On February 28, 2022, EPA issued an Information Collection Request (ICR) to nine companies comprising approximately 20 different Plywood and Composite Wood Products (PCWP) mills in connection with its review of National Emissions Standards for Hazardous Air Pollutants (NESHAP). EPA will use the collected information to develop new emission standards for inclusion in the PCWP NESHAP scheduled for promulgation by 2023. ICR responses must be submitted by July 6, 2022.
The ICR requires emissions testing of 15 different process units for nine parameter categories, the combination of which varies with the process unit. Emission testing results must be reported using specific process-based rates, which also vary by process unit. Importantly, emission testing results must be reported using EPA’s Electronic Reporting Tool (ERT).
ICR testing programs are among the most important that a facility can undertake because the results will determine future regulatory requirements for both the facility and industry. These test programs require a comprehensive understanding of the scope of the ICR that includes the process units, the measurement methods, the challenges associated with applying those measurement methods to the process units, process data collection requirements, careful evaluation and calculation of non-detect values, data reduction and reporting requirements, and the quality control procedures required to produce a technically sound and defensible submittal.
TRC has supported the ICR emissions testing requirements for numerous industries and clients over the past two decades. We have a long history of service to the Forest Products industry and have been sustaining members of the National Council for Air and Stream Improvement (NCASI) since that membership category was opened. Whether you need help in gathering data to support an ICR response or to determine how your mill might be affected once EPA promulgates new standards, TRC has both the regulatory and industry-specific experience that PCWP mills need to navigate the evolving regulatory landscape.
Jon Howard has supported the emissions testing needs of the forest products industry for 30 years and is available to help PCWP clients chart a compliance strategy for NESHAP compliance. Jon can be reached at firstname.lastname@example.org or 334.728.2252.