Plywood and Composite Wood Products (PCWP)
NESHAP Summary
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7. How Does a Source Demonstrate Initial Compliance With
the Final Rule?
The initial compliance requirements in the PCWP rule vary
with the different compliance options.
Production-Based Compliance Options (PBCO)
 If the source is complying with the PBCO in PCWP MACT rule, they must conduct
an initial performance test using specified test methods to demonstrate initial
compliance. The source must test the efficiency of their emissions capture device
during the initial performance test if the process unit is a press or board cooler.
The actual emission rate of the press or board cooler is equivalent to the measured
emissions divided by the capture efficiency. The source must test prior to any
wet control device operated on the process unit. During the performance test,
the source must identify the process unit controlling parameter(s) that affect
total HAP emissions; these parameters must coincide with the representative operating
conditions the source describes in the performance test.
For each parameter, the source must specify appropriate monitoring methods and
monitoring frequencies, and for continuously monitored parameters, they must
specify averaging times not to exceed 24 hours. They must install process monitoring
equipment or establish recordkeeping procedures to be used to demonstrate compliance
with the operating requirements for the parameters they select. During the initial
performance test, the source must use the process monitoring equipment or recordkeeping
procedures to establish the parameter value (e.g., maximum, minimum, average,
or range, as appropriate) that represents their operating requirement for the
process unit. Alternatively, they may install a total hydrocarbon (THC) continuous
emission monitoring system (CEMS) and monitor the process unit outlet THC concentration
and establish their THC operating requirement during the performance test.
Add-On Control System Compliance Options
 If
the source uses the compliance options for add-on control systems, they must
conduct an initial performance test using specified test methods to demonstrate
initial compliance. With the exception of the 20 ppmvd THC concentration option,
they must test at both the inlet and the outlet of the HAP control device.
For HAP-altering controls in sequence, such as a wet control device followed
by a thermal oxidizer, the source must test at the functional inlet of the
control sequence (e.g., prior to the wet control device) and at the outlet
of the control sequence (e.g., thermal oxidizer outlet).
If the source uses a wet control device as the sole means of reducing HAP emissions,
they must develop and implement a plan to address how organic HAP captured in
the wastewater from the wet control device is contained or destroyed to minimize
re-release to the atmosphere such that the desired emission reduction is obtained.
If the source uses any of the six
compliance options for add-on control systems, and the process unit is a
press or a board cooler without a wood products enclosure, they must also test
the capture efficiency of their partial wood products enclosure. Prior to the
initial performance test, the source must install control device parameter monitoring
equipment or THC CEMS to be used to demonstrate compliance with the operating
requirements for add-on control systems in the final rule. During the initial
performance test, the source must use the control device parameter monitoring
equipment or THC CEMS to establish the parameter values that represent their
operating requirements for the control systems.
 If the source's add-on control system is preceded by a particulate control
device (e.g.,
baghouse or wet electrostatic precipitators (WESP)), they must establish operating
parameter values for the HAP control system and not for the particulate control
device.
If the control device is a biofilter, then the source may use values recorded
during previous performance tests for the biofilter to establish their operating
requirements as long as they were in compliance with the emission limits in
final rule when the data were collected, the test data were obtained using
the test methods in final rule, and no modifications were made to the process
unit or biofilter subsequent to the date of the performance tests.
Emissions Averaging Compliance Option
If the source elects to comply with the emissions averaging compliance option
in the final rule, they must submit an Emissions Averaging Plan (EAP) to the
regulating agency for approval. The EAP must describe the process units the
source are including in the emissions average. The plan also must specify which
process units will be credit-generating units (including under-controlled,
debit-generating process units that also generate credits) and which process
units will be debit-generating units. The EAP must also include descriptions
of the control systems used to generate emission credits, documentation of
the total HAP measurements made to determine the required mass removal (RMR),
calculations and supporting documentation to demonstrate that the actual mass
removal (AMR) will be greater than or equal to the RMR, and a summary of the
operating parameters that will be monitored.
 Following
approval of the EAP, the source must conduct performance tests to determine
the total HAP emissions from all process units included in the EAP. The credit-generating
process units must be equipped with add-on control systems; therefore, for
those process units, the source must follow the procedures for demonstrating
initial compliance as outlined above for add-on control systems. For debit-generating
process units without air pollution control devices (APCD), the source must
follow the same procedure for establishing their operating requirements as
outlined above for process units meeting the PBCO.
The emissions averaging provisions require the source to conduct all total
HAP measurements and performance test(s) when the process units are operating
under representative operating conditions. The PCWP MACT rule defines “representative
operating conditions” as those conditions under which the process unit
will typically be operating following the compliance date. Representative conditions
include such things as using a representative range of materials (e.g., wood
material of a typical species mix and moisture content, typical resin formulations)
and operating the process unit at typical operating temperature ranges.
Work Practice Requirements
The work practice requirements in the PCWP MACT rule do not require the source
to conduct any initial performance tests. To demonstrate initial compliance
with the work practice requirements for dry rotary dryers, the source must
install parameter monitoring devices to continuously monitor the dryer inlet
operating temperature and the moisture content (dry basis) of the wood furnish
(i.e., wood fibers, particles, or strands used for making board) entering the
dryer. The source must then use the parameter monitoring devices to continuously
monitor and record the dryer temperature and wood furnish moisture content
for a minimum of 30 days.
 If the monitoring data indicate that during the minimum 30-day demonstration
period, the
dry rotary dryer continuously processed wood furnish with an inlet moisture
content less than or equal to 30 percent, and the dryer was continuously operated
at an inlet dryer temperature less than or equal to 600[deg]F, then the dryer
meets the definition of a dry rotary dryer in today’s final rule. The
source must submit the monitoring data as part of the notification of compliance
status report.
To demonstrate initial compliance with the work practice requirements for
hardwood veneer dryers, the source must calculate the annualized percentage
of softwood veneer processed in the dryer by volume, using veneer dryer production
records for the 12-month period prior to the compliance date. If the total
annual percentage by volume of softwood veneer is less than 30 percent, the
veneer dryer meets the definition of hardwood veneer dryer. The source must
then submit a summary of the production data for the 12-month period and a
statement verifying that the veneer dryer will continue to process less than
30 percent softwoods as part of the notification of compliance status report.
To demonstrate initial compliance with the work practice requirements for
softwood veneer dryers, the source must develop a plan for minimizing fugitive
emissions from the veneer dryer green end and heated zones. The source must
submit the plan with the notification of compliance status report.
 To
demonstrate initial compliance with the work practice requirements for veneer
redryers, the source must install a device that can be used to continuously
monitor the moisture content (dry basis) of veneer entering the dryer. The
source must then use the moisture monitoring device to continuously monitor
and record the inlet moisture content of the veneer for a minimum of 30 days.
If the monitoring data indicate that the veneer dryer continuously processed
veneer with a moisture content less than or equal to 25 percent during the
minimum 30-day demonstration period, then the veneer dryer meets the definition
of a veneer redryer in the final rule. The source must submit the monitoring
data as part of the notification of compliance status report.
To demonstrate initial compliance with the work practice requirement for
group 1 miscellaneous coating operations, the source must submit a signed statement
with the notification of compliance status report stating that the source is
using non-HAP coatings. The source must also have a record (e.g., material
safety data sheets) showing that you are using non-HAP coatings as defined
in the PCWP MACT rule.
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