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MACT Rules

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Plywood and Composite Wood Products (PCWP): timeline

"On June 19, 2007, the United States Court of Appeals for the District of Columbia Circuit (the Court) vacated EPA’s provisions in the National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products that established an October 1, 2008, compliance deadline and that created and delisted a low risk subcategory of plywood and composite wood products facilities." (71 FR 61060) In other words, the compliance dates for existing sources is returned to the original 10/01/2007 and the low risk category is eliminated.


Proposed Rule published in the Federal Register- January 9, 2003

Final Rule published in the Federal Register - July 30, 2004

Compliance Dates:


Effective Date for all Sources

September 28, 2004
Existing Major Sources No later than October 1, 2007
Compliance Date for Existing Sources No later than October 1, 2007
Compliance Date for Existing Sources in Low-Risk Subcategory No later than October 1, 2007. All affected sources must have this designation by this date or comply with the PCWP MACT.
Compliance Date for New Sources Upon Startup
Compliance Date for Area Source that Becomes a Major Source October 1, 2007 or on Startup Date as a Major, whichever is later.

What types of processes are considered an Affected Source?

The PCWP MACT rule potentially could regulate facilities under the following industrial codes:

SIC - 2421, 2435, 2436, 2439, 2493
NAICS - 321999, 321211, 321212, 321213, 321219

Affected sources have three compliance options:

Production-Based
Emissions Averaging (existing sources only)
Add-On Control System

Existing Sources


Initial Notification

January 26, 2005
Compliance Date October 1, 2007
Complete and Maintain Startup, Shutdown and Malfunction Plan (SSMP) No later than October 1, 2007
Submit Notification of Intent to Conduct a Performance Test (if applicable) 60 days before test or no later than January 26, 2008
Submit Notification of Compliance Status 30 days after initial compliance demonstration or 60 days if a performance test is required.
Conduct Initial Performance Test No later than March 29, 2008
Submit Semiannual Compliance Reports July 31, 2008 for first one, then semiannually thereafter.
Immediate Startup, Shutdown and Malfunction Report If an event is not consistent with original SSMP, within 2 days by phone or fax and 7 days by letter.
Emissions Averaging:
Submit Emission Averaging Plan
October 1, 2006 - or no more than one year before the date the facility starts to use emissions averaging whichever is later.
Control Device:
Submit Routine Control Device Maintenance Exemption Request
No later than September 1, 2007
Extensions for Installing Controls No later than June 1, 2007

Existing Sources in Low-Risk Subcategory


Initial Notification

January 26, 2005
Compliance Date October 1, 2007
Submit Low-Risk Demonstration No later than July 31, 2006
Conduct Initial Performance Test Completed before submitting application
Area Source that becomes
a Major Source:
Submit Low-Risk Demonstration
12 months after becoming major source or after initial startup, whichever is later.

New or Reconstructed Sources After Effective Date


Initial Notification

Submit a preconstruction application before starting construction which can serve as initial notification. Otherwise, 120 days after startup.
Compliance Date Upon startup
Notification of Actual Date of Startup 15 days afterwards
Complete and Maintain Startup, Shutdown and Malfunction Plan (SSMP) By startup
Submit Notification of Intent to Conduct a Performance Test (if applicable) 60 days before test
Conduct Initial Performance Test Upon startup or within 180 days of startup
Submit Low-Risk Demonstration Within 180 days of startup
Submit Notification of Compliance Status 30 days after initial compliance demonstration or 60 days if a performance test is required.
Submit Semiannual of Compliance Reports For first one, July 31 or January 31 after a complete six months compliance period, then semiannually thereafter.
Immediate Startup, Shutdown and Malfunction Report If an event is not consistent with original SSMP, within 2 days by phone or fax and 7 days by letter.
Control Device:
Submit Routine Control Device Maintenance Exemption Request
No later than 30 days before startup