituted. See the douglas fir VOC
sheet for lab-scale test data and calculations.
Larch (Douglas Fir Substitution) WPP1 VOC Emission Factor
WPP1 VOC (Ib/mbf): 0.01460x - 1.77130 ;wherex is maximum drying temperature in °F
Page 31 of 49
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Hazardous Air Pollutant Emission Factors for Drying Lodgepole Pine Lumber
This sheet presents lab-scale test data and calculations used to create HAP EF for drying lodgepole pine lumber in an indirect steam-heated batch kiln. The EF are calculated by averaging test results. Lodgepole pine testing was performed while
drying lumber at a relatively high maximum temperature of around 237°F. Because emissions increase with maximum drying temperature, employing an EF based upon testing at 237°F would overreport emissions when drying at maximum drying
temperatures less than than 237°F.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of
VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Lodgepole Pine HAP Emission Test Data by Drying Temperature1
Maximum Dry Bulb
Temperature (°F)
Methanol
(lb/mbf)
Formaldehyde
(lb/mbf)
Acetaldehyde
(lb/mbf)
Propionaldehyde
(lb/mbf)
Acrolein
(lb/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
HAP Sample
Collection Technique
Reference
195
no data
©£42
no data
no data
no data
no data
no data
no data
14
195
&092
no data
no data
no data
no data
no data
no data
no data
no data
195
©£64
no data
no data
no data
no data
no data
no data
no data
no data
195
©£2S
no data
no data
no data
no data
no data
no data
no data
no data
195
002
no data
no data
no data
no data
no data
no data
no data
no data
< 200°F
no data
236
0.063
0.0041
no data
no data
no data
2x4
59.1 /15
16
NCASI Method
IM/CAN/WP-99.01
without cannisters.
3, 4, 12, 14
237
0.062
0.0041
no data
no data
no data
2x4
59.7/15
16.6
238
0.056
0.0039
no data
no data
no data
2x4
56.9/15
16
1 Blue highlight denotes data not considered by EPA Region 10 in 2012. Five test runs considered by EPA Region 10 in 2007 are not considered here due to lack of documentation. The omitted test values are presented in Oregon Department of
Environmental Quality memorandum May 8, 2007 entitled, "Title III Implications of Drying Kiln Source Test Results." The memorandum lists "Forintec #1, #2 and #5" along with "OSU QA # 1 and #2 " as the test data sources.
2 Dry basis. Moisture content = (weight of water/weight wood) x 100
Step Two: Adjust Lodgepole Pine VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
236
0.057
0.0030
no data
no data
no data
237
0.056
0.0030
no data
no data
no data
238
0.051
0.0029
no data
no data
no data
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "lb/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
Methanol Formaldehyde Acetaldehyde Propionaldehyde Acrolein
Full-Scale Kiln 0.205 0.0155 0.039 0.001 0.006
OSU Kiln 0.225 0.0210 0.065 0.003 0.009
Step Three: Calculate Lodgepole Pine HAP Emission Factors
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
0.0550
0.0030
no data
no data
no data
Page 32 of 49
-------
Volatile Organic Compound Emission Factors for Drying Lodgepole Pine Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying lodgepole pine lumber in an indirect steam-heated batch kiln. Although three RM25A VOC tests were performed while drying lodgepole pine, they were performed while drying
lumber at a relatively high maximum temperature of around 238°F. Because emissions increase with maximum drying temperature, employing an EF based upon testing at 238°F would overreport emissions when drying at maximum drying temperatures less than than 238°F.
RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are VOC and known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The missed pollutant compounds (some HAP and some non-HAP) are accounted for
through separate testing. RM25A test data is adjusted to fully account for two known pollutant compounds that are VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds. This technique is consistent with EPA's Interim VOC Measurement Protocol for the
Wood Products Industry - July 2007 (WPP1 VOC).
More specifically, one VOC emission rate is calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol and formaldehyde emission rates are calculated for each temperature at which RM25A testing was performed using temperature-dependent best-fit linear
equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. EPA Region 10 is not aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by the RM25A test method (based on known flame ionization detector response
factors) is subtracted from the RM25A measured emission rate. The remaining "unspeciated" RM25A emission rate is adjusted to represent propane rather than carbon and then added to the speciated VOC emission rate to provide the "total" temperature-specific VOC emission rate.
Note that reporting the unspeciated VOC as propane (mass-to-carbon ratio of 1.22 and a response factor of 1) may underestimate the actual mass of VOC for certain wood species because VOC compounds like ethanol and acetic acid with higher mass-to-carbon ratios (1.92 and 2.5, respectively) and lower response factors
(0.66 and 0.575, respectively) can be a significant portion of the total VOC. Based upon the mass-to-carbon ratios and response factors noted above, 1 Ib/mbf ethanol is reported as 0.4194 Ib/mbf propane and 1 Ib/mbf acetic acid is reported as 0.2806 Ib/mbf propane through the use of EPA Reference Method 25A unless
compound-specific sampling and analysis is performed. The contribution of ethanol and acetic acid has been quantified through sampling and analysis for douglas fir and ponderosa pine. For douglas fir, ethanol's contribution over three tests was measured to be 0, 1.4 and 5.4 percent of WPP1 VOC, and acetic acid's
contribution over the same three tests was measured to be 37, 20 and 13 percent of WPP1 VOC. For ponderosa pine, ethanol's contribution over one test was measured to be 32 percent of WPP1 VOC, and acetic acid's contribution over the same test was measured to be 6.4 percent. Without reliable lodgepole pine lumber
drying test data for ethanol and acetic acid, EPA assumes propane adequately represents the mix of unspeciated VOC.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern
Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
236
1.17
2x4
59.1 /15
16.01
JUM 3-200
3, 4, 12
238
0.87
2x4
56.9/15
16.01
240
1.19
2x4
64.9/15
16.81
1 Dry basis. Moisture content = (weight of water / weight wood) x 100
Step Two: Calculate Lodgepole Pine VOC Emission Factor1
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
238
1.0767
1 Three-run average.
Step Three: Adjust Ponderosa Pine VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions1
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (Ib/mbf)
238
0.8951
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "Ib/mbf documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "Ib/mbf measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
Full-Scale Kiln
OSU Kiln
NCASI TB No. 845 - Emission Rate (Ib/mbf)
RM25A VOC as carbon
3.53333
4.25000
Step Four: Compile Lodgepole Pine Speciated HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing1
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
238
0.0550
0.0030
no data
no data
no data
1 See lodgepole pine HAP sheet for lab-scale test data and calculations.
Step Five: Compile Lodgepole Pine Speciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing
Maximum Dry Bulb
Ethanol
Acetic Acid
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
238
no data
no data
Step Six: Convert Lodgepole Pine Speciated HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RFX) X (SCX) X [(MWC) / (MWX)] X [(#CX) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
Speciated Compounds
as Carbon
Page 33 of 49
-------
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
238
0.0148
0
no data
no data
no data
no data
no data
Element and Compound Information
(Ib/mbf)
0.0148
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
C3H4O
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3h8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in
units of "ppm."
Step Seven: Subtract Speciated HAP and Non-HAP Compounds from Lodaepole Pine VOC Emission Factors and Convert Result to "as Propane
FROM STEP THREE
FROM STEP SIX
Method 25A VOC
Maximum Dry Bulb
Method 25A VOC
Speciated Compounds
as Carbon without
Temperature
as Carbon
as Carbon
Speciated Compounds
(°F)
(Ib/mbf)
MINUS
(Ib/mbf)
EQUALS
(Ib/mbf)
238
0.8951
¦=>
0.0148
"=>
0.8803
Propane
Mass
Conversion
Factor
X 1.2238 =
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
1.0773
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFc3hs) X [(MWc3hs) / (MWC)] X [(#Cc) / (#Cc3hs)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
MWC3h8 equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
#CC3H8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)], equals 1.2238 and can be referred to as the "propane mass conversion factor."
Step Eight: Calculate WPP1 VOC by Adding Speciated HAP and Non-HAP Compounds to Lodqepole Pine VOC Emission Factors "as Propane"
WPP1 VOC = Method 25A VOC as propane without speciated compounds + X speciated compounds expressed as the entire mass of compound
FROM STEP SEVEN
Method 25A VOC
as Propane without
Maximum Dry Bulb
Speciated Compounds
Temperature (°F)
(Ib/mbf)
238
1.0773
PLUS
¦=>
FROM STEP FOUR
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.0550
0.0030
no data
no data
no data
PLUS
¦=>
FROM STEP FIVE
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
no data
no data
EQUALS
¦=>
WPP1 VOC
(Ib/mbf)
1.1352
Page 34 of 49
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Hazardous Air Pollutant Emission Factors for Drying Ponderosa Pine Lumber
This sheet presents lab-scale test data and calculations used to create HAP EF for drying ponderosa pine lumber in an indirect steam-heated batch kiln. The methanol and formaldehyde EF are temperature dependent best-fit linear equations.
The temperature variable reflects the maximum temperature of the heated air entering the lumber. The acetaldehyde, propionaldehyde and acrolein EF are calculated by averaging test results.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study
of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Ponderosa Pine HAP Emission Test Data by Drying Temperature
Maximum Dry Bulb
Temperature (°F)
Methanol
(lb/mbf)
Formaldehyde
(lb/mbf)
Acetaldehyde
(lb/mbf)
Propionaldehyde
(lb/mbf)
Acrolein
(lb/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
HAP Sample
Collection Technique
Reference
170
0.035
0.0027
0.042
0.0019
0.0017
2x4
82.6/15
42
NCASI Method 105
17, 18
176
0.05
0.0022
no data
no data
no data
2x10& 2x12
107.1 /12
55
NCASI Method
IM/CAN/WP-99.01
without cannisters
3, 4, 12, 14
176
0.08
0.0036
no data
no data
no data
2x10& 2x12
124.1 /12
57
Link to March 7,
180
0.058
0.005
0.100
0.0035
0.0055
2x4
103.9/15
39.4
NCASI Method 105
2013 HamDton
Affiliates - Randle
Test Report
235
0.144
0.0092
0.028
0.0032
0.0045
2x4 or 2x6
89.1 /15
19
NCASI Method 105
18, 21
1 Dry basis. Moisture content = (weight of water/weight wood) x 100
Step Two: Adjust Ponderosa Pine HAP Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
170
0.032
0.0020
0.025
0.0006
0.0011
176
0.046
0.0016
no data
no data
no data
176
0.073
0.0027
no data
no data
no data
180
0.053
0.0037
0.060
0.0012
0.0037
235
0.131
0.0068
0.017
0.0011
0.0030
Adjusted OSU emission test data value, = (OSU reported emission test data value,) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value,)
where: OSU reported emission test data value, is the emission rate "lb/mbf for compound "i" documented in Step One (not highlighted in green)
NCASI study full-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value, is the average emission rate "lb/mbf for compound "i" measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Full-Scale Kiln
0.205
0.0155
0.039
0.001
OSU Kiln
0.225
0.0210
0.065
0.003
Step Three: Calculate Ponderosa Pine HAP Emission Factors
Methanol1
Formaldehyde1
Acetaldehyde2
Propionaldehyde2
Acrolein2
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
0.00137x-0.18979
0.000074X- 0.010457
0.0340
0.0010
0.0026
Acrolein
0.006
0.009
1 Best-fit linear equations with dependent variable maximum drying temperature entering the lumber
2 Because acetaldehyde, propionaldehyde and acrolein emissions across different species are not consistently dependent upon maximum drying temperature, EF are calculated by averaging test results.
Page 35 of 49
-------
Dry Bulb Temperatures (°F)
Page 36 of 49
Dry Bulb Temperatures (°F)
-------
Volatile Organic Compound Emission Factors for Drying Ponderosa Pine Lumber
This sheet presents lab-scale EPA Reference Method 25A (RM25A) and speciated VOC test data and calculations used to create VOC EF for drying ponderosa pine lumber in an indirect steam-heated batch kiln. RM25A has some limitations in that it misses some pollutant compounds (or portions thereof) that are
VOC and known to exist and reports the results "as carbon" which only accounts for the carbon portion of each compound measured. The missed pollutant compounds (some HAP and some non-HAP) are accounted for through separate testing. RM25A test data is adjusted to fully account for seven known
pollutant compounds that are VOC using separate speciated test data and is reported "as propane" to better represent all of the unspeciated VOC compounds. This technique is consistent with EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 (WPP1 VOC) except that the
RM25A results are adjusted to account for not only methanol and formaldehyde but also for acetaldehyde, propionaldehyde, acrolein, ethanol and acetic acid in this case.
More specifically, ten separate drying-temperature-specific VOC emission rates (upon which a best-fit linear equation will be established) are calculated based upon underlying RM25A and speciated VOC test data as indicated above. Temperature-specific methanol and formaldehyde emission rates are calculated
for each temperature at which RM25A testing was performed using temperature-dependent best-fit linear equations. The temperature variable reflects the maximum temperature of the heated air entering the lumber. The temperature-independent acetaldehyde, propionaldehyde and acrolein emission rates reflect
the average of all test results independent of the temperature of heated air entering the lumber. The ethanol and acetic acid emission rates reflect the results of a single test. EPA Region 10 is not aware of any further speciated VOC test data. That portion of the (speciated) VOC compounds that are measured by
the RM25A test method (based on known flame ionization detector response factors) is subtracted from the RM25A measured emission rate. The remaining "unspeciated" RM25A emission rate is adjusted to represent propane rather than carbon and then added to the speciated VOC emission rate to provide the
"total" temperature-specific VOC emission rate. The resultant VOC EF is a 10-point best-fit linear equation with dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Test data generated through the use of the smaller of the two small-scale kilns at Oregon State University (OSU) has been adjusted to account for bias documented in NCASI's May 2002 Technical Bulletin No. 845 entitled, "A Comparative Study of VOC Emissions from Small-Scale and Full-Scale Lumber Kilns
Drying Southern Pine." See last spreadsheet of this workbook for Stimson Lumber Company's October 18, 2019 letter to EPA Region 10 highlighting the bias.
Step One: Compile Ponderosa Pine RM25A VOC Emission Test Data by Drying Temperature1
Maximum Dry Bulb
Temperature (°F)
Method 25A VOC
as Carbon (lb/mbf)
Lumber
Dimensions
Moisture Content2 (%)
(Initial/Final)
Time to Final Moisture
Content (hours)
Method 25A
Analyzer
Reference
170
1.59
2x4
82.6/15
42
JUM VE-7
17, 18
170
1.795
1x4
112.8/15
29
JUM VE-7
2
170
1.925
1x4
88.7/15
28
176
1.29
2x10& 2x12
107.1 /12
55
JUM 3-200
3, 4, 12
176
1.54
2x10& 2x12
124.1 /12
57
176
1.40
2x10& 2x12
114.8/12
58.5
JUM 3-200
3, 4
176
1.30
2x10& 2x12
93.0/12
57.1
180
1.48
2x4
103.9/15
39.4
JUM VE-7
Link to March 7. 2013
Hampton Affiliates -
Randle Test Report
180
1.72
2x4
122.0/15
43.6
235
3.00
2x4 or 2x6
89.1 /15
19
JUM VE-7
18, 21
1 Green highlight denotes data generated by testing conducted on the small-scale kiln at the University of Idaho. All other data was generated by testing conducted on the smaller of the
two small-scale kilns at OSU.
2 Dry basis. Moisture content = (weight of water / weight wood) x 100
Step Two: Adjust Ponderosa Pine VOC Emission Test Data to Account for Bias in Underlying Small-Scale Kiln to Represent Full-Scale Kiln Emissions
Maximum Dry Bulb
Method 25A VOC
Temperature (°F)
as Carbon (lb/mbf)
170
1.32
170
1.795
170
1.925
176
1.07
176
1.28
176
1.16
176
1.08
180
1.23
180
1.43
235
2.49
1 Green highlighted results from the test conducted at the University of Idaho have not been adjusted because the kiln was not calibrated to a full-scale kiln.
Adjusted OSU emission test data value = (OSU reported emission test data value) X (NCASI TB No. 845 study full-scale kiln value/NCASI TB No. 845 study OSU small-scale kiln value)
where: OSU reported emission test data value is the RM25A VOC as carbon emission rate "lb/mbf documented in Step One (not highlighted in green)
NCASI study full-scale kiln value is the average RM25A VOC as carbon emission rate "lb/mbf" measured while drying southern yellow pine lumber in a full-scale indirect steam-heated batch lumber dry kiln
NCASI study OSU small-scale kiln value is the average RM25A VOC as carbon emission rate "lb/mbf measured while drying southern yellow pine lumber in OSU's small-scale indirect steam-heated batch lumber dry kiln
The lumber dried in the OSU kiln was (a) extracted from the pool of lumber dried in the full-scale kiln and (b) dried according the schedule employed by the full-scale kiln.
NCASI TB No. 845 - Emission Rate (lb/mbf)
RM25A VOC as carbon
Full-Scale Kiln 3.53333
OSU Kiln 4.25000
Step Three: Calculate/Compile Ponderosa Pine Speciated HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A VOC Testing1
Maximum Dry Bulb
Methanol2
Formaldehyde3
Acetaldehyde
Propionaldehyde
Acrolein
Temperature (°F)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
(lb/mbf)
170
0.0431
0.0021
176
0.0513
0.0026
0.0340
0.0010
0.0026
180
0.0568
0.0029
235
0.1322
0.0069
1 See ponderosa pine HAP sheet for lab-scale test data and calculations.
Page 37 of 49
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2 Methanol EF = 0.00137x- 0.18979; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
3 Formaldehyde EF = 0.000074x- 0.010457; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber.
Step Four: Compile Ponderosa Pine Speciated Non-HAP Emission Test Data by Drying Temperature
Maximum Dry Bulb
Temperature (°F)
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
Lumber
Dimensions
Moisture Content1 (%)
(Initial / Final)
Time to Final Moisture
Content (hours)
VOC Sample
Collection Technique
Reference
180
0.826
0.162
2x4
103.9/15
39.4
NCASI Method 105
Link to March 7, 2013
HamDton Affiliates -
Randle Test ReDort
1 Dry basis. Moisture content = (weight of water / weight wood) x 100
Step Five: Calculate Ponderosa Pine Speciated Non-HAP Emission Factors
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
0.826
0.162
Step Six: Calculate/Compile Ponderosa Pine Speciated Non-HAP Emission Factors at Maximum Drying Temperatures Observed during RM25A Testing
Maximum Dry Bulb
Ethanol
Acetic Acid
Temperature (°F)
(Ib/mbf)
(Ib/mbf)
170
176
0.826
0.162
180
235
Step Seven: Convert Ponderosa Pine Speciated HAP and Non-HAP Emission Factors to "as Carbon" and Total
Speciated Compound "X" expressed as carbon = (RF*) X (SC*) X [(MWC) / (MW*)] X [(#Cx) / (#Cc)]
where: RFX represents the flame ionization detector (FID) response factor (RF) for speciated compound "X"
SCX represents emissions of speciated compound "X" expressed as the entire mass of compound emitted
MWC equals "12.0110" representing the molecular weight (MW) for carbon as carbon is becoming the "basis" for expressing mass of speciated compound "X"
MWX represents the molecular weight for speciated compound "X"
#CX represents the number of carbon atoms in speciated compound "X"
#Cc equals "1" as the single carbon atom is becoming the "basis" for expressing mass of speciated compound "X"
Maximum Dry Bulb
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
Ethanol
Acetic Acid
Temperature
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
as Carbon
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
170
0.0116
0
176
0.0139
0
0.0093
0.0004
0.0011
0.2843
0.0373
180
0.0153
0
235
0.0357
0
Element and Compound Information
Speciated Compounds
as Carbon
(Ib/mbf)
0.3461
0.3487
0.3505
0.3749
Element / Compound
FID RF1
Molecular Weight
(Ib/lb-mol)
Formula
Number of Carbon
Atoms
Number of Hydrogen
Atoms
Number of Oxygen
Atoms
Reference
Methanol
0.72
32.042
CH40
1
4
1
1
Formaldehyde
0
30.0262
ch2o
1
2
1
16
Acetaldehyde
0.5
44.053
c2h4o
2
4
1
20
Propionaldehyde
0.66
58.0798
c3h6o
3
6
1
20
Acrolein
0.66
56.064
c3h4o
3
4
1
20
Ethanol
0.66
46.0688
c2h6o
2
6
1
1
Acetic Acid
0.575
60.0524
C2H4O2
2
4
2
1
Propane
1
44.0962
c3H8
3
8
0
16
Carbon
-
12.0110
c
1
-
-
-
Hydrogen
-
1.0079
H
-
1
-
-
Oxygen
-
15.9994
O
-
-
1
-
1 FID RF = volumetric concentration or "instrument display" / compound's actual known concentration. Numerator and denominator expressed on same basis (ie. carbon, propane, etc) and concentration in units
of "ppm."
Page 38 of 49
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Step Eight: Subtract Speciated HAP and Non-HAP Compounds from Ponderosa Pine VOC Emission Factors and Convert Result to "as Propane"
FROM STEP TWO
FROM STEP SEVEN
Method 25A VOC
Maximum Dry Bulb
Method 25A VOC
Speciated Compounds
as Carbon without
Temperature
as Carbon
as Carbon
Speciated Compounds
(°F)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
170
1.3219
0.3461
0.9758
170
1.7950
0.3461
1.4489
170
1.9250
0.3461
1.5789
176
1.0725
0.3487
0.7238
176
1.2803
0.3487
0.9316
176
1.1639
0.3487
0.8152
176
1.0808
0.3487
0.7321
180
1.2304
0.3505
0.8799
180
1.4300
MINUS
0.3505
EQUALS
1.0795
235
2.4941
>=>
0.3749
2.1192
Method 25A VOC as propane without speciated compounds = (VOCc) X (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)]
where: VOCc represents Method 25A VOC as carbon without speciated compounds
RFC3H8 equals "1" and represents the FID RF for propane. All alkanes, including propane, have a RF of 1.
Propane
Mass
Conversion
Factor
X 1.2238 =
MW,
C3H8
equals "44.0962" and represents the molecular weight for propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Method 25A VOC
as Propane without
Speciated Compounds
(Ib/mbf)
1.1942
1.7732
1.9323
0.8857
1.1401
0.9976
0.8959
1.0769
1.3210
2.5934
MWC equals "12.0110" and represents the molecular weight for carbon
#Cc equals "1" as the single carbon atom was the "basis" for which Method 25A VOC test results were determined as illustrated in Step One of this spreadsheet
#CC3H8 equals "3" as three carbon atoms are present within propane; the compound that is the "basis" for expressing mass of VOC per WPP1 VOC
Note: The following portion from the equation immediately above, (1/RFC3H8) X [(MWC3H8) / (MWC)] X [(#Cc) / (#CC3H8)], equals 1.2238 and can be referred to as the "propane mass conversion factor."
Step Nine: Calculate WPP1 VOC by Adding Speciated HAP and Non-HAP Compounds to Ponderosa Pine VOC Emission Factors "as Propane"
WPP1 VOC = Method 25A VOC as propane without speciated compounds + £ speciated compounds expressed as the entire mass of compound
FROM STEP EIGHT
Method 25A VOC
as Propane without
Maximum Dry Bulb
Speciated Compounds
Temperature (°F)
(Ib/mbf)
170
1.1942
170
1.7732
170
1.9323
176
0.8857
176
1.1401
176
0.9976
176
0.8959
180
1.0769
180
1.3210
235
2.5934
PLUS
¦=>
FROM STEP THREE
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.0431
0.0021
0.0431
0.0021
0.0431
0.0021
0.0513
0.0026
0.0513
0.0026
0.0340
0.0010
0.0026
0.0513
0.0026
0.0513
0.0026
0.0568
0.0029
0.0568
0.0029
0.1322
0.0069
PLUS
Step Ten: Generate Ponderosa Pine Best-Fit Linear Eguation with Dependent Variable Maximum Drying Temperature to Model WPP1 VOC Emissions
WPP1 VOC (Ib/mbf): 0.02083x - 1.30029 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumber
FROM STEP SIX
Ethanol
(Ib/mbf)
Acetic Acid
(Ib/mbf)
0.826
0.162
EQUALS
¦=>
WPP1 VOC
(Ib/mbf)
2.2650
2.8440
3.0031
1.9652
2.2195
2.0771
1.9753
2.1621
2.4063
3.7581
Dry Bulb Temperatures (°F)
Page 39 of 49
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Hazardous Air Pollutant Emission Factors for Drying Western White Pine Lumber
This sheet presents the HAP EF for drying western white pine lumber. EPA Region 10 is not aware of any HAP emission testing of western white pine. When
actual test data is not available, data for a similar species is substituted as noted. When there are more than one similar species, the highest of the EF for the
similar species is substituted.
Given the limited western white pine test data, ponderosa pine test data has been substituted. Western white pine is similar to ponderosa pine and lodgepole
pine in that all three species are resinous softwood species in the scientific classification genus Pinus. EPA Region 10 is aware of three Lodgepole Pine test runs
for methanol and formaldehyde and none for acetaldehyde, propionaldehyde and acrolein. Five ponderosa pine test runs were conducted for methanol and
formaldehyde and three for acetaldehyde, propionaldehyde and acrolein. While the lodgepole pine runs were conducted at about the same maximum drying
temperature, the ponderosa pine runs were distributed across a wide maximum drying temperature range. Based upon the available test data, ponderosa pine is
higher-emitting than lodgepole pine for methanol and formaldehyde. See the ponderosa pine and lodgepole pine HAP sheets for lab-scale test data and
calculations.
Western White Pine (Ponderosa Pine Substitution) HAP Emission Factors
Methanol
Formaldehyde
Acetaldehyde
Propionaldehyde
Acrolein
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
(Ib/mbf)
0.00137X- 0.18979
0.000074X-0.010457
0.0340
0.0010
0.0026
Page 40 of 49
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Volatile Organic Compound Emission Factors for Drying Western White Pine Lumber
This sheet presents the VOC EF for drying western white pine lumber. EPA Region 10 is aware of one test being conducted while drying western white
pine lumber, and it was conducted at 170°F. Because VOC emissions increase with maximum drying temperature, employing an EF based upon testing at
170°F would underreport emissions when drying at maximum drying temperatures greater than 170°F. A temperature of 170°F is not a particularly high
drying temperature. When little or no actual test data is available, data for a similar species is substituted as noted. When there are more than one similar
species, the highest of the EF for the similar species is substituted.
Given the limited western white pine test data, ponderosa pine test data has been substituted. Western white pine is similar to ponderosa pine and
lodgepole pine in that all three species are resinous softwood species in the scientific classification genus Pinus. EPA Region 10 is aware of three
lodgepole pine test runs and eight ponderosa pine test runs. While the lodgepole pine runs were conducted at about the same maximum drying
temperature, the ponderosa pine runs were distributed across a wide maximum drying temperature range. Based upon the available test data, ponderosa
pine is higher-emitting than lodgepole pine. See the ponderosa pine and lodgepole pine HAP and VOC sheets for lab-scale test data and calculations.
Western White Pine (Ponderosa Pine Substitution) WPP1 VOC Emission Factor
WPP1 VOC (Ib/mbf): 0.02083x - 1.30029 ; where dependent variable "x" equal to the maximum drying temperature of heated air entering the lumt
Page 41 of 49
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Index to References Appearing in
EPA Region 10 HAP and VOC Emission Factors for Lumber Drying, June 2018
Reference No. 1
(Undated) J.U.M. Flame Ionization Detector Response Factor Technical Information presented at http://www.ium-aerosol.com/imaqes/E-Fakt-02.pdf
Notes
Methanol response factor (RF) of 0.72 equals average of three response factors 0.69, 0.68 and 0.79 for J.U.M. models 3-200 and VE-7. These two
models were exclusively employed to determine Method 25A VOC in the testing EPA Region 10 is relying upon to support VOC emission factor
derivation.
An alternative RF of 0.65 from Appendix 3 to EPA's Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 at
http://www.epa.gov/ttn/emc/prelim/otm26.pdf could have been employed instead.
Employing RF of 0.72 (as opposed to 0.65) generates lower VOC emission factors (EF). A higher RF means that the EPA Method 25A flame ionization
detector (FID) measures more of the compound. With the methanol EF having already been determined through speciated sampling and analysis,
assuming the FID measures a greater portion of the methanol leaves less of the Method 25A measurement to be accounted for as unspeciated VOC.
Reference No. 2
National Council of the Paper Industry for Air and Stream Improvement, Inc. Technical Bulletin No. 718. July 1, 1996. A Small-Scale Kiln Study on Method
25A Measurements of Volatile Organic Compound Emissions from Lumber Drying.
Notes
To convert Method 25A VOC from "lb C/ODT" to "lb C/mbf," the following calculations were performed:
White Fir - Runs 15 and 16.
(0.85 Ib/ODT) X (0.57 Ib/mbf) / (0.77 Ib/ODT) = 0.63 Ib/mbf
(0.68 Ib/ODT) X (0.57 Ib/mbf) / (0.77 Ib/ODT) = 0.50 Ib/mbf
See pages 14 and 15 of the reference document.
Western Red Cedar - Runs 10 and 11.
(0.12 Ib/ODT) X (0.12 Ib/mbf) / (0.15 Ib/ODT) = 0.096 Ib/mbf
(0.17 Ib/ODT) X (0.12 Ib/mbf) / (0.15 Ib/ODT) = 0.136 Ib/mbf
See pages 14 and 15 of the reference document.
Douglas fir - Runs 1 and 3.
(1.00 Ib/ODT) X (0.81 Ib/mbf) / (0.86 Ib/ODT) = 0.942
(0.71 Ib/ODT) X (0.81 Ib/mbf) / (0.86 Ib/ODT) = 0.669
See pages 12 and 15 of the reference document.
Ponderosa Pine - Runs 5 and 6.
(1.92 Ib/ODT) X (1.86 Ib/mbf) / (1.99 Ib/ODT) = 1.795 Ib/mbf
(2.06 Ib/ODT) X (1.86 Ib/mbf) / (1.99 Ib/ODT) = 1.925 Ib/mbf
See pages 14 and 15 of the reference document.
Page 42 of 49
-------
The moisture content of wood was originally reported on a wet basis. It has been corrected to be on a dry basis using the following equation:
(moisture content on dry basis) = (moisture content on wet basis) / [1 - (moisture content on wet basis)]
Reference No. 3
Small-scale Kiln Study Utilizing Ponderosa Pine, Lodgepole Pine, White Fir, and Douglas-fir. Report by Michael R. Milota to Intermountain Forest
Association. September 29, 2000.
Reference No. 4
Milota, Michael. VOC and HAP Emissions from Western Species. Western Dry Kiln Association: May 2001, p. 62-68.
Reference No. 5
Milota, M.R. 2003. HAP and VOC Emissions from White Fir Lumber Dried at High and Conventional Temperatures. Forest Prod. J. 53(3):60-64.
Reference No. 6
VOC and HAP Emissions from the High Temperature Drying of Hemlock Lumber. Report by Michael R. Milota to Hampton Affiliates. June 21, 2004.
Reference No. 7
Fritz, Brad. 2004. Pilot- and Full-Scale Measurements of VOC Emissions from Lumber Drying of Inland Northwest Species. Forest Prod. J. 54(7/8):50-56.
Notes
To convert acetaldehyde from "|jg/min-bf' to "Ib/mbf," the following calculations were performed:
White fir.
0.0550 Ib/mbf = (7.7 jjg/min-bf) X (60 min/hr) X (54 hr) X (kg/1x109g) X (2.205 lb/kg) X (1,000 bf/mbf).
See page 54 of the reference document.
Douglas fir.
0.030 Ib/mbf = (4.9 jjg/min-bf) X (60 min/hr) X (46 hr) X (kg/1x109g) X (2.205 lb/kg) X (1,000 bf/mbf).
0.022 Ib/mbf = (3.6 jjg/min-bf) X (60 min/hr) X (46 hr) X (kg/1x109g) X (2.205 lb/kg) X (1,000 bf/mbf).
See page 53 of the reference document.
Reference No. 8
VOC and Methanol Emissions from the Drying of Hemlock Lumber. Report by Michael R. Milota to Hampton Affiliates. August 24, 2004.
Reference No. 9
VOC, Methanol, and Formaldehyde Emissions from the Drying of Hemlock Lumber. Report by Michael R. Milota to Hampton Affiliates. October 15, 2004.
Reference No. 10
VOC Emissions from the Drying of Douglas-fir Lumber. Report by Michael R. Milota to Columbia Vista Corporation. June 14, 2005.
Reference No. 11
Milota, M.R. and P. Mosher. 2006. Emissions from Western Hemlock Lumber During Drying. Forest Prod. J. 56(5):66-70.
Reference No. 12
Milota, M.R. 2006. Hazardous Air Pollutant Emissions from Lumber Drying. Forest Prod. J. 56(7/8):79-84.
Page 43 of 49
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Reference No. 13
VOC, Methanol, and Formaldehyde Emissions from the Drying of Hemlock, ESLP, and Douglas Fir Lumber. Report by Michael R. Milota to Hampton
Affiliates. March 23, 2007.
Reference No. 14
Oregon Department of Environmental Quality memorandum May 8, 2007 entitled, "Title III Implications of Drying Kiln Source Test Results."
Notes
The reference document presents a compilation of EF.
Reference No. 15
HAP Emissions from the Drying of Hemlock and Douglas-fir Lumber by NCASI 98.01 and 105. Report by Michael R. Milota to Hampton Affiliates. May 22,
2007 report.
Reference No. 16
EPA Interim VOC Measurement Protocol for the Wood Products Industry - July 2007 presented at http://www.epa.gov/ttn/emc/prelim/otm26.pdf
Notes
VOC determined through use of this document is referred to as WPP1 VOC. The document is alternatively known as EPA Other Test Method 26 or
"OTM26."
Default formaldehyde RF of 0 and propane (an alkane) RF of 1 appear in Appendix 3 - Procedure for Response Factor Determination for the Interim VOC
Measurement Protocol for the Wood Products Industry.
Reference No. 17
HAP Emissions by NCASI 98.01 and 105 from Drying of Ponderosa Pine and White Wood Lumber. Report by Michael R. Milota to Hampton Affiliates.
July 25, 2007.
Reference No. 18
Milota, M.R. and P. Mosher. 2008. Emission of Hazardous Air Pollutants from Lumber Drying. Forest Prod. J. 58(7/8):50-55.
Reference No. 19
VOC Emissions From the Drying of Douglas-fir Lumber. Report by Michael R. Milota to Columbia Vista Corp. November 12, 2010.
Reference No. 20
NCASI Technical Bulletin No. 991. September 2011. Characterization, Measurement, and Reporting of Volatile Organic Compounds Emitted from
Southern Pine Wood Products Sources.
Notes
Acetaldehyde and propionaldehyde RF appear in Table C-1 of Appendix C. The values are estimates based upon dividing the compound's effective
carbon numbers (ECN) by the number of carbon atoms in the compound. See Attachment 2 to Appendix C.
Acrolein RF is also an estimate based upon dividing the compound's ECN by the number of carbon atoms in the compound. In this case, the RF estimate
does not appear in Table C-1 of Appendix C. The value is calculated as described above pursuant to Attachment 2 to Appendix C.
RF = (ECN) / (number of carbon atoms in compound)
Page 44 of 49
-------
where ECN = 2 given the aliphatic carbon contribution of CH2CHCHO (see Table 2.1 to Appendix C) and the number of carbon atoms in acrolein = 3.
RF = 2/3 or 0.66
Reference No. 21
Email of 03/26/12 email from Oregon State University's Michael Milota to EPA Region 10's Dan Meyer.
Page 45 of 49
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18 October 2019
Mr. Douig Hardesty
U.S. EPA
1435 N Orchard
Boise, Idaho 83706
RE: Proposed Kiln Emissions Factors for Stimson, Pliummer Title V Renewal
Dear Mr. Hardesty:
Stimson wishes to thank EPA for the time and effort that has gone into the technical analysis needed for
renewal of the Plummer facility's Title V permit. We are appreciative of the opportunity to review the
proposed emissions factors for the permit analysis.
We have looked over the proposed kiln emission factors, as well as the work done by the Washington
Southwest Clean Air Agency (SWCAA) and have the following comments. In general, we agree that the
approach is an improvement over previous efforts and, in particularly,, the use of a regression equation
for the formaldehyde and methanol emissions is superior to having a single cut point.
The issue of concern is the reliance upon small lab-scale kilns to derive the emissions factors. For a
number of reasons, these kilns are not representative of operations at full-scale production kilns. Based
upon work that we present below, this seems to be particularly true of the OSU kiln used by Dr. Mi Iota,
which serves as the primary source of HAP emission factors for western species. The unfortunate fact is
that there is very little data comparing the emissions from a small lab kiln to those of a production kiln -
in fact, we are only aware of NCAS1 Technical Bulletin 645 from 2002. However, based upon that study,
we find the following differential in measured emissions:
From WCASI Technical Bulletin 845:
Pollutant
FSK
OSU
OSU:FSK
voc
3.5
4.3
1-23
Formaldehyde
0.016
0.021
1.31
Methanol
0.21
0.23
1.10 i
Acetaldehyde
0.039
0.065
1.67
Acrolein
0.006
0.0C©
1.50
Proprionaldetiyde
0.001
0.003
3.00
FSK = Full Scale Kiln
OSU = Oregon State University lab scale kiln
We note that the OSU kiln yields a consistently higher bias in the emissions - by an average of 64%.
Neither the Mississippi State nor the Horizon Engineering kilns demonstrated this consistent high bias so
we do not believe it is simply a matter of the difficulty in fully characterizing the production kiln. In the
technical bulletin NCASI staff come to the conclusion that "...VOC emissions measured at a small-scale
kiln can reasonably approximate those from a full-scale kiln..." However, this conclusion is based upon
STIMSON LUMBER COMPANY
Environmental Affairs
520 5W Yamhill, Suite 7CO
Portanfl, Oregon 972D4-1330
<503} 306-4655
-------
Stunsoc. Comments on Proposed EPA Kiln Emission Factors Page 2
18 October 2019
the full sample set from multiple small scale kilns. Indeed, if we include the Phase II M5U kiln results in
the analysis the average results are much closer. Unfortunately, virtually all of the western species data
is from the OSU kiln, so there is a high bias. What significant differences in the operation of the QSU kiln
can account for this consistently higher bias?
Unidirectional flow; Unlike full scale production kilns, the OSU kiln features unidirectional airflow.
Production kilns have reversible fans that allow bidirectional air flow. "IT® OSU design results in uneven
drying that would be unacceptable in a commercial environment.
Hotter wood: The smaller charge size in the OSU kiln results in less volume of wood to absorb the
thermal energy of the surrounding air. This is further compoun ded by the shorter linear distance the air
has to travel over in the lab kiln. The result is anticipated to be hotter wood than equivalent kiln
temperatures would yield in a full scale production kiln. Thus, we would expect the dry bulb
temperature to be less indicative of the actual wood temperature in a full scale kiln than in the lab kilns.
This is borne out by the fester drying time in the OSU kiln.
Increased airflow: Table 8.3 of NCASI Technical Bulletin 845 illustrates the dramatically enhanced
airflow through the lab kiln relative to a full scale production kiln:
T able S. J. Phage II T oral Volume Kile Exhaust Gds pei MBF
FSK MSU OSU
Trst fJtrrap vncf * 10'' [it VRF
Direct
rued Drying Scflietfole
DFl
1S.S0
E 36 9M
DT2
33.10
872 9.01
DFS
J 7.50
£ 74 9.11
IS 10
7
-------
StmEsoa Comments on Proposed EPA Kiln Emission Factors
Page 3
IB October 2019
Thus, Stimson proposes revised emission factors for the facility. We noter however, that this accepts
that temperature is a valid parameter for correlation with emissions. At this time, Stimson has not
looked dosety at whether moisture contents might be a useful in this regard. Less data is likely to be
available for a moisture approach and it would likely suffer the same issues with scaling of lab kiln
results. Further, we have largely accepted EPA's sample selection arid analysis due to time constraints.
Stimson may look at this in more detail as discussions continue.
We will be providing an analysis of boiler emission factors shortly.
Sincerely,
STEVEN PETRIN
Environmental Manager
-------
NCASI Technical Bulletin No. 845
Pollutant
Emission Rate (lb/mbf)*
# of Runs
Run ID
Location of Data
within Technical
Bulletin
Full Scale Kiln
Oregon State
Universtity Kiln
VOC as carbon
3.533333
4.25
6
1-3 & 5-7
Table 8.2
Formaldehyde
0.0155
0.021
2
1 & 3
Table 9.5**
Methanol
0.205
0.225
2
1 & 3
Table 9.6**
Acetaldehyde
0.039
0.065
1
3
Appendix BB1
Acrolein
0.006
0.009
1
3
Propionaldehyde
0.001
0.003
1
3
Value reflects arithmetic mean in those instances when more than one run was performed
** Run 3 data also in Appendix BB1
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