The US EPA mailed the ICR by registered mail to 391 facilities in the PCWP industry that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering National Emission Standards for Hazardous Air Pollutants (NESHAP) applicability.

 Recipients are asked to complete the ICR by February 9, 2018.

Continue reading “The EPA Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) Was Mailed by the EPA and is Due February 9, 2018”

The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), for the “Plywood Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Risk  and Technology Review (RTR)” (Kiln MACT) to the office of Management and Budget (OMB) for preview and approval.

This Kiln MACT applies to every sawmill that is a Major Source or Synthetic Minor Source for Hazardous Air Pollutants (HAP).

The ICR will be sent to all known operators of PCWP facilities that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering NESHAP applicability. The information collection seeks to collect facility-level information (e.g. facility name, location, contact information, and process unit details), emissions information, compliance data, control information, and descriptions of technological innovations.

The EPA will either establish an emission limit or work practices in order to minimize emissions for process units included in the PCWP MACT source category. Capturing, controlling, and the measurements of kiln emissions is not feasible. Installing emissions capture and add-on control equipment for VOC/HAP removal have not been identified. It is therefore predicted that facilities will choose to use work practice requirements in lieu of emission limits.

The purpose of work practices is to minimize HAP emissions. For most kiln schedules, the HAP emissions increase near the end of the drying cycle when the wood reaches its final moisture content. HAP emissions increase as the moisture content decreases.

If you operate a lumber kiln, you will need to develop a plan for minimizing HAP emissions from the lumber kiln(s) by minimizing the annual average variability in dried lumber moisture content. Plans must be required to be submitted to the appropriate regulatory agency with your Notice of Compliance Status and you will need to maintain appropriate records of compliance with the work practices.

Changes in kiln operating temperatures can significantly affect mill operations and drying capacity. Lower kiln temperatures result in longer drying times. This is a production and capacity issue for mills. A mill operating four lumber kilns at full capacity at 225OF would have to add two more lumber kilns to dry the same amount of lumber at 180OF. To overcome the potential Kiln MACT limitation, facilities will need to prepare a compliance work practice plan that minimizes emissions with the least affect to drying production.

Shortly Major Source and Synthetic Minor Source of HAPs will receive an ICR survey. You will have 120 days after ICR mailout to submit it. CTI is experienced in this area in assisting many lumber mills in the permitting process that includes most of the information requested in the survey. CTI also has assisted facilities with ICR for other regulations in the past.

Upon receipt of the ICR, feel free to contact us for a proposal to assist you to prepare it. If you have any questions or need additional information, please contact us.

Under the previous EPA Non-Hazardous Secondary Materials (NHSM) rule, treated wood was prohibited from being used as boiler fuel; however, EPA recently issued an amendment permitting creosote-treated wood to be used as boiler fuel under special conditions.

Read the rest of our article in Waste Advantage Magazine online ( or in the April 2016 digital edition (

Conversion Technology Inc. (CTI) is celebrating its 30th year of business. For the last 30 years, CTI has been assisting our clients across the United States achieve environmental and safety compliance.
CTI began its existence as a firm that designed systems for the conversion of waste material to energy and other useful by-products. We completed the design and installation of a system that was fueled by cotton seed husks and was able to generate the energy required for the drying of raw cotton. This system converted the cotton waste to energy. This style of energy conversion was the origin of the name “Conversion Technology Inc.”

Continue reading “A Word From the Founder”

If you missed our free webinar on Boiler MACT Compliance, you can stream it online now on your own time. To view the webinar visit and register to view (or enter your email if already registered).


If you wanted to have the presentation slides from the webinar, we have made them available here: 2016 Boiler MACT Webinar Slides.

The Q/A for the webinar is available here: QA Boiler MACT Webinar.

If you have any questions or comments about Boiler MACT Compliance or the webinar, feel free to contact us at 770-263-6330 or


Sponsored by: Hurst Boiler and Conversion Technology Inc.
Title: Boiler MACT Deadline is here. Are you in Compliance?
Date: Thursday, January 21, 2016
Time: 02:00 PM Eastern Standard Time
Duration: 1 hour

If your facility is covered under the Boiler MACT rule, the compliance deadline is January 31, 2016 ! Continue reading “Free Webinar: Boiler MACT Deadline is here. Are you in Compliance?”

Boiler Area Source applies to a boiler in a facility with actual emissions of Hazardous Air  Pollutants (HAP) less than 10 tons per year of any single HAP or less than 25 tons per year of all HAPs combined. EPA allows Boiler Area Source facilities the use of Generally Available Control Technologies (GACT) or management practices to reduce emissions of hazardous air pollutant (as compared to Boiler MACT facilities explained later requiring stricter practices). If your facility is an Area Source, you should have submitted the Initial Notification Report and Notification of Compliance Status to the State and US EPA by May 31, 2013. Continue reading “Meeting Compliance Schedule and Requirements for Boiler MACT”


Check our site to see if Boiler MACT or Boiler Area Source is applicable to your facility.

The January 31, 2016 Boiler MACT deadline is rapidly approaching. You must be in compliance with the applicable requirements of the Boiler MACT rule by this deadline.

Most of you have completed the Energy Assessment and Tune-Up of your boilers as required by the Boiler MACT rule. However, the Energy Assessment and Tune-Up requirement is a small and relatively easy, part of the Boiler MACT rule. More actions are required for your facility to be in compliance with the rule such as: Continue reading “Boiler MACT Compliance Implementation”

The purpose of this article is to walk you through the Boiler MACT applicability, compliance dates and what regulations are applicable to your facility’s boiler and/or process heater. The full names of Boiler MACT and GACT as published in the Federal Register 40 CFR Part 63, is as follows: Boiler GACT (Generally Achievable Control Technologies), in short refers to the USEPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Source: Industrial, Commercial and Institutional Boilers. Boiler MACT (Maximum Achievable Control Technology) refers to the USEPA’s NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

The Four Rules

To figure what rule applies to your facility, you first need to understand the Boiler MACT basic 4 rules. Boiler MACT is used in a generalized form to include the following specific rules: Continue reading “Meeting Compliance Schedule and Requirements of Boiler MACT”

OSHA has implemented a National Emphasis Program (NEP) to raise awareness of the dangers associated with isocyanate exposure.

Isocyanates are hazardous chemicals that are often found in activities using paints, foam insulation, polyurethane, surface coatings, rubber, and adhesives.

They are powerful irritants to the mucous membranes of the eyes, nose, and throat. Hazardous health effects associated with occupational exposure to isocyanates include irritation of the skin and mucous membranes, hypersensitivity pneumotitis (inflammation in the lungs), and chest tightness.  A more serious hazardous health effect resulting from exposure to isocyanates is occupational asthma. Occupational asthma is an illness that can make it difficult to breath and causes chest tightness, wheezing, coughing, and shortness of breath. It is frequently serious and can be fatal. Isocyanates also include compounds that are classified as potential human carcinogens and have been known to cause cancer in animals.

Continue reading “Are your employees at risk of isocyanate exposure?”