

INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT
EPA ICR No. 2552.01
INFORMATION COLLECTION REQUEST FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)












Sector Policies and Programs Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711












August 10, 2016
SUPPORTING STATEMENT
INFORMATION COLLECTION REQUEST FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)
Part A of the Supporting Statement
1.	Identification of the Information Collection
(a)	Title of the Information Collection
"Information Collection Request for Plywood and Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Residual Risk and Technology Review (RTR)." This is a new information collection request (ICR).
(b)	Short Characterization
This information collection is being conducted by the U.S. Environmental Protection Agency (EPA)'s Office of Air and Radiation (OAR) to assist the EPA Administrator, as required by sections 112(d) and 112(f)(6) of the Clean Air Act (CAA), as amended, to determine the current affected population of plywood and composite wood products (PCWP) processes and to reevaluate emission standards for the source category. The information from this ICR would also be made available to the public.
This is a one-time information collection. Currently, information necessary to identify PCWP facilities is available from the EPA's Toxics Release Inventory (TRI) and from the EPA's Emission Inventory System (EIS). Neither the TRI nor the EIS contain all of the details (capacity, fuel types, operating schedule, emission source design, materials processed, emissions collection and control systems, regulatory alternatives used, and emissions test data) necessary to characterize PCWP NESHAP affected sources for purposes of regulatory analyses. Although some of the needed information may be included in title V or state air emissions permits, many permits do not contain all of the detail needed and are not readily available from any single source. Furthermore, there are no readily available sources for previously conducted emissions test results (since the late 1990s) that will provide data for emissions of the variety of pollutants under consideration. To obtain this information, the EPA is soliciting information with a survey, under authority of CAA section 114, from all potentially affected units. The EPA intends to administer the survey in electronic format as indicated by the spreadsheet and instruction document in Attachment 1. The survey will be sent to all PCWP manufacturing facilities described as CAA major or synthetic area sources (which used technology to avoid major PCWP NESHAP source status) in EPA databases.
The proposed data-gathering effort has two phases: Phase I is a spreadsheet questionnaire to be completed by all affected facilities and Phase II is emissions testing to be completed in accordance with an EPA-approved protocol for selected emissions sources. The amount of data from previously-conducted emissions tests and other emission data gathered in the Phase I of the ICR will influence the scope of the collection under Phase II of the ICR. If enough emissions data are collected in Phase I to perform the required regulatory analyses, then Phase II will not be implemented. However, if significant data gaps remain after Phase I that would prevent the EPA from performing the regulatory analyses required under the CAA, then the portions of the Phase II ICR needed to resolve the data gaps will be implemented.
The EPA estimates the total cost to industry of the ICR (gathering, entering, and quality assurance (QA) of data submitted in response to Phase I of the survey for 425 respondents and emissions testing in response to Phase II of the survey for up to 38 selected respondents) will range from 106,065 to 114,306 hours and $12,003,650 to $19,778,180 including $7,119 to $7,755 in operating and maintenance (O&M) costs for digital media (CD, DVD, or flash drive) and postage for mailing survey responses to the EPA. The lower end of the ranges of burden and cost estimates presented is based on Phase I, while the higher end of the range encompasses the additional burden and costs associated with Phase II should Phase II be required for the Agency to gather sufficient emissions data to fulfil its duty. The overall average burden and cost per respondent ranges from 250 to 269 hours and $28,227 to $46,519, depending on whether Phase II must be exercised. 
2. 	Need for and Use of the Collection
(a)	Need/Authority for the Collection
      The PCWP production source categories includes any CAA major source facility engaged in the production of PCWP and kiln-dried lumber. This category includes, but is not limited to, plywood, dry veneer, particleboard, medium density fiberboard (MDF), hardboard, fiberboard, oriented strand board (OSB), engineered wood products (EWP) and lumber dry kilns. The PCWP production process units include operations such as conditioning, digesting, refining, fiber washing, drying, adhesive application, forming, pressing, cooling, sawing, sanding, wastewater treatment and miscellaneous coating application. Different material preparation, drying, adhesive, pressing and coating processes are used in the different industry segments. The federal emission standard that is the subject of this information collection is 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).
In general, the PCWP NESHAP covers hazardous air pollutant (HAP) emissions from the wood products production areas (e.g., material preparation, drying, adhesive application, pressing) at PCWP facilities. The PCWP NESHAP includes several alternative emission limits for each covered process that are designed to provide flexibility and to promote and encourage the use of new technology, particularly air pollution controls and pollution prevention technologies. 
Section 112(f)(2) of the CAA directs the EPA to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards and determine if additional standards are needed to reduce residual risks. The section 112(f)(2) residual risk review is to be done 8 years after promulgation. Section 112(d)(6) of the CAA requires the EPA to review and revise the MACT standards, as necessary, taking into account developments in practices, processes, and control technologies. The section 112(d)(6) technology review is to be done at least every 8 years. The PCWP NESHAP was promulgated in 2004 and is due for review under CAA sections 112(f)(2) and 112(d)(6). As a result of PCWP air pollution control requirements, the EPA amended the 40 CFR part 429 effluent guidelines concurrent with the 2004 PCWP NESHAP. It was determined that facilities subject to zero discharge limits in the Timber Processing Industry section of the guidelines should be allowed an exception for discharges from pollution control equipment installed to comply with the PCWP NESHAP. The amendments allowed facilities to establish case-by-case guideline limits and the EPA indicated at the time of PCWP NESHAP promulgation that additional information would be necessary for reviewing those limits subsequent to PCWP NESHAP compliance and to amend the effluent guidelines as necessary. The planned ICR will collect information to assist in the effluent guidelines review.
In addition to the CAA-required reviews, recent case law and legal petitions suggest the need to review the PCWP NESHAP. In June, 2007, The U.S. Court of Appeals for the District of Columbia Circuit issued a remand order for the EPA to re-evaluate the MACT floors and standards for several PCWP process unit groups. Among the issues to be addressed are MACT floors and standards that had no emissions reduction requirements. Also, in December 2008, the U.S. Court of Appeals for the D.C. Circuit vacated the startup, shutdown, and malfunction (SSM) provisions contained in the NESHAP General Provisions that apply to PCWP facilities. To the extent that these legal actions need to be addressed in the PCWP NESHAP, the EPA intends to investigate potential rule revisions at the same time as the CAA statutory reviews are conducted.
Additionally, in 2008, the California Air Resources Board (CARB) finalized an Airborne Toxic Control Measure (ATCM) to reduce formaldehyde emissions from hardwood plywood, MDF, and particleboard. Consistent with the CARB ATCM, in 2008, Congress passed the Formaldehyde Standards for Composite Wood Products Act, as Title VI of Toxic Substances Control Act (TSCA), [15 U.S.C. 2697], and the EPA subsequently proposed a rule in 2013 to implement TCSA Title VI to reduce formaldehyde emissions from composite wood products. The TSCA implementation rule (Formaldehyde Emission Standards for Composite Wood Products, RIN 2070-AJ44) was finalized by the EPA on July 17, 2016. The CARB ATCM and the rule to implement TSCA Title VI emphasize the use of low emission adhesives, including ultra-low-emitting formaldehyde (ULEF) and no added formaldehyde (NAF) resin systems, and many composite wood products facilities have changed resin systems over the past 7 years following promulgation of the PCWP NESHAP. The planned ICR would provide the EPA with information on the recent advances in resin system technology and allow the EPA to determine the effects of these changes on HAP emissions from composite wood product manufacturing facilities.
The data used as the basis for the originally promulgated PCWP NESHAP are over 15 years old. The EPA is aware that significant changes have been made in the intervening years in the number of affected facilities, in industry ownership practices, types of resins used, and in emissions collection and control configurations. Further, in light of the statutory requirements for reviewing emission standards under CAA section 112 and the recent case law interpreting those requirements, the EPA has concluded that obtaining updated information will be crucial to informing its decisions on the RTR for the manufacturing sources covered by the PCWP NESHAP.
Compliance and engineering testing data collected through this ICR are expected to provide most of the emissions data for the sources regulated by the PCWP NESHAP. Additionally, the ICR is expected to provide emissions test data, emissions estimates, information on work practices and equipment design criteria for the process units remanded for regulation by the U.S. Court of Appeals in 2007. Since the remand was issued, environmental research conducted by the wood products industry has included some effort to evaluate the suitability of remanded process units for emissions testing and to develop emission factors. The ICR will inform the EPA about the availability of emissions test data, use of work practices that reduce emissions, and application of any new emission factors. The emissions data collected by the ICR may also have benefits to other EPA programs valued by the public. The RTR ICR data can be used for QA of information in the EPA's National Air Toxics Assessment (NATA) program as well the National Emissions Inventory, which is built using the EIS first to collect the data from state, local, and tribal air agencies and then to blend that data with other data sources. The RTR ICR data collected in the survey may be helpful in updating the data sets for facilities with no data or inaccurate data in current databases. Preliminary risk analysis results for this industry sector (based on the current NATA data sets) indicate that some facilities may present risk above the thresholds for further consideration under the residual risk process. Additional facility-specific information would allow the EPA to better characterize emissions sources, refine the risk analysis, and to address any unacceptable residual risk that remains. Information collected directly from PCWP facilities will have the greatest practical utility for purposes of performing the RTR regulatory analyses as information from the affected industry will contain the most up-to-date, accurate, and reliable equipment and operational data for each facility. The ICR will request that new information be supplied for a 2015 base year, and therefore, will not suffer from the considerable "lag time" that can be associated with different inventory and permit review cycles (e.g., where the currently available inventory does not yet reflect recent changes in equipment).
CAA section 114(a) states that the Administrator may require any owner or operator subject to any requirement of the Act to:
(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.
(b)	Use/Users of the Data
As mentioned above, the data used for the originally promulgated NESHAP are outdated and do not reflect the significant changes in emissions collection and control configurations that have occurred since promulgation of the NESHAP. The NESHAP contain a number of compliance alternatives to allow for a variety of equipment configurations and process changes to be used in meeting the emission standards. The EPA is also required to address the 2007 D.C. Circuit Court remand order for the EPA to re-evaluate MACT floors and standards for several "remanded" PCWP process unit groups. The PCWP NESHAP required changes to effluent limitations under the Clean Water Act. Additionally, the CARB ATCM and the EPA's TSCA implementation rule limit formaldehyde indoor-air emissions from composite wood products and have resulted in a shift to low emission adhesives, including ULEF and NAF resin systems at hardwood plywood, MDF, and particleboard products.
At present, the EPA does not have a database reflecting the post-NESHAP, post-effluent guidelines, and post-CARB (or TSCA implementation rule) configurations of PCWP resin systems, emissions sources, and air pollution control systems. It is essential for the EPA to have updated information to use in the regulatory analyses required under CAA sections 112(d) and 112(f)(2). The EPA also needs information to develop standards for the remanded process unit groups, and to address the D.C. Circuit Court's vacatur of SSM provisions. The EPA can make use of a single collection of information that would allow the agency to consider control strategies that are the most effective for both HAP and effluent from pollution control devices installed for compliance with the NESHAP, and evaluate standards (e.g., for the remanded emissions sources) that are consistent with the advances in technology implemented to comply with the CARB ATCM and TSCA implementation rule. The data would also allow the EPA to evaluate compliance options for startup and shutdown periods and to consider ways to consolidate monitoring, reporting, and recordkeeping requirements for facilities subject to multiple requirements.
The data collected will be used to update facility information and equipment configuration, develop new estimates of the population of affected units, and identify the control measures and alternative emission limits being used for compliance with the existing rules that are under review. This information, along with existing permitted emission limits will be used to establish a baseline for purposes of the regulatory reviews. The emissions test data (test reports and continuous emission monitoring system (CEMS) data) collected will be used to verify the performance of existing control measures, examine variability in emissions, evaluate emission limits, and to determine the performance of superior control measures considered for purposes of reducing residual risk. Emissions test data will also be used to formulate options for MACT limits for the remanded PCWP process units that are feasible to test. Emissions data will also be used along with process and emission unit details to consider subcategories for further regulation and to estimate the environmental and cost impacts associated with any regulatory options considered.
In addition to informing the CAA-required RTR regulatory analyses for the PCWP categories, it is the EPA's intent that the updates supplied through this information collection will be available for the affected industry and for state, local, and tribal agencies to be used in future versions of the National Emissions Inventory (NEI), which is updated through the EIS. The NEI, which is developed through the EIS, is used by the EPA, states, and the public for a variety of purposes including tracking of national trends in emissions of criteria pollutants and HAP. More information on the NEI and EIS can be found at https://www.epa.gov/air-emissions-inventories/national-emissions-inventory and https://www.epa.gov/air-emissions-inventories/emission-inventory-system-eis-gateway, respectively.
The non-confidential information collected with this ICR would also be available to the public, including industry trade groups that may find the information useful for their ongoing data gathering, analyses, and publications. In addition, such trade groups may wish to use the data collected to review and verify the EPA's regulatory conclusions.
3.	Non-duplication, Consultations, and Other Collection Criteria
(a)	Non-duplication
The agency recognizes that a fraction of the information requested in the information collection effort may already be included in the submittals made by individual companies, pursuant to state and national emissions inventories, operating permits applications, initial notification forms, and compliance reports. However, the complete extent of the data fields requested under this survey is not available in any consistent or usable format. Additionally, these sources of information do not provide detailed emissions test data. As mentioned above, there is a lag time associated with state and national emissions inventories, and permit review cycles. There is also a lag time associated with obtaining emissions test reports from state agencies (i.e., agencies may be reluctant to release emissions test results they have not yet processed). The EPA's proposed information collection seeks up-to-date equipment configuration and operational data for the 2015 operating year and thus avoids the effects of any such lag time on data availability. Although some state permits are provided to the public as searchable portable document format (pdf) files, many states do not provide electronic versions of their issued title V permits. Even when the permit is available, the unit-specific operating data are often not contained within the permit. Some of the initial notifications and compliance reports submitted are available in hard copy only, where only the facility-level information (facility name, location, contact) is available in an electronic format. In order to address SSM issues when reviewing another rule, the EPA obtained semi-annual compliance reports and found the reports to contain a widely varying level of detail. Such variation in the level of detail of permits and compliance reports means that it would be extremely time consuming for the EPA to extract the level of process detail needed for regulatory analyses from existing documents (assuming that these documents were readily available to the EPA), and that significant data gaps would remain even after data from existing documents were compiled.
Emissions test reports are also often retained as hard copies by state agencies and thus are not readily available for all facilities. Although one industry trade organization (National Council for Air and Stream Improvement [NCASI]) collects and compiles emissions test data in technical bulletins, these bulletins alone (while quite informative and valuable) do not inform all of the EPA's emissions data analyses because: (1) the NCASI technical bulletins are coded to mask facility identities, such that the emissions data cannot be reconciled with other emissions data available to the EPA; (2) the data contained in the NCASI reports may not be reported in the units of measure needed for analysis of emission limits; (3) much of the data pre-dates implementation of the NESHAP, and (4) the data are generally representative of NCASI member facilities whereas information collected by the EPA would be requested from the entire population of affected facilities. Emissions test data collected by NCASI before development of the PCWP NESHAP were combined with emissions test reports collected by the EPA before development of the PCWP NESHAP and used to update the EPA's AP-42 emission factor documentation for the PCWP industry. While these emission factors are useful for purposes of developing emissions estimates, they do not reflect changes to the industry that have occurred over the past decade (i.e., implementation of the PCWP NESHAP and the CARB ATCM/TSCA Title VI Amendments).
To summarize, the information requested relevant to the current (post-PCWP and WBP NESHAP) equipment configuration and operation, resin systems in use, regulatory alternatives, emissions data, and effectiveness of various control systems at removing HAP is not readily available from other sources. In the absence of an industry data collection, the EPA would be forced to try to obtain permits, compliance reports, and emissions test reports from states; extract information from these reports (which vary in detail); and then to fill data gaps where information is not available from the reports obtained. This process of acquiring and extracting data from existing reports would require more time than an industry data collection, and ultimately would be expected to yield incomplete information, Further, the PCWP NESHAP are the subject of a deadline lawsuit filed in U.S. District Court of Washington D.C.; the required CAA section 112(d) and 112(f)(2) reviews were not complete by their stipulated deadlines in the CAA. The EPA is currently negotiating an agreement under court auspices and expects to receive a court-ordered deadline for completion of this review. Information collected directly from PCWP facilities would provide the most timely and complete current data set with the greatest practical utility for purposes of performing the RTR regulatory analyses that are due to be completed under CAA sections 112(d) and (f)(2).
(b)	Public Notice Required Prior to ICR Submission to OMB
This ICR is being submitted for public review as required by the Paperwork Reduction Act of 1995 (PRA) and the subsequent rule issued by the Office of Management and Budget (OMB) on August 29, 1995 (60 FR 44978). The EPA will address public comments before submitting the ICR to OMB.
(c)	Consultations
The EPA has been in ongoing consultation with the affected industry regarding the scope of survey. An opportunity for detailed comments on the electronic survey will be provided by the Federal Register notice concerning the availability of the ICR for public review and comment.
(d)	Effects of Less Frequent Collection
This ICR will require the owner/operator of each major source and each synthetic area source PCWP facility being surveyed to complete an electronic update of their 2015 facility and emissions data to be used for RTR purposes. All facilities will be asked to complete an electronic survey of general facility information (production processes and capacities), equipment details (for material preparation, drying, adhesive, and pressing), permit limits, emissions control measures, and emissions test data (for previously conducted tests only). Some PCWP facilities may also be asked to complete emissions testing on a specific emissions source under Phase II of the ICR. The EPA expects the information requested in the two phases of this survey to be a one-time effort. The information requested in Phase I differs from request to conduct emissions testing in Phase II. These surveys are also infrequent; the last similar survey was conducted in 2000, prior to rule proposal.
(e)	General Guidelines
This ICR will adhere to the guidelines for Federal data requestors, as provided at 5 CFR 1320.6.
(f)	Confidentiality
Respondents will be required to respond under the authority of CAA section 114. If a respondent believes that disclosure of certain information requested would compromise a trade secret, it should be clearly identified as such and will be treated as confidential until and unless it is determined in accordance with established EPA procedure as set forth in 40 CFR Part 2 not to be entitled to confidential treatment. All information submitted to the agency for which a claim of confidentiality is made will be safeguarded according to the agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979, 50 FR 51661, Dec. 18, 1985, 58 FR 461, Jan. 5, 1993, 76 FR 30817, May 26, 2011; 76 FR 64015, Oct. 17, 2011). Any information subsequently determined to constitute a trade secret will be protected under 18 U.S.C. 1905. If no claim of confidentiality accompanies the information when it is received by the EPA, it may be made available to the public without further notice (40 CFR 2.203, September 1, 1976). Because CAA section 114(c) exempts emission data from claims of confidentiality, the emission data provided may be made available to the public. Therefore, emissions data should not be marked confidential. A definition of what the EPA considers emissions data is provided in 40 CFR 2.301(a)(2)(i).
(g)	Sensitive questions
This section is not applicable because this ICR will not involve matter of a sensitive nature.
4.	The Respondents and the Information Requested
(a)	Respondents/NAICS Codes.
Respondents affected by this action are owners/operators of facilities that are "major sources" of HAP emissions and produce plywood, particleboard, MDF, hardboard, fiberboard, OSB, EWP and/or operate lumber dry kilns. In the U.S., the EPA's analysis indicates that there may be a total of 425 respondent facilities out of over 1000 listed in the EPA's databases (e.g., EIS/NEI, Enforcement Compliance History Online [ECHO] and other Office of Enforcement and Compliance Assurance [OECA] databases) from the regulated North American Industry Classification System (NAICS) codes. Only major sources and synthetic area sources which used technology to avoid major PCWP NESHAP source status will be included in the respondent group. Respondents (425 total) include operations in the following wood products industry segments:
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,
11 engineered wood product facilities
The estimate above is likely to be larger than the actual number of major HAP source facilities that will be required to respond to this ICR. There are five reasons this estimate is likely to be high. First, some facilities contain multiple contiguous operations (e.g., softwood plywood, particleboard and softwood lumber together at one site) so the segments listed above likely add up to a greater number than the total number of facilities. Second, the EPA database which provided the information about major source status only identified "major" sources under the CAA and was not specific regarding being major for HAP. Facilities only classified as major sources for criteria pollutants will be eliminated from the respondent list prior to the issuance of the survey. Third, the base year for the EPA database used to identify respondents was 2011. Trade information indicates that many of the wood products industry segments subject to PCWP have been undergoing industry consolidation. It is likely that there are facilities on this list that are no longer operating. Fourth, our experience with the Pulp and Paper Sector ICR in 2011 indicates preliminary lists generally overestimate actual respondents, sometimes substantially. The EPA initially identified 386 respondents subject to that ICR and ultimately only required 173 major sources to complete that survey. Finally, a preliminary review of industry HAP emission factors indicates some industry segments in the EPA database (e.g., hardwood lumber) are unlikely to contain a significant number of major HAP sources.
The EPA anticipates collecting additional information about major HAP sources from industry trade associations before we proceed with the ICR. We have already begun the outreach process and will also emphasize, with stakeholders, our interest in identifying the correct facilities for the survey and then refining the facility survey list as part of the ICR development process. The NAICS codes for respondents affected by the information collection include 321113 for Sawmills, 321211 for Hardwood Plywood and Veneer, 321212 for Softwood Plywood and Veneer, 32121 for Engineered Wood Products, 321219 for Particleboard, MDF, OSB, Hardboard and Fiberboard.
(b)	Information Collected
(i)	Data Items. As noted in section 1(b), the proposed data-gathering effort has two phases: Phase I is a questionnaire to be completed by all affected facilities and Phase II is emissions testing to be completed in accordance with an EPA-approved protocol for selected emissions sources. If enough emissions test data are collected in Phase I to perform the CAA-required regulatory analyses, then Phase II will not be implemented. Only the portions of the Phase II ICR needed to resolve remaining data gaps will be implemented. The following paragraphs provide additional details about the phases of the survey and the testing requirements contained in those phases.
Phase I will require each owner/operator of each affected facility to complete an electronic survey that contains several components. The required components of the survey vary based on the PCWP industry segment. The draft electronic survey is a Microsoft Excel spreadsheet file (PCWP_survey.xlsx) that is divided into several worksheets or "tabs" within the spreadsheet. A separate spreadsheet is provided for collection of CEMS and continuous opacity monitoring system (COMS) data (PCWP_CEMS_COMS.xlsx). Table 1 of this document denotes which PCWP survey spreadsheet tabs are to be completed depending on the type of facility. The Mill, Prod, EquipDetail, ReleasePt, Permit, Primary HAP Emissions, and Other HAP Emissions tabs must be completed by all surveyed PCWP facilities that are major or synthetic area sources of HAP emissions. Other tabs will be required on the installed process equipment, depending on either the business segment and/or the facility. Facilities will also be asked to supply supporting documentation such as process flow diagrams and copies of operating permits.
Table 1. Survey Spreadsheets and Tabs to Complete
Spreadsheet tab (abbreviated tab name)
Types of facilities expected to complete this spreadsheet tab
Estimated number of facilities
PCWP_survey.xlsx


Mill (Mill)
All facilities
425
Products (Prod)
All facilities
425
Equipment detail (EquipDetail)
All facilities
425
Release Point Detail (ReleasePt)
All facilities
425
Permit (Permit)
All facilities
425
Resin (Resin)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
Tanks (Tank)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
Veneer Dryer (VeneerDry)
Plywood, Veneer, laminated veneer lumber (LVL)
101
Rotary Dryer (RotaryDry)
Particleboard, OSB, MDF (where applicable)
58
Tube Dryer (TubeDry)
MDF, Hardboard, Particleboard (where applicable)
29
Conveyor Dryer (ConvDry)
OSB, laminated strand lumber (LSL)
4
Fiberboard/Hardboard Equipment (FB-HB)
Hardboard, Fiberboard
8
Direct Fired Dryer Fuel (DFDryFuel)
Any PCWP facilities that use direct combustion gas to heat dryers, whether from a burner built into the dryer or from a separate combustion unit serving one or more dryers
225
Press (Press)
Plywood, OSB, MDF, Hardboard, Particleboard, EWP
175
Board Coolers (BC)
Particleboard, MDF
43
EWP Press (EWPPress)
EWP
11
Lumber Kilns (LKiln)
Lumber
235
Other Equipment (OtherEquip)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP that operate digesters, refiners, dry blending and forming operations, sanders, saws, chippers, flakers, and log vats
190
Primary and Other HAP Emissions (Emissions)
All facilities
425
Control Devices (APCD)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
SSM (SSM)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
Miscellaneous Coatings (MiscCoat)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
Wastewater (WW)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
65
Emissions Tests (EmTest)
Plywood, OSB, MDF, Hardboard, Fiberboard, Particleboard, EWP
190
PCWP_CEMS_COMS.xlsx


CEMS (CEMS)
Facilities with controlled units monitored by CEMS
95
COMS (COMS)
Facilities with controlled units monitored by COMS
95

Emissions data collected will allow the EPA to characterize the performance of equipment and controls, reevaluate emissions limits, and consider variability. Emissions data from previously conducted emissions tests, including copies of test reports and COMS or CEMS data are being requested for affected sources and emissions units for which emissions limits may be reevaluated under RTR. The pollutants for which emissions data are requested include all HAP regulated under either the PCWP NESHAP, any surrogate used to demonstrate compliance with regulated HAP, volatile organic compounds, particulate matter (filterable or condensable of any size fraction), speciated HAP metals, and opacity. The EmTest tab of the PCWP_survey.xlsx spreadsheet requests a summary of the emissions test reports provided. The PCWP_CEMS_COMS.xlsx spreadsheet contains CEMS and COMS worksheets for different pollutants and averaging periods (e.g., for 1-hour, 3-hour, or 24-hour average total hydrocarbon data). Continuous parameter monitoring system (CPMS) data are also requested.
The APCD tab of the PCWP_survey.xlsx spreadsheet requests information related to the capital and O&M costs of pollution controls and parameter monitoring equipment. The EPA requires cost information in order to perform the CAA-required regulatory analyses.
Phase II, if implemented, will provide instructions and guidance for emissions testing for those emissions sources that are selected to complete emissions testing. This testing will occur once. The results of each series of tests and analyses will be required to be reported to the EPA by using a specified standardized electronic format by the date 6 months after the facility receives the letter requesting the emissions testing. Specified Quality Assurance (QA) and quality control (QC) procedures will be required for each part of the emissions data collection effort. For this effort, the EPA believes it is highly advisable for each emissions source subject to emissions testing under Phase II of the ICR to devise a site-specific test plan. A site-specific test plan addresses the planning and QA/QC procedures and acceptance criteria for all of the testing, including the collection of process data. Developing such a plan will ensure that you address all of the testing and reporting requirements. Such a plan could include the project elements as enumerated in chapter 3 of the EPA QA document. In addition, the EPA's Electronic Reporting Tool (ERT) Version 5, in which the EPA requires that data be reported, requires that elements of a test plan be entered into the program prior to submitting test results. The cost of performing each test includes the burden of developing a site-specific test plan. Note, however, that these QA test plans will not be reviewed or approved by the EPA.
Although a large amount of information is needed for regulatory review of the NESHAP, the EPA has designed the PCWP information collection in a way to minimize the burden associated with supplying and processing this information. The survey will collect information to supply multiple regulatory actions in order to minimize the burden associated with multiple collections. The PCWP information collection is being administered in spreadsheet form (as opposed to database software) because respondents are likely to be more familiar with spreadsheet use than with databases. A table containing only the relevant and current source classification codes (SCC) will be provided to ensure that valid codes are used and to reduce respondent time associated with locating codes on the NEI website. Following QA of the data, the data from the Excel spreadsheet rows can be readily imported into Access database software for use by the agency (eliminating the time required for the EPA to key-enter data). The PCWP survey spreadsheets will be provided to facilities on a website where they can be downloaded. Respondents will save and submit their completed survey spreadsheets and other materials requested such as electronic copies of production flow diagrams, operating permits, and emissions test reports on digital media such as a CD, DVD, or flash drive. The burden associated with collection of emissions test data has been reduced in several ways:
Only existing emissions data (CEMS/COMS data or emissions test reports) are being requested for Phase I. Facilities are not required to conduct any new emissions testing under Phase I of the ICR.
Facilities are not required to install or operate any new CEMS or COMS to respond to this survey.
Data are being requested for the HAP surrogates defined in the NESHAP, as opposed to speciated HAP where that information is not readily available.
The EPA has developed a matrix of emission units and pollutants for which previous emissions test data are requested. Previous emissions data are only being requested for emissions unit and pollutant combinations for which emissions limits may be reevaluated under RTR (or for pollutants that may serve as an indicator or surrogate for emission unit or control system performance). The matrix provides a 2003 cutoff date for selected emission unit and pollutant combinations (or in some cases, only requests the most recent test data) in order to minimize respondent burden and to ensure the EPA's ability to process the data requested.
Rather than entering run-by-run entries of previous test data within the ICR, respondents are simply required to enter summary data and submit copies of emissions test reports in searchable electronic format. The EPA (or the EPA's contractor personnel) familiar with extracting test data from test reports will enter the run-by-run data in a manner that ensures consistent and reliable treatment of the data (e.g., with respect to data averaging, non-detects).
If the EPA decides to implement portions of Phase II of the ICR for selected emission units requiring additional emissions testing to inform regulatory analyses, not all PCWP facilities will be required to conduct new emissions testing. The EPA will optimize the required testing over a number of PCWP facilities that minimize the burden to the industry, especially to small businesses.
Finally, the EPA has minimized the collection of control measure cost information by focusing the collection of cost information on air pollution controls and process changes of particular interest for the RTR (i.e., HAP control measures as opposed to all control measures employed by PCWP facilities). The EPA expects cost information obtained from the industry to be some of the most reliable and valid information available since the cost data would be specific to PCWP applications. In addition, collection of cost information from the industry (as opposed to a separate collection from other sources such as vendors) would accelerate the EPA's ability to analyze the cost impacts of regulatory options.
(ii)	Respondent Activities. The activities a respondent must undertake to fulfill the requirements of the information collection are presented in Attachments 2A and 2B. These include: i) read instructions; ii) provide information on each affected source through electronic survey; and iii) submit electronic copies of flow diagrams, previous emissions test reports, operating permits, emissions averaging plans, copies of air and wastewater discharge permits, material safety data sheets (MSDS) for miscellaneous coatings, lumber dry kiln schedules, CPMS data, and data supporting emissions estimates for wastewater operations and tanks. If one of the respondent's emissions sources is selected for emissions testing under Phase II, the respondent must additionally: i) review the emissions testing plan and procure a testing contractor; ii) monitor/supervise emissions testing; iii) review emissions sampling data for accuracy and completeness; and iv) submit emissions sampling data and test reports.  The activities associated with Phase I are presented in Attachment 2A. Additional activities that would be associated with the Phase II emissions testing are listed in Attachment 2B. Phase II would only be exercised as a contingency if required for the EPA to gather sufficient emissions test data to fulfil CAA requirements for setting emissions standards.
The owner/operator of each PCWP facility emissions source required to conduct emissions testing will also be required to keep records: i) documenting that each emissions test was conducted in accordance with an approved testing protocol and ii) setting forth the results of each emissions test. These records must be retained for 3 years so that respondents can answer EPA questions about the analysis or testing procedures as needed to review and amend the standards as described previously.
5.	The Information Collected  -  Agency Activities, Collection Methodology, and Information Management
(a)	Agency Activities
A list of activities required of the EPA is provided in Attachments 3A and 3B. These include: i) develop electronic questionnaire and packages for mail out; ii) answer respondent questions (including claims of true area source status or that facility in not engaged in processes of interest); iii) review and analyze responses and emissions data; and iv) analyze requests for confidentiality; v) determine whether to implement Phase II of the ICR and if so, which facilities will be required to complete emissions testing for selected emissions sources. Attachment 3A lists the agency activities associated with Phase I of the information collection. Additional activities that would be associated with Phase II, if required to be exercised in order to obtain emissions test data, are presented in Attachment 3B.  
(b)	Collection Methodology and Management
In collecting and analyzing the information associated with this ICR, the EPA will use personal computers and applicable spreadsheet and database software. To better facilitate uniformity in the format of the requested data, and, thus, increase the ease of database entry, standardized survey questions, example responses, and Excel spreadsheet forms will be distributed to respondents. The Excel spreadsheet forms used to collect information have been programmed with pull-down menus and to pre-populate certain emission unit identification fields to reduce common respondent transcription errors that can impede database functionality. The EPA will ensure the accuracy and completeness of the collected information by reviewing each submittal. Flow diagrams may be used to answer any questions revealed during QA of each submittal. The EPA may place follow-up calls to facilities should questions remain after reviewing all materials submitted. Following QA of each submittal, the spreadsheet information from each facility will be uploaded into an Access database for further analysis. Survey responses claimed as confidential will be housed in a separate database from the non-confidential survey responses. Run-by-run data from previous emissions test reports will be entered into a database by the EPA (or the EPA's contractor personnel) familiar with extracting test data from test reports. In addition CEMS/COMS data would be uploaded in a database for analysis of emissions variability. PCWP facilities asked to complete emissions testing under Phase II will be instructed to provide their results through the ERT or other standardized format and the EPA will review those responses. The resulting databases will be checked for QA prior to and as part of regulatory analyses.
(c)	Small Entity Flexibility
All respondents required to comply with the PCWP data gathering effort will be subject to the same requirements. The EPA expects the respondents will include small entities. Small entities are likely to be lumber mills or lower-capacity PCWP facilities. Small entities that are not major or synthetic area sources of HAP emissions (i.e., true area sources) would not be required to complete the survey provided that they submit documentation of their true area source status. Small entities that are major or synthetic area sources of HAP emissions, particularly lumber mills, will have fewer portions of the survey to complete as their operations would likely be less extensive. The agency also plans to use an electronic format of the questionnaire in order to reduce the burden and improve the data accuracy from all respondents, including small entities. In addition, if the EPA determines that implementation of Phase II is necessary, the process of selecting emissions sources to be tested will consider the small entity status of each facility with that specific emissions sources, and the selection of sources at small entities will be minimized to the extent possible. Finally, the survey will contain a question to determine the small entity status of a facility. This question will help to identify, quantify, and minimize the burden on small entities during the revised rulemaking process.
(d)	Collection Schedule
The EPA anticipates issuing the CAA section 114 letters for Phase I in early 2017. These CAA section 114 letters would require the owner/operator of each PCWP facility to complete the survey spreadsheet and submit emissions test data within 90 days of receipt of the survey. The CAA section 114 letters for Phase II will be issued to facilities with emissions sources selected for testing if the EPA determines that implementation of Phase II is necessary after compiling and reviewing the results from Phase I. Letters would require the owner/operator of each PCWP facility to submit the results of the source tests within 6 months of receipt of the CAA section 114 letter for Phase II. The EPA will compile and analyze survey response data upon receipt.
6.	Estimating the Burden and Cost of the Collection
(a)	Estimating Respondent Burden
The data collection activities a respondent must undertake to fulfill the requirements of the information collection are presented Attachments 2A and 2B. As shown in Attachment 2A, data collection activities under Phase I of the survey include: i) read instructions; ii) provide information on each affected source through electronic survey; and iii) submit electronic copies of flow diagrams, previous emissions test reports, operating permits, emissions averaging plans, copies of air and wastewater discharge permits, MSDS for miscellaneous coatings, lumber dry kiln schedules, CPMS data, and data supporting emissions estimates for wastewater operations and tanks. As shown in Attachment 2B, if one of the respondent's emissions sources is selected for emissions testing under the Phase II contingency for gathering needed emissions test data, the respondent must additionally: i) review the emissions testing plan and procure a testing contractor; ii) monitor/supervise emissions testing; iii) review emissions sampling data for accuracy and completeness; and iv) submit emissions sampling data and test reports.
(b)	Estimating Respondent Costs
Attachments 2A and 2B also present estimated costs for the required data collection activities. The basis for the i) labor cost estimate and the ii) capital and operations (overhead) cost estimates follow. Labor rates and associated costs are based on Bureau of Labor Statistics data.
(i)	Estimating Labor Costs. Technical, management, and clerical average hourly rates for private industry workers and were taken from the United States Department of Labor, Bureau of Labor Statistics, March 2016, "Table 2. Civilian Workers, by occupational and industry group," available at http://www.bls.gov/news.release/ecec.t02.htm. Wages for occupational groups are used as the basis for the labor rates with a total compensation of $56.04 per hour for technical/professional, $67.78 per hour for managerial, and $25.10 per hour for clerical. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $117.68, management at $142.34, and clerical at $52.71. These estimates represent the one-time burden that will be incurred by the recipients.
In addition, there are costs associated with conducting emissions testing in Phase II. The unit costs for the tests that the EPA expects to require if Phase II is implemented are shown in Table 2 of this document.
Table 2. Unit Costs for PCWP Phase II ICR Testinga
Item
Cost per test
Speciated organic HAP -- NCASI ISS/FP-A105.01
$18,700
Total hydrocarbon -- EPA Method 25A
$15,900
Methane -- EPA Method 18
$23,300
Methylene diphenyl diisocyanate (MDI) -- EPA Other Test Method (OTM) 14
$23,300
Metals/PM (filterable) -- EPA Method 29
$41,800
Gas flow rate, Moisture, Oxygen/carbon dioxide content -- EPA Method 2, 3, and 4
$15,900
Methanol, Phenol, and Speciated carbonyl HAP in wastewater -- NCASI Method DI/MEOH-94.03, NCASI Method PC-97, SW-846 Method 8315A
$1,300
Site-specific biodegradation rates -- Appendix C to 40 CFR Part 63 - Aerated reactor batch test with oxygen addition (BOX test)
$37,000
Temporary Total Enclosure
$12,000
Travel/Mobilization to individual facility (to conduct multiple tests)
$22,500
Test Report
$7,000 + ($640 x number of tests required)
a Unit costs assume seven runs will be conducted during each stack tests.

(ii)	Estimating Operating and Maintenance (O&M) Costs. Costs for mailing survey responses to the EPA including digital media (CD, DVD, or flash drive) and postage are estimated at $7,119.
(iii)	Estimating Capital/Start-up Costs. We do not anticipate any capital costs.
(iv)	Annualizing Capital Costs. We do not anticipate any capital costs so there are no annualized capital costs.
(c)	Estimating Agency Burden and Costs
The costs the Federal Government would incur are presented in Attachments 3A and 3B. The agency labor rates are from the Office of Personnel Management (OPM) 2016 General Schedule which excludes locality rates of pay. These rates can be obtained from Salary Table 2016-GS, available on the OPM website at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2016/general-schedule/. The government employee labor rates are $16.77 per hour for clerical (GS-7, Step 1), $35.38 for technical (GS-13, Step 1), and $49.18 for managerial (GS-15, Step 1). These rates were increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at $26.83, technical at $56.61, and managerial at $78.69.
(d)	Estimating the Respondent Universe and Total Burden and Costs
Estimates based on several of the EPA's databases (e.g., EIS/NEI, ECHO and other OECA databases) indicate that the potential respondent universe consists of 425 facilities. All 425 of these facilities will be required to complete some portion of the electronic survey, with the exception of facilities that provide documentation to the EPA showing that either: (1) they are not a major or synthetic area source of HAP emissions, (2) they were not operational in 2015 and remain closed, or (3) they do not produce PCWP products.
The government burden estimate provided in Attachment 3A assumes that 15 percent of facilities will provide documentation of true area source status, facility closure, or that PCWP operations are not performed at the facility. However, it is not known how many of these claims will be valid, so all facilities are included in the burden estimate for respondents (in Attachment 2A). Attachment 2A lists the various portions of the Phase I survey in detail and provides an estimated number of facilities required to complete each portion of the survey. Specific counts of the different types of facilities used in the burden estimates are provided in Section 4(a) of this supporting statement.
(e)	Bottom Line Burden Hours and Costs Tables
(i)	Respondent tally. The bottom line industry burden hours and costs, presented in Attachments 2A and 2B, are calculated by summing the person-hours column and by summing the cost column. A range of burden and cost estimates is presented because it is unknown whether the Phase II portion of the information collection will be needed to collect emissions test data. Whether the Phase II contingency is exercised will depend on the number of previously-conducted emissions tests for the pollutants of interest collected under Phase I. The burden and cost to the industry under Phase I for 425 respondents is 106,065 hours and $12,003,650. No capital or annualized costs are applicable because this is a one-time submittal. O&M costs of $7,119 are estimated for digital media (CD, DVD, or flash drive) and postage to mail in the survey response to the EPA. If Phase II is implemented, an additional 8,242 hours and $7,774,453 (including $637 for O&M) is estimated to be incurred by up to 38 respondents selected based on their Phase I responses. Thus, the total burden and cost to the industry for the entire collection involves 425 respondents and ranges from 106,065 to 114,306 hours and $12,003,650 to $19,778,180 (including $7,119 to $7,755 for O&M), depending on whether Phase II must be exercised.
(ii)	Agency tally. The bottom line Agency burden and cost, presented in Attachments 3A and 3B is calculated in the same manner as the industry burden and cost. The estimated burden and cost for 425 respondents under Phase I is 14,658 hours and $511,033, which includes $7,353 in O&M costs to send certified CAA section 114 letters to all respondents with electronic return receipt, questionnaire printing costs, and computer storage of data received.  If Phase II must be exercised for up to 38 respondents, then an additional 994 hours and $34,872 (including $706 for O&M) is estimated to be incurred by the Agency. The overall Agency burden and costs for 425 respondents are estimated to range from 14,658 to 15,652 hours and $511,033 to $545,905 (including $7,353 to $8,059 in O&M) depending on whether Phase II is exercised.
(iii)	The complex collection. This ICR is a simple collection; therefore, this section does not apply.
(iv)	Variations in the annual bottom line. This section does not apply as this is a one-time collection.
(f)	Reasons for Change in Burden
This is the initial estimation of burden for this information collection; therefore, this section does not apply.
(g)	Burden Statement
Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for the EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
The total cost burden for the PCWP data gathering effort is estimated to range from 106,065 to 114,306 hours and $12,003,650 to $19,778,180 (from 250 to 269 hours and $28,227 to 46,519 per respondent for 425 respondents). This ICR does not include any requirements that would cause the respondents to incur either capital or start-up costs. O&M costs of $7,119 to $7,755 ($16.75 to $18.25 per respondent) are estimated for digital media (CD, DVD, or flash drive) and postage to mail in the survey response to the EPA.  The range of costs presented depends on whether it is necessary for the Agency to exercise Phase II of the collection to require emissions testing. The lower end of the range is estimated for Phase I, and the upper end of the range encompasses Phase II.
To comment on the EPA's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, the EPA has established a docket for this ICR under Docket ID No. EPA-HQ-OAR-2016-0243, which is available for online viewing at http://www.regulations.gov, or in hard copy at the EPA Docket Center, Room 3334, EPA WJC West Building, 1301 Constitution Avenue NW., Washington, DC. The EPA/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 202-566-1744, and the telephone number for the Air and Radiation Docket Center is 202-566-1742.
An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select "search," then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include EPA Docket ID No. EPA-HQ-OAR-2016-0243 in any correspondence.


INFORMATION COLLECTION REQUEST FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)
Part B of the Supporting Statement
1.	Respondent Universe
In the U.S., the EPA's analysis indicates that there may be a total of 425 respondent facilities out of over 1000 listed in the EPA's databases from the regulated NAICS codes. However, the EPA's information indicates that some PCWP facilities do not have all of the emissions sources for which the questionnaire requests information. Therefore, not all of the PCWP facilities will be required to complete every section of the Phase I questionnaire. Attachment 1 lists the various portions of the survey in detail, and Attachment 2A provides an estimated number of PCWP facilities required to complete each portion of the survey.
The EPA is considering implementing an emissions testing phase of the ICR, or Phase II, for two groups of sources as a contingency in case EPA does not receive enough emissions test data to adequately fulfill CAA requirements for setting emission standards. First, there are some direct-fired emissions sources that have numeric emission limits for organic HAP in the PCWP NESHAP but also have the potential to emit metal HAP that are not covered by the PCWP NESHAP. Second, there are other emissions sources without any numeric emissions limits in the PCWP NESHAP at all (i.e., remanded process units). These two groups of emissions sources are the most likely emissions sources for which the EPA would need to implement Phase II of the ICR due to the unavailability of sufficient data collected from Phase I of the ICR. These emissions sources include:
Softwood veneer dryers
Rotary strand dryers
Primary tube dryers
Secondary tube dryers
Green rotary dryers
Press predryers
Fiberboard mat dryers
Board coolers
Dry rotary dryers
Softwood plywood presses
Hardwood plywood presses
EWP presses (laminated veneer lumber [LVL], parallel strand lumber [PSL], laminated strand lumber [LSL])
Hardwood veneer dryers
Humidifiers
Atmospheric refiners
Dry blending/forming operations
Sanders/saws/chippers
Fiber washers
Stand-alone digesters
Wastewater operations

2.	Selection of Units to Conduct Emissions Testing
PCWP emissions sources to be tested will be selected to provide representative emissions data from emissions sources for which the EPA has little to no emissions data (including current information and information submitted through Phase I of this ICR). The emissions testing will cover three groups of HAP and criteria pollutants (as potential surrogates) that may potentially be regulated. The groups of HAP are organic HAP, metallic HAP, and methylene diphenyl diisocyanate (MDI). For those units required to complete stack testing, each facility is required to test after the last control device or at the stack if the last control device is not shared with one or more other units. In this way, the facility would test before any "dilution" by gases from a separately-controlled unit. Under certain circumstances, however, testing after a common control device or at the common stack will be allowed. The EPA also plans to require sampling and analysis to determine the site-specific fraction of HAP organic compounds biodegraded at selected wastewater treatment operations.
The EPA plans to request testing of up to 80 PCWP emissions sources. Sources to be tested will be selected to ensure that representative data are collected for emissions sources for which the EPA has little to no existing information or for which additional information is needed in order to evaluate emission standards for this source category. For the direct-fired emissions sources that are subject to the PCWP NESHAP for organic HAP, the EPA plans to select five units to perform emissions testing. For the remanded units for which there are little to no existing data, the EPA plans to select four units to perform emissions testing. See Table 3 of this document for the numbers of emissions sources that the EPA plans to select for testing (if sufficient data are not gathered in Phase I of the ICR), shown in by industry segment and type of source to be tested.
Table 3. Number of Emissions Sources to be Selected for Emissions Testinga
Industry segmentb
Emissions Source
Number of emissions sources to be tested:
Softwood plywood
Softwood veneer dryers
5

Softwood plywood presses
4
Hardwood plywood
Hardwood plywood presses
4

Hardwood veneer dryers
4
Particleboard
Green rotary dryers
5

Dry rotary dryers
5

Atmospheric refiners
4

Finishing sander, saw, and chipper emission points
4
OSB
Rotary strand dryers
5

Dry blending/forming operation emission points
4
Hardboard
Press predryers
2

Humidifiers
4

Stand-alone digesters
4
Fiberboard
Fiberboard mat dryers
2

Fiber washers
2
MDF
Primary tube dryers
5

Secondary tube dryers
5

Board coolers
4
EWP
EWP presses (laminated veneer lumber [LVL], parallel strand lumber [PSL], laminated strand lumber [LSL])
4
--
Wastewater operations
4
a If the EPA determines that it is necessary to implement Phase II of this ICR for specific types of emissions sources, the numbers in this table represent the counts of that type of emissions source for which the EPA anticipates requesting emissions testing. The emissions sources selected for testing will be optimized to minimize the burden across the industry and for individual small entities.
b Some of the emissions sources listed are present in more than one industry segment. The industry segment shown in this table is the industry segment of the sources that the EPA anticipates targeting as a part of the effort to optimize the emissions sources tested and minimize the burden across the industry.

Once the EPA receives the data from Phase I of the ICR and determines whether to implement all or part of Phase II, including the final number of tests to be conducted, the EPA will select the emissions sources at specific facilities to be tested considering the size of the unit (i.e., how representative it is expected to be of units in the source category); the type of control device, if any; the company's small entity status; and the number of tests already requested for a given facility or corporation. The EPA will specifically try to minimize the testing required for small entities while still collecting data for a range of typical unit sizes.
3.	Response Rates
Since the information will be requested pursuant to the authority of CAA section 114, the EPA expects that all respondents requested to submit information will do so.

Attachment 1.
Draft Questionnaire Content
The draft electronic questionnaire may be found in separate files accompanying this supporting statement, including the following:

File name
Description
PCWP_ICR_survey_instructions.doc
This is the draft survey instruction document. This file provides instructions for completing and submitting the survey (including confidential and non-confidential responses). The instruction document also contains the request for flow diagrams; previous emissions test data (emissions test reports or CEMS/COMS data); emissions averaging plans; copies of air and wastewater discharge permits; MSDS for miscellaneous coatings; lumber dry kiln schedules; CPMS data, and data supporting emissions estimates for wastewater operations and tanks.

The following appendices are included in the survey instruction document: 

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

2
Emission Units to Include in the PCWP Survey Response

3
Previous Emissions Test Data Requested

4
Acronyms and Abbreviations

5
Signed Certification Form

6
Checklist of Materials to Submit with Your Survey Response

7
PCWP NESHAP Definitions

8
Industry Source Classification Codes

9
List of Hazardous Air Pollutants

10
Resources for Estimating Emissions
PCWP_survey.xls
This multi-tabbed spreadsheet file is the main portion of the survey. A listing of the tabs in this file is provided in Table 1, Section 4 of this supporting statement.
PCWP_CEMS_COMS.xlsx
This file contains templates for the requested CEMS and COMS data.


Attachment 2A.
Industry Burden and Costs for Responding to the Phase I Questionnaire
Respondent Activity
(A) Hours per Occurrence
(B) Occurrences/ Respondent/Year
(C) Hours/ Respondent/ Year (A x B)
(D) Respondents/ Year1
(E) Technical Hours/Year
(C x D)
(F) Managerial Hours/Year
(E x 0.05)
(G) Clerical Hours/Year
(E x 0.10)
(H) Cost, $/Year2
1. APPLICATIONS (Not Applicable)
 
 
 
 
 
 
 
 
2. SURVEY AND STUDIES (Not Applicable)
 
 
 
 
 
 
 
 
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
 
 
 
 
 
 
 
 
4. REPORT REQUIREMENTS
 
 
 
 
 
 
 
 
A. Read Instructions
10
1
10
425
4,250
213
425
$552,806 
B. Required Activities
 
 
 
 
 
 
 
 
a. Phase I: General Survey
 
 
 
 
 
 
 
 
Complete and submit survey spreadsheet tabs, as follows:
 
 
 
 
 
 
 
 
Mill (general information (Mill)
3
1
3
425
1,275
64
127.5
$165,842 
Products (Prod)
3
1
3
425
1,275
64
127.5
$165,842 
Equipment detail (EquipDetail)
24
1
24
425
10,200
510
1020
$1,326,733 
Release Point Detail (ReleasePt)
24
1
24
425
10,200
510
1020
$1,326,733 
Permit
8
1
8
425
3,400
170
340
$442,244 
Resin
2
1
2
190
380
19
38
$49,427 
Tanks (Tank)
2
1
2
190
380
19
38
$49,427 
Veneer Dryer (VeneerDry)
4
1
4
101
404
20
40.4
$52,549 
Rotary Dryer (RotaryDry)
4
1
4
58
232
12
23.2
$30,177 
Tube Dryer (TubeDry)
4
1
4
29
116
6
11.6
$15,088 
Conveyor Dryer (ConDry)
4
1
4
4
16
1
1.6
$2,081 
Fiberboard/Hardboard Equipment (FB-HB)
4
1
4
8
32
2
3.2
$4,162 
Direct Fired Dryer Fuel (DFDryFuel)
6
1
6
213
1,275
64
127.5
$165,842 
Press
8
1
8
175
1,400
70
140
$182,101 
Board Coolers (BC)
2
1
2
43
86
4
8.6
$11,186 
EWP Press (EWP)
2
1
2
11
22
1
2.2
$2,862 
Lumber Kilns (Lkiln)
4
1
4
235
940
47
94
$122,268 
Other Equipment (OtherEquip)
4
1
4
190
760
38
76
$98,855 
Primary and Other HAP Emissions
100
1
100
425
42,500
2125
4250
$5,528,056 
Control Devices (APCD)
8
1
8
190
1,520
76
152
$197,709 
SSM
8
1
8
190
1,520
76
152
$197,709 
Miscellaneous Coatings (MiscCoat)
4
1
4
190
760
38
76
$98,855 
Wastewater (WW)
8
1
8
65
520
26
52
$67,637 
Emission Tests (EmTest)3
12
1
12
190
2,280
114
228
$296,564 
CEMS4
4
1
4
95
380
19
38
$49,427 
COMS4
4
1
4
95
380
19
38
$49,427 
Organize and submit other requested materials:








Process flow diagrams
4
1
4
425
1,700
85
170
$221,122 
Signed certification form
0.2
1
0.2
425
85
4
8.5
$11,056 
Release point map
1
1
1
425
425
21
42.5
$55,281 
Electronic copy permit
0.5
1
0.5
425
213
11
21.25
$27,640 
Emissions averaging plan
1
1
1
21
21
1
2.1
$2,732 
TANKS emission estimates
1
1
1
21
21
1
2.1
$2,732 
Lumber dry kiln schedules
2
1
2
235
470
24
47
$61,134 
Copies of semiannual compliance reports
1
1
1
190
190
10
19
$24,714 
MSDS for HAP-containing miscellaneous coatings
2
1
2
425
850
43
85
$110,561 
Wastewater treatment plant flow diagrams
0.5
1
0.5
8
4
0
0.4
$520 
Wastewater treatment plant emission estimates
1
1
1
8
8
0
0.8
$1,041 
Wastewater treatment plant effluent limits
0.5
1
0.5
65
33
2
3.25
$4,227 
Plan demonstrating wet control device HAP destruction 
0.5
1
0.5
8
4
0
0.4
$520 
Previous emissions test reports3
2
1
2
190
380
19
38
$49,427 
CPMS data for selected process units
4
1
4
331
1,324
66
132.4
$172,215 
Subtotal for Phase I







$11,996,531
C. Create Information (Included in 4B)








D. Gather Existing Information (Included in 4B)








E. Write Report (Not Applicable)








5. RECORDKEEPING REQUIREMENTS (Not applicable)








TOTAL ANNUAL LABOR BURDEN AND COST
 
 
 
 
92,230 
4,612 
9,223 
                                                                    $11,996,531
 
 
 
 
 
 
Total Labor: 
106,065
 
 
 
 
 
 
Avg. hr./facility: 
250
 Avg. $/facility: 
$28,227
ANNUAL CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

ANNUALIZED CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

TOTAL ANNUAL COSTS (O&M)5
 
 
 
 
 
 
 
$7,119
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)
 
 
 
 
 
 
 
$7,119
TOTAL LABOR AND O&M COSTS
 
 
 
 
 
 
 
$12,003,650
1. The number of respondents per year is based on the facility counts listed in Section 4(a) of the Supporting Statement.
2. Based on Bureau of Labor Statistics, Sept. 2016 'Table 2. Civilian Workers, by Occupational and Industry Group" Technical/Professional: $117.68/hour, Managerial: $142.34/hour, Clerical: $52.71/hour (includes 110 percent increase for overhead expenses).
3. Estimated based on PCWP facilities that were required to install controls will submit 4 test reports each. It is estimated that it would take 1.5 hour to locate and scan each test report, 1.5 hours to enter data into the survey spreadsheet, and 0.5 hour per test to assemble files to send to the EPA.
4. Assumes PCWP facilities that were required to install controls will submit either CEMS or COMS reports for 2015, but not both.
5. Postage Costs for mailing survey responses to the EPA are estimated at $9.75 for Federal Express letter size envelope flat rate (1 per respondent). The costs of digital media (CD, DVD, or flash drive) are estimated to be $7 each.



Attachment 2B.
Industry Burden and Costs for Responding to the Questionnaire if the Phase II Contingency for Emissions Testing Must be Exercised
Respondent Activity
(A) Hours per Occurrence
(B) Occurrences/ Respondent/Year
(C) Hours/ Respondent/ Year (A x B)
(D) Respondents/ Year
(E) Technical Hours/Year
(C x D)
(F) Managerial Hours/Year
(E x 0.05)
(G) Clerical Hours/Year
(E x 0.10)
(H) Cost, $/Year
1. APPLICATIONS (Not Applicable)
 
 
 
 
 
 
 
 
2. SURVEY AND STUDIES (Not Applicable)
 
 
 
 
 
 
 
 
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
 
 
 
 
 
 
 
 
4. REPORT REQUIREMENTS
 
 
 
 
 
 
 
 
A. Read Instructions
10
1
10
38
                                                                            380
                                                                             19
                                                                             38
                                                                       $49,427 
B. Required Activities
 
 
 
 
 
 
 
 
a. Phase I: General Survey (Subtotal from Attachment 2A)
 
 
 
 
 
 
 
$11,996,531
b. Phase II: Emissions Testing and Analysis1








Read Test Plan provided by the EPA for testing
0.7
1
0.7
38
27
1
2.66
$3,460
Procure contractor to perform testing
20
1
20
38
760
38
76
$98,855
Plant personnel for testing oversight
32
2
64
80
5,120
256
512
$665,968
Review the test report data
6
1
6
80
480
24
48
$62,435
Submit stack test results through the ERT
3
1
3
80
240
12
24
$31,217
QA/QC data to be submitted to the EPA
2
1
2
80
160
8
16
$20,812
Emissions tests








Softwood Plywood

5





$697,520
Hardwood Plywood

4





$816,160
Particleboard

5





$1,530,140
OSB

5





$720,400
Hardboard

4





$849,520
Fiberboard

2





$431,960
MDF

5





$992,420
EWP

4





$532,480
Wastewater Treatment

4





$271,120
Subtotal for Phase II







$7,724,466
C. Create Information (Included in 4B)








D. Gather Existing Information (Included in 4B)








E. Write Report (Not Applicable)








5. RECORDKEEPING REQUIREMENTS (Not applicable)








TOTAL ANNUAL LABOR BURDEN AND COST (PHASE II)
 
 
 
 
7,167 
358 
717 
                                                                    $7,773,893 
 
 
 
 
 
Total Labor (Phase II): 
8,242
 
ANNUAL CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

ANNUALIZED CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

TOTAL ANNUAL COSTS (O&M)2
 
 
 
 
 
 
 
$637
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)
 
 
 
 
 
 
 
$637
TOTAL LABOR AND O&M COSTS (PHASE II)
 
 
 
 
 
 
 
$7,774,530








                                                                               
TOTAL ANNUAL LABOR BURDEN AND COST (PHASE I + PHASE II)
 


 
99,397 
4,970 
9,940 
                                                                    $19,770,425
 
 


 
 
 Total Labor: 
114,306 
                                                                              
 
 
 
 
 
 Avg. hr./facility: 
269 
 Avg. $/facility: 
                                                                        $46,519
ANNUAL CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

ANNUALIZED CAPITAL COSTS (Not Applicable)
 
 
 
 
 
 
 

TOTAL ANNUAL COSTS (O&M)[2]
 
 
 
 
 
 
 
                                                                         $7,755
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)
 
 
 
 
 
 
 
                                                                         $7,755
TOTAL LABOR AND O&M COSTS (PHASE I + PHASE II)
 
 
 
 
 
 
 
                                                                    $19,778,180
1. Phase II will only be implemented if the EPA determines that data gaps remain after the completion of Phase I.
2. Postage Costs for mailing survey responses to the EPA are estimated at $9.75 for Federal Express letter size envelope flat rate (1 per respondent). The costs of digital media (CD, DVD, or flash drive) are estimated to be $7 each.

Attachment 3A.
Agency Burden and Costs for Phase I
Agency Activity
(A) EPA Hours/ Occurrence
(B) Occurrences/ Respondent/Year
(C) EPA Hours/ Respondent/Year (A x B)
(D) Respondents/ Year1
(E) EPA Technical Hours/Year (C x D)
(F) EPA Managerial Hours/Year (E x 0.05)
(G) EPA Clerical Hours/Year (E x 0.1)
(H) Cost, $/Year2
Develop/revise questionnaire spreadsheets and instructions
400
1
400
1
400
20
40
$15,806
Develop survey webpage
10
1
10
1
10
1
1
$395
Mail out questionnaire3
0.7
1
0.7
425
298
15
30
$11,756
Analyze and respond to claims that survey is not required to be completed due to area source status, facility closure, or because facility does not produce PCWP products4
1
1
1
106
106
5
11
$4,199
Answer respondent questions via phone, email, and/or frequently asked questions posted on webpage5
1
1
1
106
106
5
11
$4,199
Analyze requests for confidentiality6
1
1
1
106
106
5
11
$4,199
Review and analyze responses (including follow-up)
 
 

 
 
 
 

PCWP_survey.xlsx spreadsheet data
20
1
20
425
8500
425
850
$335,886
PCWP_CEMS_COMS.xlsx spreadsheet data
4
1
4
425
1700
85
170
$67,177
Enter/Analyze emissions test data from test reports
 
 

 
 
 
 

Enter/analyze previous emissions test data7
2
4
8
190
1520
76
152
$60,064
Review/analyze the Phase II stack testing data8
10
2.1
21.1
38
800
40
80
$31,613
 








Total Annual Hours/Cost




13,546
677
1,355
$535,294





 
Total Labor:
15,578

Expenses (O&M)9




 
 
 

Printing questionnaire (letter and instructions)




 
 
 
$1,275
Postage




 
 
 
$4,038
Computer storage of data




 
 
 
$2,040
Total O&M Expenses




 
 
 
$7,353
TOTAL ANNUAL LABOR BURDEN AND COST
 
 
 
 
 
 
 
$542,646
1. The number of respondents per year is based on the facility counts listed in Section 4 of the Supporting Statement, except for Phase II, which is based on the number of facilities for which testing could be requested (Part B of the Supporting Statement).
2. Based on GS Scale 2016: Technical/GS 13-1: $35.38/hour, Managerial/GS 15-1: $49.18/hour, Clerical: $16.77/hour.
3. The mailout package includes section 114 letter with standard enclosures and a hard copy of the survey instruction document. Assumes the EPA will mail one questionnaire per facility.
4. Assumes 15 percent of facilities provide documentation of area source status, facility closure, or that PCWP processes are not performed at the facility. It is not known how many of these claims will be valid so this number of facilities has not been subtracted from the burden estimates associated with completing the survey.
5. Assumes that 25 percent of the facilities will have questions.
6. Assumes that 25 percent of facilities will have confidential data.
7. It is estimated that PCWP facilities that were required to install controls will submit 4 test reports each. Emissions test results within the range of other test results will require little time for analysis. Other tests, such as best performers, will require additional analysis. Expect to spend an average of 0.5 hr per test result.
8. Based on testing of 80 total process units at 38 different facilities (80 process units/38 facilities = 2.1 process units tested per facility)
9. Cost Estimate Basis: Copy costs for 60 pages at $0.05/page; Postage Costs at $9.50 for Federal Express flat rate. Data storage at $6/GB/month assuming 10 GB data for 24 months; webpage cost at $600.

Attachment 3B.
Agency Burden and Costs if the Phase II Contingency for Emissions Testing Must be Exercised
Agency Activity
(A) EPA Hours/ Occurrence
(B) Occurrences/ Respondent/Year
(C) EPA Hours/ Respondent/Year (A x B)
(D) Respondents/ Year
(E) EPA Technical Hours/Year (C x D)
(F) EPA Managerial Hours/Year (E x 0.05)
(G) EPA Clerical Hours/Year (E x 0.1)
(H) Cost, $/Year
Mail out Phase II letters[1]
                                                                            0.7
                                                                              1
                                                                            0.7
                                                                             38
                                                                             27
                                                                              1
                                                                              3
                                                                         $1,051
Answer respondent questions via phone or email
                                                                              1
                                                                              1
                                                                              1
                                                                             38
                                                                             38
                                                                              2
                                                                              4
                                                                         $1,502
Review and analyze Phase II stack testing data[2]
                                                                             10
                                                                            2.1
                                                                           21.1
                                                                             38
                                                                            800
                                                                             40
                                                                             80
                                                                        $31,613
 








Total Annual Hours/Cost (Phase II)




                                                                            865
                                                                             43
                                                                             86
                                                                        $34,166





                                                        Total Labor (Phase II):
994

Expenses (O&M)3




 
 
 

Printing questionnaire (letter and instructions)




 
 
 
                                                                            $57
Postage




 
 
 
                                                                           $361
Computer storage of data




 
 
 
                                                                           $288
Total O&M Expenses




 
 
 
                                                                           $706
TOTAL ANNUAL LABOR BURDEN AND COST (PHASE II)
 
 
 
 
 
 
 
                                                                        $34,872









Total Annual Hours/Cost (Phase I + Phase II)
                                                                              
                                                                              
                                                                              
                                                                              
                                                                         13,611
                                                                            681
                                                                          1,361
                                                                        537,846
 
                                                                              
                                                                              
                                                                              
                                                                              
                                                  Total Labor (Phases I + II): 
                                                                        15,652 
                                                                              
Expenses (O&M) (Phase I + Phase II)
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
Printing questionnaire (letter and instructions)
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                         $1,332
Postage
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                         $4,399
Computer storage of data
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                         $2,328
Total O&M Expenses (Phase I + Phase II)
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                         $8,059
TOTAL ANNUAL LABOR BURDEN AND COST 
(PHASE I = PHASE II)
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                       $545,905
1. The mailout package includes section 114 letter for Phase II with a copy of EPA's test plan. Assumes the EPA will mail one questionnaire per facility.
2. Based on testing of 80 total process units at 38 different facilities (80 process units/38 facilities = 2.1 process units tested per facility)
3. Cost Estimate Basis: Copy costs for 60 pages at $0.05/page; Postage Costs at $9.50 for Federal Express flat rate. Data storage at $6/GB/month assuming 2 GB data for 24 months.

