Page
1
of
2
Memorandum
From:
Jan
Matuszko
USEPA/
OW/
OST
ph:
(
202)
566
1035
matuszko.
jan@
epa.
gov
To:
304(
m)
Record
(
EPA
Docket
Number
OW­
2003­
0074)

Date:
December
1,
2003
Re:
Status
of
Timber
Products
Processing
(
CFR
Part
429)
Review
During
EPA's
screening
level
analysis
for
its
effluent
guidelines
program
plan
for
2004,
EPA
identified
timber
products
processing
as
a
Group
II
category.
This
industry
currently
ranks
29th
and
2nd
in
TRI
and
PCS
rankings,
respectively.
This
category
covers
wood
preserving
(
which
we
estimate
to
be
the
major
source
of
toxic
releases),
sawmills,
and
"
manufactured
wood
products"
such
as
plywood,
oriented
strand
board,
and
particle
board.
The
effluent
guidelines
for
several
Timber
Products
subcategories
are
zero
discharge
of
"
process
wastewater."
Noncontact
cooling
water,
material
storage
yard
runoff,
and
boiler
blowdown
are
explicitly
excluded
from
the
definition
of
process
wastewater.
The
primary
pollutants
discharged
(
pounds
of
pollutants
collectively
discharged
in
the
highest
quantities)
by
this
industry
are
ammonia­
nitrogen,
BOD
5,
COD,
TSS,
and
creosote.
The
lb­
equivalent
results,
however,
are
largely
driven
by
dioxin
and
polyaromatic
hydrocarbon
compounds.

EPA
recently
proposed
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAPs)
for
the
Plywood
and
Composite
Wood
Products
industrial
category
(
40
CFR
Part
63,
Subpart
DDDD)
based
on
the
use
of
wet
air
pollution
control
(
January
9,
2003;
68
FR
1276).
Industry
has
requested
EPA
amend
the
effluent
guidelines
in
40
CFR
part
429
which
require
no
discharge
of
process
wastewater
pollutants,
to
allow
discharge
of
wastewaters
from
air
pollution
control
devices
(
APCD)
operation
and
maintenance.
Industry
suggests
that
effluent
limitations
for
these
wastewaters
be
developed
by
permit
writers
on
a
case­
by­
case
basis
using
BPJ.

The
preamble
to
the
proposed
NESHAP
stated
that
EPA
"
will
consider,
through
the
CWA
section
304(
m)
planning
process,
whether
it
is
appropriate
to
revise
part
429
at
a
later
time,"
(
68
FR
1305).
We
are
still
considering
whether
to
revise
Part
429
to
address
wastewaters
associated
with
the
APCD
operation
and
maintenance.

As
noted
above,
we
estimate
that
wood
preserving
is
the
major
source
of
toxic
releases
reported
by
this
industry
category.
EPA
and
wood
preservers
have
voluntarily
agreed
to
cancel
certain
chromated
copper
arsenate
(
CCA)
wood
preservative
products
and
terminate
certain
uses
Page
2
of
2
of
other
CCA
products
(
68
FR
17366;
April
9,
2003).
These
changes,
when
fully
implemented,
may
affect
the
toxicity
of
discharged
process
wastewater.

The
PCS
results
indicate
that
only
a
few
facilities
are
primarily
contributing
pollutants
collectively
for
this
category;
however,
TRI
results
indicate
that
the
pollutant
discharges
may
be
more
widespread.
We
will
continue
investigating
the
pollutant
discharges
from
this
industry
with
a
focus
on
the
wood
preserving
subcategories.
