Interim VOC Measurement Protocol for the Wood Products Industry – July 2007
On July 12, 2006, Mr. William Wehrum, EPA Acting Assistant Administrator, sent a letter to Mr. Timothy G. Hunt, Senior Director, Air Quality Programs, at the American Forest and Paper Association outlining a path forward for the complex issue of measuring and reporting volatile organic compounds (VOCs) in the forest products industry. In this letter, EPA discussed their desire for the forest products industry to report VOCs as the total mass of the individual organic compounds comprising the VOCs to determine major source applicability of federal programs such as NSR and Title V. EPA recognized, however, that the existing test methods fall short of this goal, and that “…it is impracticable to identify and quantify every compound…” EPA recognized that it will take some time to develop practical methods to accurately characterize VOC mass in forest products industry emissions. Therefore, EPA endorsed the use of interim VOC measurement approaches to estimate the total mass of VOC emissions while more appropriate methods and additional information are being developed. EPA stated that a “…reasonable approximation (of total mass) will be sufficient for assessing the applicability of several regulatory programs.” VOC measurements for existing SIP, NESHAPS, and NSPS requirements and permit limits should continue to use the specified methods.
This interim protocol establishes calculation procedures and emission measurement methods to approximate VOC emissions for determining applicability with federal programs (particularly for NSR and Title V) and to establish consistency across state programs for the forest products industry. For purposes of this protocol, “reasonable approximation” of total VOC mass means expressing VOC as propane and requiring individual measurements of methanol and formaldehyde at sources for which these compounds are significant, as listed in Appendix 1. Historically, the forest products industry has reported its VOC emissions in terms of the mass of carbon atoms in the VOC compounds because the analytical methods measured the VOCs in those terms. For many facilities, therefore, this interim protocol will substantially increase the reported total mass of VOCs to be used in applicability determinations.
Interim VOC Measurement Protocol for the Wood Products Industry – July 2007 (pdf)