Update on Plywood PCWP Risk and Technology Review
"This update covers information related to Plywood PCWP Risk and Technology Review, including background, purpose, testing phases, and comment request topics. The focus is on meeting regulatory requirements and improving data collection for emission estimation. The review aims to enhance clarity and quality while minimizing burdens associated with compliance. Electronic submission options are explored for better efficiency and data quality control."
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Presentation Transcript
Update on the Plywood (PCWP) Risk and Technology Review Information Collection Request (ICR) NCASI West Coast Meeting September 27, 2016
Overview Background Comments ICR Purpose Testing Next Steps Internal, Deliberative Do Not Cite or Quote
Background Clean Air Act MACT Review Requirements Risk and Technology Review CAA 112 (d)/(f) 2007 PCWP Court Remand No Control MACT Floor (brick) Units 2016 Deadline Lawsuit 3 Internal, Deliberative Do Not Cite or Quote
ICR Purpose Currently, our information is limited. We have: Insufficient Process and control technology Info Insufficient emission and test data Insufficient Remanded Units info Complex, Large Category OMB Review needed Internal, Deliberative Do Not Cite or Quote
Comment Request Topics General ICR Comment Requests: Evaluate Practical Utility Evaluate the Burden Estimate Suggestions to Enhance Utility, Clarity, Quality Suggestions to Reduce, Minimize Burden Emission Estimation Tool Usefulness On-line Electronic Submission Alternative 5 Internal, Deliberative Do Not Cite or Quote
ICR ICR divided into two phases: Phase 1: Survey (see docket) Regulated Unit Info, Compliance Tests Remanded Unit Info Emissions Inventory Phase 2: Conditional Testing Remanded Unit focus PM for Direct Fired Dryers Internal, Deliberative Do Not Cite or Quote
Testing Testing, phase 2, is Contingent on Survey Data Test where Survey Data is insufficient to set standard, resolve Brick Issues Metric for Sufficiency Work Practice Requirements under CAA 112 (h) 7 Internal, Deliberative Do Not Cite or Quote
Electronic Submission Option Via CEDRI Download and upload spreadsheet on-line Option to prepopulate facility attributes (e.g., units, processes, and released points and parameters) based on latest data available to EPA 2014 National Emissions Inventory (NEI) Real-time quality control of facility attributes, fewer follow-up questions from EPA Potential advantages Burden Reduction: Facility data available for all EPA reporting programs, electronically (examples: NEI, TRI, CEDRI, future ICR). Quality Improvement: Ready availability of data for use, review, revision and amendment by facilities. Improved Accuracy: Future NEI and National Air Toxics Assessment (NATA) Industry input regarding implementation is being sought Internal, Deliberative Do Not Cite or Quote
Next steps With survey data we will .. Evaluate residual risk in the category Evaluate technology changes in practices, processes and controls that impact HAP emissions in the category Assess the need to collect test data to set MACT standards for Remanded PCWP process units. Testing data will allow us to set MACT standards for Remanded PCWP process units. Timeframes are contingent on petition responses by the U.S. District Court. Internal, Deliberative Do Not Cite or Quote
Remanded Units 2007 Court Ruling Sanders Saws Fiber washers Chippers Log vats Lumber kilns Storage tanks Wastewater operations Miscellaneous coating operations Stand-alone digesters Press pre-dryers Fiberboard mat dryers Board coolers Dry rotary dryers Veneer re-dryers Softwood plywood presses Hardwood plywood presses Hardwood veneer dryers Humidifiers Atmospheric refiners Formers Blenders Engineered wood products presses Rotary agricultural fiber dryers Agricultural fiber board presses 10 Internal, Deliberative Do Not Cite or Quote
Questions? Docket: Go to: https://www.regulations.gov/ Search: EPA-HQ-OAR-2016-0243 FR Notice: https://www.gpo.gov/fdsys/pkg/FR-2016-09-08/pdf/2016-21507.pdf 81 FR 62125 PCWP Web Site: https://www.epa.gov/stationary-sources-air-pollution/plywood-and- composite-wood-products-manufacture-national-emission CAER Participation. Email: CAER@epa.gov. Comments Due: November 7th Internal, Deliberative Do Not Cite or Quote
Remanded Units 2007 Court Ruling Sanders Saws Fiber washers Chippers Log vats Lumber kilns Storage tanks Wastewater operations Miscellaneous coating operations Stand-alone digesters Press pre-dryers Fiberboard mat dryers Board coolers Dry rotary dryers Veneer re-dryers Softwood plywood presses Hardwood plywood presses Hardwood veneer dryers Humidifiers Atmospheric refiners Formers Blenders Engineered wood products presses Rotary agricultural fiber dryers Agricultural fiber board presses 12 Internal, Deliberative Do Not Cite or Quote
Remanded Units 2007 Court Ruling Sanders Saws Fiber washers Chippers Log vats Lumber kilns Storage tanks Wastewater operations Miscellaneous coating operations Stand-alone digesters Press pre-dryers Fiberboard mat dryers Board coolers Dry rotary dryers Veneer re-dryers Softwood plywood presses Hardwood plywood presses Hardwood veneer dryers Humidifiers Atmospheric refiners Formers Blenders Engineered wood products presses Rotary agricultural fiber dryers Agricultural fiber board presses 13 Internal, Deliberative Do Not Cite or Quote
Remanded Units 2007 Court Ruling Sanders Saws Fiber washers Chippers Log vats Lumber kilns Storage tanks Wastewater operations Miscellaneous coating operations Stand-alone digesters Press pre-dryers Fiberboard mat dryers Board coolers Dry rotary dryers Veneer re-dryers Softwood plywood presses Hardwood plywood presses Hardwood veneer dryers Humidifiers Atmospheric refiners Formers Blenders Engineered wood products presses Rotary agricultural fiber dryers Agricultural fiber board presses 14 Internal, Deliberative Do Not Cite or Quote
