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Responses to EPA’s Information Collection Request (ICR) for PCWP MACT Due February 9, 2018

The U.S. EPA has issued the ICR to facilities subject to 40 CFR 63 Subpart DDDD – National Emission Standards for Hazardous Air Pollutants (HAP) for Plywood and Composite Wood Products Manufacture (PCWP MACT) as part of the Risk and Technology Review (RTR) program. The data will be used by EPA to perform detailed modeling and analyze the effectiveness of the PCWP MACT.

Are You Affected? The ICR has been mailed to a total of 391 facilities, of which 205 are lumber mills with dry kilns. Major sources of HAP that produce the following will be required to respond:

  • Plywood
  • Veneer
  • Kiln-dried lumber
  • Particleboard
  • Fiberboard (including MDF)
  • OSB
  • Other resin-containing engineered wood products

What Needs to be Done? The ICR requires a significant amount of site-specific data to be developed or compiled and entered. Response submittal packages may be uploaded via the CEDRI online portal or mailed as a CD, DVD, or flash drive, and will consist of the following:

  • Completed survey
  • Searchable copy of the operating permit
  • Process flow diagram(s)
  • Map with emission release points identified
  • Lumber kiln schedule(s) (if applicable)
  • Copies of 2016 compliance reports
  • WWT effluent limit(s), flow diagram, and emission estimates (if applicable)
  • Searchable copies of stack test reports (if applicable)

The ICR survey is in spreadsheet format and has tabs for input of the following information:

  • General Mill Information*
  • Products*
  • Equipment Detail*
  • Release Point Detail*
  • Permit Information*
  • Resin Data
  • Tanks Information
  • Specific Equipment Data, including:
    • Veneer, Rotary, Tube, and Conveyor Dryer
    • Fiberboard/Hardboard Equipment
    • Lumber Kilns*
    • Direct Fired Dryer Fuel Data*
    • Presses
    • Board Coolers
    • Other Equipment
  • Control Devices
  • Startup, Shutdown, and Malfunction (SSM)
  • Miscellaneous Coatings
  • Wastewater
  • Emissions Tests*
  • HAP Emissions*
  • Certification*

* Lumber mills with dry kilns are only required to complete these tabs, if applicable.

EPA has estimated that it will take 150 hours for PCWP facilities and 60 hours for lumber mills to complete the ICR. Responses are due February 9, 2018.

The EPA webpage for the PCWP MACT ICR is here: https://www.epa.gov/stationary-sources-air-pollution/information-collection-plywood-and-composite-wood-products-industry

How Can We Help? EPS consultants have been attending conferences and webinars related to the PCWP MACT ICR survey. Our team members have industry-specific knowledge necessary to provide the assistance you need and have assisted with ICR responses for other MACTs. If you are not a current client of EPS and would like our assistance, please call us at (404) 315-9113.

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