Columns H, N, T, Z, AF, and AL  -  EPA should not use the term "Actual" when the results being reported have not actually been continuously measured throughout the year.  The data input would be an estimate at best based on operating times and emission factors from NCASI database, one off NCASI engineering test, or performance test.  Engineering tests and NCASI database values may not represent the emission factor value obtained from the same production rate level as used for a performance test. Performance test will reflect max production level to test the APCD, so is that reasonable to apply to the entire year?
Change made. The term "Actual" has been replaced with "Estimated Actual." Residual risk modeling is intended to be based on actual emissions to the extent that actual (measured) emissions data are available for a given HAP.  However, when actual (measured) emissions data are not available for a given emission point, reasonable estimates of actual emissions may be used for purposes of risk modeling. We revised the terminology to reflect this intent. Similarly, we added the term "estimated" to the columns seeking allowable and maximum emissions. Facilities are asked to provide their best estimate of emissions based on information available to them.
F46
NCASI
Primary HAP Emissions and Other HAP Emissions tabs:
Columns for "Maximum Emissions"  -  Will mills not know how to estimate this?  Seems that this will be very difficult to determine and thus responses will be variable making this data useless.
First, mills will only have lb/hr data from stack test reports which only reflect conditions during the test.  How to translate an emission factor or test report value to the highest short term emissions on a lb/hr basis is going to very difficult.  At best, one would simply use the uncontrolled dryer emissions, but uncontrolled emissions are seldom measured anymore for all 6 individual HAPs.
Second, this data should also have a max emission time frame associated with it so that the worst case emissions are not used for the entire year.
Third, EPA should waive this if the mill has been in compliance for say 90% of the year, then no short term estimate is required.
Facilities are asked to provide their best estimate of maximum short-term emissions in pound per hour based on information available to them. Maximum emissions on a short-term basis are requested for purposes of acute risk modeling. An example of maximum hourly emissions may be short term (peak) uncontrolled emissions during peak production rates or during a time when the routine control device maintenance exemption (RCDME) is used (e.g., when the 90% control efficiency is not being achieved). Within the provisional calculations, the maximum short-term emissions are calculated as the annual uncontrolled emissions divided by annual operating hours to approximate maximum lb/hr assuming there is 1 hour when the process is operating but the control device is out of service (e.g., during the RCDME). For uncontrolled process units or process units that do not use the RCDME, facilities can provide the maximum lb/hr assuming peak production or by another means according to their best engineering judgement.

F47
NCASI
Tank tab:
Columns B through E are not being prepopulated. It appears that the VLOOKUP formula contained in these fields is returning a "#NA" from the referenced data within the `Tank Calcs' worksheet. The VLOOKUP considers this an error, therefore the formula results in a blank value. The data being referenced in the `Tank Calcs' worksheet is "#NA" because there are multiple issues with the VLOOKUP formulas being used in that worksheet. The following is an attempt to diagnose and resolve the issue within the `Tank Calcs' worksheet:
Columns R through AC in the `Tank Calcs' worksheet are seeking incorrect references.
First, there is a breakdown in the formula thread with the referenced `table_array' range of $A$3:$M$252.  This is incorrect because the data required to be referenced begins in Column B instead of Column A. This first issue can be corrected by replacing the `table_array' range $A$3:$M$252 with $B$3:$M$252.
The second issue becomes evident after the first correction when the Columns S through AC return incorrect data.  {See p. 6-7 of NCASI supplemental comment for VLOOKUP issues}
Column F Product Trade Name and Catalogue Number  -  This column has been changed from a prepopulated entry in the first draft to a dropdown menu option but the column is still grey.  Grey shading needs to be changed to no fill.
Column G Principal resin type  -  The instruction for this column in cell G8 are incorrect, the prepopulated entry will work when data is selected in Column F of this tab not the Resin Tab. Instructions should be corrected.
(B thru E) Change made. Prepopulated.

(R thru AC) Change made. References fixed.

(F) Change made. Shading eliminated

(G) Change made. Instruction clarified.
F48
NCASI
EmTest tab:
The initial input for this tab should be revised. The Emission Unit ID should not be the first entry point since all test reports will be referencing outlet locations and associated results. The outlet location is the most logical point to begin data collection.  The first data to be entered, therefore, should be the Emission Release Point ID.  From there, EPA should be able to pre-populate current Columns B, E, H, I, and J.
Change made. The Emission Release Point ID column was moved to precede columns containing process unit details and pre-population was added.
F49
NCASI
EmTest tab:
Column K Pollutant  -  The drop down menu options Total HAP, Total non-PCWP HAP, Total PM, PM10, PM2.5, and THC need to be revised for the following reasons:
 Total HAP:  The individual concentration values for each of the six PCWP HAP cannot be added together, only mass related values can be added together. As a consequence, Columns M and N cannot be reported in this survey for total HAP.
 Total non-PCWP HAP: Is EPA requesting that other organic HAPs be combined with HAP metals? It does not appear to be the case since the last menu selection is "Total HAP metals". EPA should revise the term "total non-PCWP HAP" to "total non-PCWP organic HAP". Note that the individual concentrations of non-PCWP organic HAP cannot be added together on a concentration basis, however.
 Total PM: EPA should recognize that `Total PM' is an obsolete term. Since Column L provides a menu option for Method 5, EPA should use the correct terminology used in Method 5: particulate matter (PM).
 PM10: This terminology relates to Primary PM10 or Direct PM10 that represents the combination of filterable PM10 and CPM.  Column L only allows for the entry of one method whereas reporting of this parameter requires both M201A/M202.
 PM2.5: Likewise, this parameter represents the combined results from two methods: filterable PM2.5 and CPM.
 THC: The term "THC" is an acronym for total hydrocarbons which is a class of organic compounds that technically only includes alkanes, alkenes, alkynes, dienes, and arenes. Method 25A is designed to determine total gaseous concentration of vapors consisting primarily of alkenes, alkenes, and/or arenes. This means that M25A will measure this subset of THCs but also will measure other organic compounds. EPA should clarify if only this subset of THCs are to be reported or if the total gaseous organic concentration (THCs and non-THC response) from M25A is to be reported.
 Missing VOC?: The ICR Survey Instruction manual includes "VOC" on page 29, third paragraph.  But the dropdown menu does not include this option.  EPA should clarify or remove VOC from instruction manual.
(K)(1) Change made. "Total HAP" was omitted from the menu, and replaced with the individual HAP compounds comprising Total HAP as defined in the PCWP rule. The columns M-P requesting respondents to enter numerical emissions values were deleted from the table to significantly reduce respondent burden. The purpose of the EmTest tab is for respondents to provide a detailed catalogue of emission test reports submitted by pollutant so EPA can quickly assess the breadth of test report data collected and prioritize test data extraction for compilation of an emissions data base.

(K)(2) Change made. The terms "Total metals" and "Total non-PCWP HAP" were removed from the menu. Facilities are now requested to list the individual HAP compounds tested (e.g., toluene, xylenes). Tests involving HAP groups measured by the same test method such as Method 29 HAP metals or Method 429 POM/PAH may be listed as "HAP metals" or "POM" on one row instead of listing every specific compound. The EPA will speciate compounds when extracting the data from the test reports.

Methylene diphenyl diisocyanate (MDI) was added to the pollutant menu, and Conditional Test Method 031 was added to the test method menu for MDI (in addition to Method 320 which was already in the test method menu).  Furthermore, the "sealed caul plate" test method ASTM D7770 was added to the test method menu because this alternative method may have been used by engineered wood products producers to estimate press HAP emissions.

(K)(3) Change made. The menu was changed to refer to "PM" instead of "Total PM." The intent is to collect Method 5 filterable PM data.

(K)(4) and (5) Change made. The combined Method 201A/202 was added to the menu to correspond to the combination of filterable PM10 (or PM2.5) and CPM. Method 201A and Method 202 were also retained in the menu for tests where the two methods were not combined.

(K)(6) Change made. The instructions were clarified to state that we are seeking the value of the Method 25A THC response, which is consistent with THC measurements conducted under the PCWP rule.

(K)(7) Change made. The reference to VOC was removed from the instructions.
F50
NCASI
EmTest tab:
Column L Test Method  -
 Menu options provide M201A and M202, but the parameters measured by these methods, filterable PM and condensable particulate matter (CPM), are not offered as a selection in Column K.
 EPA has not provided Method 29 for metals.
 If VOC is to be included and based on a calculation technique, then is the calculation technique to be included here as a test method? Any VOC value from a calculation technique will not apply to the ppmvd only to mass emission rates.
(L)(1) Change made, as noted above.

(L)(2) Change made. Method 29 was added to the menu.

(L) (3) Change made. References to VOC have been removed.
F51
NCASI
EmTest tab:
Column M Concentration  -  Cannot add or average concentration values for total HAP, total non-PCWP HAP or HAP metals.  No units provided for opacity readings.
Column N Concentration Result Units  -  EPA uses "ppmdv" this should be changed to "ppmvd".
(M and N) Change made. After further consideration of the burden associated with completing the EmTest tab and the EPA's need for consistent test data entry, we elected to delete columns M through P. The EPA will tabulate the emissions test results using the test reports provided.
F52
NCASI
EmTest tab:
Column O  -  Instructions do not address mixed set of detects or how the average total HAP is to be determined.
For total HAP, do the individual run values get added first then the three sums get averaged and reported?
No instructions provided for opacity
Column P  -  Mass-based production units for pneumatic dust collection systems and coating and wastewater operations will be difficult to apply or interpret. For example, finishing area process unit, such as saws and sanders, may be associated with the press production or surface area of the panels processed (with a further complexity of reporting only one or both surfaces). The problem here is that most product lines run finishing area process units independent of the press. Compiling reported results based on multiple production rate units will be challenging.
Column R Other emission units/pollutants  -  Note that the examples show PM as a pollutant but the instructions state not to include PM.
(O and P) Change made. After further consideration of the burden associated with completing the EmTest tab and the EPA's need for consistent test data entry, we elected to delete columns M through P. The EPA will tabulate the emissions test results using the test reports provided.

(R) Change made. The examples were edited to remove reference to PM.
F53
NCASI
EmTest tab:
Column W Frequency of PCWP NESHAP Testing  -  The instructions in row 9 specify frequency only relative to PCWP NESHAP testing while the column header in row 10 refers to frequency of testing for all pollutants. EPA should resolve this discrepancy. Also, provide a "Other: (specify)" option in drop down menu.
Change made. The instructions were edited to clarify that we are interested in the testing frequency of the pollutant listed in each row of the spreadsheet, not limited to PCWP NESHAP testing. Should EPA find reason to expand the current PCWP testing requirements, it will be useful to know the testing frequency already required by permitting authorities (if applicable) as we consider incremental testing costs. The "other" option was added to the menu.

F54
NCASI
EmTest tab:
Column X Cost per test  -  Instructions on how to calculate the cost per test for the pollutant listed should be provided. For example, an itemized cost between M25A "THC" testing and NCASI Method A105 (BHA) reasonably attainable. But itemizing the cost between methanol and acrolein within the BHA Method is more difficult. Should responders divide the total cost of the BHA Method for stack testing and analytical by 6?
Change made. The instructions were clarified to indicate that for test methods that measure multiple compounds (e.g., NCASI A105.01), the total cost of the test is of interest, not the itemized lab cost for each pollutant measured by the method.

G. Phase II: Emissions Testing
No.
Commenter
Comment Summary
EPA Response/Action Taken
G1
AWC

Boise Cascade
Concerned about the meaningfulness of any new data collected under the proposed test plan, especially at the high estimated cost of testing. It is not feasible for EPA to prescribe or enforce a numeric emission standard for many of the sources included in the proposed test plan, and many of these sources will qualify for a design, equipment, work practice or operational standard in accordance with section 112(h). In addition, data that are collected will be very limited data or of poor quality and representativeness and any limit developed will not reflect the actual level of emissions from those sources nor will it reflect the achievable level of performance across all sources and operating conditions.

The PCWP MACT remanded sources cannot be tested in a manner that assures the emissions are solely representative of the emission source or that assure emission limits established for those sources capture all the emissions attributable to that source. Even under circumstances where the tests could be reliable measures of the emissions from those units, it is not likely that the emissions tests could reliably take into account all the factors that affect the variability of emission rates at these units. It is not reasonable to attempt to test these units and establish emission limits based on the best performing units when emission performance is not based on the unit itself but rather the specific product being manufactured in that unit. It is also not reasonable to establish emission limits based on existing emissions information that does not take into consideration all these different factors. For these reasons we strongly urge EPA to forgo testing and setting emission limits for most of the remanded sources, and instead work with industry to develop reasonable work practice standards for these sources.

While existing data may not be appropriate to establish emission limits, it may be useful emission data to support EPA's work on the residual risk at these facilities. If EPA needs additional emissions information to support the residual risk evaluation, then additional testing for that purpose may be reasonable. Such a testing program could be designed to test worst case emission rates that would be useful for a conservative risk assessment even if that data was not useful for establishing emission limits from the various remanded sources.

As discussed in Sections III and VI of this memo, Phase II of the ICR has been eliminated as a result of timing, burden, and testing feasibility considerations. The EPA now intends to rely on the emissions data gathered through Phase I to complete the RTR.

G2
CPA

Boise Cascade
Testing and Controlling Most Downstream Sources would be Inherently Unreliable.
Most of these units have emissions that are unrelated to the function of the source (e.g. sanders and trim saws), but related to the product emissions as the panels move through the production process after pressing. These sources do not have emissions generated by combustion or heating of the materials.
There is an inherent variability of emissions dependent on the type, resin content, wood species and thickness of the product.
Some of these downstream units also work off-line, i.e. they may process panels after production. Emissions could be different than when processing newly pressed panels.
Given the variability of those products and the fact that these sources typically do not generate emissions but rather experience emissions as the product flows through them, it is difficult, if not impossible to collect meaningful emissions data for the sources or establish defensible numeric emission limits for them.
Requiring estimates or devising extensive testing regimens to attempt to capture emissions data from these sources would be inherently unreliable and unnecessary for the residual risk evaluation or for establishing emission limits for the miscellaneous sources.
It is very difficult to precisely capture and measure emissions from most emission sources downstream from dryers, such as plywood presses, trim saws, and sanders. These emission units are typically fugitive emission sources, or sources that are not isolated from other sources, and they often have very low HAPs concentrations that will require extended test runs. Some of these obstacles can be at least partially overcome through construction of enclosures, construction of testing stacks, and long test runs, such requirements are often complicated for various reasons and usually rather costly.
      Without assurances that sources can be carefully controlled to represent emissions from the unit tested, it is not reasonable to establish an emission limit for the specific units based on the test data because the data may include more or less emissions than actually emitted by the source. While such data may be useful to estimate emissions for modeling, it is likely not of the quality necessary to set an emission limit for which other facilities must then test to demonstrate compliance when those facilities may also have similar or different test issues. These issues make it impracticable to measure emissions from many of the PCWP MACT remanded sources due to technical and/or economic limitations. As such, EPA should conclude that it is not feasible to prescribe or enforce emission limitations for most of the PCWP MACT remanded sources and conclude these sources are subject to work practices.
As noted previously, Phase II emissions testing has been eliminated.
G3
AWC
After the review of the Phase I data is complete, OMB and the public should have an opportunity to review and comment on EPA's decision on whether a Phase II information collection is appropriate and if so, the scope of the Phase II test plan. The public cannot fully comment on the scope of the test plan without knowing the particular facilities and sources impacted and whether there is practical utility in further data collection.
As noted previously, Phase II emissions testing has been eliminated.
G4
NCASI
Section 1.0:
Existing emissions testing data
Historical performance tests on dryers and presses would include three 1-hour runs
Highly unlikely that there would be test data on emission points associated with remanded processes that would have seven test runs as stipulated in the ICR Test Plan

Therefore, suggests that if a facility has conducted testing that is applicable to the ICR and testing was comprised of a minimum of three 1-hour runs then the facility not be required to perform additional testing for those pollutants.
As noted previously, Phase II emissions testing has been eliminated.
G5
AWC

EPA should not require testing of equipment eligible for a work practice or alternate standard approach, as not all of the listed source types are isolatable and testable and would produce measurable HAP emissions: The following sources should be removed from the test plan:
Chippers: there is nothing to suggest that there would be measurable HAP emissions from chipping wood (especially green wood).
Miscellaneous sources that currently are not subject to HAP emissions standards under the PCWP MACT
As noted previously, Phase II emissions testing has been eliminated.
G6
NCASI
Section 1.1: Emission sources:
PCWP MACT I dryers:
A technically justifiable alternative to new testing would be to use existing data for boilers in the Boiler MACT database (stokers/sloped grate units designed to burn kiln-dried biomass or suspension burners designed to burn biomass, etc.) to carry out the residual risk analysis
If new data collection is necessary, the following should be considered for softwood veneer dryers
Units have both heating and cooling zones
PCWP MACT I has emission limits for heated zones and work practice standards for cooling zones
PM (HAP Metals) data collection should be limited to the heating zones instead of all atmospheric vents
PCWP MACT II Hardwood Dryers
If testing is required only the heated zones of direct-fired (non-natural gas) dryers should be tested for HAP metals and PM.
PCWP MACT II Hardboard ovens
Section 1.1.2 indicates a requirement to collect production rate data for hardboard ovens, but hardboard ovens are not mentioned in the list of required emission sources to be tested.
As noted previously, Phase II emissions testing has been eliminated.
G7
NCASI
Emission Point Definition/Characteristics
Dry blending, forming, and finishing sources are served by pneumatic dust collection systems that are not designed to collect organic HAP emissions at 100% and are instead open systems that utilize building air to transport fugitive, sander, and saw dust.
Use of the term "emission point" underscores the fact that the emissions from these miscellaneous baghouses are expected to be non-specific and variable.
It is infeasible for facilities to certify that collocated units were operating in a normal and representative manner during emission tests as normal operations may not include all collocated units in operation.
Inability to fully enclose and isolate process units will have a significant impact on the emission data collected.
As noted previously, Phase II emissions testing has been eliminated.
G8
NCASI
Normal and Representative Operating Conditions
Please clarify and define "normal and representative" for process units associated with the "dry forming and blending emission points" and the "finishing sander, saw, and chipper emission points"
Blending  -  Composition of resinated furnish processed through face and core blending units can vary depending on the type of panel manufactured but the amount of dry wood furnish processed will likely be consistent due to the surge bins ability to receive the resinated wood furnish and can accommodate fluctuations. Blending operations should be considered as separate entity from the formers and press production areas and have stand-alone production rates. EPA should stipulate what blender throughput is considered "normal and representative" so blending operations from similar product types can be compiled and evaluated.
Forming  -  Amount of resinated furnish laid down by the former will depend on the type of product being manufactured. EPA needs to designate a normal and representative mat thickness and/or line speed for formers of the same product type. Formers and presses can be operated at different rates and should be considered separate entities and could have different throughputs increasing the complexity if they share the same emission point.
As noted previously, Phase II emissions testing has been eliminated.
G9
NCASI
Use of term "performance test":
Consider an alternate terminology that is more representative of this data collection effort such as "PCWP ICR testing." "Performance testing" could be seen as a compliance test where process unit specific emissions are evaluated against a standard.
As noted previously, Phase II emissions testing has been eliminated.
G10
NCASI
Certification that APCD was in operation during testing:
Clarify that this question refers to the "air pollution control device" that was in operation is relevant to the parameter being tested. For instance, a baghouse is an APCD for PM but not for organic emissions.
As noted previously, Phase II emissions testing has been eliminated.
G11
AWC

Enclosing/Testing Sources
   NCASI has conducted a detailed survey of various source types that documents the difficulties associated with enclosing sources for HAP emissions testing.
   It will be challenging, if not impossible, to completely separate emissions from different types of sources that are located in close proximity to each other within a building. Building air brought in to these tests will contaminate the sample with fugitive emissions from surrounding sources.
   Many locations will not meet Method 1 criteria, especially older baghouse configurations and sources that exhaust through building vents. Facilities should not be forced to spend money to make modifications to exhaust vents to meet Method 1 criteria.
   Concerns with the required methods' ability to measure HAPs at low levels, and suspect that much of the data will be below detection limits for several sources. EPA should consider sources with high amounts of non-detects as candidates for work practices, not emission limits.
   Requirement for a temporary total enclosure would be needed not only for presses and board coolers but to all of the units for which EPA proposes to gather organic HAP data, if EPA means to gather emissions data that is associated to a particular process unit. Units that are not currently controlled under PCWP MACT are not enclosed for capture or control of organic HAP emissions. In order to set standards based on the test data, the tests must be carefully controlled to ensure that the emissions measured at the test location represent the total emissions from the specific unit and exclude any emissions not associated with the specific unit.
   Some temporary enclosures may be feasible for a few days, however permanent enclosure around the equipment may be impossible to design and install without severely hindering operations and compromising worker safety where a facility would need frequent access to the equipment for maintenance, operational adjustments, or product manipulation.
As noted previously, Phase II emissions testing has been eliminated.
G12
NCASI
Testing of alternative unit.
   The determination of what units are "more amenable to testing" has the potential to be highly subjective (and open to interpretation) especially in the case of collocated miscellaneous remanded sources. It is unclear how a facility will make this determination.
     Does this provision apply only to process unit emissions (versus those characterized as emission points)?
     Does this mean that the company must look to another facility that has more amenable individual process unit-specific emission points, for example, a former baghouse that is separate from a saw line baghouse?
     What if the more amenable emission point is serving a process unit that is actually in a worse location relative to a fugitive HAP source?
     How would the test results from the more amenable process unit emission point be related to a non-amenable emission point at another facility?
As noted previously, Phase II emissions testing has been eliminated.
G13
NCASI
Required Stack Test Methods - THC
 Provide instructions on how to adjust Method 25A response for the presence of non-THCs such as oxygenated organic compounds. Note that THC does include the contribution from methane.
 For Method 25A EPA should use terminology that will accurately describe the output they desire. Method 25A determines a "total gaseous organic concentration" (TGOC).
 Method 25A does not address the conversion of TGOC to organic mass emission rate [concentration (ppmvd) to mass rate (lb/hr)] as the ICR requires. EPA should include a standard procedure for converting concentration to a mass rate for all ICR test data
As noted previously, Phase II emissions testing has been eliminated.
G14
NCASI
"Filterable particulate matter (PM)":
The use of the term "filterable particulate matter" in this ICR test plan needs further clarification since the term "filterable" is typically only used to describe the collection of particulate matter by EPA Method 201A. We believe EPA's intent was to not include the condensable fraction. We recommend the use of the term "particulate matter" for PM collected using Method 29 and Method 5.
As noted previously, Phase II emissions testing has been eliminated.
G15
NCASI
Required Stack Test Methods  -  Methane for direct gas-fired dryers
  Methane can be a significant component of Method 25A response being measured at certain APCDs and other emission points that are comprised of building air. Methane measurements are therefore important to back-out the contribution of methane (non-methane TGOC) for all sources where THC measurements are required (not just direct gas-fired dryers).

  Mandated Concurrent Testing: If concurrent testing is mandated, methane needs to be added to the dry blending/forming and finishing emission points within Table 1.1. Board coolers should also be included in the list of sources for methane co-sampling. Not including methane in the exercise of correlating "THC" to HAP emissions will be a significant issue for most of the targeted PWCP MACT II emission sources because methane is not directly emitted by the associated process units but is being contributed by nearby fugitive methane sources. The contribution of methane, therefore, is expected to be highly variable and very much dependent on the physical location of the PCWP MACT II process unit. As the physical location of most finishing process units, for example, varies from mill to mill, the amount of methane contribution to "THC" is expected to vary. As a consequence, the correlation of "THC" to total HAP or individual HAP will not be applicable industrywide. Therefore, concurrent testing for most PCWP MACT II process units or emission points should be thoroughly reviewed and perhaps exemptions granted where deemed inappropriate. While the technical requirement of concurrent testing for "THC" and total HAP is probably not a huge issue for most testing companies, the concern with the concurrent testing issue is more to do with the cost and effort put in to collect data that will be utilized inappropriately. Furthermore, requiring seven (7) tests where "THC" and total HAP have to be tested simultaneously at emission sources with multiple emission points is going to be a technical challenge and very expensive.
As noted previously, Phase II emissions testing has been eliminated.
G16
Earthjustice
Stack Test Methods
EPA is proposing the use of NCASI Method ISS/FP-A105.01 for quantifying the regulated organic HAP. In the NCASI method, non-traditional blanks are specified. EPA should specify the use of more traditional field blank which includes the preparation and recovery of a sample train which has been used for sampling stack gas and specify the use of duplicate sample trains which use two complete sampling trains rather than a single probe and filter box with two impinger trains.
Table 1-2 uses Method 29 to quantify emissions of metals from processes which essentially dry the wood and bind wood pieces or veneers together. It is not expected that metals would be released from fuels used to heat the presses or dryers, wood which is not combusted, or glues used as binders. However, the tests will document either the low emissions or that emissions are below the capabilities of Method 29. If EPA is attempting to determine low level pollutants, several of the processes involve heating wood to levels at which incomplete combustion may be present. As a result, polycyclic organic ("POM") compounds may be formed. Thus, we recommend that EPA use CARB 429 to quantify POM compound emissions.
Also in Table 1-2, EPA has specified sampling for filterable particulate using Method 29 or, alternatively, Method 5. Rather than quantifying only the filterable component of particulate, EPA should require use of Method 202 combined with Method 5 to quantify total particulate matter included in the sampling.
As noted previously, Phase II emissions testing has been eliminated.
G17
NCASI
Number of Test Runs for Concurrent Testing:
Requiring seven (7) tests where "THC" and total HAP have to be tested simultaneously at emission sources with multiple emission points is going to be a technical challenge and very expensive.
As noted previously, Phase II emissions testing has been eliminated.
G18
NCASI
Enclosure for Plywood Presses:
The inherent design of plywood mills is to have one layup line that feeds multiple presses within a single large building. If a temporary total enclosure (TTE) is to be constructed around one of the collocated presses, the close proximity to other press(es) would make the complete isolation of the enclosed press unachievable. While TTE might meet the associated criteria, the emissions collected from the enclosure would include emissions from the rest of the building including the layup line and other presses. This manufacturing footprint configuration is a unique characteristic of the plywood product category which distinguishes the process of manufacturing plywood from manufacturing particleboard, OSB, and MDF.
As noted previously, Phase II emissions testing has been eliminated.
G19
NCASI
Table 1.2 Summary of Test Methods: Speciated Organic HAP
The use of the term "at least" for establishing the Sample System Minimum Measurement Level (SSMML) might be confusing to some testers.
If the "maximum" allowable SSMMLs are at the 0.2 (aldehyde) / 0.5 (alcohol) ppmvd levels provided in Test Plan, then running the BHA method according to the parameters used by NCASI for field validation (and outlined in the referenced example that is provided in the Method's Appendix A4) will not meet the ICR's test method SSMML criteria because the SSMMLs would be higher that the "at least" values stipulated in Table 1.2 of the ICR test plan, except for phenol.
To achieve the SSMML requirements in the ICR Test Plan, one or more sampling parameters need to be modified. Since the test plan is requiring 7 sample runs, the sample time of 60 minutes is likely not the parameter to modify. Increasing the sample flow rate to > 1.00 L/min will lower the methanol SSML to 0.45 ppmvd and formaldehyde SSMML to 0.2 ppmvd. Lowering the formaldehyde and methanol SSMMLs to the ICR Test Plan criteria, however, significantly challenges the quality assurance (QA) measures for the remaining compounds. Ultra-low concentrations detected at or just above the SSMML concentrations can cause the bracketed spike range between the low and high ESLs to be too narrow. Very low spiking levels are also difficult to formulate to get exact spike solutions from neat compounds and testers will have to make sure that they run the high ESL of the Bracketed Spike below 2 ppmvd for any compound detected below 0.5 ppmvd to guarantee that the proper spike recovery criteria are met.
As noted previously, Phase II emissions testing has been eliminated.
G20
NCASI
Table 1.2 - The sample line should be no longer than 2 meters
Further clarify this statement. Normally when total HAPs are tested concurrently with M25A, testers will use a heated 100 ft sample line to bring a slipstream of stack gas to a manifold that feeds both the M25A analyzer and the HAP trains. The sample gas is the conveyed from the heated manifold to the first impinger of each HAP train by a section of unheated Teflon sample line. EPA should clarify that the 2 meter sample line restriction applies only to the unheated section of sample line connected to the first impinger. Otherwise, testers will be restricted to conducting BHA testing near the test ports, which may not be feasible for some Phase II elevated emission points. Modify text to read: "The unheated section of sample line attached to the first impinger of the HAP sampling train should be no longer than 2 meters."
As noted previously, Phase II emissions testing has been eliminated.
G21
NCASI
Table 1.2 - Testing gas streams with entrained water droplets using a VOST probe
EPA has included modifications to the NCASI BHA method for testing gas streams with entrained droplets. The BHA Method does address use of the method at saturated emission sources: "This method should not be used on sources where significant amounts of entrained water droplets are present unless it is used in an isokinetic manner." This modification in the ICR Test Plan, however does not require isokinetic sampling but does recommend that a VOST prove be used. A VOST probe is a 3-foot glass probe that is configured with a short section that has a 5/8-inch section is considered to be a "cup" where water droplets are designed to fall out and the collected moisture would presumably drain out the probe tip. Since there is a potential for aldehydes and alcohols to concentrate in water droplets within the source duct or stack, failure to capture a representative amount of water droplets can bias the results.
As noted previously, Phase II emissions testing has been eliminated.
G22
NCASI
Table 1.2 - BHA Method QA measures
All QA/QC...criteria...must be...met: The following topics relate to the BHA method's QA measures that should be taken into consideration
    The BHA Method is primarily designed to be conducted in three (3) sample runs. The field QA that is conducted within those three sample runs is one spike run or one bracketed spike (consisting of two spike runs) and one duplicate run. Since EPA is requiring seven (7) sample runs, EPA needs to state that this ICR Test Plan only requires the reporting of one field QA dataset for all 7 sample runs. That is one duplicate and one single run spike or one bracketed spike.
As noted previously, Phase II emissions testing has been eliminated.
G23
NCASI
   The BHA method has been written in such a manner as to allow the end user the flexibility to interpret and evaluate method performance. Note that there is no statement within the BHA method that links the failure of an individual QA criterion to the invalidation of the three source gas concentration determinations. There is language within the method requiring that all QA procedures are to be performed and must be within certain criteria. However, the method does not declare what to do about failed QA criteria other than to clearly describe the circumstance for transparency purposes. This designed ambiguity gives the end user the ability to evaluate the results from the numerous QA criteria which cover a wide range of measurement capabilities. Due to the unique complexities of individual organic compound measurement, the QA steps in the BHA method provide the end user with an array of performance metrics which can be used to access the validity of the source gas concentration measured by the method's normal train.
As noted previously, Phase II emissions testing has been eliminated.
G24
NCASI
   The NCASI BHA method is a self-validating method which is different than performance based methods, such as EPA Method 5. EPA Method 25A is also a self-validating method but M25A is able to utilize direct measurement system response to reference gases that meet EPA Protocol 1 criteria. The BHA Method, on the other hand, relies on neat compounds for calibration of laboratory analytical equipment and spiking for assessing method execution. Since those neat compounds are transitioned through multiple matrices and environments during method execution, the complexity of handling and recovering individual volatile organic compounds has to be recognized and appreciated. While the focus will be to meet all of the QA criteria within the BHA method, the immense scope of this ICR test effort will inevitably result in cases where one of the numerous BHA Method QA criterion might not be met. Since each of the six HAP compounds will have an individual set of QA data, there will be more than sufficient QA information to diagnose any criteria failures and distinguish whether there was a systematic method failure or an anomaly with an individual compound measurement.
As noted previously, Phase II emissions testing has been eliminated.
G25
NCASI
   EPA should also clarify whether anomalies in sample analysis can be investigated and resolved by reanalysis of samples. NCASI recommends that sample reanalysis be allowed to evaluate anomalies. If the anomaly is rectified based on the result of the reanalysis, then the rerun result is to be reported as the correct value but the original value is also to be clearly reported with a summary of the issue.
As noted previously, Phase II emissions testing has been eliminated.
G26
NCASI
   Acetaldehyde, acrolein, and propionaldehyde: Emissions of acetaldehyde, acrolein, and propionaldehyde are for the most part generated when heat is applied to wood chips during drying activities and to wood surfaces during pressing activities. Since these three compounds are not a significant component in urea-formaldehyde or phenol-formaldehyde resins, process units that handle resinated dry wood furnish or conduct finishing activities on cured panels are not expected to generate emissions of these three compounds. Based on the limited data available, atmospheric refiners, blenders, formers, saws, and sanders appear to have non-detect levels of these three compounds. The historical data, however, are based on higher detection levels than being required by this ICR test plan. To ease the burden of this testing effort, EPA should waive the run spike QA requirements for these three compounds when testing is conducted for this group of emission points. Even if one or more of these compounds were to be detected, the levels would be so low that any associated QA-spike measures would not be of any consequence. Since the run spike would still be conducted for formaldehyde, methanol, and phenol, the second QA-spike train would provide valuable duplicate data for acetaldehyde, acrolein, and propionaldehyde since these compounds would not be in the spike solution. The tester would obviously still be required to conduct the train spike for all six compounds.
As noted previously, Phase II emissions testing has been eliminated.
G27
NCASI
Table 1.2 - Total Hydrocarbons (THC):
Change the term "THC" to better reflect what EPA is actually trying to measure. Also to avoid confusion, EPA should specify if the "THC" values includes methane or not. The stipulation that measured concentrations must be bracketed by the low and high level calibration gases is unrealistic for most low concentration "THC" sources such as finishing emission points. Most Method 25A analyzers are operated within a specified concentration range, for example 0-10 ppmv or 0-100 ppmv. Method 25A requires that the analyzer be calibrated with a zero gas and a high level gas that is 80% - 90% of the concentration range setting. The low level gas is required to be 25% to 35% of the concentration range setting. Most low concentration PCWP sources have "THC" concentrations that fall within the range of 5 to 20 ppmvd "THC" as propane and can be significantly impacted by the presence of methane. Methane is not generated by the majority of PCWP MACT 2 process units/emission points and methane can cause the "THC" levels to fluctuate between the 1st and 2nd analyzer range settings. Under this strict ICR "THC" criteria, any source within a concentration between 9 and 25 ppmvd "THC" as propane would not be testable since the source gas would be above the high level gas for 0-10 ppmv range setting and below the low gas for the 0-100 range setting. Since EPA is requiring concurrent testing of "THC" and total HAP for 7 sample runs, any source "THC" concentration drift between the 1st and 2nd analyzer range setting would invalidate the test and require the tester to recalibrate the M25A measurement system and replace the HAP train(s) for a substitute sample run. This calibration gas bracket stipulation has the potential to be time consuming, very expensive, and adds unnecessary burden to the test plan. Method 25A analyzers do provide predominantly linear responses. Therefore, it should be sufficient to allow the tester to follow the method's written QA and select the concentration range that includes the maximum expected source gas "THC" concentration. If EPA remains concerned that Method 25A analyzers will not return a reasonably linear response to measured concentrations below the low calibration gas, then the "THC" criteria could allow testers to include a 4th calibration gas that will challenge the analyzer at some lower level.
As noted previously, Phase II emissions testing has been eliminated.
G28
NCASI
Table 1.2 - Measurement of methane via Method 18:
While Method 18 may be an appropriate method for measuring methane, it is an inappropriate method for this ICR application if the "THC" value is to be adjusted for methane and/or will be used as part of the concurrent test evaluation being conducted to evaluate the correlation between "THC" and total HAP. While M18 does use a gas chromatograph/flame ionization detector (GC/FID), the issue with M18 is that it is a separate analysis method with no direct link to the M25A "THC" measurement. The M25A "THC" response will have a methane component to it and an associated methane FID response factor specifically for the field flame ionization analyzer (FIA) that has been calibrated with propane. As a consequence, basing any methane result on Method 18 will not accurately reflect the actual methane response or contribution to the "THC" measurement collected by the M25A FIA. If EPA is going to allow adjustment of the M25A concentration for Method 18 methane measurements, then clear instructions are required to show how that adjustment is to be calculated, including the impact of the FID response factor for methane. An alternative to Method 18 that would avoid this issue would be to allow the use of a M25A FIA that is equipped with two FIDs, one dedicated to measuring "THC" and the other dedicated to measuring methane. The "THC" FID would be calibrated with propane and the output would be the "THC" response on a propane basis. The methane FID would be fed through a duplicate instrument path that includes a methane cutter to allow only methane through. This FID would be calibrated with methane and the output would only reflect the direct response to methane. Since both FIDs are operating simultaneously within this FIA, this arrangement would allow for (1) the direct measurement of the "THC," (2) the direct measurement of methane, (3) the direct determination of the methane response factor on the "THC" FID, and (4) the accurate determination of non-methane "THC" concentration.
As noted previously, Phase II emissions testing has been eliminated.
G29
NCASI
Table 1.2 - Metals and PM (filterable):
EPA is requiring HAP metals and PM testing at the PCWP MACT I dryer emission sources via Method 29, with Method 5 as an option for PM. Since these PCWP MACT I dryers already have organic HAP APCDs installed, EPA needs to clarify that the testing needs to be at the APCD outlet.
EPA is requiring seven (7) sample runs to be conducted, with each run having to collect at least 105 dscf, or 3 dscm. This would imply each sampling run will have to be 2.5 to 3 hours in duration; making the testing effort labor intensive and very expensive.
As noted previously, Phase II emissions testing has been eliminated.
G30
NCASI
Table 1.2  -  Mercury:
While Method 29 does collect total mercury, this method requires that five (5) different mercury sample fractions be collected to account for total mercury, with each sample fraction having a different detection level. Particulate bound mercury associated with the firing of sander dust is expected to be very low at the outlet of organic HAP APCDs because these APCDs normally have some method for minimizing particulate loading to the organic HAP APCD. As a consequence, particulate emissions from controlled dryers are expected to be low and EPA should allow the use of Method 30B for mercury instead of Method 29, where applicable. M30B is an approved test method in Boiler MACT. EPA should also consider conducting an initial HAP metal risk assessment based on fuel analysis to estimate maximum HAP metals emissions and then apply PM removal efficiencies to estimate applicable controlled emissions. These two estimation techniques may provide sufficient evidence for this purpose.
As noted previously, Phase II emissions testing has been eliminated.
G31
NCASI
Table 1.2 - MDI:
Target reporting units are missing in Table 1.2 under the column heading Reported Units of Measure
As noted previously, Phase II emissions testing has been eliminated.
G32
NCASI
Table 1.2  -  O2/CO2
Measurement of O2/CO2 for every run at ambient air supplied emission sources is a burden. EPA should stipulate that O2/CO2 data collection can be limited to one test result showing ambient O2/CO2 levels for ambient air supplied sources.
As noted previously, Phase II emissions testing has been eliminated.
G33
NCASI
Table 1.2  -  Moisture
Moisture determinations by wet/dry bulb should be allowed for ambient air supplied emission sources that have low to moderate levels of moisture.
As noted previously, Phase II emissions testing has been eliminated.
G34
NCASI
"You should collect emissions samples for the identified pollutants downstream of the last relevant APCD (i.e., stack or other point representing the composition of the flue gases at the exit to the atmosphere), unless otherwise indicated": EPA needs to be more specific with regard to emission sample collection points for emissions sources with non-relevant APCDs..
As noted previously, Phase II emissions testing has been eliminated.
G35
NCASI
PWCP Process Data Collection (pg 7, 2nd paragraph):
   EPA has not provided production rate criteria for "Dry blending and forming operation emission points," "Finishing sander, saw, and chipper emission points," and fiber washers. This is a significant issue because establishing a standard production rate basis for these types of process units is a major challenge. The production unit selected should be applicable to all of the process units/emission points associated with each category.
   For temporary total enclosed non-isolated process units collocated with other similar process units, such as for multiple plywood presses located within the same building and only one press is being tested, the production rate for the enclosed press should be based on the production rate from all presses.
   For collocated dissimilar process units under the same emission point or collocated process units of the same type under the same emission point, the total production rate should be based on all relevant process units.
     Hardboard ovens are not included on the list of emission sources to be tested but are required to report production rates?
     Clarify what is meant by "Emission unit operating temperature"; does EPA want the operating temperature of the process unit itself or the temperature of the gas stream associated with the process units at the emission point to the atmosphere or test location?
     EPA should stipulate that wood moisture content determinations can be reported by typical/standard mill collection methods.
     EPA needs to clarify the intent of collecting the operating parameters for APCDs, i.e., is EPA soliciting 1) the "operating parameters relevant for the APCD" or 2) "operating parameters relevant for the APCD relevant to the test parameter/pollutant"?
baghouse parameters relevant for organic HAP and "THC" testing
RTO parameters relevant for metal HAP and PM testing
     It is our recommendation that EPA provide exemptions for instances where APCDs are not applicable for the pollutant being tested
As noted previously, Phase II emissions testing has been eliminated.
G36
Boise Cascade
PCWP MACT sources are highly variable. Among other factors:
   The emissions generated at the presses are due to heating of wood and resin. Because the wood has been previously heated during drying, most, but not all, of the emissions from the wood have been driven off. However, as the wood is reheated during pressing, additional HAPs are emitted from the wood.
   Most of the HAPs emissions generated at the press come from the resin applied to the veneer.
   In addition, the resin application rate, the thickness of the panel, and the number of veneers in the panel greatly affect the HAPs emission rate.
   Press temperature and press time can affect HAPs emissions during pressing.
   The variability of emission rates due to the range of conditions at the press would likely carry over to all downstream emission units such as the trim saws and sanders as the hot panels pass through those emission units.  Cool panels passing through those same units would likely emit less HAPs as HAPs emissions tend to decrease as the panels cool.

While we have concerns with, and recommend EPA not pursue emissions testing of most of the remanded sources, we think the test plan omits some important data that must be collected to assure that tests data can be understood in terms of the variability of the processes. For example, EPA should request that all the product and operating parameters described above should be required to be included in the test reports.
As noted previously, Phase II emissions testing has been eliminated.
G37
NCASI
Appendix A
The guidance on detection levels does not include handling of NCASI BHA minimum measurement level (MML) or sample system minimum measurement level (SSMML). Since the ERT does not support the BHA method, does EPA plan to incorporate these flags in the "PCWP Testing Supplement" Flag column?
Since M29 has five sample fractions for Hg and each sample fraction has its own detection level, EPA should provide guidance on how to combine non-detect and detect fractions into a total Hg result. NCASI recommends the use of Method 30B for Hg testing given the potential for high bias
As noted previously, Phase II emissions testing has been eliminated.
G38
SLMA
EPA has requested that facilities provide emissions data in response to the Phase I ICR survey. Capturing and quantifying emissions from lumber kilns is difficult, particularly for continuous kilns which remain open during operation. We urge EPA to focus on the development of work practice standards for lumber kilns and to revise the ICR survey to achieve this objective.
As noted previously, Phase II emissions testing has been eliminated.
G39
Masonite
We believe that EPA will learn from the ICR Phase I Questionnaire that many of 19 sources included in the test plan have not been tested, and cannot be tested due to several reasons inherent to the wood products industry including:
the lack of isolated emission points,
::	the fugitive nature of the emissions
::	the inability to capture and direct the emissions through an emission point,
the very low concentrations of HAPs,
the high cost and of enclosing the sources and modifying the emission points to make testing possible.
The wood products industry has been successful in identifying the primary sources of HAP emissions in our industry. This can be substantiated through scientific understanding of the processes, including parameters that impact HAP emission such as temperature, moisture content, wood species, and process additives. We urge EPA to use this information to develop work practice standards rather than to employ costly and potentially non-representative testing for these remaining low-emitting sources where testing is not technically feasible.
As noted previously, Phase II emissions testing has been eliminated.
G40
Weyerhaeuser
Eliminate testing for remanded presses
EPA should carefully consider the safety, technical and cost issues with attempting to enclose and test emissions from presses that were not regulated with process unit specific emission limits under the current PCWP NESHAP for technical feasibility reasons.
EPA toured a Weyerhaeuser engineered wood products facility in 2008, observing and documenting the configuration of very large multiple, continuous, laminated veneer lumber (LVL) presses. Discussions with Weyerhaeuser staff at the facility pointed to the difficulties that would thwart enclosing such presses to isolate and capture the low level, largely fugitive emissions in order to quantitatively test and/or convey the emissions to control devices. Industry and university investigators developed the heated sealed caul plate test method, considered the most accurate method for estimating emissions from difficult-to-test presses. Emission factors developed from data based on the sealed caul method are appropriate for EPA's RTR evaluations. The history of the development of the sealed caul method is evidence of the appropriateness of an EPA decision to not require attempts at full-scale press enclosure and emissions testing.
As noted previously, Phase II emissions testing has been eliminated.
G41
Earthjustice
Suggests that EPA modify the ERT to document the NCASI ISS/FP-A105.01 Method.
As noted previously, Phase II emissions testing has been eliminated.
G42
Earthjustice
EPA should require additional testing for the two categories for which it is proposing testing in Phase II; requiring only a small number of tests from only 4-5 units, as EPA has proposed, is unlikely to produce sufficient data to inform EPA's rulemaking duties. EPA estimates the number of facilities to include:
235 sawmills with lumber dry kilns,
92 plywood and veneer facilities,
36 OSB facilities,
22 MDF facilities,
21 particleboard facilities,
4 hardboard facilities,
4 fiberboard facilities, and
11 engineered wood product facilities.
On page 28, EPA is proposing a total of 80 emissions tests to characterize 20 different processes, with only two to five tests of each individual process (as shown in Table 3 of the Supporting Statement). If the facilities to be tested will be randomly selected, we believe that this is an insufficient number of tests to characterize the average emissions of the best performing 12% of the facilities and the lowest emitting source. In addition, if EPA intends to assess if there are significant differences in the type of wood being processed or the process employed or if the wood types or processes can be combined for regulatory purposes, the number of samples would likely only identify order of magnitude differences. We suggest that EPA re-evaluate both the number of tests proposed for individual process types and the selection of the facilities for testing such that the tests represent the better performing sources.
As noted previously, Phase II emissions testing has been eliminated.
G43
Earthjustice
EPA should ensure that Phase II can cover all additional HAP data needed going beyond just the proposed categories. It is extremely likely that, in response to Phase I, EPA will receive little or no emission test data, or that some tests will be 13 years old. EPA should include in Phase II additional tests for all known HAPs emitted that are currently covered by the NESHAP, so that it gets an accurate picture of what the existing standards are controlling and the health risks under those standards.
As noted previously, Phase II emissions testing has been eliminated.
G44
Earthjustice
EPA should request testing for additional metal HAPs and others that may potentially be emitted even if not known to be emitted. As EPA knows from other rulemakings, such as the Wool Fiberglass rule, tests may show previously-unknown HAPs (like hexavalent chromium, in the case of the Wool Fiberglass rule) are being emitted, requiring EPA regulation. EPA should ensure this ICR gives the agency an accurate picture of the emissions inventory from this sector so that community members are not subject to hidden health threats without EPA doing the investigation needed to discover those threats that may well be coming from unregulated HAPs emitted. The situation near a plywood facility in Crossett, Arkansas, is an example of why broader emission testing is needed in this ICR to ensure appropriate pollution limits are in place for this and other similar facilities.

In particular, in order to assess the actual and potential air emissions from wastewater systems for enhanced biodegradation units and wastewater sources, EPA should require both testing of the effluent for specific parameters and air emission testing for all known and potential HAPs, including but not limited to for methanol, phenol, benzene, xylene, and others. This would provide information that EPA and stakeholders could evaluate to fulfill all of the stated objectives of this ICR.
As noted previously, Phase II emissions testing has been eliminated.
G45
Georgia Pacific
The Crossett plywood facility was idled in October 2011 and has since been permanently closed. It has not been the focus of concerns about health impacts or air pollution.
As noted previously, Phase II emissions testing has been eliminated.

G46
Boise Cascade
If requiring additional testing it is very important for EPA to collect information on the cost and complexity of installing temporary enclosures and temporary test stacks on the various sources that must be tested. Photos of the enclosures would be helpful. EPA should also require documentation that the enclosures either meet the definition of temporary total enclosures or provide measures of capture efficiency for each temporary enclosure.
As noted previously, Phase II emissions testing has been eliminated.
H. Other/General
No.
Commenter
Comment Summary
EPA Response/Action Taken
H1
AWC
CPA
Many of the identified miscellaneous sources are not susceptible to control and the application of measurement methodology is not practicable due to technological and economic limitations. Work practice standards would be the better statutory standard setting approach for many of these sources at our members' facilities. An appropriate work practice standard is readily available to limit HAP emissions  -  mill production of panels with emissions consistent with those required under Phase II of the California Air Resources Board's Air Toxic Control Measure (ATCM) for Formaldehyde Emissions from Composite Wood Products. California Air Resources Board (CARB) for work practice standards Model work practice standards after CARB II production management system to document and verify the minimization of HAP emissions. Resin-based work practice standards would be appropriate for many of the remanded sources.
We acknowledge that there are technological and economic limitations associated with testing many of the miscellaneous sources. The Phase I ICR results will be used to more fully understand equipment configurations, emission levels, and potential work practices for reducing HAP emissions such as the CARB ATCM or related resin-based work practices. Phase I of the ICR will provide information on resins used in PCWP mills today following implementation on the CARB ATCM and the TSCA formaldehyde rule.
H2
CPA, WWPA, SLMA, Masonite
Supports AWC comments.
The commenters' support for AWC's comments is acknowledged.
H3
APA, Hardwood Federation, Weyerhaeuser
Supports AWC and NCASI comments.
The commenters' support for the comments from AWC and NCASI is acknowledged.
H4
Boise Cascade
Supports AWC, NCASI, CPA, and APA comments.
The commenter's support for the comments from AWC, NCASI, CPA, and APA is acknowledged.
H5
Earthjustice
Public Information: The instructions for this ICR recognize that EPA has reviewed certain information (e.g., emission tests, compliance reports, permits, and industry-association technical bulletins from the National Council for Air and Stream Improvement). See Survey Documents and Spreadsheets Appendix 10. EPA should put into the docket for this ICR all information that it reviewed to create this ICR; commenters were hampered from evaluating the ICR and being able to provide an informed comment due to a lack of supporting material from EPA. In addition, EPA should ensure that all data received from this ICR, and for which a CBI claim has not been proven and substantiated by EPA, are made publicly available as soon as possible on EPA's website or in the docket for this ICR on regulations.gov.
The types of information the commenter mentions (emission tests, compliance reports, permits, and data from NCASI technical bulletins) were docketed as part of research to support prior PCWP rulemaking actions. General industry knowledge of the PCWP industry gained from prior rulemaking research was used to construct the ICR. The purpose of the ICR will be to gather information (e.g., test reports, compliance reports, emissions estimates, and permit information) which will be tabulated and included in the docket for the proposed PCWP RTR.  Technical memoranda and reports documenting our analyses of the collected information will be available in the docket and on the web site for the proposed RTR.


Alan Stout EPA OAR, OTAQ, ASD Received Date: 07/ 07/ 2004 11: 50: 25 AM Transmission Date: 07/ 07/ 2004 11: 50: 25 AM To: rtheroux@ omb. eop. gov cc: Subject: Excerpts Rich, Here are the excerpts you requested.

Regarding warranty claims and coverage ( new text in bold): § 1068.110: Clarify that the manufacturers' warranty obligation includes all expenses related to diagnosing and repairing or replacing emission related parts. This is not intended to include incidental expenses ( such as replacement units during warranty service), consequential damage ( such as damage caused by engine malfunction), or opportunity costs ( such as foregone revenue from engine downtime).

Regarding the cross over certification ( simply): We are proposing to add a new section 90.913 to better define the responsibilities for manufacturers choosing to certify their engines below 19 kW to the emission standards for Large SI engines in 40 CFR part 1048.

Let me know if I can follow up on these things or clarify anything else.

Glenn and I are leaving today at about 3: 00 for our trip tomorrow, so it would be great if you could get back to us before that. If not, we'll pick things up Friday morning.

Thanks much.

Alan