Plywood and Composite Wood Products Manufacturing - Frequently Asked Questions
- ICR Applicability
- Navigating the Spreadsheet
- Process Units to Include in the ICR Response
- Mill and Prod Tabs
- EquipDetail and ReleasePt Tabs
- Permit Tab
- Resin and Tank Tabs
- EmTest Tab and Test Report Submittals
- HAP Emissions Tab and Provisional Calculations
- Facility Release Point Map
- Submitting the ICR
- Confidential Business Information
1000. My facility produces lumber, not plywood and composite wood products (PCWP). Why did I receive the PCWP information collection request?
Lumber kilns located at any “major source” facility are part of the affected source under the PCWP National Emission Standards for Hazardous Air Pollutants (NESHAP), found in the Code of Federal Regulations at 40 CFR part 63, subpart DDDD.
Some facilities that produce kiln-dried lumber are major sources of hazardous air pollutants (HAP). Major sources of HAP emissions are facilities that have the potential to emit 10 tons per year or more of any one HAP or 25 tons per year or more of any combination of HAP.
The January 9, 2003 PCWP NESHAP proposal discussed inclusion of lumber kilns at any major source facility. The preamble to the proposed rule explained:
Today’s action serves to broaden the PCWP source category to include lumber kilns located at stand-alone kiln-dried lumber manufacturing facilities or at any other type of facility. Wood products industry representatives requested that all lumber kilns (regardless of location) be considered in today’s proposed rule so there would be one MACT determination for all lumber kilns nationwide. If lumber kilns at stand-alone kiln-dried lumber manufacturing facilities and other types of facilities are not included in the PCWP NESHAP, kiln-dried lumber manufacturing could be listed as a major source category under section 112(c) of the CAA in the future, requiring a separate section 112(d) rulemaking, and may become separately subject to the provisions of section 112(g) of the CAA as well. Because the design and operation of lumber kilns are essentially the same regardless of whether the kilns are located at a sawmill or are co-located with PCWP or other types of manufacturing operations, we have included lumber kilns in the PCWP source category. Broadening the scope of the PCWP source category to include lumber kilns located at any type of facility is reasonable because based on our information, there are no currently applicable controls at any lumber kilns and it is both more efficient and expeditious to include them in the MACT process now than to separately address them in a rulemaking that would not likely result in meaningful emissions reductions from lumber kilns. Moreover, including all lumber kilns in the PCWP MACT results in placing them on a faster schedule for purposes of future residual risk. (68 FR 1279, January 9, 2003)
After considering public comments on the proposal, lumber kilns were included in the PCWP NESHAP finalized on July 30, 2004. The final PCWP NESHAP specifies no control requirements for lumber kilns based on the 2004 maximum achievable control technology (MACT) determination.
The PCWP ICR is designed to provide data to enable the EPA to conduct the residual risk and technology reviews required under the Clean Air Act. In addition, the ICR will provide information needed for the EPA to address a 2007 court remand of various aspects of the regulation. The ICR will supply information needed for the EPA to assess residual risk, identify small businesses that are major sources operating lumber kilns, and estimate impacts of regulatory options (such as work practices) considered for lumber kilns.
Lumber facilities that believe they may have received the ICR in error are encouraged to review the applicability criteria for the ICR in section A1 of the ICR instructions. The EPA intended to limit distribution of the ICR to lumber facilities that operate lumber kilns and are major sources of HAP. If you believe the ICR does not apply to your facility, then please submit the appropriate Appendix 1A or 1B form.
If the ICR applies, please note that lumber kilns are the only equipment required to be included in the spreadsheet form for lumber facilities that do not have collocated PCWP production.
1010. Our facility is currently a synthetic area source (as described on page 2 of the ICR instructions). Our facility became a synthetic area source after the MACT compliance date. Does the EPA expect our facility to submit the full response to the ICR, or may we submit the short Appendix 1B response that is an option for sources that became synthetic area sources before the MACT compliance date?
For the purposes of responding to the PCWP ICR, if your facility is currently a synthetic area source (as described on page 2 of the ICR instructions), the EPA will allow your facility to submit the shorter Appendix 1B response, if you choose.
1200. How can I easily transfer my responses from the prior proposed ICR to the final ICR spreadsheet?
If you began working on a previous public-comment draft of the ICR spreadsheet, you may copy and paste data as values into unlocked fields of the final ICR spreadsheet. See page 17 of the instructions document for more information on how to paste as values.
The spreadsheet does not allow data to be pasted across or into the gray locked fields containing formulas. These fields will populate automatically as you complete the spreadsheet moving from left to right beginning with the Mill tab. Be sure to carefully follow the column headings and instructions at the top of the spreadsheet because the final spreadsheet was adjusted to address public comments.
1210. How should I populate the EquipDetail tab for a process unit such as a former with multiple pick-up points that are routed to one baghouse?
The EquipDetail tab is designed to list individual process units. Use one row of the EquipDetail tab to enter the information about each process unit such as a former. If all pick-up points are routed to one emissions release point (such as a baghouse), then the facility would only need to complete the ReleasePt tab for the one release point associated with the process unit.
1220. How should I populate the EquipDetail and ReleasePt tabs when emissions from multiple process units are routed to the same release point?
The EquipDetail tab was designed for respondents to enter one process unit on each row to provide the EPA with a nationwide count of each type of process unit. Therefore, you should enter each process unit on a separate row of the EquipDetail tab. In columns R through W of the EquipDetail tab (Emission Release Point Information section), enter the same Emission Release Point ID for each process unit that shares the same release point.
Then in the ReleasePt tab, the repeated Emission Release Point IDs will show up in bold purple font in column F. With the possible exception of the SCC, the release point parameters such as stack exit gas temperature, velocity, and height would be the same for every release point appearing multiple times (in purple) in the ReleasePt tab. You could cut/paste the release parameters as values on each row for the same release point.
Note: You can hit control [CTRL] + apostrophe [‘] at the same time to copy down the value from the row above if the repeated release points are on adjacent rows.
1230. My ICR ID does not automatically show up in the Prod tab.
The ICR ID in column B of the Prod tab does not appear until you have entered a selection in Column C, the first column to enter data.
Several tabs in the spreadsheet do not display the ICR ID until you have entered text in the first data-entry column. This allows unused rows to remain blank.
Process Units to Include in the ICR Response
1400. Should OSB stranders (flakers) be included in the ICR response?
No. Appendix 2 of the ICR instructions specifies which process units to include in the ICR response. OSB stranders (flakers) are green-end wood handling units that are not listed in Appendix 2 of the ICR.
1600. If a particleboard mill uses UF resins with different formulations for the face and core, should “1” or “2” be entered for the number of resins used in the Prod tab, Column O?
The instructions refer to significantly different types of resins (e.g., PF, MDI or PVA) so it is acceptable to enter “1” for different formulations of UF resin in the face and core.
The distinction between significantly different UF resin formulations is made in the Resin tab, where different Resin IDs are entered and Column G asks if the resin is used in the face or the core. The face and core UF resin formulations can be entered on two separate rows of the Resin tab. The Resin IDs assigned for the face and core formulations will appear again later in the spreadsheet (in the Tank tab and OtherEquip tab for dry blending/forming).
EquipDetail and ReleasePt Tabs
1800. My facility is located in Eastern Maine. The X-coordinate (longitude) columns in ReleasePt do not extend to my longitude.
The validation criteria for X-coordinates (longitudes) in column U, as well as for columns W and Y (for fugitive 2-dimensional release point types), are too narrow for a few of the eastern-most facilities in the U.S. There are options for entering longitudes in these cases:
(1) If the facility's working spreadsheet does not currently contain any CBI, the facility could email it to the EPA at pcwpicr@epa.gov and ask the EPA to unlock it, expand the range, and then send it back.
1810. Do I need to include non-HAP miscellaneous coating operations in the EquipDetail tab?
No. There is no need to include non-HAP-emitting miscellaneous coating operations in the EquipDetail tab. The “miscellaneous coating operation” process unit type in the EquipDetail tab is available for coating processes within the PCWP source category that emit HAP.
The PCWP NESHAP defines “miscellaneous coating operations” included in the PCWP source category, and specifies a non-HAP coating work practice for “Group 1 miscellaneous coating operations.” Definitions are provided in Appendix 7 of the ICR instructions.
The MiscCoat tab asks questions about each miscellaneous coating used that is part of the PCWP source category, including coatings with HAP emissions (which are included in the EquipDetail tab) and Group 1 miscellaneous coating operations subject to the non-HAP coating work practice (which do not need to be included in the EquipDetail tab).
1820. Why isn’t my ReleasePt tab prepopulating with my process units?
The ReleasePt tab prepopulates your process units once emission release point ID(s) are entered into columns S through W of the EquipDetail tab. Please ensure you have entered an Emission Release Point ID for the process unit.
1900. Google Earth uses WGS84 datum, but the ICR instructions say to use NAD83 for longitude/latitude coordinates. Can we use WGS84?
Yes, WGS84 coordinates may be used. However, please add a note in the comments column of the ReleasePt tab to let us know you used WGS84.
2000. The Permit tab asks for permit limits by process unit, but my permit has limits for each emission release point. How can I enter limits for the following scenarios: (1) a process unit that has multiple emission points with different limits (e.g., a former with multiple baghouses on pick-up points), and (2) multiple process units that share a control device and therefore share an emission limit?
The Permit tab will be used to evaluate limits for each type of process unit, and therefore, was structured around each unique Process Unit ID instead of each release point.
In scenario 1, where multiple control devices are all associated with one Process Unit ID (e.g., multiple baghouses collecting particulates from pickups along the former), you may leave the individual permit limit columns blank and put a note in the comment field with a response such as:
“Different emission limits apply to multiple release points associated with this Process Unit. See the permit for the [HAP, VOC, PM, Opacity] limit(s).”
In the sentence above, you could provide only the applicable pollutant type(s) from the options in the square brackets. For example, for former baghouses, the last sentence might say, “See the permit for the PM and opacity limits.”
For scenario 2, when multiple process units are ducted to the same stack, you could cut and paste “as values” the permit information on each row for process units that have the same release point. The EPA will know this is a common release point because the Emission Release Point IDs provided in the EquipDetail tab of the ICR will be the same.
2200. Should non-HAP isocyanate compounds in MDI resins be included in the resin HAP percentages in columns L through P the Resin tab?
No. You do not need to report non-HAP compounds in columns L through P of the Resin tab.
The HAP list contains the CAS number 101688 for “methylene diphenyl diisocyanate (MDI)” which includes 4,4'-methylenediphenyl diisocyanate, the principle isocyanate compound in MDI resins.
2210. Does the HAP percent by weight requested in the Resin tab refer to “free” or “total” HAP? The examples provided seem really high for formaldehyde.
Columns L through O of the Resin tab request that you review resin safety data sheets (SDS) for your facility and enter information on the percent by weight of HAP. If your SDS specifies both the “total” HAP amount in the resin formulation prior to crosslinking and the “free” HAP percent representing the amount of HAP that is not cross-linked with other compounds in the resin, then please provide the “free” HAP percent. For example, if the SDS says <0.1% for free formaldehyde, enter “<0.1” in column L. If the SDS says 3% methanol, enter “3” in column M.
The examples provided in the spreadsheet were intended to distinguish between providing the percent as an actual value versus using a decimal percent. The EPA recognizes that many of the resin HAP values provided will be decimals. The resin HAP columns of the spreadsheet are designed to accept whole numbers, decimals, and the less than “<” sign.
2220. On the Resin tab, we provide the information (%solids, formaldehyde content, etc.) for the resin as it is purchased from the supplier. As it is received, it is immediately mixed with water within the tanks, so the throughput reported on the Tank tab is for the “diluted” product. Is this the correct way to enter the data?
This approach to the Resin and Tanks tabs makes sense. However, for added clarity, you could note in the comments column of the Resin tab that the “data provided are for the resin ‘as purchased,’” and then note in the Tanks tab that the “throughput reported on the Tank tab is for the ‘diluted’ product.”
EmTest Tab and Test Report Submittals
3800. Are PM species test reports only required for direct fired dryers?
Yes. PM and/or HAP metals test reports from previously conducted testing are requested for direct-fired dryers only. The PM data are requested because PM could be a surrogate for HAP metals from direct-fired dryers. PM data are not requested for indirect-fired dryers or other PCWP process units. See Appendix 3 of the instructions document for cutoff dates for previously conducted emissions test reports. No new emissions testing is required for the ICR.
3810. Does EPA only want “official” test reports performed for requirements outlined in our Title V permits? What about engineering emission tests conducted to evaluate resin changes, press temperature changes, line speed changes, new product trials, etc. that did not require a test plan and may or may not have been performed using full EPA methodology?
As stated in section D4a of the ICR instructions, the EPA is requesting full test reports with field and lab data sheets and example calculations, not just summary reports. Engineering reports are likely to be summary reports that do not meet the criteria for what is being requested. Engineering reports are not required to be submitted. However, this does not preclude facilities from submitting engineering reports that could be useful for purposes of showing how a change in a process or practice alters emissions. Such reports may not be useful for setting emission limits because of the lack the typical lab documentation, but they may help lend credibility to an operational practice considered in lieu of an emission limit.
3820. The calculation in Column F of the EmTest tab seems to be incorrect. Is there a solution for this?
The EPA is aware that the underlying array formula that prepopulates column F in the EmTest tab is not working as intended. Column F pulls Process Unit IDs from elsewhere in the spreadsheet for informational purposes only, and is not critical to completion of the EmTest tab or other parts of the spreadsheet. Given the glitch in the formula, respondents may hide and ignore Column F. The EPA will populate this information once the nationwide PCWP data base is compiled.
HAP Emissions Tab and Provisional Calculations
4000. If I speciate my estimate of total chromium into chromium III and chromium VI in the HAP Emissions tab, do I also need to add the total chromium value?
Please do not enter the total value if you provide speciated values. Including both the speciated and total values would double-count emissions.
4010. What do I do if one of the SCCs in the HAP Emissions tab does not match the SCC entered into the ReleasePt tab?
This question is relevant for respondents using the provisional calculations for release points aggregating emissions from multiple processes units of different types (for example, a baghouse serving both a blender and former, or baghouse serving both sanding and sawing).
Source classification codes (SCCs) associated with each release point are first entered into the ReleasePt tab, and then are carried forward to the HAP Emissions tab for use by respondents choosing to use the provisional calculations. Multiple differing SCCs may be associated with release points aggregating emissions from multiple processes units of different types (e.g., an SCC for the blender and a different SCC for the former routed to the same baghouse, BH1). The lookup formula carrying the SCCs into the HAP emissions tab prepopulates the first SCC listed in the ReleasePt tab for the release point in the HAP Emissions tab. Thus, if the blender venting to BH1 appears on row 10, and the former venting to BH1 appears on row 15 of the ReleasePt tab, the formula prepopulates the blender’s SCC into the HAP Emissions tab for both the blender and the former baghouse (BH1). The provisional calculation emission factors are based on the SCCs in the HAP Emissions tab, so it is important for respondents using the provisional calculations to review the SCCs if they have multiple process unit types venting to the same release point.
If you encounter this circumstance in the HAP Emissions tab SCC column, a solution is to temporarily rename the second and subsequent instances of the release point ID (e.g., BH1) in columns S-W of the EquipDetail tab (e.g., rename the release point “BH1-temp” for the former in our example). This creates a unique ID in the ReleasePt tab so the lookup carries the proper SCC from the ReleasePt tab into the HAP Emissions tab. Once you have created the temporary release point ID in the EquipDetail tab, then you can proceed with pasting the provisional calculation results based on the correct SCC (in columns AF-AH) into columns M-O of the HAP Emissions tab. Then return to the EquipDetail tab and change the temporary release point ID back to BH1.
4200. On the Facility Emission Point Map, how should I indicate emissions from a process unit inside a building that does not have an associated stack?
Facility knowledge and engineering judgment are needed to approximate where emissions would be most likely to be released into the outside atmosphere. For operations inside a building that themselves do not have direct emission points, the release point could be identified as the nearest building vent (or vents). The building vent(s) would be the emission point(s) to show on the Facility Release Point Map (e.g., as a fugitive vent source).
The emission release points entered on the Facility Emission Point Map should match the Emission Release Point IDs entered in the EquipDetail tab of the ICR survey spreadsheet. You may find it helpful to review page 25 of the ICR Instructions Document, specifically the tip box and information on associating building vents with fugitive sources and use of the predominant venting mechanism.
4600. Can I submit my full ICR response to pcwpicr@epa.gov?
No. Please review section C of the ICR instructions document for ICR submittal procedures (via CEDRI or mailed disk/flash drive).
The pcwpicr@epa.gov email was set up to accommodate Appendix 1A and 1B submittals and for question/answer purposes. It is not set up for the total file size of full ICR responses (e.g., survey spreadsheets plus other documents) and is not an appropriate submittal method for responses containing confidential business information.
4610. The FRS ID in my PCWP ICR letter differs from the FRS ID for my facility in CEDRI. How should I handle this?
When you select your facility in CDX/CEDRI, it will display the FRS ID (EPA Registry ID) stored in CEDRI. There is no need to change the current CEDRI FRS ID for purposes of submitting the PCWP ICR.
You can use the CEDRI FRS ID in your PCWP spreadsheet response instead of the FRS ID you received in your PCWP ICR letter if you prefer. If you use a different FRS ID than was provided in your ICR letter, please make a note in the PCWP spreadsheet Mill tab comments column indicating that you are using a different FRS ID.
You will be able to submit your PCWP ICR response using CEDRI regardless of which FRS ID you include in the PCWP spreadsheet.
4620. When I try to upload my response into CEDRI, I get an error message saying, the file “did not upload because the file is not complete. The cell located on Sheet: 'sheetName' in Row: 'rowNumber', Col: 'IcrId' is invalid.” How do I fix this?
CEDRI checks to ensure an ICR ID is associated with all rows that contain data to prevent extraneous, orphaned data from being imported into the data base the EPA compiles from the ICR responses. This error message appears when extra information was inadvertently left in the blank rows of the tab below the last row of data having an ICR ID.
To correct the spreadsheet, look across the white cells in the blank rows to see where extraneous information appears and delete it. Then upload your ICR spreadsheet into CEDRI.
If you do not readily see the information, please contact the ICR Help Desk to receive instructions for an alternate solution.
4630. I received two email messages from CDX CEDRI after submitting my ICR, one saying the submission was successful and another saying “CDX CEDRI FRS failure occurred.” Was my submissions successful?
Yes, your submission was successful. If you receive a second email saying the “CDX CEDRI FRS failure occurred,” it is likely because the FRS ID in your spreadsheet differed from the FRS ID in CEDRI. You may ignore this second email.
Confidential Business Information
4700. A cell with a menu list prevents me from entering the letters “CBI” as instructed to do when removing confidential information from my response.
The instructions say to shade cells red and enter the letters “CBI” to indicate that confidential business information (CBI) was removed from your non-confidential spreadsheet if you are submitting separate files containing non-CBI and CBI responses.
Certain cells contain drop-down menus or other validation criteria that do not allow entry of the letters “CBI.” For those cells, when creating the non-CBI spreadsheet, simply leave the cell blank and shaded red to indicate CBI information was removed and is being submitted separately in the CBI version of your response.
Please do not include CBI information in your non-CBI response.