August 31, 2026
Plywood and Composite Wood Products NESHAP Amendments Address 2007 Vacatur
After 20 years in the making, EPA finalized amendments to the plywood and composite wood products (PCWP) NESHAP on July 6, 2026. [91 FR 41410] This final rule is, in part, meant to address the 2007 partial remand and vacatur of a 2004 rule in which it was determined that EPA’s use of “no-control” emission floors for certain emission sources was unlawful. [National Resources Defense Council and Sierra Club vs. EPA; U.S., Court of Appeals, D.C. Circuit; Docket No. 04-1323; June 19, 2007] The amendments also establish regulations for hazardous air pollutants that were previously unregulated within the source category, as required by Louisiana Environmental Action Network vs. EPA (U.S., Court of Appeals, D.C. Circuit; Docket No. 17-1257; April 21, 2020).
No changes were made to the applicability of the PCWP source category in Subpart 63, Subpart DDDD. Thus, for the 219 affected major source facilities subject to the standard, the following provisions became effective July 6, 2026:
Summary of Final Amendments
Final Amendments | Summary |
|---|---|
Standards for lumber kilns | Work practice standards to limit emissions of organic HAPs, combustion-related HAPs, and VOCs from lumber kilns. |
Standards for organic HAPs emitted by process units with previous “no control” MACT determinations | Numeric standards for organic HAPs for new and existing atmospheric refiners and heated zones of existing fiberboard mat dryers and press predryers; establishes work practice standards for new and existing resinated material handling process units, stand-alone digesters, fiber washers, and log vats; and defines mixed PCWP process emissions streams subject to the NESHAP. |
Standards for previously unregulated resin-related HAPs | Numeric standards for MDI emissions for reconstituted wood products presses, tube dryers that blow-line blend MDI resin, and miscellaneous coating operations. |
Standards for previously unregulated combustion-related HAPs | Numeric standards for emissions of combustion-related HAPs for new and existing direct wood-fired dryers; establishes work practice standards to limit emissions of combustion-related HAPs, including D/F, by requiring burner tune-ups for burners associated with direct wood-fired and direct natural gas-fired dryers and by requiring continuous monitoring of an indicator of combustion unit bypass stack usage associated with PCWP dryers and lumber kilns. |
Other updates and revisions | Performance testing requirements for new and existing source emission limits; establishes monitoring, recordkeeping, and reporting requirements; removes obsolete rule language, including the emissions averaging compliance option for existing affected sources, dates, and startup/shutdown provisions that are no longer in effect; and updates and clarifies electronic reporting requirements. |
D/F = dioxin/furan; HAP = hazardous air pollutant; MACT = maximum achievable control technology; MDI = methylene diphenyl diisocyanate; VOC = volatile organic compound
Source: McCoy and Associates, Inc., adapted from 91 FR 41412.
©2026 McCoy and Associates, Inc. All rights reserved. McCoy does not use artificial intelligence (AI) in its writing and publishing.
McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.
Disclaimer
Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.
This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
