May 15, 2003
Division for Air Quality
803 Schenkel Lane
Frankfort KY 40601
These comments are submitted by the Kentucky Resources Council, Inc. concerning the draft Title V air quality permit for Cox Interior, Inc.'s Campbellsville facility.
KRC has reviewed the draft permit and offers these comments:
1. The operating limitations for Emissions Units 04, 06 and 07 (Indirect Heat Exchangers) indicate that the fuel will be "wood" or "woodmat." Clarification is needed that the wood that will be fired in the boilers, whose pollution control devices appear to be cyclones and cyclone/filer bed with fairly low capture efficiencies (80 and 90% respectively), will be clean wood that has not been treated with CCA or other metals as preservatives. If treated wood is to be used, consideration must be given of the fate and transport mechanics of any metals or other preservatives used.
2. The operating limitations on Emissions Unit 05 should clarify that the #2 fuel oil be clean oil, in order to assure that waste oils (potentially containing higher metals and other impurities) are not utilized.
Thanks for your consideration of these comments.