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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.
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.
The US Environmental Protection Agency (EPA) has proposed to issue an Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as the “PCWP MACT” or “Kiln MACT”. This is an important update for those in the lumber industry, as lumber drying kilns are one of the sources regulated under the standard. While the PCWP NESHAP covers many types of process units, this discussion will be primarily focused on the standard’s effect on sawmills operating lumber drying kilns.
What is the history of the rule? Continue reading “EPA Proposes Collection of Information for “Kiln MACT””
The US Environmental Protection Agency (EPA) has issued a final rule to revise the Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program. The update contains over 60 revisions and will be effective May 30, 2017. One of the EPA’s objectives of the revisions is to reorganize the regulations to make them more user-friendly and easier to understand for generators. The revisions also include changes that address gaps in existing regulations, provide more flexibility for generators to mange hazardous waste, and make technical corrections. 
Below is a list of some the program changes: Continue reading “EPA Issues Changes to RCRA Hazardous Waste Generator Rule”
The publication of the new ISO 45001 Standard, Occupational Health and Safety Management System, is once again being delayed. While the drafting committee has processed several thousand comments from the first draft already, another meeting is being scheduled for February 2017 to discuss and review the remaining comments. Once all of the comments have been reviewed, the committee is expected to publish the new standard by the end of 2017 or early 2018. With the additional time the finalization of the ISO 45001 standard is being delayed, companies now have more time to prepare and implement any programs and changes for the new requirements. Stay tuned for more information on the finalization of this standard.
EPA is working on the Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP). The comment period for preparing the ICR ended on November 7, 2016. This is the MACT standard commonly referred to as the Kiln MACT as it will apply to lumber drying kilns in some fashion, in addition to plywood and composite wood products. Continue reading “EPA Information Request for Kiln MACT Standard (40 CFR 63 Subpart DDDD)”
As we reported in an earlier blog post, the Georgia Environmental Protection Division (GAEPD) has posted a draft of the 2017 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity. The current (2012) version of the permit is set to expire on May 31, 2017, and this revision will replace it. The GAEPD has held three stakeholder meetings that were open to the public, and representatives from CTI were in attendance. There are a few obvious trends that we can see from the direction the GAEPD is heading. Most notably, there is an increased focus on erosion and sedimentation control, and there is a push for higher accountability in completing corrective actions. We will discuss both of these below, but keep in mind that the permit is in an early draft phase. The GAEPD will be issuing a second draft based on input received during the stakeholder meetings and the preliminary comment period, and there will be a second opportunity for the public to comment before the final permit is issued. Continue reading “Update on Georgia’s Draft Industrial Stormwater General Permit”
The Georgia Environmental Protection Division (GAEPD) has posted a draft of the 2017 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity. The current (2012) version of the permit is set to expire on May 31, 2017, and this revision will replace it. Most facilities with industrial activities exposed to stormwater are required to have a permit to allow the stormwater to discharge. Some facilities have individual permits, but the majority of industrial facilities are able to obtain coverage under this General Permit, which establishes requirements that are applicable to all covered facilities. Continue reading “Georgia Issues Draft Industrial Stormwater Permit”
On July 29, 2016, the U.S. Court of Appeals for the D.C. Circuit ruled on the lawsuits over EPA’s Boiler MACT (40 CFR Part 63, Subpart DDDDD) and Boiler GACT (40 CFR Part 63, Subpart JJJJJJ) regulations. The lawsuit was the consolidation of multiple suits from industry and environmental groups. The split of the suits from industry versus environmental groups was stated by the court to be approximately 50/50. In summary, the court rejected all the industry petitions and granted some of the petitions from environmental groups. The most significant aspects of this ruling pertain to vacating portions of the standard and remanding additional portions of the standard to EPA to provide further explanation.
Under the Boiler MACT regulation, boilers are divided into subcategories based on the type of fuel utilized and the configuration of the combustion unit. Continue reading “Court Rules on Lawsuit over EPA’s Boiler MACT Regulation”
The Occupational Safety and Health Administration (OSHA) has issued a final rule to protect workers from exposure to respirable crystalline silica. The rule is comprised of two standards, one for Construction (1926.1153) and one for General Industry (1910.1053). Before going into the details of the final rules, here is a review of what crystalline silica is and why a new rule governing exposure to it is being pushed out. Continue reading “OSHA Releases Final Rule on Silica Exposure Requirements”
