Final EPA Rule on NESHAP for Plywood and Composite Wood Products (PCWP) Amendment

November 4, 2020

By: Sandra Alvarado, PE

The NESHAP for Plywood and Composite Wood Products (PCWP) was published in the Federal Register on Thursday, August 13, 2020.  The key impacts are summarized here:

  1. Facilities are required to submit notifications, semi-annual reports, and compliance reports (which include performance test reports) electronically through EPA’s Compliance and Emissions Data Reporting Interface (CEDRI). Facilities must comply within 1 year after the template is made available on CEDRI.
  2. Elimination of the startup, shutdown, and malfunction (SSM) provisions, if you use the emission rate with add-on controls option. Accordingly, emission standards will apply at all times and recordkeeping and reporting requirements related to the SSM exemption will be void on February 10, 2021.
  3. Emissions testing is now required at least every 5 years to demonstrate compliance for add-on controls. Previously, only initial emissions testing was required. Note that repeat emissions testing requirement does not apply to biofilters. Facilities must comply by August 13, 2023, or within 5 years of the previous performance test, whichever is later.
  4. The following parameter monitoring requirements were revised:
    • A 10 percent variability margin was added for the upper and lower biofilter bed temperatures to allow for fluctuations in weather, but cannot exceed 8 °F at the upper limit.
    • Validation semiannually in lieu of calibration checks are approved for previous thermocouple calibration language.

The amendment also included minor revisions and clarification to language and references. There were no changes to PCWP source categories, no additional controls requirements, and no revisions to MACT emissions limit standards based on EPA’s risk or technology review.

What This Means for You:
PCWP facilities subject to the NESHAP must

  1. Monitor the availability of reporting templates in CEDRI before submission of the next semiannual and annual compliance reports.
  2. Recordkeeping and reporting requirements related to the SSM exemption will be void after February 10, 2021. The SSM Plan will no longer be required.
  3. Schedule performance testing to be completed by August 13, 2023, or within 5 years of the previous performance test using the methods outlined in Table 4 of 40 CFR 63 Subpart DDDD.

For More Information
You can read more on the ruling in the Federal Register here.

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Sandra Alvarado, P.E.
Sandra Alvarado has 20 years of experience in the chemical engineering and environmental compliance field. She has prepared permitting applications, regulatory applicability determinations, and compliance report documentation and notifications for facilities across the country.

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