Plywood and Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP)
               Residual Risk and Technology Review (RTR) Survey

                                Instructions:
                   Mill Overview and Subpart DDDD 2015 Data

This survey instruction document provides instructions for completing of the PCWP Information Collection Request (ICR) survey.  This instruction document is organized as follows:
Table of Contents
A.	Introduction	2
B.	Confidential Business Information (CBI)	4
C.	How to Submit Your Survey Response	4
C1. 	Submitting Your Non-CBI Response	5
C2. 	Submitting Claimed CBI	5
D.	How to Complete the Survey	6
D1. 	Flow Diagrams	8
D2. 	Facility Emission Point Map	9
D3. 	Process Data Tabs (PCWP_survey.xlsx)	10
a. 	Mill tab	12
b. 	Product (Prod) tab	14
c. 	Equipment Detail (EquipDetail) tab	15
d. 	Release Point Detail (ReleasePt) tab	18
e. 	Permit Limits (Permit) tab	22
f. 	Resin and Tanks (Resin and Tank) tabs	23
g. 	Dryer (VeneerDry, RotaryDry, TubeDry, ConvDry, LKiln, and DFDryFuel) tabs	23
h. 	Press and Board Cooler (Press, BC, and EWPPress) tabs	24
i. 	Fiberboard and Hardboard Equipment (FB-HB) tab	24
j.  	Other Equipment (OtherEquip) tab	24
k.  	Control Devices (APCD) tab	25
l. 	Startup, Shutdown, Malfunction (SSM) tab	26
m. 	Miscellaneous Coatings (MiscCoat) tab	27
n. 	Wastewater (WW) tab	27
D4. 	Emissions Estimates, Emissions Testing, and Monitoring Data	27
a. 	Emissions Tests (EmTest) tab	28
b. 	CEMS and COMS data (PCWP_CEMS_COMS.xlsx)	29
c. 	Emissions Estimates (Primary HAP Emissions and Other HAP Emissions) tabs	30
d. 	Parameter Monitoring Data	31
Appendix 1. Documentation of True Area Source, Non-Operational, or Non-Applicable Status	33
Appendix 2. Emission Units to Include in the PCWP Survey Response	34
Appendix 3. Previous Emissions Test Data Requested	35
Appendix 4. Acronyms and Abbreviations	38
Appendix 5. Signed Certification Form	41
Appendix 6. Checklist of Materials to Submit with Your Survey Response	42
Appendix 7. Plywood and Composite Wood Products NESHAP Definitions	44
Appendix 8. Industry Source Classification Codes	54
Appendix 9. List of Hazardous Air Pollutants	64
Appendix 10. Resources for Estimating Emissions	66

A.	Introduction

The Plywood and Composite Wood Products (PCWP) industry information collection request (ICR) applies to facilities that are major sources or synthetic area sources of hazardous air pollutant (HAP) emissions. Facilities that must respond to this ICR are those that:
 manufacture plywood or veneer (softwood, or hardwood), or
 manufacture composite wood or agricultural panels [wood and non-wood particleboard, medium density fiberboard (MDF), fiberboard, hardboard, and/or oriented strand board (OSB)], or
 manufacture engineered wood products [such as laminated veneer lumber (LVL), laminated strand lumber (LSL), wood I-joists, and/or glue-laminated beams] or
 operate a lumber kiln (softwood or hardwood lumber), or
 are otherwise subject to 40 CFR Part 63 Subpart DDDD.

As defined in 40 CFR Part 63, subpart A,
       "Major source" means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this sentence.

A "synthetic area source" is a stationary source which is subject to federally-enforceable conditions that limit its potential to emit to below major source thresholds.

This survey is limited to sources that are major or synthetic area sources due to operations regulated under PCWP MACT (Subpart DDDD).

Certain facilities are not required to complete the PCWP ICR survey. You received this survey because EPA records indicate Subpart DDDD is applicable to your facility. If your mill meets one of the following conditions, then you should complete the exemption form titled "Documentation of True Area Source, Non-Operational, or Non-Applicable Status" in Appendix 1 of this instruction document and email it to John Bradfield at EPA (contact information is provided on the form). You are required to complete this ICR survey unless you meet one of the three exemption criteria listed below. Conditions for exemption from all parts of the PCWP ICR survey are as follows:
 Your facility is not a major source or synthetic area source of HAP emissions, or
 Your facility was not operational in 2015, remains closed, and does not have an active operating permit, or
 Your facility is not a PCWP manufacturing facility as defined in 40 CFR Part 63 Subpart DDDD.

This survey is to be completed in Microsoft Excel[(C)] spreadsheet format that is divided into worksheets or "tabs" within the spreadsheet. There are two spreadsheets to be completed: PCWP_survey.xlsx and PCWP_CEMS_COMS.xlsx. We are also requesting that you provide Continuous Parameter Monitoring System (CPMS) data for certain sources (see section D4.d). You may provide the requested CPMS data in the electronic format of your choice, depending on how the data are stored at your facility. Whenever possible, the EPA prefers to receive an Excel[(R)] spreadsheet with the requested data. You must complete the worksheet tabs that are relevant to the type of facility you operate. Table 1 below denotes which survey spreadsheet tabs to complete depending on facility type. Not all worksheets will be required for all facility types.

             Table 1.   Survey Worksheets ("tabs") to Complete
Spreadsheet tab full name
Spreadsheet tab abbreviation used
Types of facilities that will complete this spreadsheet tab
PCWP_survey.xlsx

Mill
Mill
All facilities
Products
Prod
All facilities
Equipment Detail
EquipDetail
All facilities
Release Point Detail
ReleasePt
All facilities
Permit
Permit
All facilities
Resins
Resin
All PCWP facilities applying adhesive. Veneer and lumber mills may not need to complete this tab.
Tanks
Tank
All PCWP facilities applying resin. Veneer and lumber mills may not need to complete this tab.
Veneer Dryer
VeneerDry
Plywood, veneer and LVL mills
Rotary Dryer
RotaryDry
Particleboard, OSB and any other PCWP facility using a rotary dryer
Tube Dryer
TubeDry
MDF, hardboard and any other PCWP facility using a tube dryer
Conveyor Dryer
ConDry
OSB, LSL, and any other PCWP facility using a conveyor dryer
Fiberboard-Hardboard Equipment
FB-HB
Fiberboard and hardboard mills
Direct Fired Dryer Fuel
DFDryFuel
Any PCWP facility with a direct-fired dryer
Press
Press
Any PCWP facility that uses a hot press
Board Coolers
BC
Particleboard, MDF and any other PCWP facility using a board cooler
Engineered Wood Press
EWPPress
LVL, LSL, PSL, glulam, I-joist or any other PCWP facility using an engineered wood press
Lumber Kilns
LKiln
Lumber mills and any other PCWP facility with a lumber kiln
Other Equipment
OtherEquip
PCWP facilities with digesters, refiners, blenders, formers, sanders, saws (not at lumber mills), chippers, flakers or log vats
Control Devices
APCD
Any PCWP facility with pollution control equipment
Startup, Shutdown & Malfunction
SSM
Any PCWP facility for which an SSM plan was developed
Miscellaneous Coatings
MiscCoat
All PCWP facilities applying a coating, including miscellaneous coating as defined in Subpart DDDD
Wastewater
WW
Any PCWP facility that treats wastewater generated at the plant
Emission Tests
EmTest
All facilities
Emissions
Primary HAP Emissions, Other HAP Emissions
All facilities
PCWP_CEMS_COMS.xlsx

CEMS data
CEMS, CEMS3hr, or CEMS24hr
Facilities operating CEMS measuring THC, PM, CO or HAP on emission units listed in Appendix 2 to this document
COMS data
COMS
Facilities operating COMS on emission units listed in Appendix 2 to this document

Please complete the survey for the facility listed in the CAA Section 114 letter you received in the mail. If you received more than one CAA Section 114 letter for multiple facilities in your company, you must create a separate survey response for each facility, with one exception:  If your manufacturing site has more than one PCWP category facility (e.g., your site produces both particleboard and softwood plywood) you would return one survey spreadsheet response containing both facilities. Blank copies of the survey spreadsheet can be downloaded from:  (WEB SITE TO BE DEVELOPED)

Use the 2015 calendar year as the base year for all survey responses (e.g., 2015 emissions inventory, 2015 capacity, 2015 equipment configurations, etc.), unless another year is specified in the instructions (e.g., for emissions test data).

This survey asks questions about the emission units listed in Appendix 2 of this document. Section D of this document, How to Complete the Survey, explains how to treat various configurations of emission units (e.g., multiple emission units venting to the same pollution control device stack, etc.).

Appendix 3 of this survey contains a table of pollutants for which existing data from previously conducted emissions test measurements are requested. Appendix 4 provides a list of acronyms and abbreviations used throughout this instruction document and the survey spreadsheets.

Note that the information submitted by a facility is not intended for a compliance assessment. If actual data are not available, the facility should provide the best engineering estimates where appropriate. In addition, it is not the intent of the EPA to use this data to confirm data/information submitted in the facility's Toxic Release Inventory (TRI) or other regulatory required reports. It is understood that data submitted in this survey could vary due to the nature of the questions.

B.	Confidential Business Information (CBI)

The EPA's procedures for handling confidential business information (CBI) are described in the letter (and attachments) accompanying the ICR. If you believe that providing any specific information to us would reveal a trade secret, please identify this information clearly in your spreadsheet response by shading the spreadsheet cell containing the CBI with red highlight and indicating in the red block at the top of each worksheet that the tab contains information you believe is CBI. (You will find the red highlighting and red CBI block at the top of the worksheet helpful when you separate your claimed CBI data from non-CBI data for submittal as indicated in section C2 below). Also, please clearly label any flow diagrams or other attachments submitted with your survey that contain claimed CBI. However, please do not label your entire response as CBI. Only label portions of your survey response that include information you believe contains trade secrets. The EPA is likely to follow up with a request for validation of CBI claims for facilities claiming large amounts of information as trade secrets, especially information that is readily reported by other facilities without such claims or that is otherwise publicly available. The following information is generally not regarded by the EPA as CBI:

 General contact information. On the attached spreadsheets this information is in the Mill worksheet of the PCWP_survey.xls file.
 Emission tests and emission data.
 Continuous monitoring (CEMS and COMS) data.

C.	How to Submit Your Survey Response

If your response to this information collection request includes data with a claim of CBI, you should follow the instructions in this section to ensure the protection of your data. Please note that if you submit claimed CBI, you will be separating your data into two portions and sending your data to EPA using two different mailing addresses.

C1. 	Submitting Your Non-CBI Response

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely non-CBI.)

After you have completed and reviewed your survey response, sign and date the certification form in Appendix 5 of this instruction document. Remove the claimed CBI components from your survey as instructed in section C2, leaving only the red shading and replacing the claimed CBI data with the letters "CBI". Save the Excel[(R)] spreadsheet(s) containing the non-CBI portions of your completed response, non-CBI flow diagrams, emission test reports, and any other electronic non-CBI attachments on a disk (CD or DVD) or flash drive. Assemble any non-CBI hard copy attachments to your survey (such as the signed certification form, flow diagrams, test data, air emissions modeling reports, etc.). Electronic copies of attachments are preferred in lieu of hard copies. A checklist of materials to be provided with your response is included in Appendix 6. Please clearly label and mail the non-CBI disk (or flash drive) and any non-CBI hard copy materials in one envelope to the EPA at the address specified below by LIST RESPONSE DEADLINE DATE HERE.  (Note:  If the spreadsheet/diagrams/attachments contain claimed CBI, use the address for Ms. Purifoy provided in section C2 of this document.)

      U.S. Environmental Protection Agency
		Office of Air Quality Planning and Standards
            U.S. EPA Mailroom (E143-03)
            Attn: John Bradfield
      109 TW Alexander Drive
		Research Triangle Park, NC 27711

The EPA recommends sending your non-CBI files via Registered U.S. Mail with a return receipt requested, Federal Express, or any other method for which a receipt signature is required.

C2. 	Submitting Claimed CBI

Follow these instructions for any portion of your survey response that contains claimed CBI.

Please create and label a separate flash drive or disk containing a version of your spreadsheet response with only the claimed CBI portion of your data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any flow diagrams or pages of other attachments to your survey response containing claimed CBI, with the claimed CBI portions of the diagrams/pages clearly marked (e.g., highlighted or circled). Clearly mark the disk with the words "Confidential Business Information." Send only these claimed CBI files under separate cover to:

      U.S. Environmental Protection Agency
      Office of Air Quality Planning and Standards
      U.S. EPA Mailroom (C404-02)
      Attn:  Ms. Tiffany Purifoy, Document Control Officer
      109 T.W. Alexander Drive
      Research Triangle Park, NC 27711

For the security of your data, the EPA recommends sending your confidential files to Ms. Purifoy via Registered U.S. Mail with a return receipt requested, Federal Express, or any other method for which a receipt signature is required.

DO NOT ELECTRONICALLY TRANSMIT CLAIMED CONFIDENTIAL BUSINESS INFORMATION TO THE EPA. E-mail and facsimile are not secure forms of communication and should never be used to transmit claimed CBI.

D.	How to Complete the Survey

Your survey response will consist of completed Microsoft[(C)] Excel[(R)] spreadsheets (PCWP_survey.xlsx and PCWP_CEMS_COMS.xlsx), flow diagrams, test reports, and other materials. A checklist of materials to be provided with your response is included in Appendix 6. You must complete certain tabs of the PCWP_survey.xls spreadsheet file (depending on the type of facility you operate) as shown in Table 1 above. Complete the PCWP_CEMS_COMS.xlsx spreadsheet if you have continuous emissions or continuous opacity monitoring data to submit.

Enter data into the white (unshaded) cells of the spreadsheets. The spreadsheet contains pull-down menu choices that function best in Excel[(R)] version 2010 or higher. Gray shaded areas are prepopulated based on inputs from previous worksheets. Please do not enter data into the blue shaded area of the spreadsheet, in the orange-colored column headings, or in the hidden rows or columns surrounding the questionnaire area. Figure 1 provides a screen shot with annotations.

What if I do not have Excel[(R)] 2010 or higher?

   Users without a recent version of Microsoft Excel (2010 or later), including those on Mac or Linux computers may want to use LibreOffice (http://www.libreoffice.org) to open the ICR Workbook. LibreOffice is open source and available without cost. Detailed installation instructions are available at https://www.libreoffice.org/get-help/install-howto/.

   Once the LibreOffice suite has been installed, you may use LibreOffice Calc to open the ICR workbook. If you choose to use LibreOffice Calc, please keep the ICR spreadsheet in Excel format (xlsx) when saving your changes (i.e., do not change to LibreOffice format if prompted during the save).
What if I do not have Excel[(R)] 2010 or higher?

   Users without a recent version of Microsoft Excel (2010 or later), including those on Mac or Linux computers may want to use LibreOffice (http://www.libreoffice.org) to open the ICR Workbook. LibreOffice is open source and available without cost. Detailed installation instructions are available at https://www.libreoffice.org/get-help/install-howto/.

   Once the LibreOffice suite has been installed, you may use LibreOffice Calc to open the ICR workbook. If you choose to use LibreOffice Calc, please keep the ICR spreadsheet in Excel format (xlsx) when saving your changes (i.e., do not change to LibreOffice format if prompted during the save).

                          Instructions and examples
                              Pre-populated data
                               Drop down menus
                          User manually entered data

                    Figure 1: Screenshot of survey shading
D1. 	Flow Diagrams

Please provide a process flow diagram (or diagrams) showing the equipment listed in Appendix 2.

Readily available block flow diagrams (e.g., such as those used for permit applications) will suffice. Electronic or hard copies are acceptable. You need not prepare any new flow diagrams unless you currently do not have diagrams that adequately represent your facility. It is acceptable to hand-mark changes on an older diagram that may no longer be completely reflective of current operations.

How detailed must my diagram(s) be?
   The EPA will use the diagram(s) to aid in understanding the general facility flow and any unique characteristics in the facility layout. It is not necessary to show every single vent of every emission unit on the diagrams. However, the diagram should provide enough information so it is clear how emissions are collected and controlled.
How detailed must my diagram(s) be?
   The EPA will use the diagram(s) to aid in understanding the general facility flow and any unique characteristics in the facility layout. It is not necessary to show every single vent of every emission unit on the diagrams. However, the diagram should provide enough information so it is clear how emissions are collected and controlled.

D2. 	Facility Emission Point Map

The EPA is requesting that each facility provide a facility emission point map. This map should be an aerial view of the facility with emission points clearly indicated. This map can be obtained from Google Maps or other mapping software. Please indicate the Emission Release Point IDs used elsewhere in your survey response for each emission point. See Figure 2 below as an example. The numbers shown in Figure 2 reflect Emission Release Point IDs. The red lines denote large fugitive emission sources, and the stars reflect the location of the southwest corner of each fugitive source area.

Coordinates (longitude and latitude) for the Emission Release Point IDs are required to be provided in the survey response in the Release Point (ReleasePt) tab described below. These coordinates are used for residual risk modeling. Creating the facility emission point map will ensure that the coordinates provided are on the facility property. Specifying coordinates for each Emission Release Point ID improves the accuracy of the risk modeling.

                 Figure 2: Example facility emission point map

D3. 	Process Data Tabs (PCWP_survey.xlsx)

In this portion of the survey, you are asked to add data to the various tabs in the PCWP_survey.xlsx spreadsheet (Mill, Prod, etc). Many of the instructions you need for completing the survey tabs are included in the "Instruction" row of each tab in the PCWP_survey.xlsx spreadsheet. However, additional information is provided below to account for common situations and to provide information on how the data will be used by the EPA.

Each survey tab includes fields with pull-down menus for common entries. Use these pull-down menus whenever possible. The pull-down menus are indicated by the triangle that appears next to the cell when clicked. Some columns with pull-down menus allow you to write in information if your selection is not contained in the pull-down menu, while others require use of the pull-down menu choices. Selections appearing as "Other: {specify}" indicate that you should write in a site-specific response in place of the word {specify} (e.g., your response may be "Other: use a unique low-emitting material"). Many survey tabs contain pre-populated data from other tabs. A few columns of data that you supply appear in bold to indicate that these columns contain data that will be used to prepopulate other tabs of the ICR.

A "comments" column is included to the right of each spreadsheet should you wish to supply any comments on the information provided. Please use the "comments" column for any notes, and please do not enter in-cell pop-up comments because the in-cell comments will not transfer into the EPA's data base designed to house the PCWP survey information.

In addition to the pull-down menus, other data validation criteria are included in many of the spreadsheet cells. For example, many cells require entry of 255 characters or less to ensure there are no truncation issues when the data are imported into a data base by EPA at a later date. If you receive an error message for responses exceeding 255 characters, use the comments column to continue your response. Cells with production rate units such as (MSF/yr) will also provide a warning if values lower than expected are entered to help prevent facilities from entering million square feet when the required units are thousand square feet.

Several IDs are requested throughout the PCWP survey response spreadsheet(s), including:
 FRS Site ID (Federal Registry Service)
 Emission Unit ID
 Emission Release Point ID
 APCD_ID (Air Pollution Control Device)

The FRS Site ID is used to identify your facility. The FRS Site ID may be found at: https://www.epa.gov/enviro/frs-query-page. If no FRS Site ID already exists, you will need to create a Site ID for purposes of the PCWP ICR. Use "NEW_____" for the Site ID and enter your facility's zip code where the blank is. Generally, your zip code will provide a unique identifier for your facility for purposes of this ICR.

The Emission Unit IDs, Emission Release Point IDs, and APCD_IDs are identifiers for each emission unit (e.g., dryer), emission release point (e.g., dryer stack), and air pollution control device (APCD) (e.g., a wet scrubber). One option for creating these IDs is to use any IDs already used in your permit.

A number of PCWP facilities may have some emissions estimates in the most recent version of EPA's National Emission Inventory (NEI). The EPA is requesting more recent emission estimates in this ICR, specifically for HAP. This ICR has been designed to facilitate compilation of a nationwide PCWP emissions inventory designed specifically for the residual risk modeling required by the Clean Air Act. However, NEI data are available at [WEB SITE TO BE DEVELOPED] if you would like to review, update, and use the information available for your facility. If HAP data are included in the NEI for your facility, the NEI data base may provide Emission Unit IDs, Emission Release Point IDs, and other information that you may wish to use as a starting point as you complete your PCWP ICR response. You are not required to use the NEI data for your facility.

A Note About Identification Numbers (IDs)

   The different parts of the PCWP survey include the following IDs:
 FRS Site ID
 Emission Unit ID
 Emission Release Point ID
 APCD ID

   It is imperative that you use the same IDs to describe the same facility, equipment/emission unit, and emission release point throughout all parts of this survey. These ID codes will be used to link the various PCWP data base tables together into a functional and informative data base to be used for nationwide regulatory analyses. If you wish to avoid follow-up calls regarding your survey data, please make every effort to ensure that your IDs match throughout the spreadsheet(s) and in each part of your survey response.  For example, any Emission Unit ID or APCD ID you create/specify in one tab should also be used when referring to the same piece of equipment in other tabs of the survey response.

   Also, please be sure that no extra spaces or characters are included in the ID cells.  For example, Emission Unit ID "DRY1" is not read by data base software the same as "DRY-1" or "DRY-1_".
A Note About Identification Numbers (IDs)

   The different parts of the PCWP survey include the following IDs:
 FRS Site ID
 Emission Unit ID
 Emission Release Point ID
 APCD ID

   It is imperative that you use the same IDs to describe the same facility, equipment/emission unit, and emission release point throughout all parts of this survey. These ID codes will be used to link the various PCWP data base tables together into a functional and informative data base to be used for nationwide regulatory analyses. If you wish to avoid follow-up calls regarding your survey data, please make every effort to ensure that your IDs match throughout the spreadsheet(s) and in each part of your survey response.  For example, any Emission Unit ID or APCD ID you create/specify in one tab should also be used when referring to the same piece of equipment in other tabs of the survey response.

   Also, please be sure that no extra spaces or characters are included in the ID cells.  For example, Emission Unit ID "DRY1" is not read by data base software the same as "DRY-1" or "DRY-1_".

Follow the instructions below and in the "Instruction" rows of the spreadsheet to complete the survey tabs. Refer to Table 1 of this document to determine which tabs you must complete depending on the type of facility you operate.

In several parts of the survey, the agency requests "nominal daily throughput capacity." These values are typical operating rates for the process or emission unit and can be used by the agency to compare the relative size of the unit. Use the press line nominal capacity (throughput) for all equipment in the press line. Each segment specific process data sheet is set up to use the traditional production line reference bases: Particleboard/MDF at (3/4)-inch thickness; plywood/OSB at 3/8-inch thickness; etc. Dryer throughput is requested in oven dried tons per hour (ODT/hr) and lumber dry kiln throughput in thousand board feet per hour (MBF/hr). The EPA is interested in capacity values that would be used for estimating emissions (for example, values used in your permit application). We are not interested in maximum capacity values for each piece of equipment outside of the constraints of the production process within which it is located.

What if I do not know or have the information to answer a survey question?

   There may be survey questions that you do not know the answer to, or for which information is not readily available. The following codes may be used:

      Blanks: You may also leave obviously inapplicable questions blank.

      Unknown (UK): If you do not have the requested information, cannot obtain the information without extraordinary effort, and cannot provide a reasonable estimate, then you may enter "UK" for unknown.

      Not Applicable (NA): If a question is not applicable to your operations, then you may enter "NA" for not applicable.

   Survey respondents are reminded that their certification of the accuracy of their response includes a certification that any identification of information as "unknown" or "not applicable" is accurate. Further, survey respondents providing an excessive number of responses as "UK," "NA" or blank are likely to receive scrutiny and follow-up inquiries from the EPA related to their survey response.
What if I do not know or have the information to answer a survey question?

   There may be survey questions that you do not know the answer to, or for which information is not readily available. The following codes may be used:

      Blanks: You may also leave obviously inapplicable questions blank.

      Unknown (UK): If you do not have the requested information, cannot obtain the information without extraordinary effort, and cannot provide a reasonable estimate, then you may enter "UK" for unknown.

      Not Applicable (NA): If a question is not applicable to your operations, then you may enter "NA" for not applicable.

   Survey respondents are reminded that their certification of the accuracy of their response includes a certification that any identification of information as "unknown" or "not applicable" is accurate. Further, survey respondents providing an excessive number of responses as "UK," "NA" or blank are likely to receive scrutiny and follow-up inquiries from the EPA related to their survey response.

Refer to Table 1 above to determine which of the PCWP Process tabs you will need to fill out for your facility. The tabs are organized by PCWP segment specific process units.  If your facility does not operate a process covered by the tab, ignore that tab.

What averaging period should be used in responding to process detail questions?

   Several questions in the Process tabs ask for process parameters such as exhaust flow rate (ACFM), temperature, etc.  Unless otherwise specified, typical values are requested, and are subject to the respondent's discretion.  For example, if you measure a particular parameter with an online meter and you have data available for most operating hours of the year, then you may choose to supply an annual average for the parameter.  However, if the parameter is only measured periodically, then you may want to provide the most recent measurement.

What averaging period should be used in responding to process detail questions?

   Several questions in the Process tabs ask for process parameters such as exhaust flow rate (ACFM), temperature, etc.  Unless otherwise specified, typical values are requested, and are subject to the respondent's discretion.  For example, if you measure a particular parameter with an online meter and you have data available for most operating hours of the year, then you may choose to supply an annual average for the parameter.  However, if the parameter is only measured periodically, then you may want to provide the most recent measurement.

a. 	Mill tab

Complete the columns following the instructions provided in the "Instruction" row. Your response in the Mill tab will most likely consist of one row of data, unless there is more than one FRS facility located at the same site. These data will be used by the EPA to characterize your facility and identify applicable regulations.

      Facility identifiers. The EPA is requesting multiple facility identifiers for facilities in order to collect data from additional sources, if needed. These identifiers include IDs from the NEI, AFS, CEDRI, EIS, and TRI. Provide these identifiers, if they have previously been assigned to your facility. See the box below for instructions on locating IDs.
      Where can I find the FRS, EIS, TRI, CEDRI and AFS IDs?

 Open your internet browser and navigate to https://www.epa.gov/enviro/frs-query-page
 Search for your facility using either one or a combination of the available search methods. The search methods include: Facility name, Geography search, Tribal Search, SIC or NAICS code search, and Affiliated Organization and Contact search.
 At the bottom of the page, under "National Systems Search", select the "Selected National Systems from the list below" button. Click the checkboxes for the following databases:
 EIS (Emission Inventory System)
 TRI (Toxics Release Inventory)
 EIA-860 (Energy Information Administration-860 Database
 AIRS/AFS (AIRS Facility Subsystem" databases.
 Press the "Search" Button at the bottom of the page
 Find your facility in the results page. If you do not see your facility, please adjust your search parameters and try again. Select you facility by clicking your facility name.
 On your FRS Facility Detail Report, you should see the name of your facility at the top along with your EPA Registry ID and the address of your facility.
 The EPA Registry ID at the top of the report contains your FRS ID AND your CEDRI ID, if one has been assigned. Please record the EPA Registry ID in the FRS ID column AND in the CEDRI ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the AFS database, the Air Facility System database. In the "Information System ID/Report Link" column, you will find the AFS ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.  Please record your AFS ID in the AFS ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the EIS database, the Emission Inventory System database. In the "Information System ID/Report Link, you will find your EIS ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.   Please record the EIS ID in the EIS ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the TRI database, the Toxic Release Inventory System database. In the "Information System ID/Report Link, you will find your TRI ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.   Please record the TRI ID in the TRI ID column in the ICR Survey.
 If you do not see your TRI ID in the FRS report. Navigate to https://www.epa.gov/enviro/tri-search
 Search for your facility using either one or a combination of the available search methods. Click the search button at the bottom of the page.
   Find your facility in the results page. If you do not see your facility in the results page, please adjust your search parameters and try again. The TRI Facility ID is located to the left of the Facility name, in the column labeled "TRI Facility ID". Please record the TRI ID in the TRI ID column in the ICR Survey.
Where can I find the FRS, EIS, TRI, CEDRI and AFS IDs?

 Open your internet browser and navigate to https://www.epa.gov/enviro/frs-query-page
 Search for your facility using either one or a combination of the available search methods. The search methods include: Facility name, Geography search, Tribal Search, SIC or NAICS code search, and Affiliated Organization and Contact search.
 At the bottom of the page, under "National Systems Search", select the "Selected National Systems from the list below" button. Click the checkboxes for the following databases:
 EIS (Emission Inventory System)
 TRI (Toxics Release Inventory)
 EIA-860 (Energy Information Administration-860 Database
 AIRS/AFS (AIRS Facility Subsystem" databases.
 Press the "Search" Button at the bottom of the page
 Find your facility in the results page. If you do not see your facility, please adjust your search parameters and try again. Select you facility by clicking your facility name.
 On your FRS Facility Detail Report, you should see the name of your facility at the top along with your EPA Registry ID and the address of your facility.
 The EPA Registry ID at the top of the report contains your FRS ID AND your CEDRI ID, if one has been assigned. Please record the EPA Registry ID in the FRS ID column AND in the CEDRI ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the AFS database, the Air Facility System database. In the "Information System ID/Report Link" column, you will find the AFS ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.  Please record your AFS ID in the AFS ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the EIS database, the Emission Inventory System database. In the "Information System ID/Report Link, you will find your EIS ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.   Please record the EIS ID in the EIS ID column in the ICR Survey.
 In the "Environmental Interests" table, look for the TRI database, the Toxic Release Inventory System database. In the "Information System ID/Report Link, you will find your TRI ID, if one has been assigned. Leave the cell blank if an ID has not been assigned.   Please record the TRI ID in the TRI ID column in the ICR Survey.
 If you do not see your TRI ID in the FRS report. Navigate to https://www.epa.gov/enviro/tri-search
 Search for your facility using either one or a combination of the available search methods. Click the search button at the bottom of the page.
   Find your facility in the results page. If you do not see your facility in the results page, please adjust your search parameters and try again. The TRI Facility ID is located to the left of the Facility name, in the column labeled "TRI Facility ID". Please record the TRI ID in the TRI ID column in the ICR Survey.

      Size of entity. The EPA needs to identify small businesses in its survey. The U.S. Small Business Administration has set the threshold for the definition of a small businesses in the wood products industry based on the number of employees shown in Table 2 below. The threshold metric applies to all full or part time employees in a corporation, not just at a location. Please use the thresholds in Table 2 for small business questions in the PCWP survey. For reference, the Small Business Size Regulations codified at 12 CFR 121.06.

           Table 2. Small Business Size Standards for NAICS Subsector 321
                            -  Wood Product Manufacturing
NAICS
Codes

NAICS U.S. industry title

                                     Size
                                 standards in
                                   number of
                                   employees
321113
Sawmills
                                      500
321211
Hardwood Veneer and Plywood Manufacturing
                                      500
321212
Softwood Veneer and Plywood Manufacturing
                                     1,250
321213
Engineered Wood Member (except Truss) Manufacturing
                                      750
321219
Reconstituted Wood Product Manufacturing
                                      750
321999
All Other Miscellaneous Wood Product Manufacturing
                                      500
      Source:  U. S. Small Business Administration Table of Small Business Size Standards Matched to North American Industry Classification System Codes, 2016. Accessed March 28, 2016 at: https://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf.

      Facility Location, Contact and Owner Information.  Enter the location, a facility contact for facility-specific follow up, and the facility owner.  Note that the zip code will automatically fill in city, state and EPA region address information.  Respondents can over-ride the automatic entry if errors are noted.  Select from the tribal name drop down to get the tribal code.  If physical and mailing address are identical, answering `yes' in the 1[st] mailing address column will provide an automatic fill in.

      Federal rule coverage. Identify the Federal rules that are applicable to the facility. If the rule is not applicable because the facility has a permit condition that makes the facility a synthetic area or minor source, choose that answer. The major rules applicable to industry sources are listed. List other NESHAP/NSPS rules that are applicable.

b. 	Product (Prod) tab

Enter information about PCWP products produced, product lines, and capacity utilization in this tab. There are a series of questions about PCWP processes  -  lumber drying, plywood/veneer production, OSB, MDF, particleboard, hardboard, fiberboard, LVL, PSL, LSL, glu-lam and I-joists. Identify whether you produce the product then provide the nominal production capacity and the average production at your facility for the survey base year (2015). Wood products industries are cyclical and business cycles impact cost estimates. To help the EPA develop better regulatory cost impact data we are asking you to estimate 5-year average production capacity utilization over the period from 2011 to 2015. Provide a percentage number (i.e. `80' for 80%). It should be noted that the owner may not have production data back to 2011 if the facility was purchased after January 1, 2011. If this is the case, the facility should average the years that are available and note as such in the "comments" column.

      Product lines. Product lines often correspond with press lines. For example, if there are two presses at a mill making two different products, then you would enter two different product lines on separate rows. However, if a mill with multiple presses makes the same product on all presses (i.e., with the same resin formulation) then it is acceptable to enter only one product line that sums the capacity/production from all presses. However, if you include more than one press in a product line, note the number of press included in the comment section.  If your facility uses multiple significantly different resin systems to make the same product on the same press (e.g., UF and UF/MDI at different times), a separate Product Line should be specified on two rows for the two significantly different resin systems. For the purpose of this ICR, different resin systems are defined as separate product lines.

      When considering which product lines and resin systems to specify, resins applied more than 5% of the time on a product line are of interest. Exclude temporary mill trials of different resin formulations.

      Production and capacity units of measure. Use the following units of measure for reporting production and capacity:

                  Table 3. Production and Capacity Units of Measure
Product
Units of measure for reporting production and capacity
Veneer
                                    MSF/yr
Lumber
                                    MBF/yr
Fiberboard
                                 MSF/yr 1/2"
Hardboard
                                 MSF/yr 1/8"
Particleboard, MDF
                                 MSF/yr 3/4"
Hardwood & Softwood plywood, OSB, and any other plywood panel products
                                 MSF/yr 3/8"
LVL, LSL, and PSL
                                    Mft3/yr
I-joists
                                    MLF/yr
      "M" refers to thousand (e.g., MSF = thousand square feet)

      Agricultural fiber. The use of agricultural fiber at PCWP facilities is important for PCWP and other current and potential federal requirements. Identify whether these processes are integrated into operations and estimate the degree. For example, enter "wheat straw, 80%" to indicate that 80% (by weight) of furnish in the product is wheat straw.

c. 	Equipment Detail (EquipDetail) tab

All facilities are asked to complete the EquipDetail tab. This tab asks for information for each individual emission unit, its air pollution control device (APCD), and emission release points. The purpose of this tab is to provide the EPA with equipment-specific details needed for the Agency to review the technology-based standards (i.e., nationwide numbers of equipment, configuration of controls, pertinent equipment details, and regulatory compliance options used). This tab also includes certain yes/no questions to assist in prepopulating information in other relevant tabs.

The types of emission units listed in Appendix 2 that you operate should be included in the EquipDetail tab. Appendix 7 provides definitions from the PCWP rule, including supplemental definitions. These definitions are helpful for understanding the types of emissions units. Essentially, you are requested to provide information for most of the equipment at your mill.

Specify the Emission Unit ID, product, product line, APCD type and IDs, and Emission Release Point IDs by following the directions in the Instruction row of the spreadsheet.

The following APCD type codes are included in the selection menu in the EquipDetail and APCD tabs:
APCD Type Code
None
RTO - Regenerative Thermal Oxidizer
RCO - Regenerative Catalytic Oxidizer
TCO - Thermal Catalytic Oxidizer
TO - Thermal Oxidizer
PINC - Process incineration (incineration of 100% of the exhaust in a combustion unit such as a boiler): {describe combustion unit}
SINC - Partial process incineration (incineration of a portion of the exhaust in a combustion unit): {describe combustion unit}
BIO - Biofilter
WESP - Wet Electrostatic Precipitator
ESP - Dry ESP
BH - Baghouse
MC - Multiclone
CYC - Cyclone
RBP - Rotary bed protector
SCBR - Wet scrubber
EFB - Electrified filter bed
SF - Sand filter
Other: {specify}

Some common emission unit, control, and release point configurations are addressed below:

      Multiple emission units ducted to a single release point. You should list each emission unit separately in the EquipDetail tab even if the exhaust from the emission unit is ducted to a common release point. For multiple emission units ducted to the same release point, list each Emission Unit ID (and corresponding APCD ID) separately but enter the same Emission Release Point ID.

      Single emission unit with multiple release points. If the emission unit has different release points (e.g., multiple uncontrolled vents or stacks) then you would list the emission unit once, specify the release point APCD ("None" for this example with uncontrolled stacks), specify the number of release points, and provide the release point IDs in columns Q through V.

      If a single emission unit has multiple release points with different controls then a separate row will be needed for release points that are controlled differently. A veneer dryer where the heated sections are controlled and the cooling sections vent to the atmosphere would be an example of such a unit. The controlled and uncontrolled would be listed separately for such a unit.

      Emission units that are not vented. Include emissions units that are not vented in the EquipDetail tab. Do not enter an emission release point ID. Select "Not Vented" from the menu in the "Emission Routing and Control Configuration" column.

      Emission units vented into the building. Include emissions units that vent into a building in the tab, and enter "BLDG" in the Emission Release Point ID column. Select "Vented into building (fugitive source)" from the menu in the "Emission Routing and Control Configuration" column.*

      Emission units with fugitive emissions. Include emissions units with fugitive emissions in the EquipDetail tab, and include an ID in the Emission Release Point ID column. If an emission unit produces both fugitive emissions and emissions that are emitted though a conveyance, then you need to specify the fugitive emissions in a separate "Emission Release Point ID" column (e.g., as a "Single emission unit with multiple release points" as described above.*

            *Note that the predominant venting mechanism is to be described. Incidental fugitives or small amounts of dust escaping from equipment in the building such as sanders, saws, or blender transfer points is not of interest when the emission unit has a collection system designed to be the primary and predominant means of collecting and ventilating the emission unit. Units labeled "BLDG" or as fugitive sources are those with no primary means of collecting and ventilating the emission unit.  For example, if there is some incidental fugitive emissions within the building as a result of blended material being transferred, but the blender also has a dust collection system, you only need to list the dust collection system associated with the blender and you are not required to list the insignificant, incidental fugitive emissions associated with transferring blended material.

      Bypass stacks. Do not include data for bypass stacks or control system bypasses in the EquipDetail tab, but do include them in the process flow diagram.

      Emission units routed to a boiler for emissions control. Enter the Emission Unit IDs for each emission unit in the Emission Unit ID column. Provide the Emission Release Point ID for the boiler stack. This emission control system will also need to be described in the control system tab.

      Wastewater/process water operations. Complete the questions in EquipDetail for any wastewater (or process water) operations that are closed and/or vent through a conveyance, or are potential sources of fugitive HAP emissions. Include wastewater/process water operations that are potential sources of HAP emissions and/or participate in biological degradation of HAP to prevent HAP emissions.  Wastewater operations may include individual treatment units that reduce HAP within wastewater treatment plants (WWTP), or enhanced biological treatment units. You may aggregate multiple treatment units with similar venting characteristics within a single "wastewater operations" entry in the EquipDetail tab. For example, if the entire wastewater treatment system is a fugitive source, you may choose to include it on one row of EquipDetail. Do not include sewage handling equipment.

With the exception of dryers, presses, and other significant sources of HAP emissions, you may group similar emission units of lesser importance in terms of total facility HAP (such as saws and chippers with similar emissions venting characteristics) to report these emission units on one row in the EquipDetail tab. If you choose to aggregate emission units, it requested to indicate the number of units in the emission unit description column (e.g., enter "dry end saws (4)" as the emission unit description).

Regardless of the presence or absence of prepopulated information in other tabs, you should carefully review the list of tabs in Table 1 of this instruction document to determine which tabs are relevant and required to be completed for your facility.

Use the pull-down menus to respond to the questions regarding the PCWP compliance options and work practices used to demonstrate compliance with subpart DDDD. You only need to select one of the compliance options even if you can demonstrate compliance with more than one of the PCWP compliance options. Select the option associated with your most recent compliance demonstration.

The menu choices are as follows:
PCWP Compliance Options (EquipDetail)
No Control Required
Work Practice Only
Production Based Compliance Option (PCWP Table 1A)
Emissions Averaging
Reduce emissions of total HAP, measured as THC (as carbon) by 90 percent (PCWP Table 1B option 1)
Limit emissions of total HAP, measured as THC (as carbon), to 20 ppmvd (PCWP Table 1B option 2)
Reduce methanol emissions by 90 percent (PCWP Table 1B option 3)
Limit methanol emissions to less than or equal to 1 ppmvd if uncontrolled emissions > 10 ppmvd (PCWP Table 1B option 4)
Reduce formaldehyde emissions by 90 percent (PCWP Table 1B option 5)
Limit formaldehyde emissions to less than or equal to 1 ppmvd if uncontrolled emissions > 10 ppmvd (PCWP Table 1B option 6)

If emissions averaging is used, provide a short description of the emissions averaging approach, indicate whether the emission unit listed in the row is a debit or credit generating source in the emissions average, and submit a copy of the Emission Averaging Plan (EAP) required under §63.2280(f) with your survey responses if the EAP is not already included in the facility permit (also submitted with the survey response). In an emissions average:
      "Debit" sources are emission units that are required to meet the emission limits in Table 1B of the PCWP NESHAP.
      "Credit" sources are emission units that are over-controlled in order to offset emissions from "debit" sources that are either not controlled or under-controlled.

If the facility uses the production based compliance option (PBCO), you are asked to describe any methods used to meet the PBCO such as pollution prevention measures (P2), use of low-HAP resins, or other measures. If your emission unit meet the PBCO simply because it is inherently lower-emitting without the use of any deliberate P2 measures, select "no P2 measures required."

d. 	Release Point Detail (ReleasePt) tab

The purpose of the ReleasePt tab is to gather details on the conditions and location of emissions releases. These details will be used in the residual risk assessment. As noted in Section D2 above, you are required to supply an emission release point map displaying the location of each Emission Release Point ID specified in the ReleasePt tab. Accurately accounting for emission release location and characteristics improves the accuracy and precision of the risk modeling.

As noted in the instructions for EquipDetail above, there may be one or more emission release points for a given Emission Unit ID. There may also be multiple Emission Unit IDs ducted to the same Emission Release Point ID. For each combination of Emission Unit ID and Emission Release Point ID, you will specify emission release parameters (e.g., stack gas parameters or fugitive release parameters), and longitude/latitude coordinates in the ReleasePt tab. This worksheet is prepopulated with Emission Unit IDs and Emission Release Point ID from the EquipDetail tab. You must populate all appropriate fields for each Emission Release Point ID.
      Note: You will specify emission rates for each pollutant in each combination of Emission Unit ID and Emission Release Point ID in the Primary HAP Emissions and Other HAP Emissions tabs.

      Emission Release Point Type. Each emission release point is characterized by an emissions release point type code. Emission release point type codes 01, 07, and 08 apply for fugitive emission sources, while other emission release point type codes (02 through 06) apply for point source (e.g., stack) releases. The emission release point type codes are as follows:
Emission Release Point Type Codes used for PCWP Sources
01 - Fugitive
02 - Vertical
03 - Horizontal
04 - Goose Neck
05 - Vertical with Rain Cap
06 - Downward-facing Vent
07 - Fugitive Area
08 - Fugitive Point
99 - Unknown

The release parameters exit gas temperature ([o]F) and release height (feet) apply for both the fugitive and stack emission release point type codes. Generally, the higher the release height, the greater the dispersion of air emissions, which in turn leads to reduced risk to the surrounding population. The EPA will specify conservative default release height parameters if you do not supply this information.

      Stack parameters. Additional point source (e.g., stack or vent) gas parameters to be specified include stack diameter, exit gas velocity, and gas flow rate (in acfm). You are asked to provide typical or representative values based on information you have in hand. For example, if you have a one-time measurement of these parameters (e.g., from a stack test), then you could use that measurement. If you have continuous monitoring data, then you may choose to use the annual average for the parameter. If you have periodic monitoring data (e.g., quarterly data), then you could average the quarterly data for the year. If you do not supply this information, then EPA will specify conservative default parameters. Please ensure that you specify positive, non-zero temperatures for your emission releases. Ambient temperature is considered to be 72[o]F.

      You are asked to specify the moisture content of the exhaust gas stream (which along with stack gas temperature will allow EPA to convert to units of dscfm for use in various analyses separate from the residual risk review). The spreadsheet calculates the gas flow rate in cubic feet per second (cu ft/sec) which is needed for the risk modeling.

         PCWP Notes:
              Circular baghouses that vent 360 degrees around the sides of the baghouse can be treated as stack emission sources.
              Outdoor chippers can be treated as fugitive sources, unless they have a gas flow rate.

      Fugitive parameters. Emission Release Point Type Code 01 is a generic code for fugitive release. If code 01 is used, the EPA will assume that the fugitive will be modeled as an area source (the same as code 07). Fugitive releases are modeled either as a single point with a latitude and longitude, an area source, a volume source, or a line source. Because there are no known fugitive line or volume sources for PCWP, these options have been omitted from the PCWP ICR.

      Fugitive point sources do not require fugitive length, width, or angle. Enter "NA" in these columns of the spreadsheet for fugitive point sources. Emissions from fugitive point sources are not as dispersed as emissions from fugitive area sources.

      Fugitive area sources are modeled as rectangles with latitude and longitude reported at the SW corner of the release. Figure 3 is a depiction of fugitive area source parameters. The red dashed lines represent the coordinate plane with north towards the top. The purple SW points at the southwest corner show correct location of fugitive coordinates. The x and y represent fugitive length and width. The figure also shows rotation of angles.

  Figure 3. Graphical view of the fugitive length (x), width (y), and angle.
A Note About Emission Release Parameters
Please pay particular attention when entering emission release point stack parameters and locations (latitude/longitude). These data are critical inputs to the modeling files that EPA will use to determine the risk profile for the residual risk review process.

Valid parameters for the physical characteristics of each emission release point are necessary to correctly place facility release points and associated emissions into vertical layers for proper air quality modeling. Gaussian dispersion models use stack parameters to characterize the plume. The ambient concentration at ground level is inversely proportional to the plume height (i.e., ground-level concentration decreases with increasing plume height). The plume height is a function of the actual physical release height (stack height) and the plume's rise due to buoyancy and momentum. Plume rise is a function of the plume's exit gas velocity, volumetric flow, and release temperature. Different plume heights can result in different ambient concentrations and resulting risks. The plume height is related to the type of emission point release.
A Note About Emission Release Parameters
Please pay particular attention when entering emission release point stack parameters and locations (latitude/longitude). These data are critical inputs to the modeling files that EPA will use to determine the risk profile for the residual risk review process.

Valid parameters for the physical characteristics of each emission release point are necessary to correctly place facility release points and associated emissions into vertical layers for proper air quality modeling. Gaussian dispersion models use stack parameters to characterize the plume. The ambient concentration at ground level is inversely proportional to the plume height (i.e., ground-level concentration decreases with increasing plume height). The plume height is a function of the actual physical release height (stack height) and the plume's rise due to buoyancy and momentum. Plume rise is a function of the plume's exit gas velocity, volumetric flow, and release temperature. Different plume heights can result in different ambient concentrations and resulting risks. The plume height is related to the type of emission point release.

      Default fugitive release parameters. Certain defaults used in developing the EPA's NEI are applied for fugitive releases. You may specify the release height (between 0.1 and 100 ft). In the NEI, fugitive releases over 100 ft are considered invalid and will be set to the default height of 10 ft. Similarly, the default will be 10 ft if you do not specify a height for fugitive releases. In addition to height, you may specify the fugitive length, width, and angle (or these column will remain zero - indicating essentially no dispersion). The exit gas temperature default is set to ambient (72[o]F) unless you specify a different temperature.

      Certain defaults for fugitive releases will be set for risk modeling following NEI conventions and cannot be changed. The defaults for stack diameter (0.003 ft), velocity (0.0003 ft/sec), and flow (0 cu ft/sec) are set to indicate essentially no flow. You should consider this information pertaining to default fugitive parameters as you select Emission Release Point Type Codes pertaining to fugitive emission sources. When selecting fugitive Emission Release Point Type Codes, you are strongly encouraged to provide the actual release height and fugitive dimensions (particularly length and width) because these parameters will result in more accurate dispersion estimates when risk modeling if performed.

      Longitude/latitude coordinates. You are asked to provide the longitude/latitude for each emission release point. The longitude/latitude coordinates should correspond with the actual location of each emission point (e.g., the location of each stack - not the general street address of the mill). For point sources, longitude/latitude is specified at the center of the emission source. For fugitive are sources (codes 01 or 07), longitude/latitude is specified at the southwest corner of the emission source if the fugitive angle (defined below) is zero or the western most corner if the fugitive angle is greater than zero. The EPA requires longitude/latitude for each emission point provided in North American Datum (NAD) 83 with 6 digits to the right of the decimal point.

      Source Classification Codes (SCCs). Appendix 8 provides a list of the SCCs for PCWP emission units grouped by product type. Once you key in an SCC code, its description appears in the spreadsheet. Please use the description as a check that the proper SCC was entered.

      The SCCs will be used by EPA to group similar emission units and draw conclusions regarding the emission levels and residual risk associated with each type of emission unit. Proper assignment of SCCs will allow EPA to pinpoint emission unit types that need to be examined in more detail for residual risk rulemaking. The SCC codes for the PCWP industry have were updated within the past 5 years to include more descriptive codes and to provide some guidance on which codes should be used for certain equipment types.

      Use the SCC that best describes your process and avoid using generic not-elsewhere-classified (NEC) SCCs whenever possible. If you do not find an SCC that matches your emission unit, then include an accurate "Emission Unit Description" in the comments column of the spreadsheet.

e. 	Permit Limits (Permit) tab

Permit limits for each emission unit/point listed in the EquipDetail tab should be entered here. The list of emission units and their PCWP compliance options from the EquipDetail tab are prepopulated in the Permit tab.

In the Permit tab, you are asked for information regarding the test method used to demonstrate compliance with the PCWP NESHAP and about any HAP permit limits for HAP other than the 6 total HAP defined in the PCWP NESHAP.  Leave the rows in the permit limits tab blank for any emission units with no requirements under the PCWP NESHAP and/or air permit limits.

You are asked to provide emission limits for HAP, VOC and PM. If HAP or VOC limits are provided in multiple formats in your permit, please provide limits in the following units of measure (in order of preference): concentration, lb/production unit, mass/time. Please indicate units of measure for permit limits as specifically as possible. For example, if concentration limits are specified as "ppm" or "ppmv" instead of "ppmdv," use the limits as specified in your permit. VOC concentration limits should note whether they are on a carbon basis (i.e., `as C') or some other basis. PM limits are requested in units of concentration (gr/dscf) with the permit limit PM size fraction noted. Permit limits of most interest to EPA are concentration limits (ppmdv, gr/dscf, etc.), percent reduction, mass per unit production (lb/ton of material throughput, etc.) because these limits can be compared from facility to facility independent of emission unit or facility capacity. The EPA will use the permit limit information you supply in comparing permit limits across similar emission units nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction factors (% O2). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way in your permit (ppmdv, ppmdw, ppmv, ppmw). Please note:

      State mass-based Limits:   Mass emission rate limits (lb/hr or tpy), or limits based on state-only required modeling, are not being requested unless this is the only way in which limits are specified in the permit. The EPA is most interested in state permit limits that are more stringent than those limits in federal rules (e.g., PSD Avoidance or BACT limits).

      Permits restating PCWP limits. Your permit may simply restate the emission limits contained in PCWP (NESHAP subpart DDDD). Some permits may list all of the compliance options contained in the Federal rules as permit limits. If this is the case, you do not need to enter permit limits that are exactly the same as PCWP. Instead, note that "all of the Table 1B compliance options are listed in the permit" in the comments column at the far right. If your permit contains additional State limits in terms other than the Federal limit, please indicate these limits in the appropriate column.

      Submit a copy of permit:  Attach an electronic, searchable copy of the operating permit with the survey.

f. 	Resin and Tanks (Resin and Tank) tabs

In the Resin tab you are requested to provide MSDS sheets for resins and resin additives (e.g. formaldehyde scavengers) used to manufacture PCWP. You do not need to include waxes or other non-adhesive additives in either the Resin or Tank tabs. Enter the Product Trade Name and Catalogue Number for each resin and identify the resin type. The Product Trade Name and Catalogue Number is used to link to the Tank tab and must exactly match between the Resin and Tank tabs. The following resin type selections are included in the tab:

      PF: phenol-formaldehyde
      UF: urea-formaldehyde
      MF: melamine-formaldehyde
      MUF: melamine-urea-formaldehyde
      MDI: methylene diisocyanate (includes pMDI)
      PVA: polyvinyl acetate
      PRF: phenol/resorcinol formaldehyde

Please specify any key resin types used by the facility that are not included in the list above. List each unique resin on one row. Slight variations in the same general type of resin need not be listed separately (e.g., slight variations in UF resins), but resins used in different product lines (as indicated in the Prod tab) or resins of significantly different formulation should be should be listed on separate rows. Describe HAP scavengers (such as urea, ammonia, etc.) by overwriting the word "specify" the in the `Other' pull down menu choice. HAP scavengers are additives of interest because they reduce HAP emissions from resins. Enter the information requested regarding use of the resin in the panel face or core (or throughout the whole panel), the resin percent solids, HAP percentages, and possible lower-HAP substitutes for the resin.

With the exception of HAP scavengers, non-HAP-containing resins or additives are not required to be included in the tank tab since they have no HAP emissions to model. Each tank with HAP containing resin or additive (or any scavenger) should appear on one row. Select the type of tank from the menu and provide the parameter requested. If the facility has modeled the tank emissions unit with TANKS or a similar software package, please provide a copy of the emission estimates.

g. 	Dryer (VeneerDry, RotaryDry, TubeDry, ConvDry, LKiln, and DFDryFuel) tabs

Dryer information requests are tabbed by industry segment. You only need to complete tabs which match equipment present at your facility. Specify the emission unit details requested in the dryer tab that matches the facility industry segment. Indicate if the dryer is direct or indirect fired or radio-frequency heated in the "Firing method" column.

The dryer tabs also request information on work practices, like balancing air flow, gas recycling and gas volume control, which reduce HAP and/or improve energy efficiency. Describe any work practices, for example, that prevent overdrying, or equipment design modifications (e.g., to heat/energy systems) that reduce HAP and/or improve energy efficiency. Use the comments column on the far right if more than 255 characters are needed.

Complete the DFDryFuel tab for direct-fired dryers. Direct-fired" dryers have hot combustion gases coming into contact with the wood furnish, while "indirect-fired" dryers are typically steam-heated where combustion gases do not come into contact with the wood.

      Direct Fired Dryer Fuel. Fuel types are requested for fuel-fired dryers because fuel type can have an effect on emissions. The EPA may consider fuel types and perform calculations based on fuel firing rates for various nationwide impact analyses. Because the types and amounts of fuels fired can vary throughout the year, the EPA is requesting the approximate percent of annual heat input capacity in million British thermal units per year (MMBtu/yr) supplied by each fuel. Primary and supplemental fuel information is requested for direct-fired dryers.

You are asked to provide wood moisture content on a dry basis in the dryer tabs.  On a wet basis, fresh green wood is about 50% moisture, but on a dry basis fresh green wood is about 100% moisture.  Please ensure you provide moisture contents on a dry basis. The expressions below may help you convert:
      Dry MC% = (Wet MC%/100) / (1  -  Wet MC%/100) x 100
      Dry MC% = (weight of water in wood / oven dried weight of wood) x 100
      Wet MC% = (weight of water in wood / total weight of wood including water) x 100

h. 	Press and Board Cooler (Press, BC, and EWPPress) tabs

Press and board cooler information requests are tabbed by equipment type. You only need to complete tabs which match equipment present at your facility. Specify the emission unit details requested in each tab. Separate questions are asked for batch and continuous presses.

In the Press tab, there are a series of questions for presses used to manufacture products subject to the CARB Air Toxic Control Measure (ATCM) or the Toxic Substance Control Act (TSCA) Formaldehyde Standards for Composite Wood Products Implementation Rule. The purpose of these questions is for EPA to understand how resin systems and the air emissions potential composite wood products pressing operations have changed since the formaldehyde rules were developed. The EPA intends to consider whether there are work practices applicable for existing source presses, board coolers or other PCWP manufacturing equipment following resin application (particularly for difficult to test emission units).

You are also asked to provide details on the technical feasibility and costs of enclosing pressing equipment (e.g., plywood presses) and board coolers. This information will assist the EPA in formulating options for emission units that are not currently subject to emission limits in the PCWP NESHAP.

i. 	Fiberboard and Hardboard Equipment (FB-HB) tab

Complete the FB-HB tab if your facility has fiber washers, fiberboard mat dryers (wood or agricultural fiber), press predryers, hardboard ovens, and hardboard humidifiers. Note that hardboard tube dryers should be reported in the TubeDry tab.

You are asked to describe the manufacturing process at your facility as:
 wet process (wet forming/wet pressing)
 wet/dry process (wet forming/dry pressing)
 dry process (dry forming/dry pressing)
 wet-formed fiberboard (no pressing)

This tab also requests information on work practices, like balancing air flow, gas recycling and gas volume control, which reduce HAP and/or improve energy efficiency from process dryers (not tube dryers) and ovens. Describe any work practices, for example, that prevent overdrying, or equipment design modifications (e.g., to heat/energy systems) that reduce HAP and/or improve energy efficiency.  Use the comments column if more than 255 characters are needed.

j.  	Other Equipment (OtherEquip) tab

Complete the OtherEquip tab if your facility has stand-alone digester, pressurized refiners, atmospheric refiners, dry blending and forming, sanders, saws, chippers, or log vats.

Facilities that produce kiln-dried lumber as their only PCWP product are not required to provide information on sanders, saws, and chippers. Only lumber kilns are of interest at these facilities.

Describe any work practices or equipment design modifications (e.g., to heat/energy systems) that reduce HAP and/or improve energy efficiency for the units covered in this tab. Use the comments column if more than 255 characters are needed.

k.  	Control Devices (APCD) tab

Complete the APCD tab by following the instructions in the "Instruction" row. The data requested in the APCD tab include design parameters that will be used by EPA to evaluate control devices and to understand the non-air environmental impacts associated with the control devices (e.g., amount of wastewater or solid waste generated and methods for handling). Enter the information on each APCD identified in the EquipDetail tab on a separate line in the spreadsheet.

Only enter data in the relevant columns for the particular type of APCD. Columns are available for:
 APCD information
 Pressure drop
 Control efficiency
 Thermal Oxidizers/Incinerators (including catalytic oxidizers)
 Process Combustion Unit Control
 Sorbent injection
 Baghouses/Fabric filters
 Cyclones and multiclones
 Electrostatic Precipitators (ESP)
 Wet ESPs
 Scrubbers (including packed bed scrubbers)
 Biofilters

Alternate controls. Alternate (or backup) controls include alternative controls used when flow from an emission source is diverted from the primary control device to a less frequently used control device. If the facility has such a system, please describe it and the typical use circumstances in the `Comments' column of this tab.

Dryers venting into press enclosures. The APCD to be identified for dryers venting into press enclosures is the press APCD. Note that under the ReleasePt tab the same emission release point ID would be provided for press and the dryer exhaust stream vented through the press enclosure and out through the press control device.

Presses vented through dryers. When press exhaust is used as dryer burner makeup air and subsequently combusted in the dryer burner, the dryer burner is a form of process incineration. Complete the series of columns in the "Process Combustion Unit Control" section of the press tab for this configuration. The APCD details for the dryer APCD would be completed on a separate row of the APCD tab.

If press exhaust mixed with dryer exhaust, but is not combusted in the dryer burner, then the dryer APCD would be the same APCD used for the press. Note that under the ReleasePt tab the same emission release point ID would be provided for press and the dryer exhaust stream vented through the press enclosure and out through the press control device.

Follow the instructions in the Emission Unit Type column for identifying multiple emission unit types controlled by the same APCD. Also, note in the emission unit and control configuration in the comments column for added clarity.

Actual control efficiency. Actual control efficiencies are requested for the different types of control. This information will be used in determining the capability of different control devices for reducing emissions. If you have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant across the control device, then you would enter this test result as the "actual" control efficiency. You may leave the control efficiency columns blank (rather than marking as "NA") if actual control efficiency is not known (or not applicable for a given pollutant).

Additional questions relate to:
 Control System Water Source and Usage
 Solid Material Handling and Disposal
These questions must be completed for APCDs that generate solid or liquid waste streams

There are also questions pertaining to use of the Routine Control Device Maintenance Exemption (RCDME). Further there are questions specific to APCD startup and shutdown. The intent with startup and shutdown questions is to gather information on practices used to reduce emissions during these periods, and information on APCD monitoring parameters that cannot feasibly be met during startup and shutdown.

Last, there are questions pertaining to control device and continuous parameter monitoring system costs. As described in EPA's Air Pollution Control Cost Manual:
      Capital Cost means:
      (1) The present worth of a uniform series of periodic costs that continue for an indefinitely long time (hypothetically infinite).
(2) The value at the purchase date of the asset of all expenditures to be made in reference to this asset over an indefinite period of time. This cost can also be regarded as the sum of capital which, if invested in a fund earning a stipulated interest rate, will be sufficient to provide for all payments required to maintain the asset in perpetual service. (November 1990)
      Operating Cost means the expenses incurred during the normal operation of a facility, or component, including labor, materials, utilities, and other related costs. Includes all fuel, lubricants, and normally scheduled part changes in order to keep a subsystem, system, particular item, or entire project functioning. Operating costs may also include general building maintenance, cleaning services, taxes, and similar items.
      Maintenance And Repair Cost means the total of labor, material, and other related costs incurred in conducting corrective and preventative maintenance and repair on a facility, on its systems and components, or on both. Maintenance does not usually include those items that cannot be expended within the year purchased. Such items must be considered as fixed capital.

l. 	Startup, Shutdown, Malfunction (SSM) tab

The EPA evaluates the standards that apply during startup and shutdown events while conducting Risk and Technology Reviews (RTR). In December 2008 the US Court of Appeals for the DC Circuit vacated the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart A. Consequently, we are evaluating whether the current standards developed for normal operation can apply during startup and shutdown in PCWP facilities. Questions pertaining to emission unit and control device startup and shutdown are asked in order to provide EPA with an understanding of the duration and definition of startup and shutdown events for the types of emission units and control devices used at PCWP facilities. The EPA is seeking information on the integral nature of startup and shutdown events for the different combinations of emission units and control devices used in PCWP. The SSM tab asks about emission unit startup/shutdown. The APCD tab contains a series of startup/shutdown questions pertaining to control devices. Because Federal NESHAP require continuous monitoring of emissions or control device operating parameters, information is requested about control device parameter limits that cannot feasibly be met during startup and shutdown events. Certain parameters may be "instant on" while others are more transient in nature (i.e., changing as startup or shutdown progresses). Examples could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved due to low exhaust gas flow from the emission unit. The EPA will use this information to evaluate which existing control device parameter limits may remain in effect during startup and shutdown events, and which parameter limits may need to be replaced with another requirement during startup and shutdown.

Deviation Reporting. For the startup and shutdown questions in columns E through J, you are asked to supply information for routine startup and shutdown events associated with planned equipment or facility downtime. Only enter for units currently subject to PCWP control requirements (e.g. presses, dryers, etc). For Columns K and L, provide information for unplanned startup/shutdown events associated with equipment malfunctions that led to excess emission reporting. This information is required to be recorded under §63.2281(e)(5). Columns M and N ask about the duration of the deviations during due to startup, shutdown, control system problems, control device maintenance, process problems, and other causes, which is required to be recorded by §63.2281(e)(6).

m. 	Miscellaneous Coatings (MiscCoat) tab

Complete the MiscCoat tab for any coating applied in the facility. Describe all non-HAP coatings and/or coatings that meet the PCWP definition of Group 1 miscellaneous coating in subpart DDDD. For columns requesting HAP information, describe coatings that contain "measurable" concentrations of HAP. Only include in this tab additives with measurable quantities of HAP as reported on the material safety data sheet (MSDS) for the coating. For purposes of this survey, "measurable" is defined consistent with OSHA requirements that chemical suppliers provide specific constituent amounts in MSDS for any carcinogens that are present in amounts greater than 0.1 percent and any non-carcinogens that are present in amounts greater than 1 percent.

Do not include coatings subject to the Wood Building Products NESHAP (40 CFR 63 subpart QQQQ) in this tab.

n. 	Wastewater (WW) tab

Zero discharge facilities that do not generate process wastewater requiring treatment under Clean Water Act regulations and guidelines only need to fill out columns C through F of the WW tab.  Review the questions in columns C through F to determine if your facility needs to fill out the information requested in the remainder of the tab. Generally, facilities with wastewater permits which have established effluent guidelines for wastewater discharges or treat PCWP process wastewater using biological treatment will need to complete the entire spreadsheet. If PCWP process wastewater is sent to a POTW for treatment, respondents will only need to complete the spreadsheet as far as the POTW information in column K and provide technical support documents from the POTW that demonstrate how HAP in process wastewater is contained and destroyed. For facilities with wastewater treatment, complete the remainder of the WW tab by following the instructions in the "Instruction" row. Within the WW tab, you are requested to provide documentation to support various responses, including (if applicable):
 Wastewater effluent limit permits and any case-by-case BPT/BAT analyses;
 Wastewater treatment plant (WWTP) flow diagram showing each wastewater handling/treatment unit if your facility has obtained a wastewater permit establishing an effluent limit;
 Plan required under Tables 5 and 7 of the PCWP rule to demonstrate how HAP captured by a wet control device are destroyed, if your facility uses a wet control device as the only means of HAP control; and
 WWTP emission estimates from measurements, fenceline monitoring, or modeling, if available.

D4. 	Emissions Estimates, Emissions Testing, and Monitoring Data

Appendices 2 and 3 of this survey contains a table of emission units and pollutants for which existing emissions data are requested. Emissions data and emissions estimates are being requested in the form of emissions test reports, emissions estimates provided to state or federal agencies, and continuous emissions monitoring data, whichever may be available. At this time, you are not required to conduct any new emissions testing or continuous emissions monitoring to respond to this survey. The EPA may issue emission test requests under a second phase of this survey after evaluating the data provided through this ICR.

Supply previous emissions test data by following the instructions for the Emissions Tests (EmTest) tab. Provide emissions estimates in the Primary HAP Emissions and Other HAP Emissions tabs. Supply continuous emissions monitoring system (CEMS) and continuous opacity monitoring system (COMS) data by following the instructions for the PCWP_CEMS_COMS.xlsx spreadsheet.

The emissions data collected will provide valuable information on current emissions levels and will allow EPA to consider variability in emissions from facility to facility (and over time for a given emission unit and pollutant) in reviewing and setting emission standards, particularly regarding process units for which the EPA did not establish emission standards in the PCWP NESHAP.

a. 	Emissions Tests (EmTest) tab

Appendix 3 contains a table of the emission units and pollutants for which existing emission test data are requested. As stated previously, you are not required to conduct any new emissions testing for Phase I of this survey. The EPA is only requesting previous emission test reports at this time for PCWP process units. If the EPA does not receive enough emissions data from previous emissions tests from the PCWP industry through Phase I of the ICR, then the EPA may implement Phase II of the ICR which would require selected facilities to perform emissions testing.

Using the EmTest tab, please list previous emissions tests that have been conducted since January 9, 2003, as requested in Appendix 3. Attach an electronic, searchable copy of each test report to your response (e.g., a searchable Adobe pdf file). When submitting test data, EPA is requesting full test reports with field and lab data sheets and example calculations, not just summary reports.

The purpose of the EmTest tab is to provide a catalogue of the emissions test reports provided to aid the EPA in tracking agency progress in reviewing test reports for purposes of compiling an emissions data base. In the EmTest tab, enter the file name of the emission test report provided and the year when the test was conducted. You will create one row for every PCWP emission unit and/or emission point (whichever is relevant) and pollutant tested in the test report. Reenter the file name and year on each row, as needed, to create rows for every PCWP emission unit and pollutant. For example, if dryer_test.pdf is a test report containing two dryers (one stack each) tested for PM and THC, you would enter 4 rows (dryer 1 PM, dryer 1 THC, dryer 2 PM, and dryer 2 THC).

The EPA is requesting previous emissions test data for the PCWP process units and pollutants listed in Appendix 3. This includes speciated HAP, total HAP (as defined in the PCWP NESHAP as the sum of acetaldehyde, acrolein, formaldehyde, methanol, phenol, and propionaldehyde), THC, methane associated with THC tests, VOC, PM (filterable or condensable of any size fraction), speciated HAP metals, and opacity. The EPA is also requested capture efficiency testing in conjunction with emission sources such as presses were a capture demonstration is required. You are not required to enter rows in the EmTest tab for emission sources outside of the PCWP source category (e.g., boilers), or to enter data for pollutants other than those listed in Appendix 3. If emissions data for PCWP process units beyond those requested are in the test report (e.g., dryer NOx or SO2 data), just note the data available for PCWP process units in the column asking about additional data. You do not need to note data for emission units outside of the PCWP source category.

When entering rows into the EmTest tab, you may lists tests containing "total HAP" as defined in the PCWP NESHAP and total metals on one row and provide the average emissions for the total HAP or metals. Use the comments column to indicate if the data are available in speciated form in the test report. The EPA will extract speciated data from the emissions test report at a later date. The menu choices for pollutants to include on each row of the EmTest tab are as follows:
Tested Pollutant (EmTest)
Methanol
Formaldehyde
Total HAP (6 HAP defined in PCWP NESHAP)
Total non-PCWP HAP
THC (as carbon)
THC (as carbon) minus methane
Total PM
PM10
PM2.5
Opacity (Method 9)
Total HAP metals

Specify the air pollution control system used during the emission test. This is the control system affecting emissions upstream of the emission point. If the control system or equipment configuration has changed since emission testing was conducted, such that the test data are no longer representative, note the process change in the column asking about configuration changes.

Enter the multi-run average emission test result in units of concentration and mass/production. Select the specific units of measure from the menu. This will allow the EPA to quickly evaluate the emissions test results and additional data needs following Phase I of the ICR.

Questions regarding testing frequency for the emission unit and pollutant are asked to gauge how often facilities are required to test. Emissions testing costs are requested to help inform EPA for purposes of evaluating the costs of additional emissions testing requirements for related emission units.

b. 	CEMS and COMS data (PCWP_CEMS_COMS.xlsx)

The EPA is requesting existing CEMS data and/or continuous opacity monitoring system (COMS) data for calendar year 2015 (CY2015) operations from facilities that have installed continuous monitoring systems on APCD controlling process units regulated under PCWP NESHAP. You are only required to provide CEMS or COMS data for emission units that are currently subject to emission limits or work practices under the PCWP rule. For example, provide CEMS data if you continuously monitor THC to demonstrate compliance with the 20 ppm limit from the add-on control compliance option 2 in Table B of 40 CFR subpart DDDD. As another example, if you use a combustion device with COMS as an add-on control to demonstrate compliance with PCWP rule, provide data from the COMS. You are not required to install or operate any new CEMS or COMS to respond to this survey.

CEMS data that are representative of your current operations are requested. You are not required to supply CEMS data that are no longer representative of the current emission unit and control system configuration.

You do not need to supply CEMS or COMS data for power boilers unless they were installed to show compliance with a NESHAP subpart DDDD emission limit. Each worksheet is designed to accommodate data from one CEMS (including oxygen data). If you have multiple CEMS/COMS (e.g., two CEMS on different emission units), then you must make multiple copies of the tab in order to enter data for the additional CEMS.

  What if my data are not in a form that can be inserted into the CEMS tab?
   It is very helpful for EPA's data analysis purposes if data are entered into the CEMS template provided.  However, we understand that some CEMS software may not be configured to provide output that can be easily converted to our preferred spreadsheet format.  We also understand that, in some cases, the hourly production data requested in the CEMS spreadsheet may not be coupled with the CEMS data or may not be available in a manner to be easily linked to the CEMS data.  If you face these or related issues, please note that EPA is not asking you to hand enter hard copy CEMS data into the spreadsheet.  You may provide CEMS data in an alternative format if you are unable to convert it to our spreadsheet format within the timeframe for this survey.  We ask only that you provide CEMS data in a form suitable for analysis (e.g., spreadsheet or data base format).  We will accept more recent CEMS data (e.g., from the most recent 6 months) if 2015 CEMS data are no longer in electronic form due to company records retention policies.  Further, you may omit the production data if they cannot reasonably be included in your CEMS spreadsheet.  Estimates of production data are acceptable (e.g., if you have a daily production rate, you may divide by 24 operating hours in a day to estimate hourly production).
What if my data are not in a form that can be inserted into the CEMS tab?
   It is very helpful for EPA's data analysis purposes if data are entered into the CEMS template provided.  However, we understand that some CEMS software may not be configured to provide output that can be easily converted to our preferred spreadsheet format.  We also understand that, in some cases, the hourly production data requested in the CEMS spreadsheet may not be coupled with the CEMS data or may not be available in a manner to be easily linked to the CEMS data.  If you face these or related issues, please note that EPA is not asking you to hand enter hard copy CEMS data into the spreadsheet.  You may provide CEMS data in an alternative format if you are unable to convert it to our spreadsheet format within the timeframe for this survey.  We ask only that you provide CEMS data in a form suitable for analysis (e.g., spreadsheet or data base format).  We will accept more recent CEMS data (e.g., from the most recent 6 months) if 2015 CEMS data are no longer in electronic form due to company records retention policies.  Further, you may omit the production data if they cannot reasonably be included in your CEMS spreadsheet.  Estimates of production data are acceptable (e.g., if you have a daily production rate, you may divide by 24 operating hours in a day to estimate hourly production).

c. 	Emissions Estimates (Primary HAP Emissions and Other HAP Emissions) tabs

Hazardous air pollutant (HAP) emissions are requested in the Primary HAP Emissions and Other HAP Emissions tabs. Only the emission units in the PCWP source category are required to be included in the Primary HAP Emissions and Other HAP Emissions tabs. There are no red CBI blocks in these tabs because emissions data are not considered to be CBI.

Appendix 9 provides the list of 187 HAP emission. Appendix 10, Resources for Estimating Emissions, contains references to documents containing emission factors that you may find useful for developing your emission estimates. Actual HAP emission estimates (tons/year) are to be provided for each individual HAP compound emitted from each emission unit listed in Appendix 2. Emission units from other co-located NESHAP source categories such as boilers or wood building product coating operations (if present), need not be included.

These emission estimates should be representative of actual mill production rates in the 2015 base year for the ICR. Actual emissions account for the effects of any APCDs that may be installed to reduce emissions (e.g., is an RTO reduces uncontrolled emissions by 90%).

Allowable emissions data are also requested. Allowable emissions include emissions (tons/year) that are allowed. For example, if actual emissions are 10 tons/yr considering controls and compliance margin, but the facility is allowed to emit 15 tons/year under the PCWP NESHAP emission limit, then allowable emissions would be 15 tons/year.

Maximum short term emissions (lb/hr) are also requested for purposes of acute risk modeling. An example of maximum hourly emissions may be short term (peak) uncontrolled emissions during peak production rates or during a time when the RCDME is used (e.g., when the 90% control efficiency is not being achieved).

The EPA has developed an emission estimation calculator [TO BE DEVELOPED] (available on the ICR website, WEB SITE TO BE DEVELOPED that you may also find useful for compiling your emission estimates.

If emitted, compounds such as mercury, PAHs, and dioxin/furan would require speciation. The different oxidation states of mercury compounds vary in toxicity, but also in exposure pathway (e.g., inhalation, ingestion). The most common mercury species are divalent mercury (Hg[+2]) (including both particulate and gaseous forms) and elemental gaseous mercury (Hg[0]). If mercury is emitted, in the absence of data on the specific oxidation state, the mercury emissions data reported can be speciated using the NEI default multipliers of 0.2 for particulate divalent mercury (pollutant code 202), 0.3 for gaseous divalent mercury (pollutant code 201), and 0.5 for elemental gaseous mercury (pollutant code 200).

Polycyclic organic matter is comprised of a large number of individual compounds, which can be divided into the subgroups of polycyclic aromatic hydrocarbons (PAHs) and PAH-derivatives. Each compound has its own toxicity level and can vary in exposure pathway. If POM data are reported, speciation into individual PAHs is needed, if a speciation profile is available.

Similarly, if dioxin/furan is emitted from any PCWP emission units, individual dioxin/furan congeners, specifically those used to determine the 2,3,7,8-TCDD toxic equivalency (TEQ), are needed for EPA's risk analyses. The congeners of interest are listed in Appendix 10, along with the toxic equivalency factor (TEF) used to express the mass of each congener in terms of its 2,3,7,8-TCDD TEQ.

d. 	Parameter Monitoring Data

Continuous parameter monitoring (CPMS) data are requested for selected emission units that are potential candidates for work practice standards should emissions testing be determined to be technologically and/or economically infeasible [See: Clean Air Act §112(h)]. Because there are currently no federal standards specifying a format for the requested CPMS data, you may provide the requested CPMS data in the electronic format of your choice, depending on how the data are stored at your facility. Whenever possible, the EPA prefers to receive an Excel[(R)] spreadsheet with the requested data. However, an electronic and searchable pdf file will suffice. The EPA's purpose for requesting the CPMS data is to understand how (and how frequently) the parameter data are measured and recorded should a requirement for continuous parameter monitoring become part of a work practice standard.

The EPA requests CPMS data for the emission units and parameters specified in Table 4.

Table 4. Requested CPMS Data
Emission Unit Type[1]
Monitored Parameters
Specific Examples Requested
Lumber kilns
Temperature, lumber moisture content, and relative humidity inside the kiln
Provide CPMS data for one full batch kiln cycle representative of the hottest drying conditions. For continuous kilns, provide data for 24 hours of operation under the hottest drying conditions.
Process units that show compliance with the PCWP NESHAP using the production based compliance option (PBCO) in Table 1A of subpart DDDD; or process units that generate debits in an emissions average without the use of a control device
Site-specific process unit controlling operating parameters used to demonstrate ongoing compliance with the PCWP NESHAP
Provide CPMS data for one 24-hour period
Softwood and hardwood plywood presses
Pressing temperature
Provide CPMS data for one 24-hour period representing the hottest press operating temperature
Humidifier
Humidity, temperature, and cycle time
Provide CPMS data for one 24-hour period
Log vats
Operating temperature, wood species
Provide CPMS data for one 24-hour period representing the hottest conditions in the log vat
Waste Water Treatment (where CPMS info available)
Select continuously monitored biodegradation output parameter group (e.g. Fbio, Temperature, pH)
Provide CPMS data for one 168-hour period
Other Process Equipment (optional)
Any continuously monitored parameter
Provide CPMS data for one 24-hour period
1. If there are multiple emission units of this type onsite, provide data for only one of the emission units that best represents the specific examples requested in the table.

Appendix 1. Documentation of True Area Source, Non-Operational, or Non-Applicable Status

Facility Name on the Letter from EPA:

Corrected Facility Name (if applicable):

Address:

Check an explanation below:
                                                                            □

I certify that the facility listed above is not a major source or synthetic area source of hazardous air pollutant emissions (HAP) emissions. The facility is a true area source of HAP emissions. Documentation (such as a valid operating permit) confirming the true area source status is attached.

                                                                            □

I certify that that facility listed above was not operational in 2015 (the base year for the plywood and composite wood products survey), that the facility remains non-operational (closed) and does not have an active operating permit. A brief explanation is provided in the area below:

                                                                            □

I certify that the facility listed above does not produce plywood or composite wood products and/or does not operate any lumber kiln. A brief explanation is provided in the area below:

Signature: ____________________________________________
Printed name: _________________________________________
Email the completed form to:  		John Bradfield (USEPA)
<EMAIL_ADDRESS>
Appendix 2. Emission Units to Include in the PCWP Survey Response

Include the following types of equipment (emission units) in your survey response. You may not operate all of the emission units listed below. Only include equipment operated at your facility. The purpose of the detailed list below is to ensure all emission points are represented.

softwood veneer dryer
veneer redryer
hardwood veneer dryer
radio-frequency veneer dryer
rotary strand dryer
conveyor strand dryer
pressurized refiner
primary tube dryer
secondary tube dryer
green rotary dryer
dry rotary dryer
reconstituted wood product press
board cooler
hardboard oven
press predryer
fiberboard mat dryer
miscellaneous coating operation
softwood plywood presses
hardwood plywood presses
engineered wood products presses
agricultural fiber board presses
rotary agricultural fiber dryers
hardboard humidifiers
stand-alone digesters
fiber washers
atmospheric refiners
chippers/flakers/hammermills
log vats
storage tanks
blenders
formers
sanders
saws
lumber dry kilns
wastewater operations

Appendix 3. Previous Emissions Test Data Requested

Previous emissions test data representative of your current operations are requested. The table below summarizes the previous emissions tests requested in Phase I of the ICR. Please provide electronic copies of any emissions test reports the facility has matching the criteria below. The test reports provided should include the results of Methods 1, 2, 3, and 4 (or their derivatives) for selecting sampling location, determining stack gas velocity and volumetric flow rate, molecular weight, and moisture content.

Note that you are not requested to conduct and new emissions testing to response to Phase I  -  only previous emissions test reports are requested. New emissions testing may be requested as part of Phase II of the ICR after the EPA reviews the information received in Phase I.

Previously Conducted Emissions Tests Requested

Emission Unit

Pollutant

Test methods[1]
Softwood veneer dryers; primary tube dryers; secondary tube dryers; rotary strand dryers; conveyor strand dryers; green rotary dryers; hardboard ovens; reconstituted wood product presses; and pressurized refiners
Press predryers; fiberboard mat dryers; board coolers, Dry rotary dryers; veneer redryers; softwood plywood presses; hardwood plywood presses; engineered wood products presses; hardwood veneer dryers; humidifiers; atmospheric refiners; formers; blenders; rotary agricultural fiber dryers; agricultural fiber board presses; sanders; saws; fiber washers; chippers; log vats; lumber kilns; storage tanks; wastewater operations; and stand-alone digesters.
Formaldehyde
M316 or
M320 or
Method 0011 (EPA SW-8460) or
NCASI Methods
CI/WP-98.01,
CI/WP-98.02 or
ISS/FP-A105.01
     Supply all emissions measurement data collected since January 9, 2003
     Supply all emissions measurement data collected since January 9, 2003
Methanol
M308 or
M320 or
NCASI Methods
CI/WP-98.01
CI/WP-98.02 or
ISS/FP-A105.01

Total HAP[2]

M320 or
NCASI Methods IM/CAN/WP-99.02 or ISS/FP-A105.01, or ASTM D6348-03

Total hydrocarbon (THC) as carbon[3]
M25A, including M18 if subtraction of methane form the M25A result is desired.

Particulate matter (PM)[3] and opacity
M5, M29, M17
     Supply all emissions measurement data collected since January 9, 2003
     Supply all emissions measurement data collected since January 9, 2003
Speciated HAP metals[4]
M29

PM2.5 (filterable)
EPA M201 or M201A

PM2.5 (condensible)
EPA M202

Enclosure capture efficiency
M204 and M204A-F or
Appendix A to Subpart DDDD
For reconstituted wood products presses, supply all emissions measurement data collected since January 9, 2003
For enclosed presses and board coolers only. Supply the most recent capture efficiency measurement data collected since January 9, 2003
1 M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 17 and 25A, appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. NCASI and ASTM methods are incorporated by reference at 40 CFR 63.14.
[2] "Total HAP" is defined in the PCWP NEHSAP as the sum of the following 6 compounds: acetaldehyde, acrolein, formaldehyde, methanol, phenol, and propionaldehyde.
[3] If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS and COMS data using the data spreadsheet. Synthetic area sources should supply the most recent data (if data are available).
[4] The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr[+6]) and speciated mercury (Hg) test data if available.

Appendix 4. Acronyms and Abbreviations

AFS
Air facility system
ACFM
Actual cubic feet per minute
AIRS
Aerometric Information Retrieval System
APCD
Air pollution control device
ATCM
Air Toxic Control Measure
BACT
Best achievable control technology
BLDG
Building
BPT
Best Practicable Technology
CAA
Clean Air Act
CARB
California Air Resources Board
CBI
Confidential business information
CEDRI
Compliance And Emissions Data Reporting Interface
CFR
Code of Federal Regulations
CEMS
Continuous emission monitoring system
CISWI
Commercial/Industrial Solid Waste Incinerator
COMS
Continuous opacity monitoring system
CPMS
Continuous Parameter Monitoring
dscf
Dry standard cubic feet
EIS
Emission inventory system
EPA
Environmental Protection Agency
ESP
Electrostatic Precipitator
FRS
Facility Registry Service
GPM
Gallons per minute
HAP
Hazardous air pollutants
ICR
Information collection request
lb
Pound
LSL
Laminated strand lumber
LVL
M
Laminated veneer lumber
Thousand (when referring to PCWP production units of measure)
MACT
MBF
Maximum achievable control technology
Thousand board feet
MDF
Medium density fiberboard
MDI
Methylene dissocyanate
MF
Mft3
MLF
Melamine-formaldehyde
Thousand cubic feet
Thousand linear feet
MMBtu
Million British thermal units
MSDS
Material safety data sheets
MSF
Thousand Square Feet
MUF
Melamine-urea-formaldehyde
NA
Not applicable
NAD
North American Datum
NAICS
North American Industry Classification System
NEI
National emissions inventory
NESHAP
National emission standard for hazardous air pollutants
NOx
Nitrous Oxides
NSPS
New source performance standard
NV
Not vented
O2
Oxygen
O&M
Operating and Maintenance
ODT
Oven Dried Tons
OSB
Oriented strand board
OSHA
Occupational Safety and Health Administration
PAH
Polycyclic Aromatic Hydrocarbon
PBCO
Production Based Compliance Option
PCWP
Plywood and composite wood products
PDF
Portable document format
PF
Phenol-formaldehyde
PM
Particulate Matter
POM
Polycyclic Organic Matter
POTW
Publically Owned Treatment Works
ppmdv
Parts per million  -  dry volume
ppmdw
Parts per million  -  dry weight
ppmv
Parts per million - volume
ppmw
Parts per million - weight
PRF
Phenol resorcinol formaldehyde
PSD
Prevention of significant deterioration
PSL
Parallel strand lumber
PTE
Potential to emit
PVA
Polyvinyl acetate
P2
Pollution Prevention
RCDME
Routine Control Device Maintenance Exemption
RM
Routine Maintenance
RTO
Regenerative Thermal Oxidizer
RTR
Risk and technology review
SCC
Source Classification Code
SIC
Standard Industrial Classification
SO2
Sulfur dioxide
SSM
Startup, shutdown, and malfunction
THC
Total Hydrocarbons
TPY
Tons per year
TRI
Toxic Release Inventory
TSCA
Toxic Substance Control Act
TTE
Temporary Total Enclosure
UK
Unknown
USDA
United States Drug Administration
UF
Urea formaldehyde
VOC
Volatile Organic Compounds
WESP
Wet Electrostatic Precipitator
WWTP
Wastewater Treatment Plant
yr
Year

Appendix 5. Signed Certification Form

Instructions:  Submit a hard (or electronic) copy of this completed form with your survey response.

Certification Statement:
Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided in my response to this survey are (to the best of my knowledge) true, accurate, and complete.

Signature: ____________________________________________
Printed name: _________________________________________
Title: _________________________________________________
Company: _____________________________________________
Date signed: ___________________________________________

Note that the information submitted by a facility is not intended for a compliance assessment. If actual data are not available, the facility should provide the best engineering estimates where appropriate. In addition, it is not the intent of the EPA to use this data to confirm data/information submitted in the facility's Toxic Release Inventory (TRI) or other regulatory required reports. It is understood that data submitted in this survey could vary due to the nature of the questions.

Appendix 6. Checklist of Materials to Submit with Your Survey Response

                                     Item
                                  Mail* to...

Exemption form in Appendix 1 if your facility is not a major or synthetic area source of HAP emissions, is closed, or does not manufacture PCWP

John Bradfield (email or fax to address in form)

Disk (CD or DVD) or flash drive containing non-CBI materials:

John Bradfield (See section C1 for address)

 Signed certification form (Appendix 5, PCWP_certification.docx)

 PCWP_survey.xlsx spreadsheet with CBI data removed as described in section C of the instructions.

 Electronic copy of the facility operating permit in searchable format

 Process flow diagram(s)

 Emissions release point map

 For facilities using the emissions averaging compliance option, a copy of the Emission Averaging Plan (if not included in the facility permit)

 Copy of TANKS or related emission estimates, if available (requested in the Tank tab)

 Copy of lumber dry kiln schedules used OR reference the schedule followed in the USDA Forest Products Lab Dry Kiln Operators Manual (Agriculture Handbook # 188). For kilns with multiple kiln schedules, reference each here separately. (Requested in the LKiln  tab)

 Copies of the 2015 semiannual compliance reports required under §63.2281(b) and Table 9 of subpart DDDD (requested in the SSM and APCD tabs)

 Recommendations for a standard that would apply during startup or shutdown of any emission unit or APCD, if you have any (in response to this question in the SSM tab)

 Copy of Material Safety Data Sheet (MSDS) for each HAP-containing miscellaneous coating (requested in the MiscCoat tab)

 Wastewater effluent limit permits and any case-by-case BPT/BAT analyses (requested in the WW tab)

 Wastewater treatment plant (WWTP) flow diagram showing each wastewater handling/treatment unit if your facility has obtained a wastewater permit establishing an effluent limit (requested in the WW tab)
 Plan required under Tables 5 and 7 of the PCWP rule to demonstrate how HAP captured by a wet control device are destroyed, if your facility uses a wet control device as the only means of HAP control (requested in the WW tab)

 WWTP emission estimates from measurements, fenceline monitoring, or modeling, if available, requested in the WW tab.

 Electronic, searchable copies of previous air emission test reports requested in Section D4a and Appendix 3 of these instructions
 Electronic copies of CPMS data requested in section D4d.

Disk (CD or DVD) or flash drive containing only the portions of your response claimed as CBI:
Tiffany Purifoy, Document Control Officer (See section C2 for address)

 PCWP_survey.xlsx spreadsheet containing only the CBI data removed from the non-CBI version of the spreadsheet

 Any additional materials claimed CBI

*The EPA recommends using Registered U.S. Mail with a return receipt requested, Federal Express, or any other method for which a receipt signature is required.
Appendix 7. Plywood and Composite Wood Products NESHAP Definitions

                 Definitions from 40 CFR Part 63, Subpart DDDD

§63.2292   What definitions apply to this subpart?
    Terms used in this subpart are defined in the Clean Air Act (CAA), in 40 CFR 63.2, the General Provisions, and in this section as follows:
    Affected source means the collection of dryers, refiners, blenders, formers, presses, board coolers, and other process units associated with the manufacturing of plywood and composite wood products. The affected source includes, but is not limited to, green end operations, refining, drying operations (including any combustion unit exhaust stream routinely used to direct fire process unit(s)), resin preparation, blending and forming operations, pressing and board cooling operations, and miscellaneous finishing operations (such as sanding, sawing, patching, edge sealing, and other finishing operations not subject to other NESHAP). The affected source also includes onsite storage of raw materials used in the manufacture of plywood and/or composite wood products, such as resins; onsite wastewater treatment operations specifically associated with plywood and composite wood products manufacturing; and miscellaneous coating operations (defined elsewhere in this section). The affected source includes lumber kilns at PCWP manufacturing facilities and at any other kind of facility.
    Agricultural fiber means the fiber of an annual agricultural crop. Examples of agricultural fibers include, but are not limited to, wheat straw, rice straw, and bagasse.
    Biofilter means an enclosed control system such as a tank or series of tanks with a fixed roof that contact emissions with a solid media (such as bark) and use microbiological activity to transform organic pollutants in a process exhaust stream to innocuous compounds such as carbon dioxide, water, and inorganic salts. Wastewater treatment systems such as aeration lagoons or activated sludge systems are not considered to be biofilters.
    Capture device means a hood, enclosure, or other means of collecting emissions into a duct so that the emissions can be measured.
    Capture efficiency means the fraction (expressed as a percentage) of the pollutants from an emission source that are collected by a capture device.
    Catalytic oxidizer means a control system that combusts or oxidizes, in the presence of a catalyst, exhaust gas from a process unit. Catalytic oxidizers include regenerative catalytic oxidizers and thermal catalytic oxidizers.
    Combustion unit means a dryer burner, process heater, or boiler. Combustion units may be used for combustion of organic HAP emissions.
    Control device means any equipment that reduces the quantity of HAP emitted to the air. The device may destroy the HAP or secure the HAP for subsequent recovery. Control devices include, but are not limited to, thermal or catalytic oxidizers, combustion units that incinerate process exhausts, biofilters, and condensers.
    Control system or add-on control system means the combination of capture and control devices used to reduce HAP emissions to the atmosphere.
    Conveyor strand dryer means a conveyor dryer used to reduce the moisture of wood strands used in the manufacture of oriented strandboard, laminated strand lumber, or other wood strand-based products. A conveyor strand dryer is a process unit.
    Conveyor strand dryer zone means each portion of a conveyor strand dryer with a separate heat exchange system and exhaust vent(s). Conveyor strand dryers contain multiple zones (e.g., three zones), which may be divided into multiple sections.
    Deviation means any instance in which an affected source subject to this subpart, or an owner or operator of such a source:
    (1) Fails to meet any requirement or obligation established by this subpart including, but not limited to, any compliance option, operating requirement, or work practice requirement;
    (2) Fails to meet any term or condition that is adopted to implement an applicable requirement in this subpart, and that is included in the operating permit for any affected source required to obtain such a permit; or
    (3) Fails to meet any compliance option, operating requirement, or work practice requirement in this subpart during startup, shutdown, or malfunction, regardless of whether or not such failure is permitted by this subpart. A deviation is not always a violation. The determination of whether a deviation constitutes a violation of the standard is up to the discretion of the entity responsible for enforcement of the standards.
    Direct-fired process unit means a process unit that is heated by the passing of combustion exhaust through the process unit such that the process material is contacted by the combustion exhaust.
    Dryer heated zones means the zones of a softwood veneer dryer or fiberboard mat dryer that are equipped with heating and hot air circulation units. The cooling zone(s) of the dryer through which ambient air is blown are not part of the dryer heated zones.
    Dry forming means the process of making a mat of resinated fiber to be compressed into a reconstituted wood product such as particleboard, oriented strandboard, medium density fiberboard, or hardboard.
    Dry rotary dryer means a rotary dryer that dries wood particles or fibers with a maximum inlet moisture content of less than or equal to 30 percent (by weight, dry basis) and operates with a maximum inlet temperature of less than or equal to 600 °F. A dry rotary dryer is a process unit.
    Engineered wood product means a product made with lumber, veneers, strands of wood, or from other small wood elements that are bound together with resin. Engineered wood products include, but are not limited to, laminated strand lumber, laminated veneer lumber, parallel strand lumber, wood I-joists, and glue-laminated beams.
    Fiber means the discrete elements of wood or similar cellulosic material, which are separated by mechanical means, as in refining, that can be formed into boards.
    Fiberboard means a composite panel composed of cellulosic fibers (usually wood or agricultural material) made by wet forming and compacting a mat of fibers. Fiberboard density generally is less than 0.50 grams per cubic centimeter (31.5 pounds per cubic foot).
    Fiberboard mat dryer means a dryer used to reduce the moisture of wet-formed wood fiber mats by applying heat. A fiberboard mat dryer is a process unit.
    Flame zone means the portion of the combustion chamber in a combustion unit that is occupied by the flame envelope.
    Furnish means the fibers, particles, or strands used for making boards.
    Glue-laminated beam means a structural wood beam made by bonding lumber together along its faces with resin.
    Green rotary dryer means a rotary dryer that dries wood particles or fibers with an inlet moisture content of greater than 30 percent (by weight, dry basis) at any dryer inlet temperature or operates with an inlet temperature of greater than 600 °F with any inlet moisture content. A green rotary dryer is a process unit.
    Group 1 miscellaneous coating operations means application of edge seals, nail lines, logo (or other information) paint, shelving edge fillers, trademark/gradestamp inks, and wood putty patches to plywood and composite wood products (except kiln-dried lumber) on the same site where the plywood and composite wood products are manufactured. Group 1 miscellaneous coating operations also include application of synthetic patches to plywood at new affected sources.
    Hardboard means a composite panel composed of inter-felted cellulosic fibers made by dry or wet forming and pressing of a resinated fiber mat. Hardboard generally has a density of 0.50 grams per cubic centimeter (31.5 pounds per cubic foot) or greater.
    Hardboard oven means an oven used to heat treat or temper hardboard after hot pressing. Humidification chambers are not considered as part of hardboard ovens. A hardboard oven is a process unit.
    Hardwood means the wood of a broad-leafed tree, either deciduous or evergreen. Examples of hardwoods include, but are not limited to, aspen, birch, poplar, and oak.
    Hardwood veneer dryer means a dryer that removes excess moisture from veneer by conveying the veneer through a heated medium on rollers, belts, cables, or wire mesh. Hardwood veneer dryers are used to dry veneer with less than 30 percent softwood species on an annual volume basis. Veneer kilns that operate as batch units, veneer dryers heated by radio frequency or microwaves that are used to redry veneer, and veneer redryers (defined elsewhere in this section) that are heated by conventional means are not considered to be hardwood veneer dryers. A hardwood veneer dryer is a process unit.
    Kiln-dried lumber means solid wood lumber that has been dried in a lumber kiln.
    Laminated strand lumber (LSL) means a composite product formed into a billet made of thin wood strands cut from whole logs, resinated, and pressed together with the grain of each strand oriented parallel to the length of the finished product.
    Laminated veneer lumber (LVL) means a composite product formed into a billet made from layers of resinated wood veneer sheets or pieces pressed together with the grain of each veneer aligned primarily along the length of the finished product. Laminated veneer lumber is also known as parallel strand lumber (PSL).
    Lumber means boards or planks sawed or split from logs or timber, including logs or timber processed for use as utility poles or other wood components. Lumber can be either green (non-dried) or dried. Lumber is typically either air-dried or kiln-dried.
    Lumber kiln means an enclosed dryer operated by applying heat to reduce the moisture content of lumber.
    Medium density fiberboard (MDF) means a composite panel composed of cellulosic fibers (usually wood or agricultural fiber) made by dry forming and pressing of a resinated fiber mat.
    Method detection limit means the minimum concentration of an analyte that can be determined with 99 percent confidence that the true value is greater than zero.
    Miscellaneous coating operations means application of any of the following to plywood or composite wood products: edge seals, moisture sealants, anti-skid coatings, company logos, trademark or grade stamps, nail lines, synthetic patches, wood patches, wood putty, concrete forming oils, glues for veneer composing, and shelving edge fillers. Miscellaneous coating operations also include the application of primer to oriented strandboard siding that occurs at the same site as oriented strandboard manufacture and application of asphalt, clay slurry, or titanium dioxide coatings to fiberboard at the same site of fiberboard manufacture.
    Molded particleboard means a shaped composite product (other than a composite panel) composed primarily of cellulosic materials (usually wood or agricultural fiber) generally in the form of discrete pieces or particles, as distinguished from fibers, which are pressed together with resin.
    MSF means thousand square feet (92.9 square meters). Square footage of panels is usually measured on a thickness basis, such as [3]⁄8 -inch, to define the total volume of panels. Equation 6 of §63.2262(j) shows how to convert from one thickness basis to another.
    Nondetect data means, for the purposes of this subpart, any value that is below the method detection limit.
    Non-HAP coating means a coating with HAP contents below 0.1 percent by mass for Occupational Safety and Health Administration-defined carcinogens as specified in 29 CFR 1910.1200(d)(4), and below 1.0 percent by mass for other HAP compounds.
    1-hour period means a 60-minute period.
    Oriented strandboard (OSB) means a composite panel produced from thin wood strands cut from whole logs, formed into resinated layers (with the grain of strands in one layer oriented perpendicular to the strands in adjacent layers), and pressed.
    Oven-dried ton(s) (ODT) means tons of wood dried until all of the moisture in the wood is removed. One oven-dried ton equals 907 oven-dried kilograms.