In October the Environmental Protection Agency began its review of the emission standards for plywood and composite wood products manufacturers. As part of that process it is requiring such manufacturers to fill out a lengthy survey about their operations and provide supporting documentation.
The deadline for filing is just weeks away – February 9 – and the EPA estimates it will take most facilities anywhere from 100 to 250 hours to compile the documentation and complete the survey.
Here’s everything you need to know about the process as it enters the home stretch.
The EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Plywood and Composite Wood Products (PCWP) went into effect in 2004. The standards identified acetaldehyde, acrolein, formaldehyde, methanol, phenol and propionaldehyde as the main hazardous air pollutants emitted during the manufacture of these products.
As required by law, EPA is re-evaluating the emissions standards for PCWP for the first time. But the agency said its existing data is insufficient to adequately evaluate the emission standards, so it issued an Information Collection Request (ICR) to gather the data it needs to conduct a proper review.
The ICR is seeking information that includes emission inventories, compliance demonstrations, process changes, equipment configurations and information about control technologies/practices adopted since the application of maximum achievable control technology (MACT).
Who Needs to Participate in the Survey
The ICR was sent to facilities that produce plywood and composite wood products, kiln-dried lumber or are otherwise subject to the PCWP NESHAP. Generally speaking, companies that produce the following must complete the ICR:
Survey participation is limited to facilities that are major or synthetic area sources.
Not subject to the ICR is any facility that meets one or more the following:
If a facility received the ICR from EPA but believes it is exempt because it meets one or more of the criteria above, it must submit a “Documentation of True Area Source, Non-Operational, or Non-Applicable Status” form. Note: If a facility received the ICR, was not operational in 2016 and 2017 and it still has an active operating permit, it must submit this form and provide a copy of their active operating permit to EPA. It would not need to complete any other portion of the ICR.
What Needs to be Submitted
Major sources that are subject to the PCWP NESHAP must complete the applicable tabs in the ICR survey spreadsheets and provide supporting documentation. There are two spreadsheets included in the ICR – PCWP_survey.xlsx and PCWP_CEMS.xlsx. All facilities will need to fill out at least a portion of the former, while the latter is for facilities that operate a continuous emissions monitoring system that measures total hydrocarbons, particulate matter or HAPs.
In addition to the spreadsheets, the ICR requires facilities to submit supporting documentation, including:
A facility that’s designated as a synthetic area source and thus not subject to the NESHAP must complete the “Documentation of Synthetic Area Source Status” form and provide supporting materials. This facility would not have to complete the survey spreadsheets. Note: If a facility’s operating permit indicates the PCWP NESHAP applies to them, then the facility must complete the full survey even if it is a synthetic area source.
Confidential Business Information
It is important to note that responses to this ICR will be made available to the public. Facilities may report some data as confidential business information (CBI).
Each tab in the ICR spreadsheets contains a highlighted question at the top asking if any confidential business information was provided. Facilities must select yes or no from the dropdown menu next to this question. The facility should highlight in red any cell in the spreadsheet that contains CBI. Any attachments submitted as part of the ICR that are considered CBI should clearly be labeled as such.
How to Submit Your Information
Facilities submitting an exemption form or a synthetic area source form can email the form and any supporting documentation to firstname.lastname@example.org.
Facilities submitting the ICR survey can either upload their response to the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) or mail them to the EPA. Note: Surveys containing confidential business information should not be uploaded via CEDRI.