Plywood products and production on the assembly line of a plywood factory

New USEPA Information Collection Request Affecting Plywood & Composite Wood Products Facilities

March 7, 2022

The EPA has recently announced a new Information Collection Request (ICR) has been sent to a large number of Plywood and Composite Wood Products facilities. The ICR is collecting information required under the Clean Air Act and is concerned with sources of hazardous air pollutants (HAP) emissions from the wood products industry.

This new ICR has outlined a detailed process, methodology, equipment guidance, and specific reporting guidelines. Some of the important considerations and specifics include:

Test Procedure and Methods
Stack testing: owner/operator must certify tested unit was operating properly during the testing process, and all air pollution control devices are functioning properly as well. Multiple vents not ducted to a common stack required individual testing of ALL vents.  Common regulated units include dryers, pressurized refineries, presses and drying ovens.

Emissions Measurement Methods
Required testing varies depending on the type of process unit. To determine pollutant reduction accurately, inlet sampling must be conducted concurrently with outlet sampling.  Tests that are not conducted concurrently may be considered invalid and may need to be repeated.

Data Quality of Source Tests
While the EPA has not specified numerical minimum detection levels for testing, they have outlined required conditions and methods including test run sample volumes (or times).  The EPA will also weigh the quality of testing equipment when considering results – and have specifically cautioned against using low or medium quality equipment as opposed to high quality.  If the EPA determines that the owner failed to meet the testing requirement to provide data of sufficient quality for decisions, they can request additional measurements and improved testing procedures.

Reporting Data
Testing data must be submitted via the EPA’s Electronic Reporting Tool (ERT).

What’s next?
If your operation is subject to revised PCWP requirements or the ICR, a thorough review of the rules and regulations is in order. But you don’t have to navigate these changes alone – the Montrose integrated family of companies can provide the help you need, with decades of experience and a seamless program – from planning to sampling to testing to response and remediation, if necessary.  For more information, please contact us.

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