1. In the beginning of this Best Available Control Technology (BACT) assessment, the limit was going to be on "unreacted UF molecules." Now it is formaldehyde as a whole, yet PF is one of your (CARB) recommended alternatives. Is this not a contradiction? It is our understanding that the major portion of formaldehyde emissions from products made with UF resins is "unreacted" formaldehyde. While some formaldehyde may be released from previously bound molecules over time, the amount of "unreacted" formaldehyde is known to be much lower in products made with PF or NAF resins. Because the chemical bonds formed by formaldehyde in PF resins are largely irreversible, we believe that the use of PF resins will result in lower formaldehyde emissions throughout the life of the composite wood product and would be an effective alternative to the use of UF resin and an example of an ULEF resin system. Innovative ULEF resin systems, based on the use of scavengers, can be an effective alternative as well.
2. Does the new standard distinguish between urea-formaldehyde and phenol-formaldehyde or for the sake of the rule are they equally regulated? CARB's regulation pertains to formaldehyde emissions regardless of resin type. Urea-formaldehyde and phenol-formaldehyde resins may qualify as ULEF if the testing data supports, but not NAF.
