Kiln MACT/RTR – Critical Juncture

1. Kiln MACT/RTR – Critical Juncture • Timothy Hunt • Senior Director Air Quality Programs • March 7, 2019 • Southeastern Lumber Manufacturers Association • Savannah, GA

2. Background Update on EPA activities and schedule Kilns work practice for MACT Risk analysis AWC Advocacy Efforts Conclusions Overview

3. EPA has two obligations Risk and Technology Review (RTR) of PCWP Set MACT for remand sources – 2008 remand; kilns and 30+ miscellaneous sources Court deadline only applies to the RTR - June 2020 (final) “Ample Margin of Safety” – AMOS Cancer: 10-4 to 10-6; Population risk/incidence Non-cancer: hazard index of one Cost an explicit factor Background

4. ICR responses submitted February 9, 2018 Of 393 ICRs mailed: ICR Not Applicable – 154 239 Full responses: 128 sawmills and 111 wood product Survey Responses

5. ICR Data Review and QAFinishing up ► Reviewing ICR data for trends – analysis documented in memos ► Quality assurance for riskmodeling: ► Are processes and HAPs expected reported? Emissionsreasonable? ► Are coordinates on the plantsite? ► Are reasonable release parameters specified for every releasepoint? ► Are emissions speciated (e.g., polycyclic organic matter, mercury)? ► Does the magnitude of emissions look reasonable? ► Gap-filling procedures, speciation and engineering assumptions will be documented in a risk inputsmemorandum

6. Percent of Remaining HAP Emissions (8/18)

7. HAP Emissions Data UnderReview - preliminary August2018 June2018

8. EPA Considerations • Numeric limits vs work practices – no controls! • Subcategorize especially sawmills- species, kiln type, or firing system (direct)? • Risk Analysis – screening level then refinements • Enforceability – records and reporting • Relationship with HAP reductions – limited data • Burden/cost to industry

9. Remand Review – Kilns & Misc Sources Determine work practice options to reduce HAP emissions Obtain current technology information and HAP emissions test data Can HAP be captured/conveyed? Technologically and economically feasible to measure HAP? CAA section 112(h) No Yes • Analyze HAP data to establish MACT floor. Determine if additional emission reductions may be achieved by going beyond the MACT floor CAA section 112(d)(2)-(3) Develop options for emission standards Select regulatory options Document analyses in memos and preamble Estimate emission reductions and costs associated with each option for each impacted facility

10. Risk Review Progress

11. Technology Review Progress

12. Lumber Kilns – By the Numbers • 144 Sawmills • 658 Kilns – 371 SYP, 246 other softwood (western), and 41 hardwood • 284 Batch, 87 Continuous • 184 Direct-fired, 187 Indirect-fired • Trends Since PCWP Proposal: • 2003-2008: 92 Installations • 27 Southern Pine (6 continuous), 18 Hardwood, 47 Other Softwoods • 2009-2013: 39 Installations • 32 Southern Pine (28 continuous) • 2014-2018: 52 Installations • 43 Southern Pine (36 continuous) • 20 Batch to Continuous Conversions (plus 70 the new installs)

13. AWC Approach • Working with SLMA on kilns • March 14 strategy meeting • Engaging EPA – data driven, present options, analyses, white papers, & meetings (May 8-9) • NCASI – gather and analyze data! • Member input through Env Issues Committee • AWC resources – technical and legal experts • Prioritize issues – complete both remand and RTR

14. Clear case for work practices – not able to capture or convey Legal MACT guideposts: Tied to best performers – less the top 12% Little case law guidance for work practices More than status quo Enforceable with clear elements – numeric? Look at other regulatory programs – state permits and BACT Balance legal risk with acceptability of requirements Redo could raise costs significantly MACT Considerations

15. Kiln Emission Management Plan(KEMP) • Site Specific Plan – minimize over-drying of lumber – Win-Win • Operating Standard • Kiln Integrity – air flow, door seals, etc. • Charge Management – stickering, sizing, etc. • Work Practice - choice • Moisture management - maintain annual average lumber moisture 7% below product moisture specification • For KD 19 becomes >12% (at planer or in kiln) • Temperature based – maximum set point during year • Western species have 200 F as common max • SYP temperature target?

16. KEMP – con’t • Recordkeeping and reporting • KEMP inspection and repair records for #1 and 2 • Demonstrate compliance with moisture or temperature • Semi-annual reporting of compliance and deviations • KEMP is for MACT compliance

17. Kilns in the spotlight – risk even before MACT done CDKs: half mills > ten in a million; less if stacks Batch: third mills > ten in a million Which HAPs drive risk? Formaldehyde – ~ 80%; potency factor? Acetaldehyde, Acrolein, Metals Key assumptions – over-estimation of emissions; dispersion parameters (buoyancy from kiln vents) Max individual risk (MIR) vs Population risk (incidence) Acute risks Risk Analysis

18. AWC Refinements/ Analyses MACT related: Costs of developing KEMP – incremental to current practices, ~$100K? Benefits of implementing KEMP – HAP reductions by quartiles of performers (~10-15%); everybody cannot be above average … Risk related: Flow and temperature adjustments – CDKs and batch Sensitivity analyses – buoyancy, distance, leakage, emission factors; factor of 2 to 10x lower Costs of stacks (new vs retrofits) - $100K vs $200K; not appropriate for batch kilns Costs of kiln maintenance to minimize leaks Full “shadow risk analysis” by AWC for highest risk sawmills (~ top 10%) – March/April?

19. CDK Risk Scenarios – with stacks

20. CDK Risk Scenarios – no stacks

21. Batch Kiln Scenarios – no stacks

22. Work load at EPA – many RTRs, shrinking and stretched staff Environmental stakeholders engaging in nearly all RTRs – wood surface coating RTR Competing air priorities – Clean Power Plan/ACE, biomass, NAAQS, NSR, etc. Very well positioned – finish in 2020 Questions ?? Tim Hunt thunt@awc.org Conclusions