The Plywood and Composite Wood Products MACT October 2017 ICR

This article is available as a podcast episode on ALL4’s Air Quality Insider

The U.S. Environmental Protection Agency (U.S. EPA) issued an Information Collection Request (ICR) on October 5, 2017 to a long list of facilities in the Plywood and Composite Wood Products (PCWP) industry.  If you have a facility that is part of this industry sector and you received one of these letters you now know that U.S. EPA has the authority under Section 114 of the Clean Air Act to have you spend a significant amount of time over the next few months compiling information about equipment and potential hazardous air pollutant (HAP) emissions at your facility.  In this instance, EPA is requesting information for facilities regulated under the federal National Emissions Standards for Hazardous Air Pollutants or NESHAP rules.  These regulations are also referred to as the Maximum Achievable Control Technology (MACT) standards, and in this case the current PCWP MACT standards are cited at 40 CFR Part 63, Subpart DDDD.

The ICR mailed out in October included two different spreadsheets and substantial detailed instruction and guidance to aid facilities in completing and submitting the requisite information.  All of the same information included with the request and some additional resources, can be viewed and downloaded from U.S. EPA’s website.  Along with all of U.S. EPA’s guidance, the National Council for Air and Stream Improvement (NCASI), the independent, non-profit research group that provides substantial environmental support to the forest products industry, conducted training webinars in November for member companies on details for assisting facilities in completing their ICR responses.

Even with the U.S. EPA and NCASI resources, regulated entities will need to plan and account for the time and resource commitment required to respond to the ICR.  With responses due back to U.S. EPA by February 9, 2018, it may make sense to bring in outside resources to aid in the ICR response efforts.  ALL4 has substantial experience with the PCWP industry and with compiling ICR responses.  We can provide support at various levels ranging from gathering and compiling facility data, to completing the U.S. EPA spreadsheets, to submitting the data electronically, or to taking on responsibility for the entire response effort from start to finish.  Given that facilities have a number of other critical year-end responsibilities that must be attended to, and taking into account various out-of-office schedules with the upcoming holiday, and then adding in the year-end reports that will need to be compiled during January, the early February response due date could be problematic from a resource availability perspective.

If you have questions about the ICR content or would like to talk about how we might assist your facility, please reach out to John Egan (610.422.1114 or jegan@all4inc.com).