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

This survey instruction document provides instructions for completing the PCWP Information Collection Request (ICR). This instruction document is organized as follows:
Table of Contents
A.	Introduction	2
A1. Survey Applicability	2
A2. Survey Spreadsheets and Scope	3
B.	Confidential Business Information (CBI)	6
C.	How to Submit Your Survey Response	6
C1. 	Submitting Your Non-CBI Response	7
C2. 	Submitting Claimed CBI	8
D.	How to Complete the Survey	9
D1. 	Flow Diagrams	10
D2. 	Facility Emission Point Map	10
D3. 	Process Data Tabs (PCWP_survey.xlsx)	11
a. 	Mill tab	18
b. 	Product (Prod) tab	19
c. 	Equipment Detail (EquipDetail) tab	20
d. 	Release Point Detail (ReleasePt) tab	29
e. 	Permit Limits (Permit) tab	36
f. 	Resin and Tank (Resin and Tank) tabs	36
g. 	Dryer (VeneerDry, RotaryDry, TubeDry, ConvDry, LKiln, and DFDryFuel) tabs	37
h. 	Fiberboard and Hardboard Equipment (FB_HB) tab	39
i. 	Press and Board Cooler (Press, BC, and EWPPress) tabs	39
j.	Other Equipment (OtherEquip) tab	40
k.	Control Devices (APCD) tab	41
l. 	Startup, Shutdown, Malfunction (SSM) tab	44
m. 	Miscellaneous Coatings (MiscCoat) tab	44
n. 	Wastewater (WW) tab	45
D4. 	Emissions Data (PCWP_survey.xlsx and PCWP_CEMS.xlsx)	46
a. 	Emissions Tests (EmTest) tab	46
b. 	Emissions Estimates (HAP Emissions) tab	49
c. 	CEMS data (PCWP_CEMS.xlsx)	59
Appendix 1A. Documentation of True Area Source, Non-Operational, or Non-Applicable Status	61
Appendix 1B. Documentation of Synthetic Area Source Status	62
Appendix 2. Process Units to Include in the PCWP Survey Response	63
Appendix 3. Previous Emissions Test Reports Requested	64
Appendix 4. Acronyms and Abbreviations	66
Appendix 5. Checklist of Materials to Submit with Your Survey Response	68
Appendix 6A. CEDRI Upload Instructions	69
Appendix 6B. Instructions for CEDRI Registration Through CDX	75
Appendix 7. Plywood and Composite Wood Products NESHAP Definitions	91
Appendix 8. Industry Source Classification Code Crosswalk	101
Appendix 9. List of Hazardous Air Pollutants	143
Appendix 10. Resources for Estimating Emissions	147

A.	Introduction
A1. Survey Applicability
The Plywood and Composite Wood Products (PCWP) industry information collection request (ICR) is a survey that applies to facilities that are major sources or synthetic area sources of hazardous air pollutant (HAP) emissions that produce PCWP or kiln-dried lumber or are otherwise subject to the National Emission standards for Hazardous Air Pollutants: Plywood and Composite Wood Products, 40 CFR part 63, subpart DDDD (hereafter referred to as the "PCWP NESHAP").
The following types of facilities must respond to this ICR:
PCWP manufacturing facilities that produce:
Softwood plywood and/or veneer,
Hardwood plywood and/or veneer,
Oriented strandboard (OSB),
Particleboard,
Hardboard,
Fiberboard,
Medium density fiberboard (MDF) or related products such as high density fiberboard (HDF) or thin high density fiberboard (THDF),
Engineered wood products such as laminated veneer lumber (LVL), laminated strand lumber (LSL), parallel strand lumber (PSL), wood I-joists, or glue-laminated beams, or
Kiln-dried lumber
Lumber manufacturing facilities that produce:
Kiln-dried lumber
This survey is limited to sources that are major or synthetic area sources which are described as follows:
"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.
Certain facilities are not required to complete the PCWP survey. You received this survey because EPA records indicate the PCWP NESHAP is applicable to your facility or your facility is a synthetic area source. 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 1A of this instruction document and email it to the EPA at<EMAIL_ADDRESS>You are required to complete this survey unless you meet one of the three exemption criteria listed below. Conditions for exemption from the PCWP 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 2016, remains closed, and does not have an active operating permit, or
Your facility is not a PCWP manufacturing facility as defined in the PCWP NESHAP at 40 CFR 63.2292. The definition is as follows:
             Plywood and composite wood products (PCWP) manufacturing facility means a facility that manufactures plywood and/or composite wood products by bonding wood material (fibers, particles, strands, veneers, etc.) or agricultural fiber, generally with resin under heat and pressure, to form a panel, engineered wood product, or other product defined in §63.2292. Plywood and composite wood products manufacturing facilities also include facilities that manufacture dry veneer and lumber kilns located at any facility. Plywood and composite wood products include, but are not limited to, plywood, veneer, particleboard, molded particleboard, oriented strandboard, hardboard, fiberboard, medium density fiberboard, laminated strand lumber, laminated veneer lumber, wood I-joists, kiln-dried lumber, and glue-laminated beams.
Completion of the survey is not required if your facility was not operational in 2016 and remains closed but still has an active operating permit. Closed facilities that maintain an active operating permit will be included in the EPA's residual risk modeling based on the emissions allowed under their operating permit. Such facilities are asked in Appendix 1A to provide a copy of their active operating permit for the EPA to use in developing emission estimates for input into the risk model.
If your facility is a synthetic area source that is not subject to the PCWP NESHAP, then you should complete the form titled "Documentation of Synthetic Area Source Status" in Appendix 1B of this instruction document and email it to EPA at<EMAIL_ADDRESS>As noted in Appendix 1B, you are also asked to submit a valid operating permit and, if applicable, any stack test report(s) for air emissions testing used to verify HAP emissions qualify for synthetic area source status. Facilities eligible for completion of the form in Appendix 1B are not required to complete the full survey.
Who do I contact with questions about the ICR?

   If you have questions, contact the EPA's PCWP ICR Helpdesk at<EMAIL_ADDRESS>or by calling<PHONE_NUMBER> (toll free) from 8:00 to 5:00 Monday through Friday eastern standard time. In order for us to better assist you, we ask that you provide your ICR ID in any communications.
Who do I contact with questions about the ICR?

   If you have questions, contact the EPA's PCWP ICR Helpdesk at<EMAIL_ADDRESS>or by calling<PHONE_NUMBER> (toll free) from 8:00 to 5:00 Monday through Friday eastern standard time. In order for us to better assist you, we ask that you provide your ICR ID in any communications.
A2. Survey Spreadsheets and Scope
This survey is to be completed in Microsoft Excel(C) spreadsheet format that is divided into worksheets or "tabs" within the spreadsheet. Facilities submitting the forms in Appendix 1A or Appendix 1B are not required to complete the survey spreadsheet. There are two spreadsheets to be completed: (1) PCWP_survey.xlsx (hereafter also referred to as the "ICR survey spreadsheet") for all major source facilities, and (2) PCWP_CEMS.xlsx for all major source facilities operating continuous emissions monitors. Blank copies of the survey spreadsheets can be downloaded from:
https://epa.gov/stationary-sources-air-pollution/information-collection-plywood-and-composite-wood-products-industry
You must complete the worksheets that are relevant to the type facility you operate. Table 1 below denotes which worksheets to complete depending on the products you manufacture. A separate column denotes which worksheets are required for facilities that manufacture PCWP versus lumber facilities that do not otherwise produce PCWP. Lumber facilities that do not produce other PCWP only need to provide information for lumber kilns.
Table 1. Survey Worksheets ("tabs") to Complete
Tab full name
Tab abbreviation
What types of PCWP facilities complete this tab?
Do lumber facilities with kilns complete this tab?
PCWP_survey.xlsx
Mill
Mill
All PCWP facilities
Yes
Products
Prod
All PCWP facilities
Yes
Equipment Detail
EquipDetail
All PCWP facilities
Yes, for lumber kilns only
Release Point Detail
ReleasePt
All PCWP facilities
Yes, for lumber kilns only
Permit
Permit
All PCWP facilities
Yes, for lumber kilns only
Resins
Resin
All PCWP facilities applying adhesive. Veneer-only facilities do not need to complete this tab.

Tanks
Tank
All PCWP facilities applying resin. Veneer-only facilities do not need to complete this tab.

Veneer Dryer
VeneerDry
Plywood, veneer and LVL mills that operate veneer dryers

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 Units
FB_HB
Fiberboard and hardboard mills

Lumber Kilns
LKiln
PCWP facilities with lumber kilns
Yes, for lumber kilns only
Direct Fired Dryer Fuel
DFDryFuel
Any PCWP facility with a direct-fired dryer or lumber kiln
Yes, for direct-fired lumber kilns only
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

Other Equipment
OtherEquip
PCWP facilities with digesters, refiners, blenders, formers, sanders, saws, panel trim chippers, or log vats.

Control Devices
APCD
Any PCWP facility with pollution control equipment
Yes, for lumber kiln control devices only (if applicable)
Startup, Shutdown & Malfunction
SSM
Any PCWP facility for which an SSM plan was developed under the PCWP NESHAP

Miscellaneous Coatings
MiscCoat
All PCWP facilities applying a coating, including miscellaneous coating as defined in the PCWP NESHAP

Wastewater
WW
Any PCWP facility that treats wastewater generated at the plant

Emission Tests
EmTest
All PCWP facilities
Yes, for lumber kilns only
HAP Emissions
HAP Emissions
All PCWP facilities
Yes, for lumber kilns only
Certification
Certification
All PCWP facilities
Yes
PCWP_CEMS.xlsx
CEMS data
CEMS, CEMS3hr, or CEMS24hr
Facilities operating CEMS measuring THC, PM, CO or HAP on process units listed in Appendix 2 to this document

This survey asks questions about the process 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 process units (e.g., multiple process units venting to the same pollution control device stack). Appendix 3 of this survey contains a table of pollutants for which stack test reports 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.
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. Your survey response for each facility will be comprised of the survey spreadsheet(s) and other documentation requested throughout these instructions. Appendix 5 contains a checklist of materials to be provided with your response.
Only one ICR survey spreadsheet may be used for each facility with a unique Federal Registry System (FRS) identification number (ID). If your manufacturing site has collocated facilities producing multiple PCWP (e.g., your site produces both particleboard and softwood plywood but has one FRS ID) you should submit one ICR survey spreadsheet containing both facilities. Alternatively, if each of the PCWP category facilities at the manufacturing site operates under its own title V permit or has its own FRS ID, you should submit one ICR survey spreadsheet per title V-permitted facility. Relevant IDs for your facility, including the 12-digit FRS ID used in EPA systems and the shorter ICR ID assigned specifically for this PCWP project, are included in the letter your facility received to request completion of this survey. If the EPA assigned only one ICR ID to a facility that instead should be entered as two separate facilities, contact the EPA's PCWP ICR Helpdesk (see section A1) for assistance in assigning ICR IDs for your facilities. The EPA's PCWP project team will rely most heavily on the ICR ID for linkages between tables in the PCWP data base developed from ICR responses.
Use the 2016 calendar year as the base year for all survey responses (e.g., 2016 capacity, 2016 equipment configurations, 2016 HAP emissions inventory, etc.), except where other years are specified in the instructions (e.g., for submittal of previously-conducted emissions test data).
Note: If 2016 is not a representative year because the facility recently submitted a permit application or received a permit for equipment modifications that impact emissions, then you may provide post-project projections of your operations instead of 2016 information. Please note in the "comments" columns in the appropriate tabs throughout the survey that you are providing projected information. Alternatively, if your project is not far enough along to be included in your ICR response, it is acceptable to provide 2016 information and use the "comments" columns to note planned configuration changes that impact emissions. Regardless of the base year you choose, the equipment information, emissions release parameters, and emission estimates provided throughout the ICR response must be consistent.
Note that the information submitted by a facility is not 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 worksheet 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 as CBI the 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 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. This information is requested in the Mill tab of the ICR survey spreadsheet.
Emission tests and emission data.
Continuous emissions monitoring data (although the accompanying production data may be claimed as CBI).
C.	How to Submit Your Survey Response
If your response to this ICR 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 the EPA using two different procedures.
When is my ICR Response Due?

   Your non-CBI and CBI responses are due by the date specified in the letter you received requesting completion of the ICR.
When is my ICR Response Due?

   Your non-CBI and CBI responses are due by the date specified in the letter you received requesting completion of the ICR.
C1. 	Submitting Your Non-CBI Response
Follow these instructions for the non-CBI portions of your survey response (or for complete responses that are entirely non-CBI.)
After you have completed and reviewed your survey response, sign and date the certification tab in the ICR survey spreadsheet. Remove the claimed CBI components from your ICR survey spreadsheet and your CEMS spreadsheet (if applicable) as instructed in Section C2, leaving only the red shading and replacing the claimed CBI data with the letters "CBI." Assemble 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. Assemble any non-CBI hard copy attachments to your survey (such as 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 5.
CEDRI Upload (Preferred): Upload your non-CBI materials into the EPA's Compliance and Emissions Data Reporting Interface (CEDRI) following the instructions in Appendix 6. Do not upload CBI into CEDRI. All CBI must be mailed separately to Ms. Purifoy as explained in Section C2.
Optional Disk Mail-in: If you would prefer to mail your ICR response to the EPA instead of using CEDRI, please save the non-CBI portions of your response on a disk (CD or DVD) or flash drive. Please clearly label and mail the non-CBI disk (or flash drive) and any non-CBI hard copy materials in one envelope postmarked to the EPA at the address specified below. (Note: If the spreadsheet, diagrams, or 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 T.W. 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. The deadline for submittal of the CBI portion of your response is the same as the deadline for the non-CBI submittal.
Please create two separate versions of your spreadsheet response. Retain the red highlighted CBI data in the ICR survey spreadsheet as shown in Example 1 below for the confidential copy of your spreadsheet. Create a separate non-CBI version of your response by redacting the confidential data in the red shaded cells and entering "CBI" instead. This non-CBI version should appear as Example 2 and be submitted to the address in Section C1 above. (Follow a similar procedure for your CEMS spreadsheet if you are claiming the production data as CBI.)
Example 1: Example showing CBI portion of ICR survey spreadsheet response:

Example 2: Example showing non-CBI ICR survey spreadsheet response after removal of CBI:

Please create and label a separate flash drive or disk containing the claimed CBI portion of your data. Include on the CBI disk the confidential version of your spreadsheet(s). You should also include 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 confidential disk with the words "Confidential Business Information" and send only these claimed CBI files, separately from the non-CBI data, to one of the two addresses below.
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.
Please use the address below for CBI sent via U.S. postal service:
Ms. Tiffany Purifoy
Government Information Specialist (C404-02)
ATTN: PCWP Manufacturing RTR (Project #279)
Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Please use the address below for CBI sent via commercial package carriers, such as FedEx and UPS:
Ms. Tiffany Purifoy
Government Information Specialist (C404-02)
ATTN: PCWP Manufacturing RTR (Project #279)
Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency
4930 Old Page Rd.
Research Triangle Park, NC 27709
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. Similarly, do not upload CBI into CEDRI.
D.	How to Complete the Survey
As noted previously, your survey response will consist of completed Microsoft(C) Excel(R) spreadsheets (PCWP_survey.xlsx and PCWP_CEMS.xlsx), flow diagrams, test reports, and other materials. A checklist of materials to be provided with your response is included in Appendix 5.
You must complete certain tabs of the ICR survey spreadsheet (PCWP_survey.xls) depending on the type of facility you operate as shown in Table 1 above. The instructions in Sections D3a through D4b below will guide you through completion of the ICR survey spreadsheet.
Complete the PCWP_CEMS.xlsx spreadsheet following the instructions in Section D4c if you have continuous emissions monitoring data to submit.
The spreadsheets will be used by the EPA to construct a nationwide data base of responses from all PCWP facilities. The spreadsheets have been designed and locked with features to reduce data entry time and ensure the data are provided in the most consistent and quality-assured manner possible. The beginning of Section D3 describes key features of the spreadsheets.
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 process 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 process 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 and at a minimum, should clearly indicate the Emission Release Point ID and location of each emission point expected to emit HAP from process units listed in Appendix 2. The locations of the emission points provided in the map should correspond with the coordinates (longitude and latitude) for the Emission Release Point IDs required to be provided in the Release Point (ReleasePt) tab described in Section D3d. These coordinates are used for residual risk modeling; specifying coordinates for each Emission Release Point ID improves the accuracy of the risk modeling. Creating the emission point map assures that the coordinates provided are correctly positioned on the facility property.
Although optional, it would also be helpful if the facility fence-line (property boundary) is indicated on the map. If you choose to do so, you may also indicate the length and width parameters for fugitive area and volume sources (i.e., draw a rectangle on the map that corresponds to the lengths and widths described in Section D3d of these instructions). The EPA will use the release point map to answer any questions that arise from the risk modeling. Having a map showing the emission points and property boundary will usually allow the EPA to resolve questions about the location of emission releases or nearby human receptors without having to contact your facility to ask questions.
See Figure 1 for an example of a facility emission point map without the optional features of the facility fence-line and length and width parameters. The numbers shown in Figure 1 are the Emission Release Point IDs. The yellow circles denote point sources, the red squares denote the midpoint coordinates for fugitive two-dimensional sources, and the blue stars denote the center of a fugitive three-dimensional source.

Figure 1: 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 ICR survey spreadsheet (Mill, Prod, etc.). Many of the instructions you need for completing the tabs are included in the "Instruction" row of each tab in the ICR survey spreadsheet. Additional information is provided in this document to account for common situations and to provide information on how the data will be used by the EPA.
You will enter data into the white (unshaded) cells. Gray shaded columns are prepopulated based on inputs from previous tabs. Information in these gray columns will update automatically as you work. The spreadsheet contains drop-down menus for common entries. The drop-down menus are indicated by the triangle that appears next to the cell when clicked. Figure 2 provides a screen shot with annotations illustrating the spreadsheet format. Cells where data entry is not permitted are locked to prevent inclusion of data outside of the area that will be incorporated into the EPA's data base of responses.
                           Instructions and examples
                              Pre-populated data
                                Drop-down menus
                          User manually entered data
Figure 2: Screenshot of survey shading

Tab completion order. Refer to Table 1 in Section A2 to determine which of the PCWP Process tabs you will need to fill out for your facility. The tabs are organized by process unit type. If your facility does not operate a process covered by the tab, ignore that tab.
It is very important that you work through the ICR survey spreadsheet tabs moving from left to right, beginning with the Mill tab because many tabs will contain prepopulated data from other tabs previously completed. A few columns of data that you supply include notations in bold in the spreadsheet "Instruction" row to indicate that these columns contain data that will be used to prepopulate other tabs of the ICR survey spreadsheet.
As you work through the ICR survey spreadsheet, you may realize that you do not have the information in front of you that you need to answer certain detailed questions. The general instruction to work through the spreadsheet from left to right does not necessarily mean that you must answer every question on a tab before you may move forward. However, there are certain fields that should be completed at a minimum to ensure that the data prepopulate correctly throughout the spreadsheet. The left side of Table 2 shows the fields carried forward from each tab that must be completed before moving on to the tabs listed on the right side of Table 2.
Table 2. Completion Order for ICR survey spreadsheet
Complete...

Before you complete...
Tab Name
Field Carried Forward to Other Tabs
Tab Name
Mill
ICR ID
FRS Site ID
All
Prod
Product
EquipDetail, Resin, Tank, BC, EWPPress, APCD, MiscCoat, EmTest

Product Line
EquipDetail, Resin, Tank, VeneerDry, RotaryDry, TubeDry, ConvDry, Press, EmTest

Does this product use a resin?
Resin
EquipDetail
Process Unit ID
ReleasePt, Permit, Tank, VeneerDry, RotaryDry, TubeDry, ConvDry, FB_HB, LKiln, DFDryFuel, Press, BC, EWPPress, OtherEquip, SSM, EmTest, HAP Emissions

Process Unit Type
ReleasePt, Permit, VeneerDry, RotaryDry, TubeDry, ConvDry, FB_HB, DFDryFuel, Press, OtherEquip, APCD, SSM, EmTest, HAP Emissions

Process Unit Description
OtherEquip

APCD 1/2/3/4 Type
APCD 1/2/3/4 ID
APCD

Air Pollution Control System
APCD, HAP Emissions

Total Number of Emission Release Points from the Process Unit
Emission Release Point ID 1/2/3/4/5
ReleasePt, EmTest, HAP Emissions

Process Unit 2016 Operating Hours (hr/yr)
HAP Emissions*

PCWP compliance option used to demonstrate compliance with the most recent test
Permit
Release Pt
SCC
HAP Emissions*
Resin
Resin ID
Resin or Scavenger Type
Tank, OtherEquip
VeneerDry
Firing Method
DFDryFuel

2016 Dryer Throughput
2016 Dryer Throughput Unit of Measure
HAP Emissions*
RotaryDry
Firing Method
DFDryFuel

2016 Dryer Throughput (ODT/yr)
HAP Emissions*
TubeDry
Firing Method
DFDryFuel

2016 Dryer Throughput (ODT/yr)
HAP Emissions*
ConvDry
Firing Method
DFDryFuel

2016 Dryer Throughput (ODT/yr)
HAP Emissions*
FB_HB
Annual Throughput (MSF/yr)
Thickness basis for previous column (inches)
HAP Emissions*
LKiln
Firing Method
DFDryFuel

2016 Kiln Throughput (MBF/yr)
HAP Emissions*
DFDryFuel
Burner or combustion unit hourly heat input capacity (MMBtu/hr)
Combustion unit primary fuel
Approximate percent of annual heat input capacity (MMBtu/yr) supplied by primary fuel in 2016
Combustion unit supplemental fuel 1/2
Approximate percent of annual heat input capacity (MMBtu/yr) supplied by supplemental fuel 1/2
HAP Emissions*
Press
Press throughput (MSF/yr)
Press throughput board thickness basis (inches)
HAP Emissions*
BC
Cooler throughput (MSF/yr (3/4)")
HAP Emissions*
EWPPress
Annual press throughput
Press throughput units of measure
HAP Emissions*
OtherEquip
Nominal Annual Throughput Capacity Value
Throughput units of measure
HAP Emissions*
*The field is used to prepopulate the optional provisional calculations included in the HAP Emissions tab.

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. In some tabs, prepopulation occurs as you begin entering data (e.g., the ICR ID populates once you enter a product in Prod).
Also, as you work through the ICR survey spreadsheet from left to right, if you determine that you need to return to a tab to make adjustments, it is suggested that you review the subsequent tabs that may be affected by the change (see Table 2 for guidance regarding which tabs may be affected based on the field you change). Please be aware that adding a process unit or changing its process unit type in the EquipDetail tab after completing subsequent tabs can cause information entered in the white cells of subsequent tabs to misalign with the prepopulated process units. Adding units at the end of the process unit list in the EquipDetail tab should prevent these issues. Reviewing subsequent tabs after making a change will allow you to catch and correct any errors in the information.
Drop-down menus. The ICR survey spreadsheet contains drop-down menus that function best in Excel(R) version 2010 or higher. See the box below if you have an older version of Excel. Use these drop-down menus whenever possible.
Note: A printout of the spreadsheet showing the survey questions and most drop-down menu choices is available on the ICR website for reference. Lengthy drop-down menus that do not fit on a single page are noted to indicate where to locate the menu choices appearing in the spreadsheet.
Some columns with drop-down menus allow you to write in information if your selection is not contained in the drop-down menu, while others require use of the drop-down menu choices. Selections appearing as "Other: {specify}" indicate that you may write in a site-specific response in place of the word {specify}. For example, your written-in response may be "Other: use a unique low-emitting material."
Note: By default, only eight drop-down menu choices are visible on the screen at one time. Where more than eight menu choices exist, you may need to scroll up or down in the menu to find your choice. If you encounter a menu that appears blank, try scrolling up to see the choice.
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 use LibreOffice (http://www.libreoffice.org) to open the ICR survey spreadsheet. LibreOffice is open source software 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 survey spreadsheet. If you choose to use LibreOffice Calc, please keep the ICR survey 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 use LibreOffice (http://www.libreoffice.org) to open the ICR survey spreadsheet. LibreOffice is open source software 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 survey spreadsheet. If you choose to use LibreOffice Calc, please keep the ICR survey spreadsheet in Excel format (xlsx) when saving your changes (i.e., do not change to LibreOffice format if prompted during the save).

Adding Comments. A "comments" column is included as the right-most column of each tab should you wish to supply any comments on the information provided. Please use the "comments" column for any notes. The in-cell pop-up comments feature has been disabled in the locked spreadsheets because notes made using pop-up comments will not transfer into the EPA's PCWP data base.
In addition to the drop-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 the EPA's data base. If you receive an error message for responses exceeding the allotted number of 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. These warnings are designed to help prevent common data entry errors, such as preventing facilities from entering million square feet data when the required data are in thousand square feet units.
Identification numbers. Several IDs are requested throughout the ICR survey spreadsheet, including:
ICR ID
FRS Site ID
Process Unit ID
Emission Release Point ID
APCD_ID
As noted in Section A2 above, the ICR ID and FRS Site IDs are used to identify your facility. The ICR and FRS IDs may be found in the letter that you received from the EPA instructing you to complete this survey. It is important you enter the correct ICR ID for your facility as this ID will be used to identity your facility's data when we compile all of the ICR responses into the PCWP data base.
The Process Unit IDs, Emission Release Point IDs, and APCD_IDs are identifiers for each process 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 IDs from your permit. Regardless of the IDs you specify, it is imperative that you use this same ID to identify the facility, equipment/process unit, and emission release point consistently throughout all parts of this survey.
Although many PCWP facilities have emissions estimates in the most recent version of the EPA's National Emission Inventory (NEI), the EPA is requesting you provide 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 for 2014 are available at https://www.epa.gov/air-emissions-inventories/2014-national-emissions-inventory-nei-data if you would like to see the information available for your facility. If HAP data are included in the NEI for your facility, the NEI data base may provide Process Unit IDs, Emission Release Point IDs, and other information that you may wish to use to complete your PCWP ICR response. You are not required to use the NEI data for your facility.
Supplying process data. In several parts of the survey, the EPA requests production, throughput, capacity, operating hours and related process information. Unless otherwise specified, the EPA is seeking nominal or typical operating rates that can be used by the agency to compare the relative size of facilities or process units. The EPA is interested in capacity values that can 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. You may use the press line nominal capacity (throughput) for all equipment in the press line.
Similarly, several questions in the spreadsheet 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 parameter with an online meter and you have data available for most operating hours of the year, then you may choose to provide 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 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:

      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.

      Blanks: You may also leave obviously inapplicable questions blank.

   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, surveys with an excessive number of responses as "UK," "NA" or blank will receive additional scrutiny and survey respondents are more likely to receive follow-up inquiries from the EPA related to their survey responses.
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:

      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.

      Blanks: You may also leave obviously inapplicable questions blank.

   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, surveys with an excessive number of responses as "UK," "NA" or blank will receive additional scrutiny and survey respondents are more likely to receive follow-up inquiries from the EPA related to their survey responses.

 You may also use the Excel ribbon commands, choosing "paste values" as shown.

Can I paste data into the ICR survey spreadsheet?
Yes, with Caution! If you choose to copy information from another document or from another location within the ICR survey spreadsheet, you MUST paste the data using the "paste as values" function, following the steps outlined below. Failure to do so may override programming and formatting needed for the ICR survey spreadsheet to work correctly. Steps to paste values:
Copy the desired data.
Select the first cell of the ICR survey spreadsheet into which you plan to paste the data.
Right click and select "Paste Special."
Select "Values."
Note: It is highly recommended that you copy and paste small amounts of data at one time until you are sure that the data you are pasting are being inserted into the correct cells and meet all the data validation criteria for those cells. Do not paste formats.
Also, please use caution if copying data by dragging down columns. Watch for and correct any unintended incrementing of numbers, and do not copy data into the hidden area below the data entry table.

Can I paste data into the ICR survey spreadsheet?
Yes, with Caution! If you choose to copy information from another document or from another location within the ICR survey spreadsheet, you MUST paste the data using the "paste as values" function, following the steps outlined below. Failure to do so may override programming and formatting needed for the ICR survey spreadsheet to work correctly. Steps to paste values:
Copy the desired data.
Select the first cell of the ICR survey spreadsheet into which you plan to paste the data.
Right click and select "Paste Special."
Select "Values."
Note: It is highly recommended that you copy and paste small amounts of data at one time until you are sure that the data you are pasting are being inserted into the correct cells and meet all the data validation criteria for those cells. Do not paste formats.
Also, please use caution if copying data by dragging down columns. Watch for and correct any unintended incrementing of numbers, and do not copy data into the hidden area below the data entry table.

a. 	Mill tab
Complete the columns following the instructions provided in the "Instruction" row. Your response in the Mill tab will consist of one row of data. These data will be used by the EPA to characterize your facility and identify applicable regulations.
Facility identifiers. Enter your ICR ID and FRS ID in the appropriate column. These IDs may be found in the letter instructing you to complete this survey.
Facility Location, Contact and Owner Information. Enter the location, a facility contact name for facility-specific follow up on the survey (if needed), and the facility owner. If the facility is located on tribal land, select from the tribal name drop-down menu to get the tribal code. If the physical and mailing address are identical, answering "Yes" in the first mailing address column will fill in the mailing address.
Operating status. Indicate the operating status for the facility by selecting one of the following: operating, seasonal/partial year, or temporarily closed. Facilities that operated more or less continuously throughput the year should choose "operating." Facilities that were temporarily closed for all of 2016 should indicate "temporarily closed," and facilities closed for a large portion of 2016 may choose "seasonal/partial year." The next column asks for an explanation for facilities selecting "seasonal/partial year" or "temporarily closed."
Company Revenue and Dun & Bradstreet. Provide the 2016 revenue for the parent company. This information will be used in economic analyses.
Size of entity. The EPA needs to identify small businesses for consideration in impact analyses. 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 3 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 3 for small business questions in the PCWP survey. For reference, the Small Business Size Regulations codified at 12 CFR 121.06.
Table 3. Small Business Size Standards for NAICS Subsector 321
 -  Wood Product Manufacturing
NAICS code
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 June 6, 2017 at: https://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf.
Federal rule coverage. Use the drop-down menu to identify the Federal rules that are applicable to the facility. Choose "NA" if the rule is not applicable because the facility has a permit condition that makes the facility a synthetic area source. Indicate applicable subcategories if subject to the Wood Building Products surface coating NESHAP. The most-likely rules applicable to industry sources are listed. List other NESHAP or NSPS rules that are applicable.
b. 	Product (Prod) tab
Enter information about PCWP products or kiln-dried lumber produced, product lines, production, and capacity in this tab.
Products and Other Product Information. List all PCWP products produced at the plant site. Use one row per product. Mills with multiple products will have multiple rows.
Veneer and plywood mills should list veneer and plywood as two separate products entered on separate rows even if all the veneer is used onsite to manufacture plywood. A separate question in column K asks facilities to specify the proportion of  the "product used or sold within company to manufacture other products" and provides the choices: NA, <50%, 50-100%, and 100%. Plywood producers using all the veneer produced to make plywood should select 100%. An answer of "NA" is appropriate for other products that are not used to make other PCWP products. Facilities transferring products within the company, either onsite or at a different site, to make additional PCWP products should enter the appropriate percentage of product used within the company. Information is also requested for major markets. This information will be informative for the EPA's economic analysis.
The core material for hardwood plywood is requested with hardwood/softwood plywood and veneer, MDF, particleboard, and lumber provided as menu choices.
Facilities integrating agricultural fiber into products are asked to describe the "use of agricultural fiber." The description provided should include the type of agricultural fiber (e.g., bagasse, wheat straw). The EPA is interested in understanding whether the product is primarily agricultural fiber or a blend of wood and agricultural fiber. For a product that is made from wood and wheat straw, for example, you should indicate the product is approximately 75% wood and 25% wheat straw.
Questions regarding whether a product uses a resin and the number of resins used seek to identify significantly different types of adhesives such as phenol-formaldehyde resin, MDI, or PVA. If you select "Yes" indicating that the product uses resin, you are asked to enter details about the resin in Resin tab. Select "No" for products such as fiberboard that do not require resin but rely on natural binders (e.g., lignin) to adhere fibers. Select "NA" for products such as softwood veneer or lumber that do not require resin. Do not consider waxes or other non-adhesive additives when making your selection.
Product lines. Product lines often correspond with press lines. For example, if there are two presses at a mill making two distinctly different products, then you should 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 general resin formulation) then it is acceptable to enter only one product line that sums the capacity/production from all presses. 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 this ICR, significantly 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. Do not provide information for temporary mill trials or minor variations of different resin formulations.
Production and capacity. Provide the nominal mill production rate and capacity for each product line identified for the survey base year (2016). Use the units of measure in Table 4 for reporting production and capacity.
Table 4. Production and Capacity Units of Measure
Product
Units of measure for reporting production and capacity1
Veneer
MSF/yr
Lumber and glulam
MBF/yr
Fiberboard
MSF/yr 1/2"
Hardboard
MSF/yr 1/8"
Particleboard, MDF2
MSF/yr 3/4"
Hardwood and softwood plywood, OSB, and any other plywood panel products
MSF/yr 3/8"
LVL, LSL, and PSL
MCF/yr
I-joists
MLF/yr
1 "M" refers to thousand (e.g., MSF = thousand square feet)
2 Includes molded particleboard and particleboard or MDF produced with agricultural fiber.

c. 	Equipment Detail (EquipDetail) tab
All facilities must complete the EquipDetail tab. This tab asks for information for each individual process unit, its air pollution control device(s) (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 emission standards. This tab will provide the EPA with nationwide numbers of equipment, configuration of controls, pertinent equipment details, and the regulatory compliance options used. The process units and IDs you list in the EquipDetail tab will prepopulate into subsequent spreadsheet tabs prompting you to enter additional equipment-specific details for each process unit.
The types of process 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 process units and how they are delineated within the PCWP source category.
Important Notes:
   As indicated in Table 1 of these instructions, sawmills that produce kiln-dried lumber and no other PCWP products are only required to provide information for their lumber kilns in the EquipDetail tab.
   You are not required to provide information for process units outside of the PCWP NESHAP source category such as boilers or coating processes subject to other NESHAP.
   You are not required to provide information for process units that do not emit HAP.

Important Notes:
   As indicated in Table 1 of these instructions, sawmills that produce kiln-dried lumber and no other PCWP products are only required to provide information for their lumber kilns in the EquipDetail tab.
   You are not required to provide information for process units outside of the PCWP NESHAP source category such as boilers or coating processes subject to other NESHAP.
   You are not required to provide information for process units that do not emit HAP.

The Process Unit Types available in the drop-down menu for selection include:
Softwood veneer dryer
Engineered wood products press
Veneer redryer
Agricultural fiber board press
Hardwood veneer dryer
Rotary agricultural fiber dryer
Rotary strand dryer
Hardboard humidifier
Conveyor strand dryer
Stand-alone digester
Pressurized refiner
Fiber washer
Primary tube dryer
Atmospheric refiner
Secondary tube dryer
Panel trim chipper
Green rotary dryer
Log vat
Dry rotary dryer
Resin storage tank
Reconstituted wood product press
Blender
Reconstituted wood product board cooler
Former
Hardboard oven
Finishing sander
Hardboard press predryer
Finishing saw
Fiberboard mat dryer
Lumber dry kiln
Miscellaneous coating operation
Wastewater operation
Softwood plywood press
Other (see description below)
Hardwood plywood press

For the process units listed in Appendix 2, specify the Process Unit ID, Process Unit Type, APCD Type and IDs, and Emission Release Point IDs by following the directions in the Instruction row of the tab. The APCD IDs you enter in the EquipDetail tab will be used to prepopulate the APCD tab. The Emissions Release Point IDs you enter in the EquipDetail tab will be used to prepopulate the ReleasePt and HAP Emissions tabs.
Choose the Process Unit Type from the menu consistent with how process units are defined in Appendix 7, whenever possible. An "other" process unit type option is provided for HAP-emitting process units that may fall within the PCWP NESHAP source category but do not fit within the menu of PCWP process unit types provided. For example, if you have a known HAP-emitting dryer within the PCWP process that does not fit within the dryer types listed above and defined in Appendix 7, you may enter the dryer as an "other" process unit. If you use the "other" process unit option, please provide a description of the other process unit in the optional process unit description column in the EquipDetail tab. The "other" process unit type option is intended to be used with process units known to emit HAP (e.g., process units with HAP limits in the facility's operating permit and/or with quantified HAP emissions reported in an existing inventory). The "other" process unit option is not intended to suggest that facilities attempt to estimate traces of HAP emissions from process units that are not expected to be significant sources of HAP emissions.
Select the Product Line and Product associated with each process unit based on information supplied in the Prod tab. Individual process units should be listed once in the EquipDetail tab even if the same process unit is used to manufacture multiple products. Duplicate Process Unit IDs are not allowed because the EPA will use the information supplied in this tab to develop nationwide counts of the different types of PCWP process units. Data validation is included in the Process Unit ID column to prevent duplicate entries. Column G (Product Line) allows for write-in specification of multiple product lines, if needed. Enter each product line separated by a comma. For example, if "press 1" is used for two product lines each labeled "PrimoEcoPanel" and "StandardPanel" then "PrimoEcoPanel, StandardPanel" can be specified in column G.
Enter information in the EquipDetail tab representative of the primary operating scenario with respect to process unit, APCD, and emissions release point configuration. If the description of an alternate operating scenario is pertinent, please make a note of the alternate operating scenario in the Comments column at the far right of the EquipDetail tab.
Air Pollution Control Device Information. The EPA is interested in knowing what APCDs are in place for each process unit regardless of whether the APCD is used as a material handling dust collector (such as a cyclone or baghouse), as a particulate matter (PM) control, or as an organic HAP control device. Knowing what equipment is in place for each process unit is essential for the EPA to characterize equipment trends on nationwide basis and to perform regulatory baseline and regulatory impact analyses.
If a process unit is uncontrolled, select "None" for the APCD 1 type and leave the APCD 1 ID column blank. Otherwise select the APCD type and provide an APCD ID for each control device. Provide APCDs in the order they appear in the control sequence for your process unit. The following APCD Type codes are included in the selection menu:
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)
SINC - Partial process incineration (incineration of a portion of the exhaust in a combustion unit)
BIO  -  Biofilter or Bioscrubber
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}1                                                                                1 Replace the word "{specify}" with a description.

Notes for the APCD columns:
You may omit product recovery cyclones that precede other air pollution controls from the APCD columns (e.g., where furnish exiting a dryer is collected in a cyclone that vents to another control device). Product recovery cyclones are understood to be in place, and the subsequent controls are of interest.
If you have APCDs in parallel, provide both of them and add a note in the Comments column to explain the configuration (for example, if WESP-a and WESP-b each control a portion of dryer-1 exhaust, label WESP-a as APCD 1 and WESP-b as APCD 2 in the APCD type and ID columns and note the WESPs are arranged in parallel in the comments column).
Consider the predominant venting mechanism for the process unit when identifying APCDs. For example, include dust control baghouses for former pick up points in the APCD columns for the formers. You may find it helpful to review the instructions for identifying emission release points below before completing the APCD columns.
Specify the overall type of Air Pollution Control System in column Q using combinations of the APCD type codes, as needed. For an uncontrolled process unit, select "None." For a combination of controls, indicate the types of controls in the sequence, such as a "WESP/RTO" system. For systems with process units and/or controls in parallel, such as four dryers venting to four multiclones, two WESPs and two RTOs, you should enter the overall air pollution control system sequence (i.e., MC/WESP/RTO), regardless of the number of parallel units.
Emission Release Point Information. Enter the "Total Number of Emission Release Points" for each process unit. Emission release points are each stack, vent, or a fugitive emissions release from a process unit. The number of emission release points triggers conditional formatting in the Emission Release Point ID columns to indicate the number of IDs required. Some common process unit, control, and release point configurations are described below.
Note: You may find it helpful to review the ReleasePt tab instructions for selection of a release point type prior to assigning Emission Release Point IDs.
Multiple process units ducted to a single release point. You should list each process unit on a separate row in the EquipDetail tab even if the exhaust from the process unit is ducted to a common release point. For multiple process units ducted to the same release point, list each Process Unit ID (and corresponding APCD ID) separately but enter the same Emission Release Point ID.
For example, for dryers venting into a press enclosure, the APCD ID specified for the dryer should be the same as the press APCD ID. The same Emission Release Point ID should be provided for the press and the dryer exhaust stream vented through the press enclosure and out through the press control device.
Single process unit with multiple release points. If the process unit has multiple uncontrolled vents or stacks then you should list the process unit on one row, specify the APCD type ("None" for uncontrolled stacks), specify the number of release points, and provide the release point IDs in columns S through W.
If a single process unit has multiple release points with different controls (or some release points controlled and others uncontrolled), you should enter the process unit on one row in the EquipDetail tab using one Process Unit ID. Specify the applicable APCD ID(s) and APCD types for the process unit, using the Comments column to describe the configuration for the differently controlled and/or uncontrolled portions of the process unit. Add all the applicable emission release point IDs for the process unit. This will allow the Process Unit ID to prepopulate into the appropriate unit tab as one process unit, while each separate Emission Release Point ID will parse into the ReleasePt and HAP Emissions tabs for further point-by-point description. Each APCD ID will prepopulate into the APCD tab.
Process units with more than five emission release points. Space for five Emission Release Point IDs has been provided in the EquipDetail tab with the expectation the nearly all PCWP process units have or can be characterized with five or fewer emission release points. If there are more than five emission release points, particularly if the release points are uncontrolled vents located close to one-another, such as on a lumber kiln or veneer dryer cooling section, you may group these emission release points into one Emission Release Point ID. For example, if there are four roof fans near each other on a dryer cooling section you may label one release point "cooling" to represent the gas flow from all four fans). Another example would be specifying three emission release points for a 9-zone oven with uncontrolled zones a-b, followed by controlled zones c-e, followed by uncontrolled zones f-i.
The number of release points specified (and later detailed in the ReleasePt tab) will impact dispersion modeling, but grouping release points is acceptable if the HAP emissions from the release points are low and expected to be inconsequential in risk modeling. It is suggested that you review the ReleasePt tab instructions for selection of a release point type prior to grouping Emission Release Point IDs.
As a last resort, if there are more than five emission release points that are not reasonably grouped due to relatively high process unit HAP emissions and different controls or characteristics, then you should break the process unit into multiple rows in the EquipDetail tab to accommodate all the release points. For example, a large conveyor-type dryer with 10 release points could be broken into "dryer north end" and "dryer south end" to accommodate all the 10 emission release points. This approach will prepopulate both the "dryer north end" and "dryer south end" into the ConvDry tab where you should use the ConvDry comments column to explain.
Tips of the Number of Emission Release Point IDs

 For every Emission Release Point ID specified in the EquipDetail tab, you will be asked to provide release parameters and coordinates in the ReleasePt tab plus emissions estimates by process unit and pollutant in the HAP Emissions tab. For very-low-emitting process units with numerous release points or for fugitive emissions emanating from numerous building vents, you should balance the number of Emission Release Point IDs specified in EquipDetail with the level of detail you can feasibly provide in later tabs. Reviewing the emission release point types in the instructions for the ReleasePt tab may help you identify ways to group numerous related vents into fewer Emission Release Point IDs. You may want to pick the closest building vent for a low-emitting process unit emitting fugitives into the building instead of identifying all possible building vents. For higher-emitting sources, it is generally better not to group emission release points because providing details for all points will improve the dispersion modeling.

 To improve spreadsheet calculation speed, the HAP Emissions tab was designed to hold 100 Emission Release Point IDs instead of the theoretical maximum of 500 Emission Release Point IDs that can potentially be entered into the EquipDetail tab. Facilities are not expected to have more than 100 Process Units or more than 100 Emission Release Point IDs. The number of Emission Release Point IDs entered are counted in EquipDetail Row 5, Column S. Although not expected, should a facility need space for more than 100 Process Units or more than 100 Emission Release Points, please contact the EPA at<EMAIL_ADDRESS>to obtain an expanded version of the spreadsheet prior to proceeding beyond the EquipDetail tab.

Tips of the Number of Emission Release Point IDs

 For every Emission Release Point ID specified in the EquipDetail tab, you will be asked to provide release parameters and coordinates in the ReleasePt tab plus emissions estimates by process unit and pollutant in the HAP Emissions tab. For very-low-emitting process units with numerous release points or for fugitive emissions emanating from numerous building vents, you should balance the number of Emission Release Point IDs specified in EquipDetail with the level of detail you can feasibly provide in later tabs. Reviewing the emission release point types in the instructions for the ReleasePt tab may help you identify ways to group numerous related vents into fewer Emission Release Point IDs. You may want to pick the closest building vent for a low-emitting process unit emitting fugitives into the building instead of identifying all possible building vents. For higher-emitting sources, it is generally better not to group emission release points because providing details for all points will improve the dispersion modeling.

 To improve spreadsheet calculation speed, the HAP Emissions tab was designed to hold 100 Emission Release Point IDs instead of the theoretical maximum of 500 Emission Release Point IDs that can potentially be entered into the EquipDetail tab. Facilities are not expected to have more than 100 Process Units or more than 100 Emission Release Point IDs. The number of Emission Release Point IDs entered are counted in EquipDetail Row 5, Column S. Although not expected, should a facility need space for more than 100 Process Units or more than 100 Emission Release Points, please contact the EPA at<EMAIL_ADDRESS>to obtain an expanded version of the spreadsheet prior to proceeding beyond the EquipDetail tab.

Process units that are not vented. Include process units that are not vented in the EquipDetail tab by specifying a Process Unit ID as for any other process. Enter zero (0) for the total number of emission release points. Do not enter an Emission Release Point ID. Indicate in the "comments" column that the process unit is "not vented."
Process units vented into the building. Include process units that vent into a building in the EquipDetail tab, and enter "BLDG" in the Emission Release Point ID column. Select "Vented into building (fugitive source)" from the menu in the "Uncontrolled Process Unit Emission Routing and Control Configuration" column.* If there are multiple building vents with emission releases to be characterized for the process unit, you may enter BLDG1, BLDG2, etc. The same building vents should be listed as Emission Release Point IDs for all process units that impact emissions from the building vent.
Process units with fugitive emissions. Include process units with fugitive emissions in the EquipDetail tab, and include an Emission Release Point ID to represent the fugitive emissions. If a process 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 process 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 process unit has a material/dust collection system that may be considered the primary and predominant means of collecting and ventilating emissions from the process unit. Units labeled "BLDG" or as fugitive sources are those with no primary means of collecting and ventilating the process unit. For example, if there are some incidental fugitive emissions within the building because 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. In addition, you are asked to provide a maximum short-term emission rate (lb/hr) for each process unit in the HAP Emissions tab, which could reflect bypass emissions.
Process units routed to a boiler/combustion unit for emissions control. Choose PINC or SINC for the APCD type depending on the amount of PCWP process unit exhaust controlled (PINC for 100% control and SINC for partial control), and enter a combustion unit ID for the boiler (or other type of combustion unit) in the APCD ID column. Provide the Emission Release Point ID(s) for the boiler/combustion unit stack(s).
For example, when press exhaust is used as direct-fired dryer burner makeup air and subsequently combusted in the dryer burner, the dryer burner is a form of process incineration (PINC or SINC). The APCD ID for the press should be the dryer process unit ID or dryer burner combustion unit ID (if the combustion unit is separate from the dryer). The press Emission Release Point ID should be the same as the dryer Emission Release Point ID.
Alternate controls. Alternate (or backup) controls include alternative controls used when gas flow from a process unit is diverted from the primary control device to a less frequently used control device as part of a routine operating scenario. If the facility has such a system, please enter a separate APCD ID for the system in addition to the primary APCD ID(s) and describe the typical use circumstances in the "Comments" column of this tab. Similarly, you could enter a separate Emissions Release Point ID for the alternate control that will prepopulate into the ReleasePt and HAP Emissions tabs for further specification and inclusion in the risk modeling.
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 the EquipDetail tab. Do not include sewage handling equipment.
What if I need to remove or add a process unit and/or emission release points after working past the EquipDetail and ReleasePt tabs?

   If you have already completed the ReleasePt tab or subsequent tabs and you later decide to remove a Process Unit or Emission Release Point from the EquipDetail tab, you have two choices:
(1) Remove the process unit and/or emission release point and use paste values to adjust the alignment of data in subsequent tabs impacted by the change (including ReleasePt, HAP Emissions, and process-specific tabs); or
(2) Label the Process Unit ID and/or Emission Release Point ID with "[REMOVE]" to prevent any misalignment of rows in the ReleasePt and subsequent tabs. The EPA will remove Process Units and Emission Release Point IDs labeled in this manner when the EPA compiles its data base from the ICR responses.
         Ex: To remove Process Unit ID "Dryer1" and its Emission Release Point ID "Dryer1Ep1" label these IDs "Dryer1[REMOVE]" AND "Dryer1Ep1[REMOVE]" in columns D and S-W (as applicable).
   Additional Process Units and associated Emission Release Points may be added to the bottom of the EquipDetail tab without risk of misalignment of data previously entered in subsequent tabs.

   If you already listed a Process Unit on row 5, but would like to add more Emission Release Points to it after completing the ReleasePt tab, then you could flag the Process Unit ID and Emission Release Point IDs on row 5 for removal in the EquipDetail tab (i.e., label them "[REMOVE]" as described above) and then add the Process Unit and corrected Emission Release Point ID to the bottom of the EquipDetail tab.

What if I need to remove or add a process unit and/or emission release points after working past the EquipDetail and ReleasePt tabs?

   If you have already completed the ReleasePt tab or subsequent tabs and you later decide to remove a Process Unit or Emission Release Point from the EquipDetail tab, you have two choices:
(1) Remove the process unit and/or emission release point and use paste values to adjust the alignment of data in subsequent tabs impacted by the change (including ReleasePt, HAP Emissions, and process-specific tabs); or
(2) Label the Process Unit ID and/or Emission Release Point ID with "[REMOVE]" to prevent any misalignment of rows in the ReleasePt and subsequent tabs. The EPA will remove Process Units and Emission Release Point IDs labeled in this manner when the EPA compiles its data base from the ICR responses.
         Ex: To remove Process Unit ID "Dryer1" and its Emission Release Point ID "Dryer1Ep1" label these IDs "Dryer1[REMOVE]" AND "Dryer1Ep1[REMOVE]" in columns D and S-W (as applicable).
   Additional Process Units and associated Emission Release Points may be added to the bottom of the EquipDetail tab without risk of misalignment of data previously entered in subsequent tabs.

   If you already listed a Process Unit on row 5, but would like to add more Emission Release Points to it after completing the ReleasePt tab, then you could flag the Process Unit ID and Emission Release Point IDs on row 5 for removal in the EquipDetail tab (i.e., label them "[REMOVE]" as described above) and then add the Process Unit and corrected Emission Release Point ID to the bottom of the EquipDetail tab.

Operations and Emissions Testing. In the Operations section of the EquipDetail tab, you are asked to provide an estimate of the 2016 operating hours for the process unit. The EPA will use this value in regulatory impact calculations.
You are also asked for more details regarding how each process unit is vented. These questions will be particularly helpful for the EPA as we consider miscellaneous process units that do not already have emission limits under the PCWP NESHAP. The EPA is interested in whether these units are currently configured to capture HAP emissions, and whether process units are isolated from other process unit HAP emissions. Process units that are not isolated from other process units may have comingled HAP emissions. The questions in columns Y through AA are intended to help the EPA understand the types of process units where non-isolation of emissions is an issue.
In column Y, you are asked to indicate yes/no whether emissions from an uncontrolled process unit are captured through an enclosure or conveyance for discharge to the atmosphere. Uncontrolled process units are those you labeled with APCD = None.
In column Z, you are asked to indicate if uncontrolled process units are:
Vented to atmosphere (uncontrolled),
Vented into building (fugitive source), or
Fugitive source (outdoor)
If none of these configurations apply, please leave the column blank and add a note in the "comments" field to describe the configuration.
In column AA, you are asked to indicate by selecting "yes" or "no" whether emissions from the process unit are isolated from other process units that produce HAP emissions. If you answer "no," indicating that the HAP emissions from process unit may be comingled with HAP emissions from another process unit, then you are asked to explain how other process unit emission points may be contributing to emissions in column AB. As a guideline, a process unit is considered to be isolated from other process unit emissions when: (1) there are no physical connections between ventilation systems and/or material collection systems; or (2) there is no mechanism for collection of significant amounts of point or fugitive emissions from other process units.
The Emissions Testing section of the EquipDetail tab asks if the process unit has a stack suitable for gas flow measurement in order to assess whether different types of process units are already configured to allow for emissions testing.
Resins. Indicate whether the process unit processes wood containing resin, also referred to as adhesive in this survey. This will allow the EPA to quickly identify post-resin application process units in the inventory.
COMS. The EPA is requesting that you indicate whether you installed a continuous opacity monitoring system (COMS) on APCD controlling process units regulated under the PCWP NESHAP. As an example, if you use a combustion device with COMS as an add-on control to demonstrate compliance with the PCWP NESHAP, answer "yes" to this question. If you answer "yes," also provide the opacity limit from your operating permit on the Permit tab.
Rule Compliance. Use the drop-down menus to respond to the questions regarding the PCWP compliance options and work practices used to demonstrate compliance with the PCWP NESHAP. 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. Choose "NA" if no compliance option applies under the PCWP NESHAP. The menu choices are as follows:
NA
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)

Similarly, you are asked to list any applicable work practices that you must demonstrate compliance with under the PCWP NESHAP. The menu choices are as follows:
Work Practice for Dry Rotary Dryers (PCWP Table 3 option 1)
Work Practice for Hardwood Veneer Dryers (PCWP Table 3 option 2)
Work Practice for Softwood Veneer Dryers (PCWP Table 3 option 3)
Work Practice for Veneer ReDryers (PCWP Table 3 option 4)
Work Practice for Group 1 miscellaneous coating operations (PCWP Table 3 option 5)
NA

If emissions averaging is used, provide a short description of the emissions averaging approach, indicate whether the process 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 process units that are required to meet the emission limits in Table 1B to Subpart DDDD of Part 63.
"Credit" sources are process 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 process unit meets 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 HAP emissions releases. These details will be used in the residual risk assessment. As noted in Section D2 above, you are asked 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 of the risk modeling.
A Note About Emission Release Parameters

   Please pay particular attention when entering emission release point 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 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.
As noted in the instructions for EquipDetail above, there may be one or more emission release points for a given Process Unit ID. There may also be multiple Process Unit IDs ducted to the same Emission Release Point ID. The ReleasePt tab is prepopulated with Process Unit IDs and Emission Release Point IDs (referred to as "Release Point IDs") from the EquipDetail tab. For each combination of Process Unit ID and 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. You must complete all appropriate fields for each Release Point ID.
Note: Later, in the HAP Emissions tab, you will specify emission rates using a separate row for each pollutant and each combination of Process Unit ID and Release Point ID. Information from the ReleasePt and HAP Emissions tabs will be used to construct the EPA's residual risk modeling file.
Release Point ID. Review the prepopulated Release Point IDs and note if any of your IDs are duplicated because they are associated with multiple process units. Duplicate Release Point IDs appear in bold purple. With the exception of the source classification code (SCC), which can vary by process type, you should enter the exact same information for every instance of a duplicated Release Point ID in the ReleasePt tab. This includes the same emission release point type, release parameters, and coordinates.
Source Classification. Select the source classification code (SCC) that best represents the process and emission release point. Some process unit types have multiple SCCs for different release points. For example, veneer dryers have separate SCCs for heated and cooling zones. Appendix 8 provides a list of the SCCs for PCWP process units grouped by product type. Once you key in an SCC code, its description appears in the next column. Please use the description as a check that the proper SCC was entered.
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 process unit, and you use the NEC SCC, then write a "Process Unit Description" in the comments column of the ReleasePt tab. You may use an NEC SCC for PCWP wastewater operations.
The SCCs will be used by the EPA to group similar process units and draw conclusions regarding the emission levels and residual risk associated with each type of process unit. Proper assignment of SCCs will allow the EPA to pinpoint process unit types that need to be examined in more detail for residual risk rulemaking. The SCC codes for the PCWP industry 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.
If you plan to use the provisional calculations described in Section D4b of these instructions, you will want to give special attention to SCC selection because the SCC codes have been paired with the most applicable publicly-available emission factors for use in the provisional calculations, as shown in Appendix 8. See Section D4b for more information on the provisional calculations.

Emission Release Point Type. Each emission release point is characterized by an emission release point type code. Emission release point type codes 08 through 10 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:
 02  -  Vertical
 08 - Fugitive Vent
 03  -  Horizontal
 09 - Fugitive Two-dimensional
 04 - Goose Neck
 10 - Fugitive Three-dimensional
 05 - Vertical with Rain Cap

 06 - Downward-facing Vent

 07  -  Fugitive Area. Not used for new data. Reserved for historical data.

Different emissions release parameters must be specified for different emission release point type codes. The ReleasePt tab contains conditional formatting to guide you through which parameters are required for each emission release point type code. The instructions below and in the ReleasePt tab provide specific criteria pertaining to each release point type. The worksheet also contains data validations to alert you if you enter a value that does not match the required criteria used by the EPA for constructing residual risk modeling files. You are not required to populate cells that are shaded black. The black shading appears based on the Emission Release Point Type selected. Table 5 summarizes the parameter requirements for each emission release point type and provides examples of PCWP process units that might be characterized with each emission release point type.
Table 5. Summary of Required Parameters for Different Emission Release Point Types
Fugitive Parameter
Point (stack) sources
Fugitive Vent Source
Fugitive Two-Dimensional Source
Fugitive Three-Dimensional Source
Emission Release Point Type Code(s)
02 to 06
08
09
10
Fugitive Length (ft)
NA
NA
NA
NA  -  only a single side required
Fugitive Width (ft)
NA
NA
Required >0
Required >0
Stack Diameter (ft)
Required < release height and between 0.1 - 100
0.003 (Default)
NA
NA
Exit Gas Velocity (ft/sec)
Required >= 0
0.0003 (Default)
NA
NA
Exit Gas Flow Rate (cu ft/sec)
Calculated based on velocity and stack diameter assuming round stack
0 (Default)
NA
NA
Release Height (ft)
Required between 1 - 1300. Use 1 for ground-level releases.
Required >0
Release height required >0
Required >0
(Top of Three-Dimensional Source)
Exit Gas Temperature (F)
Required >50
Required >50
NA
NA
Latitude and Longitude (in decimal degrees)
Required
Required
Two sets of lat/long for the midpoints of opposing sides of source
Required, center of source footprint
Point and Fugitive Source Examples in the PCWP industry
APCD stack, powered press vent, powered building vent
Source area <10 ft2
Single roof vent/opening/window for building fugitives
Source area >10 ft2
Wastewater pond, elongated building roof vent, lumber kiln roof vents grouped into one rectangular emission release point
Entire building with multiple release points on walls and/or roof, lumber kiln with numerous wall leaks and roof vents, each end of a continuous lumber kiln where venting occurs

Release Parameters. The release parameters exit gas temperature (°F) and release height (feet) apply for both the fugitive and stack emission release point type codes. The exit gas temperature is not used for emission release point type codes 09 and 10, so these are blacked out. 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 develop and apply conservative default release height parameters based on the ICR responses received from other facilities if you do not provide this information.
Stack gas parameters. Additional point source (e.g., stack) gas parameters to be specified for emission release point type codes 02-06 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 may average the quarterly data for the year. If you do not provide this information, then the EPA will use conservative default parameters. Please ensure that you specify positive, non-zero temperatures for your emission releases. Ambient temperature is considered to be 72°F.
You are asked to specify the moisture content of the exhaust gas stream (which along with stack gas temperature will allow the EPA to convert to units of dscfm for use in various analyses separate from the residual risk review). Measured values for the exhaust gas moisture content are desired (e.g., from prior stack tests or engineering tests). If exhaust gas moisture has not been measured, then you may leave the value blank. The worksheet 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 using Release Point Type Code 03-Horizontal. Codes 02 or 06 may also be appropriate depending on the direction of the gas flow. The equivalent diameter can be approximated considering the vented area, but must meet the criteria in Table 5.
      Baghouses with side mount vents could use Emission Release Point Type Code 03-Horizontal. The equivalent diameter can be approximated considering the vented area, but must meet the criteria in Table 5.
      Outdoor process units with no gas flow rate can be treated as fugitive sources.
Fugitive parameters. When selecting fugitive Emission Release Point Type Codes (08-10), you are strongly encouraged to provide the actual release height and fugitive dimensions (particularly length and width, when required) because these parameters will result in more accurate dispersion estimates when risk modeling if performed. There are three different types of fugitive releases described below: fugitive vent sources, fugitive two-dimensional sources, and fugitive three-dimensional sources.
Fugitive vent sources (08) are fugitive emission releases from a single point, such as building fugitives from a single roof or wall vent less than 10 square feet in size. The gas exiting a fugitive vent has a minimal flow rate. If the velocity/flow rate of the gas through a roof vent is significant, you should consider choosing an Emission Release Point Type Code for a point source instead. Certain defaults for fugitive vent releases will be set for risk modeling 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. Emissions from fugitive vent sources are not as dispersed as emissions from the other types of fugitive releases.
Fugitive vent sources are modeled as a single point with a longitude and latitude. Fugitive vent sources do not require a fugitive length or width. The exit gas temperature is required and must exceed 50ºF for fugitive vent sources.
Fugitive two-dimensional sources (09) are fugitive emission releases on one plane, such as an elongated roof vent larger than 10 square feet in size or a wastewater holding pond. Fugitive two-dimensional sources are modeled as rectangles with latitude and longitude reported at the midpoints of two opposing sides of the source and a width reported as the distance between the two remaining sides of the source. In other words, the width is perpendicular to the line between the two midpoints. For irregularly shaped sources, first create a rectangle that best approximates the shape of the actual source, then determine the parameters described above. The fugitive length column of the tab does not apply for fugitive two-dimensional sources.
Figure 3 is a depiction of fugitive two-dimensional source parameters. The black stars show the location of the midpoints, for which the latitude and longitude are entered. The solid black line with arrows at each end shows the location at which fugitive width is measured.

Figure 3. Graphical view of the latitude/longitude and fugitive width for fugitive two-dimensional sources.
Fugitive three-dimensional sources (10) have multiple release vents, such as a building with many wall and roof vents or an outdoor material storage pile. Fugitive three-dimensional sources are modeled as rectangular prisms with latitude and longitude reported at the center of the footprint and a length reported as the side of the footprint of the source. Fugitive width is equal to the length for fugitive three-dimensional sources. Figure 4 is a depiction of fugitive three-dimensional source parameters.

Figure 4. Graphical view of the latitude/longitude and fugitive length for fugitive three-dimensional sources.
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 and fugitive vent sources (codes 02 through 08), longitude/latitude is specified at the center of the emission source. For fugitive two-dimensional sources (code 09), longitude/latitude is specified at the midpoints of two opposing sides of the fugitive two-dimensional source. For fugitive three-dimensional sources (code 10), longitude/latitude is specified in the center of the footprint of the square base. 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. The EPA suggests using an online satellite map of your facility to identify longitude/latitude coordinates for each release point.
Longitude is a measure in decimal degrees of the angular distance on a meridian east or west of the prime meridian. Longitude is a negative (-) data point for North America (Example: -123.123456). Latitude is a measure in decimal degrees of the angular distance on a meridian north or south of the equator. Latitude is a positive (+) data point for North America (Example: +45.123456). In this format, minutes and seconds are represented as a decimal fraction of one degree. Therefore, coordinates containing degrees, minutes, and seconds must first be converted using this formula (or using conversion tools freely accessible online):
decimal degrees=degrees+minutes60+seconds3600
Example conversion of 45 degrees, 7 minutes, 24 seconds to decimal degrees:
45.123333 degrees=45 degrees+7 minutes60+24 seconds3600

e. 	Permit Limits (Permit) tab
Permit limits for each process unit listed in the EquipDetail tab should be entered in the Permit tab. The list of process units from the EquipDetail tab are prepopulated in the Permit tab. Leave the rows in the Permit tab blank for any process units with no requirements under the PCWP NESHAP or air permit limits. You are asked to provide emission limits for HAP, VOC and PM.
In the Permit tab, you are asked for information regarding the test method used to demonstrate compliance with the PCWP NESHAP during the most recent test. The PCWP compliance option used to demonstrate compliance during the most recent test is prepopulated from the EquipDetail tab for reference.
The tab also requests information on any HAP permit limits for HAP other than the six total HAP defined in the PCWP NESHAP (acetaldehyde, acrolein, formaldehyde, methanol, phenol or propionaldehyde). 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, 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 "ppmvd," use the limits as specified in your permit. Include any oxygen correction factors (% O2). VOC concentration limits should note whether they are on a carbon basis (i.e., "as C") or some other basis. Menu choices include THC as C, THC as propane, Method 25A THC plus certain added HAP, nonmethane VOC, or you may specify another basis included in your permit.
In columns S through T, filterable PM limits are requested in units of concentration (gr/dscf) with the permit limit PM size fraction noted. If your permit contains PM10 or PM2.5 size fraction limits with or without condensable PM (CPM), you are asked to provide the smallest of the size fraction limits including CPM if applicable in columns U through X. "Primary PM10" and "Primary PM2.5" are provided as menu choices for limits including CPM based on EPA Method 201 (or 201A) combined with Method 202.
Permit limits of most interest to the EPA are concentration limits (ppmvd, 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 process unit or facility capacity. The EPA will use the permit limit information you supply in comparing permit limits across similar process units nationwide. 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).
Submit a copy of permit: Attach an electronic, searchable copy of the operating permit with your survey response.
f. 	Resin and Tank (Resin and Tank) tabs
In the Resin tab, you are requested to provide information that should be in your Safety Data Sheets (SDS) for resins and HAP-emission-altering resin additives (e.g., formaldehyde scavengers) used to manufacture PCWP. You do not need to include details for waxes or other non-HAP, non-adhesive additives in either the Resin or Tank tabs. Enter a Resin ID for each type of resin used at the facility. The Resin ID 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 Resin tab:
PF: phenol-formaldehyde
MDI: methylene diisocyanate (includes pMDI)
UF: urea-formaldehyde
PVA: polyvinyl acetate
MF: melamine-formaldehyde
PRF: phenol/resorcinol formaldehyde
MUF: melamine-urea-formaldehyde
Other: {specify}

If necessary, 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. Only marked differences in resin types are of concern; you need not report every tweak of a resin for customer preferences, mill trial, or seasonal adjustment as a separate resin type. To minimize the number of resins reported, you should report the worst-case, most-conservative formulation for a particular resin (e.g., formulation with the highest formaldehyde content) to account for routine variations in the HAP content for that resin. HAP scavengers (such as urea, ammonia, etc.) are additives of interest because they reduce HAP emissions from resins. To describe the type of HAP scavenger, select the "Other: {specify}" option in the drop-down menu. Then in the formula bar, select the text "{specify}" and overwrite it with the type of HAP scavenger.
Enter the information requested regarding use of the resin in the panel face or core (or throughout the whole panel), whether the resin is applied to the furnish in powdered or liquid form, the resin percent solids, HAP percentages, and possible lower-HAP substitutes for the resin. Please provide HAP percentages reported in your SDS or that are otherwise readily available. Indicate "UK" for "unknown" if HAP percentages are not available and cannot be reasonably obtained. Note that the percent-value provided in some SDS may not be well-defined. The EPA is specifying that resin percent solids and HAP percentages be provided by weight to ensure we are receiving data on a consistent basis. If your SDS includes "less-than" percentages of HAP by weight, please include the less-than sign in your response (e.g., report "<1%" formaldehyde). Resin HAP content is of interest to the EPA because it may be a consideration for miscellaneous process unit work practices downstream of resin application. Please use the "Comments" column should you have any comments or caveats regarding the information provided in the Resin tab.
The first columns of the Tank tab will be prepopulated to list resin storage tanks you included in the EquipDetail tab. Except for 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 a 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 emissions from the tank process unit with TANKS or a similar software package, you may choose to provide a copy of the emission estimates (optional).
g. 	Dryer (VeneerDry, RotaryDry, TubeDry, ConvDry, LKiln, and DFDryFuel) tabs
Five tabs are provided for the different dryer types commonly found in the PCWP industry: veneer dryers, rotary dryers, tube dryers, conveyor strand dryers, and lumber kilns. The VeneerDry tab is to be completed by any facility operating hardwood or softwood veneer dryers. Veneer dryers are commonly found at veneer, plywood, or certain EWP facilities. The RotaryDry tab applies for facilities that operate rotary strand dryers, green rotary dryers, dry rotary dryers, or rotary agricultural fiber dryers. Rotary dryers are commonly found at OSB, LSL, and particleboard facilities. Conveyor strand dryers which are covered in the ConvDry tab are also found at OSB or LSL facilities. The TubeDry tab applies for facilities that operate single-stage or multi-stage tube dryers. Tube dryers are typically found at hardboard, MDF, or particleboard mills. The LKiln tab applies for hardwood and softwood lumber kilns found at any type of facility. Lumber kilns are dryers. An additional tab for mat dryers, ovens, and other equipment at fiberboard or hardboard plants (the FB_HB tab) is discussed in section D3h below. You only need to complete tabs that match drying equipment present at your facility. The dryer process unit IDs you provided in the EquipDetail tab will be prepopulated into the dryer tabs according to process unit type.
The various dryer tabs (including the lumber kiln tab) ask for the dryer firing method and provide the following menu choices:
Direct-fired: Dryers heated by passing hot combustion exhaust through the dryer such that the furnish contacts the hot combustion gases.
Indirect-fired: Dryers that are heated indirectly (usually by steam) where combustion gases do not contact the wood.
Choosing "direct-fired" will cause the dryer process unit ID to appear in the DFDryFuel tab where additional fuel-combustion information is requested for direct-fired dryers. Additional firing method choices are included for veneer dryers (radio-frequency) and lumber kilns (electric dehumidification). Please use the comments column to explain any other heating methods that are not reflected in the menu choices. For example, if you have a dryer or lumber kiln that is partially direct and partially indirect-fired, please choose the predominant heating method and explain in the configuration in the comments.
For each dryer, you are asked to provide the installation year and dryer throughput. You are asked to indicate normal operational hours as 8, 12, 16, or 24 hours per day, or you may write in a site-specific response. Questions are included for typical or target dryer operating parameters. In some cases, these questions are limited to certain types of dryers (e.g., particleboard versus OSB rotary dryers) so it is suggested that you review the in-tab instructions closely. These questions will assist the EPA in making distinctions between dryer types and their emissions characteristics.
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 over-drying, 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 for descriptions.
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
Complete the DFDryFuel tab for direct-fired dryers and direct-fired lumber kilns. This tab asks for the type of combustion unit used to directly heat the dryer and includes choices for: dryer burners (gas, liquid/oil, or suspension), a combustion unit dedicated to direct-firing dryers; combustion unit serving multiple purposes (including dryer firing); a gasifier; or other combustion unit that you describe in the comments section. Questions are included regarding the installation year of the combustion unit and air rule applicability (boiler MACT, CISWI, and/or NSPS subparts Db or Dc).
The DFDryFuel tab asks for heat input capacity in million British thermal units per hour (MMBtu/hr) for each dryer burner or combustion unit. The primary fuel and supplemental fuel types are requested along with the approximate percentage of heat input capacity each fuel provides. An "approximate" percentage is requested because it is understood that the types and amounts of fuels fired can vary throughout the year. The EPA may consider fuel types and perform calculations based on fuel firing rates for various nationwide impact analyses. For wood-fired dryers, the MMBtu/hr heat input is used in the provisional HAP emissions calculations for your optional use in the HAP Emissions tab.
h. 	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. If you listed these types of process units in the EquipDetail tab, their process unit IDs will prepopulate into the FB_HB tab. Note that hardboard tube dryers should be reported in the TubeDry tab, and other equipment use in fiberboard or hardboard mills such as digesters appears in the OtherEquip tab. You are asked to enter the installation year for each process unit listed in the FB_HB tab.
Next, 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)

Because the FB_HB tab asks for information on a process-unit level, you should simply repeat the process type for each process unit. If your facility uses multiple fiberboard or hardboard manufacturing processes, choose the manufacturing process type most closely related to the emission unit listed. The remaining questions seeking the annual throughput, percentage of hardwood species, resin type and other details are asking for this information on a process-unit specific basis.
For fiber washers, only the applicable information in the columns under the headers "Hardboard Fiberboard Process Information" and "Fiber Washer" needs to be completed. The remaining columns pertain to dryers, predryers, ovens, and humidifiers.
In addition to the information under the Hardboard Fiberboard Process Information" header, the firing method is requested for dryers, predryers and ovens. See section D3g above for a description of the firing method menu choices. Process units labeled as "direct-fired" will be listed in the DFDryerFuel tab which asks you to provide specific details regarding fuel firing. Additional columns ask for details specific to each type of process unit listed in the header row.
This tab also requests information on any work practices that prevent overdrying or equipment design modifications (e.g., to heat/energy systems) that reduce HAP and/or improve energy efficiency of fiberboard/hardboard dryers and ovens. The comments column may be used for additional explanation of process characteristics if more than 255 characters are needed.
i. 	Press and Board Cooler (Press, BC, and EWPPress) tabs
The Press tab is to be completed for batch or continuous reconstituted wood products presses, plywood presses, agriboard presses, and particleboard press molds or extruders. The BC tab is to be completed for reconstituted wood products board coolers commonly found in particleboard and MDF facilities, but not limited to these product types. The EWPPress tab is to be completed for engineered wood products presses and curing devices commonly used in the production of LVL, PSL, LSL, I-joists, glulam (including cross-laminated timber) and similar products. Process unit IDs you provided in the EquipDetail tab will be prepopulated into the Press, BC, and EWPPress tabs according to process unit type. You only need to complete tabs which match equipment present at your facility.
Specify the process unit details requested in each tab. The tabs ask for the press or cooler installation year and throughput. Separate questions are asked for batch and continuous presses. Questions are also to provide information on the presence or absence of enclosures used to capture HAP emissions or, if not enclosed, the press venting configuration. You are also asked to provide any available details on the technical feasibility and costs of enclosing pressing equipment (e.g., plywood presses) and board coolers (available information only; no new engineering studies are required to answer these questions). This information will assist the EPA in formulating options for process units that are not currently subject to emission limits in the PCWP NESHAP.
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 the EPA to understand how resin systems and the air emissions potential for composite wood products pressing operations have changed since the formaldehyde rules were developed. The Press, BC, and EWPPress tabs also ask you to describe any operational practices with the potential to limit HAP emissions. 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 process units).
j.	Other Equipment (OtherEquip) tab
Complete the OtherEquip tab if your facility has stand-alone digester, pressurized refiners, atmospheric refiners, blenders, wet or dry formers, finishing sanders, finishing saws, panel trim chippers, or log vats. The process unit IDs for these types of equipment will be prepopulated based on the process unit types you enter in the EquipDetail tab. As indicated in Table 1 of these instructions, facilities that produce only kiln-dried lumber are not required to provide information in the OtherEquip tab.
The OtherEquip tab asks for nominal annual throughput capacity and installation year for all process units. In addition, you are asked to describe any work practices or equipment designs with the potential to limit or reduce HAP emissions for each process unit type listed in the tab. The EPA will look for common themes in the information provided from all facilities nationwide to determine if there are broadly applicable work practices for the process units included in the tab. The comments column may be used for additional explanation of process characteristics or work practices if more than 255 characters are needed.
A description of digesters and refiners is requested for stand-alone digesters, pressurized refiners, and atmospheric refiners. Several different PCWP processes incorporate digesters or refiners so the description provided, in conjunction with the release point information provided in the EquipDetail tab, will help the EPA characterize the type of process unit used and venting mechanisms. For example, the EPA is interested in knowing if each digester or refiner has heat applied, operates under added steam pressure, is batch or continuous, and/or vents gases to the atmosphere or into a separate process unit such as a tube dryer.
For each dry blender or former, select the associated Resin ID from the values you entered in the Resin tab. If multiple distinctly different resins are processed at different times, select the most-frequently used resin and use the comments column to note that multiple resins are processed through the blender or former.
For sanders, indicate if one or both (2) sides of the product are sanded. Select or write in the type of material chipped in panel trim chippers, choosing from resinated panel trim, other unresinated wood, or other. For log vats, specify the type (hot water vat open to atmosphere, or log steaming vat (enclosed)) and indicate the maximum target vat operating temperature. Responses to these questions will help the EPA characterize the types of operations used throughout the U.S.
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 the 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).
In the APCD tab, you are asked to enter information on each APCD identified in the EquipDetail tab on a separate row of the APCD tab. A row is prepopulated in the APCD tab for each unique APCD ID you identified in the EquipDetail tab. Additional information associated with each APCD ID is also prepopulated from the EquipDetail tab including the type of control device, product, and air pollution control system (i.e., the series of controls). The Process Unit Type associated with the first use of each APCD ID in the EquipDetail tab is also prepopulated. Each APCD ID from EquipDetail appears only once in the APCD tab regardless of the number of process units the APCD controls. Usually an APCD ID is associated with one or more process units of the same process unit type. However, in some cases, APCD IDs may be associated with different process unit types (e.g., if the APCD controls a dryer and a press). The instructions in the Process Unit Type column ask you to edit the prepopulated Process Unit Type to note when multiple process unit types are controlled by the same APCD. A menu listing the process unit types appears in Section D3c of this instructions document and in cell F14 of the tab for reference. Also, note in the process unit and control configuration in the comments column for added clarity.
The APCD tab is relatively wide due to the number of control types used in the PCWP industry. To aid you in completing the correct columns, the columns that are not relevant for the type of APCD prepopulated from the EquipDetail tab will be shaded black on the corresponding row of the APCD tab. You are asked to complete the unshaded white columns. Columns are available for:
General APCD information
Control efficiency
Thermal Oxidizers/Incinerators (including catalytic oxidizers)
Process Combustion Unit Control (e.g., incineration in an onsite combustion unit)
Sorbent injection upstream of a baghouse
Baghouses/fabric filters used for HAP control
Cyclones and multiclones
Electrostatic Precipitators (ESP)
Wet ESPs
Wet scrubbers used for HAP control
Packed bed scrubbers/absorbers
Biofilters and Bioscrubbers
Control system water usage
Solid material handling and disposal (for HAP control devices only)
Parameter monitoring (for HAP control devices only)
Routine control device maintenance exemption use (for HAP control devices only)
Control device startup and shutdown (for HAP control devices only)
Control Device and Monitoring System Costs (for HAP controls installed within the past 15 years)
General APCD information requested includes the APCD manufacturer, year installed, and pressure drop. The EPA is particularly interested in detailed information in the APCD tab for HAP control devices that are reducing emissions of organic HAP or PM metal HAP, with less emphasis on dust controls for non-HAP PM sources such as panel trip chippers, sanders, and saws. Therefore, certain questions are limited to "HAP control devices" only and questions seeking details for baghouses or solid material handling are limited. Such details are only requested for baghouses that control HAP emissions (e.g., HAP metals for direct-fired dryers). Similarly, questions pertaining to parameter monitoring, the PCWP routine control device maintenance exemption, and startup/shutdown are limited to HAP control devices only and need not be completed for dust collection/material handling equipment such as cyclones or baghouses.
Measured control efficiency. Measured control efficiencies are requested for each control device, if available. 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 should enter this test result as the "measured" control efficiency. This information will be used in determining the capability of different control devices for reducing emissions. You may leave the control efficiency columns blank (rather than marking as "NA") if control efficiency has not been measured (or is not applicable for a given pollutant).
The "thermal oxidizer/incinerator" series of questions apply for add-on incineration control devices such as RTOs, RCOs, TCOs, or TOs. Conditional formatting distinguishes between applicable questions for thermal and catalytic systems.
The "process combustion unit control" series of questions applies for controls where exhaust gas is incinerating in an onsite combustion unit such as a boiler or dryer burner. The associated APCD type codes are PINC (100% of exhaust incinerated) and SINC (a portion of the exhaust incinerated).
The sorbent injection questions refer to sorbent injection that may occur upstream of a baghouse. Typically, the baghouse series of questions should be completed if the sorbent injection questions are completed. The baghouse/fabric filter questions apply for baghouses that achieve HAP control for either PM metal HAP or organic HAP (e.g., if used with sorbent injection). The baghouse questions are limited to HAP controls because of the large numbers of baghouses used for general dust control within PCWP facilities that have no association with HAP emissions reduction.
In addition to baghouses, basic questions for cyclones and multiclones, ESPs, and WESPs are included in the APCD tab. Facilities using WESPs should complete both the ESP and additional WESP questions. Facilities using a quench section prior to a WESP are asked to complete the wet scrubber questions and the ESP and WESP questions. Details are requested for wet scrubbers used in control systems that may reduce HAP emissions. If a wet scrubber incorporates packed bed absorption you should complete both the scrubber and packed bed scrubber/absorber columns. The wet scrubber questions are also to be completed for biofilter prequench scrubbers. A separate series of questions is included for biofilters and bioscrubbers. The wet scrubber columns are also to be used for electrified filter beds and sand filters.
The questions pertaining to the control system water source and usage seek information for wet control systems including wet scrubbers, WESPs, biofilters, bioscrubbers and similar control devices that use water or generate a wastewater stream. These questions will assist the EPA in assessing the water usage costs and wastewater impacts associated with these control devices.
The solid material handling and disposal questions seek information on the solid material collected or generated for disposal by HAP control devices (e.g., PM, sorbent, packing media changes, etc.). You are not required to respond to these questions for baghouses or cyclones used solely for wood/material handling operations. The purpose of the solid material handling and disposal questions is to provide information for assessing solid waste disposal costs and impacts associated with control devices.
The parameter monitoring questions seek information on the types of continuous parameter monitoring systems (CPMS) in use for each control device such as CPMS for liquid flow rate, pressure drop, temperature, etc. This question pertains to HAP control devices. For control devices with THC continuous emissions monitoring systems (CEMS), you are asked to provide the THC concentration limit established during the performance test. You are also asked for describe any approved alternative monitoring approaches, if applicable. The latter two questions, for THC CEMS and approved monitoring alternatives, pertain specifically to APCDs used to control HAP emissions for PCWP NESHAP compliance. The monitoring questions included in this section provide valuable information on how facilities have chosen to demonstrate ongoing operation of the control device and will assist the EPA in evaluating potential future monitoring approaches, as needed.
The APCD tab includes 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 HAP emissions during these periods, and information on APCD monitoring parameters that cannot feasibly be met during startup and shutdown.