Information Collection Request for the Plywood and Composite Wood Products NESHAPS



The EPA is proposing to send an Information Collection Request (ICR) to the Plywood and Composite Wood (PCWP) NESHAP facilities for the Residual Risk and Technology Review (RTR). The ICR proposal is currently at public notice; the comment period ends on November 7, 2016. After incorporating comments received, EPA will be sending this document to the Office of Management and Business (OMB) for review.

The ICR is conducted under Section 112(d) and 112(f)(6) of the Clean Air Act (CAA) to reevaluate the emissions standards for the source category. Section 112(f)(2) of the CAA directs the EPA to conduct risk assessments on each source category subject to the maximum achievable control technology (MACT) standards to determine if additional standards are needed to reduce residual risks. Therefore, EPA has to review the industry’s emissions, air pollution control practices, and remaining risks post-2004 Rule and determine if risks have been mitigated and if the available control technologies have improved since the rule was promulgated.

Under the 1990 CAA amendments, EPA is required to set the MACT standard and then conduct a RTR eight years after promulgation. The deadline for the Residual Risk and Technology Review for the PCWP MACT would have been 2012. The Sierra Club filed a missed RTR deadline suit in February of 2016, and the PCWP litigation is ongoing. The D.C. Circuit Court decision is expected in 2016 or 2017, which will mandate when EPA must finalize the RTR for the PCWP MACT.

Facilities that are affected by the ICR are major sources of HAP emissions which produce plywood, particle board, medium-density fiberboard (MDF), hardboard, fiberboard, oriented strandboard (OSB), engineered wood products (EWP) , and/or operate lumber dry kilns. Based on EPA’s analysis, there are about 425 affected sources. However, the actual number may be a little less than estimated based on prior ICRs as some of the facilities might have shut down and closed.

EPA’s support document lists the following number of sources that will need to respond to the survey.

  • 235 sawmills with lumber dry kilns,
  • 92 plywood and veneer facilities,
  • 36 OSB facilities,
  • 22 MDF facilities,
  • 21 particle board facilities,
  • 4 hardboard facilities,
  • 4 fiberboard facilities,
  • 11 engineered wood product facilities

The NAICS codes for respondents affected by the information collection request include 321113 for Sawmills, 321211 for Hardwood Plywood and Veneer, 321212 for Softwood Plywood and Veneer, 32121 for Engineered Wood Products, 321219 for Particleboard, MDF, OSB, Hardboard and Fiberboard.

The ICR will be conducted in two phases. Phase I is a spreadsheet questionnaire that is completed by all the affected facilities. Phase II will be emissions testing for certain sources as determined if needed by EPA.

Phase I: Under Phase I, emissions data collected will allow the EPA to characterize the performance of equipment and controls, reevaluate emissions limits, and consider variability. Emissions data from previously conducted emissions tests, including copies of test reports and Continuous Opacity Monitoring System (COMS) or Continuous Emissions Monitoring System (CEMS) data, are being requested for affected sources and emissions units for which emissions limits may be reevaluated under RTR. The pollutants for which emissions data are requested include all HAPs regulated under either the PCWP NESHAP, any surrogate used to demonstrate compliance with a regulated HAP, volatile organic compounds, particulate matter (filterable or condensable of any size fraction), speciated HAP metals, and opacity.

Phase II: Phase II, if implemented, will provide instructions and guidance for emissions testing for those emissions sources that are selected to complete emissions testing.

Anticipated Timelines: It is anticipated that after the OMB review, EPA will be sending the ICR requests in the first quarter of 2017. However, this can change depending on the comments received. After the request is sent, the facilities will have 90 days to respond to the survey.

Trinity has experience in this area and has assisted several facilities with the ICR requests for other regulations in the past. Trinity, with offices nationwide, is well equipped to work with the facilities’ environmental and engineering personnel to obtain the information needed to complete the ICR response. Some of the questions will require specific environmental expertise and support. Trinity has this expertise and can help your facility determine these answers, organize the responses, and compile the information for submittal.

If you have any questions or need further information, please contact your local Trinity Consultants office at 1-800-229-6655.