# Regulatory Impact Analysis for the Plywood and Composite Wood Products NESHAP

Final Report

### EPA-452/R-04-005 February 2004

Regulatory Impact Analysis for the Plywood and Composite Wood Products NESHAP

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Air Quality Strategies and Standards Division

Innovative Strategies and Economics Group Research Triangle Park, NC

## T ABLE OF 

## C ONTENTSExecutive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-1

1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.1 Scope and Purpose of the Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.2 Need for Regulatory Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.3 Requirements for the Regulatory Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 1.4 Other Federal Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 1.5 Organization of the Regulatory Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 1.6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
2 Profile of the Plywood and Composite Wood Industries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 The Supply Side . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.3 The Demand Side . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20 2.4 Industry Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 -29 2.5 Markets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-42 2.6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-58
3 Regulatory Alternatives, Emissions, Emission Re ductions, and Control and Administrative Costs 3.1 Regulatory Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.2 Emissions and Emission Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10 3.3 Control Equipment and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22 3.4 Testing, Monitoring, Reporting, and Recordkeeping Costs . . . . . . . . . . . . . . . . . . . . . 3-33 3.5 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-36
4 Economic Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.1 Results in Brief . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.3 Economic Impact Analysis Inputs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 4.4 Economic Impact Analysis Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4 4.5 Economic Impact Analysis Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 4.6 Analysis of Economic Impacts on Engineered Wood Products Sector . . . . . . . . . . . . 4-15 4.7 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-22
5 Small Business Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.1 Results in Brief . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.3 Screening Analysis Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 5.4 Screening Analysis Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 5.5 Screening Analysis Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 5.6 Screening Analysis Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 5.7 Screening Analysis Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10 5.8 EIA Results for Small Businesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.9 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-12

6 Qualitative Assessment of Benefits of Emission Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 6.1 Identification Of Potential Benefit Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16.2 Qualitative Description of Air Related Benefits - HAP and CO . . . . . . . . . . . . . . . . . . 6-1 6.3 Qualitative Description of Effects from Reductions and Increases in Emissions from Other Pollutants Due to HAP Controls 

### . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-6 6.4 Lack of Approved Methods to Quantify HAP Benefits . . . . . . . . . . . . . . . . . . . 6-8 6.5 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-10 6.6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11
Appendix A Summary of Impacts Associated with the Delisted Low-Risk Subcategory . . . . . . . . A-1

## L IST OF 

## E XHIBITS
Exhibit 2-1: SIC & NAICS Codes for the Plywood and Composite Wood Industries . . . . . . . . . . . . . . 2-2 Exhibit 2-2: Other Primary SIC Codes fo r the Plywood and Composite Wood Industries . . . . . . . . . . . 2-3 Exhibit 2-3: SIC and NAICS Codes and Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12 Exhibit 2-4: Specialization and Coverage Ratios, 1982 - 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13 Exhibit 2-5: Summary of Annual Costs and Shipments, 1992 -1997 . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14 Exhibit 2-6: Materials Consumed By Kind for Softwood Plywood and Veneer, 1997 . . . . . . . . . . . . 2-17 Exhibit 2-7: Materials Consumed by Kind for Reconstituted Wood Products, 1997 . . . . . . . . . . . . . . 2-18 Exhibit 2-8: Industry Outputs, by SIC Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21 Exhibit 2-9: MDF Shipments by Downstream Market, 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23 Exhibit 2-10: Particleboard Shipments by Downstream Market, 1997 . . . . . . . . . . . . . . . . . . . . . . . . . 2-24 Exhibit 2-11: Housing Market Indicators, 1988 - 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25 Exhibit 2-12: Trade for Household Furniture (SIC 251), 1989 - 1996 . . . . . . . . . . . . . . . . . . . . . . . . . 2-25 Exhibit 2-13: Use of Wood and Non-wood Products in Residential Construction 1976 - 1995 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-27 Exhibit 2-14: Demand Elasticities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-29 Exhibit 2-15: Concentration Ratios by SIC Code, 1982-1992 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-30 Exhibit 2-16: Facilities with Compliance Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-31 Exhibit 2-17: Full Production Capacity Utili zation Rates, Fourth Quarters, 1992 - 1997 . . . . . . . . . . . 2-33 Exhibit 2-18a: 1998 Employment at Facilities with Compliance Costs . . . . . . . . . . . . . . . . . . . . . . . . 2-34 Exhibit 2-18b: 1998 Employment at Facilities with Compliance Costs . . . . . . . . . . . . . . . . . . . . . . . . 2-34 Exhibit 2-19: Number of Mills, Average Capacity and Utilization, 1977 - 1997 . . . . . . . . . . . . . . . . . 2-36 Exhibit 2-20: Summary of Capital Expenditures, 1992 - 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-37 Exhibit 2-21: Size Distribution of Firms Owning Affected Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . 2-38 Exhibit 2-22: Types of Firm Ownership for Lumber and Wood Products (SIC 24), 1992 . . . . . . . . . . 2-39 Exhibit 2-23: Indicators of Financial Condition, 1995-1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-41 Exhibit 2-24: Trade Balance and Selected Statistics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-44 Exhibit 2-25: Production, Trade and Consump tion Volumes for Selected Products (1988-1997) . . . . 2-45 Exhibit 2-26: 1997 U.S. Wood Products Imports by Region and Major Trading Partner . . . . . . . . . . . 2-48 Exhibit 2-27: 1997 U.S. Wood Product Exports by Region and Major Trading Partner . . . . . . . . . . . 2-50 Exhibit 2-28: Lumber and Wood Pr oducts Producer Price Index, 1988-1997 . . . . . . . . . . . . . . . . . . . 2-51 Exhibit 2-29: Producer Price Indices of Plywood and Wood Composite Products . . . . . . . . . . . . . . . . 2-52 Exhibit 2-30: F.O.B. Prices of Southern plywood, OSB, and Particleboard . . . . . . . . . . . . . . . . . . . . . 2-53 Exhibit 2-31: APA Forecasted Structural Panel Production and Demand . . . . . . . . . . . . . . . . . . . . . . . 2-56 Exhibit 2-32: APA Actual and Forecasted Structural Panel Capacity and Production . . . . . . . . . . . . . 2-57 Exhibit 3-1: Illustration of Total HAP Calculation for an Emission Source . . . . . . . . . . . . . . . . . . . . . . 3-5 Exhibit 3-2: Summary of MACT for PCWP Process Units at New and Existing Sources . . . . . . . . . . . 3-6 Exhibit 3-3: Cost-Effectiveness Analysis Of Beyond-The-Floor Control Options . . . . . . . . . . . . . . . . . 3-8 Exhibit 3-4: Illustration Of Total HAP Calculation For An Emission Source . . . . . . . . . . . . . . . . . . . 3-13 Exhibit 3-5: Uncontrolled and Baseline HAP Emissions Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17 Exhibit 3-6: Speciated Nationwide Uncontrolled HAP Emissions by Product . . . . . . . . . . . . . . . . . . . 3-18 Exhibit 3-7: Speciated Nationwide Baseline HAP Emissions by Product . . . . . . . . . . . . . . . . . . . . . . . 3-19 Exhibit 3-8: Estimated Number of Major Sources By Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20 Exhibit 3-9: Estimated Nationwide Reduction in Total HAP and THC . . . . . . . . . . . . . . . . . . . . . . . . 3-21 Exhibit 3-10: Press Enclosure Exhaust Flow Rates and Capital Costs . . . . . . . . . . . . . . . . . . . . . . . . . 3-29 Exhibit 3-11: Control Equipment Costed for Process Units with Controlled MACT Floor . . . . . . . . . 3-31 Exhibit 3-12: Default Flow Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-32 Exhibit 3-13: Estimated Nationwide Control Costs for the PCWP Industry . . . . . . . . . . . . . . . . . . . . . 3-34 Exhibit 3-14: Dollars (In Total Annualized Costs) Per Ton Of HAP And THC Reduced . . . . . . . . . . 3-35Exhibit 4-1: Baseline Characterization of Plywood and Composite Wood Markets: 1997 . . . . . . . . . . 4-3 Exhibit 4-2. Market-Level Impacts of the NESHAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 Exhibit 4-3. Industry-Level Impacts of the NESHAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10 Exhibit 4-4: Distribution of Industry-Level Impacts of NESHAP: Affected and Unaffected Producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12 Exhibit 4-5: Distribution of Social Costs Associated with the NESHAP . . . . . . . . . . . . . . . . . . . . . . . 4-13 Exhibit 4-6: Primary Uses and Substitutes for LSL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16 Exhibit 4-7: Characteristics of LSL Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 Exhibit 4-8: Primary Uses and Substitutes for PSL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 Exhibit 4-9: Characteristics of PSL Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18 Exhibit 4-10: Retail Prices of GL and PSL Beams Delivered to Los Angeles . . . . . . . . . . . . . . . . . . . 4-18 Exhibit 5-1: Net Profit Margins by Product Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 Exhibit 5-2: Affected Firms by Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4 Exhibit 5-3: Affected Firms by Process Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5 Exhibit 5-4: Affected Firms with C/S Ratios of 3 Percent or Greater . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6 Exhibit 5-5: Affected Firms with C/S Ratios of 1 Percent or Greater . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7 Exhibit 5-6: C/S to R/S Comparison for Firms with C/S of One Percent or Greater . . . . . . . . . . . . . . . . 5-8 Exhibit 5-7: Economic Impacts on Small Businesses Associated with Projected Market Adjustments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11 Exhibit 6-1: Key Health Effects of Exposure to Ambient Carbon Monoxide . . . . . . . . . . . . . . . . . . . . . 6-5



## L IST OF 

## F IGURES
Figure 2-1: Plywood and Veneer Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 Figure 2-2: Softwood Plywood and Veneer Va lue of Shipments and Production Costs, 1992 - 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15 Figure 2-3: Reconstituted Wood Products Va lue of Shipments and Production Costs, 1992 - 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-16 Figure 2-4: Materials Consumed by Softwood Plywood and Veneer Products, 1997 . . . . . . . . . . . . . . 2-17 Figure 2-5: Materials Consumed by Reconstituted Wood Product Producers, 1997 . . . . . . . . . . . . . . . 2-19 Figure 2-6 Industry Outputs of So ftwood Plywood and Veneer Industry . . . . . . . . . . . . . . . . . . . . . . . 2-22 Figure 2-7: Industry Outputs of Reconstituted Wood Products Industry . . . . . . . . . . . . . . . . . . . . . . . 2-23 Figure 2-8: Plywood and Composite Wood Facility Locations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-32 Figure 2-9: Full Production Capacity Utilization, Fourth Quarters, 1992-1997 . . . . . . . . . . . . . . . . . . 2-33 Figure 2-10: Value of Product Shipments, 1989-1995 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-46 Figure 2-11: Apparent Consumption, 1989-1995 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-47 Figure 2-12: APA Projected Housing Starts (000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-55 Figure 3-1: Variation in RTO Purchased Equipment Cost with Flow Rate . . . . . . . . . . . . . . . . . . . . . . 3-24 Figure 3-2: Relationship between RTO Electricity Consumption and Flow Rate . . . . . . . . . . . . . . . . 3-25 Figure 3-3: Relationship between RTO Natural Gas Consumption and Flow Rate . . . . . . . . . . . . . . . 3-25 Figure 3-4: Variation in RTO Total Capital Investment with Flow . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-27 Figure 3-5: Variation in RTO Total Annualized Cost with Flow . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-27 Figure 4-1: Supply Curves for Affected Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5 Figure 4-2: Market Equilibrium Without and With Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6

### EXECUTIVE SUMMARY

### ES-1 EPA is issuing a rule to reduce hazardous air po llutant (HAPs) emissions from existing and new plywood and composite wood products facilities that are major sources. This rule, which will be promulgated in February 2004, is a National Emission Standards for Hazardous Air Pollutants (NESHAP), and will reduce HAP emissions by requi ring affected plywood and composite wood products facilities to meet a level of emissions reductions needed to meet the Maximum Achievable Control Technology (MACT) floor for these sources. This MA CT floor level of control is the minimum level these sources must meet to comply with the final ru le. The major HAPs whose emissions will be reduced are formaldehyde, acetaldehyde, acrolein, methanol , phenol, and propionaldehyde. The proposed rule will also lead to emission reductions of other pollutants such as volatile organic compounds (VOC), particulate matter (PM 10 ), carbon monoxide (CO), and emission increases in nitrogen oxides (NOx) due to the application of incineration-based controls. Increased electricity use due to application of controls will also lead to general increases in the levels of sulfur dioxide (SO 2 ) and NOx emitted from electric utilities.

This rule allows an affected source to use a production-based compliance option, defined in units of mass of pollutant per unit of production, or any of six control system compliance options if an affected source is equipped with an add-on control system. As explained in the Federal Register notice, the options entail HAP reductions of 90 percent or limiting the concentration of HAPs in the exhaust from the control system. In addition, an affected source may choose to comply with an emissions averaging option that allows the sources to not control or under-control some process units while controlling other affected process units. Finally, a source can be eligible to become part of a delisted low-risk subcategory and thus not be required to control HAP emissions to meet the final rule requirements if the source’s emissions have a sufficiently low risk level.
The rule is expected to reduce HAP emissions by 11,000 tons per year in the third year after its issuance. The rule is also expected to redu ce VOC emissions, measured as total hydrocarbon, by 27,000 tons per year, PM 10 emissions by 13,000 tons per year, and CO emissions by 11,000 tons per year in the third year. The increased electricity required to opera te the control systems is also expected to increase NOx and SO 2 emissions at electricity generating utilities by 1,200 and 2,000 tons, respectively. It should be noted that the NOx SIP call and Acid Rain emission trading programs would likely reduce or eliminate any increases in emissions at utilities. The complia nce costs, which include the costs of control and monitoring, recordkeeping and reporting requirement s, are estimated at $143 million (1999 dollars). The total social costs, which account for the behavi oral response of consumers and producers to higher pollution control costs, are estimated at $135.1 million (1999 dollars). Economic impacts associated with these costs include price increases nationally of 0.9 to 2. 5 percent for products affected by this rule, and a reduction in output of only 0.1 to 0.7 percent nationally for the affected industries. An analysis of small business impacts shows that there are 17 small firms affected, with 10 of them having annual compliance costs of 1 percent or greater than their sales, and 3 of these having annual compliance costs of 3 percent or greater than their sales. The Agency has certifie d that there is no significant impact on a substantial number of small entities (SISNOSE) associated with this rule. Also, an analysis of the energy impacts associated with this rule indicates that there is no significant adverse effect on supply, distribution, or use of energy from implementation of this rule. Impact results considering the effect of a delisted low-risk subcategory show reductions in all impact s with a particular effect on costs.
The Agency is unable to monetize the benefits from the HAP, VOC, and CO emissions reductions due to lack of credible data for assigni ng a benefits value to these reductions. While the Agency has done so in past RIAs and may do so in th e future, for this rule, the Agency has not monetized the benefits and disbenefits associated with the criteria pollutant (PM, NOx, SO 2 ) emission decreases andES-2 increases, respectively. This lack of inclusion of a monetized benefits estimate for criteria pollutant emission changes is not meant to imply that the Agency will choose not to provide such monetized benefit estimates for other NESHAPs and other standards.
Results associated with a complian ce alternative to the final rule, an alternative which is based on the eligibility of sources to become part of a delisted low-risk subcategory, can be found in Appendix A.1-1 

## 1 INTRODUCTION

Under the authority of Section 112(d) of the Clean Air Act as amended in 1990, the U.S. Environmental Protection Agency (EPA or the Agency) is a regulation requiring facilities that manufacture plywood and composite wood products to re duce their emissions of hazardous air pollutants (HAPs). This regulation, a National Emission St andard for Hazardous Air Pollutants (NESHAP), will apply to major sources of HAPs in this industry. This regulatory impact analysis (RIA) presents the supporting documentation and analyses developed by the Agency that describe and quantify the expected impacts of the Plywood and Composite Wood Products NESHAP.
1.1 Scope and Purpose of the Report
The NESHAP will require the manufacturers of plywood and composite wood products to install additional pollution controls to reduce their emissions of HAPs to the air. The purpose of this EIA is to present the results of the Agency’s evaluation of the cost, economic impacts, and benefits from compliance with the requirements of the NESHAP.
The NESHAP will apply to all new and existing major sources of HAPs that manufacture plywood and composite wood products. These sources emit HAPs associated with heating of wood and related to their use of resins, adhesives, and a dditives in the pressing and drying stages of the production process. The EPA estimates that there are 447 facilities that produce plywood and composite wood products. Of these, the EPA determined that 223 facilities are major sources of HAPs.
1.2 Need for Regulatory Action
The purpose of this NESHAP is to protect public health by reducing emissions of HAP from plywood and composite wood products facilities. The au thority for doing this lies in Section 112 of the Clean Air Act (CAA), which requires EPA to list cate gories and subcategories of major and area sources of HAP and to establish NESHAP for the listed sour ce categories and subcategories. The plywood and composite wood products source category was origina lly listed as the plywood and particleboard source category on July 16, 1992 (57 FR 31576). The name of the source category was changed to plywood and composite wood products on November 18, 1999 (64 FR 63025) to more accurately reflect the types of manufacturing facilities covered by the source categor y. A major source of HAP is defined as any stationary source source or group of stationary sources within a continuous area and under common control that emits or has the potential to emit, cons idering controls, in the aggregate, 9.1 Megagrams (Mg)/year (10 tons/yr) or more of any single HAP or 22.7 Mg/year or more (25 tons/yr) of multiple HAP.
Section 112 of the CAA requires EPA to establish NESHAP for the control of HAP from both existing and new sources. The CAA requires the NESHAP to reflect the maximum degree of reduction in emissions of HAP that is achievable. This leve l of control is commonly referred to as the maximum achievable control technology (MACT).

The MACT floor is the minimum level of cont rol allowed for NESHAP and is defined under section 112 (d) (3) of the CAA. In essence, the MACT floor ensures that the standard is set at a level that assures all major sources achieve the control level that is at least as stringent as that already achieved by1-2 the better-controlled and lower-emitting sources in each source category or subcategory. For new sources, the MACT floor cannot be less stringent than the emission control that is achieved in practice by the best-controlled similar source. The MACT sta ndards for existing sources can be less stringent than standards for new sources, but they cannot be less st ringent than the average emission limitation achieved by the best-performing 12 percent of existing sour ces in the category or subcategory (or, the bestperforming 5 sources for categories or subcategories with fewer than 30 sources.)
In the course of rule development, we may also consider control options that are more stringent than the floor. EPA may establish standards more st ringent than the floor based on the consideration of cost of achieving the emissions reductions, any non-ai r quality health and environmental impacts, and energy requirements.
1.3 Requirements for this Regulatory Impact Analysis
This section describes various legislative and ex ecutive requirements that govern the analytical requirements for Federal rulemakings, and describes how each analytical requirement is addressed in this EIA.

1.3.1 Executive Order 12866
Under Executive Order 12866 (58 FR 51735, Octobe r 4, 1993) as amended by Executive Order 13258 (67 FR 9385, February 28, 2002), the EPA must determine whether the regulatory action is “significant” and therefore subject to review by the Office of Management and Budget (OMB) and the requirements of the Executive Order. The Executiv e Order defines “significant regulatory action” as one that is likely to result in a rule that may:
1) Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, comp etition, jobs, the environment, public health or safety, or state, local, or tribal governments or communities;
2) Create a serious inconsistency or otherwise inte rfere with an action take n or planned by another agency; 3) Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs, or the rights and obligation of recipients thereof;
4) Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, or the principles set forth in the Executive Order.

Pursuant to the terms of Executive Order 12866 as amended by Executive Order 13258, it has been determined that this rule is a “significant regulat ory action” because the annual costs of complying with the rule are expected to exceed $100 million. C onsequently, this action was submitted to OMB for review under Executive Order 12866 as amended by Executive Order 13258.

1.3.2 Regulatory Flexibility Act and Small Busi ness Regulatory Enforcement Fairness Act of 1996
The Regulatory Flexibility Act (RFA) of 1980 (PL 96-354) generally requires that agencies conduct a screening analysis to determine whethe r a regulation adopted through notice-and-comment1 Where appropriate, agencies can propose and justify alternative definitions of “small entity.” This RIA and the screening analysis for small entities rely on the SBA definitions.

1-3 rulemaking will have a significant impact on a subs tantial number of small entities (SISNOSE), including small businesses, governments, and organizations. If a regulation will have such an impact, agencies must prepare an Initial Regulatory Flexibility Analysis, and comply with a number of procedural requirements to solicit and consider flexible regulat ory options that minimize adverse economic impacts on small entities. Agencies must then prepare a Fi nal Regulatory Flexibility Analysis that provides an analysis of the effect on small entities from consider ation of flexible regulatory options. The RFA’s analytical and procedural requirements were strengt hened by the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996 to include the formation of a panel if a proposed rule was determined to have a SISNOSE. This panel would be made up of representatives of the EPA, the Small Business Administration (SBA), and OMB.
For reasons explained more fully in Chapter 5 of this economic impact analysis for the rule, EPA has determined that there is no SISNOSE for this ru le. While there are some impacts to some small firms, these impacts are not sufficient for a SISNOSE. Therefore, the EPA has not prepared a Final Regulatory Flexibility Analysis for this rule.
The RFA and SBREFA require the use of definitions of “small entities,” including small businesses, governments, and organizations such as non-profits, published by the SBA. 1 Screening analyses of economic impacts presented in Chapter 5 of this report examine potential impacts on small entities.
1.3.3 Unfunded Mandates Reform Act of 1995
The Unfunded Mandates Reform Act (UMRA) of 1995 (PL-4) was enacted to focus attention on federal mandates that require other governments and private parties to expend resources without federal funding, to ensure that Congress considers those co sts before imposing mandates, and to encourage federal financial assistance for intergovernmental ma ndates. The Act establishes a number of procedural requirements. The Congressional Budget Office is required to inform Congressional committees about the presence of federal mandates in legislation, and mu st estimate the total direct costs of mandates in a bill in any of the first five years of a mandate , if the total exceeds $50 million for intergovernmental mandates and $100 million for private-sector mandates.
Section 202 of UMRA directs agencies to provide a qualitative and quantitative assessment (or a “written statement”) of the anticipated costs and bene fits of a Federal mandate that results in annual expenditures of $100 million or more. The assessment s hould include costs and benefits to State, local, and tribal governments and the private sector, and identify any disproportionate budgetary impacts. Section 205 of the Act requires agencies to identify a nd consider alternatives, including the least costly, most cost-effective, or least burdensome alterna tive that achieves the objectives of the rule.
Since this rule may cause a mandate to the private sector of more than $100 million, EPA did provide an analysis of the impacts of this rule on State and local governments to support compliance with Section 202 of UMRA. A summary of this analysis is in Chapter 4 of this EIA. In short, no government entity is affected by this rule - only businesses.1-4 1.3.4 Paperwork Reduction Act of 1995
The Paperwork Reduction Act of 1995 (PRA) requir es Federal agencies to be responsible and publicly accountable for reducing the burden of Fede ral paperwork on the public. EPA has submitted an OMB-83I form, along with a supporting statement, to the OMB in compliance with the PRA. The OMB83I and the supporting statement explains the need fo r additional information collection requirements and provides respondent burden estimates for additiona l paperwork requirements to State and local governments associated with this rule.

1.3.5 Executive Order 12898
Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,” requires Fe deral agencies to consider the impact of programs, policies, and activities on minority populations and lo w-income populations. Disproportionate adverse impacts on these populations should be avoided to th e extent possible. According to EPA guidance, agencies are to assess whether minority or low-income popul ations face risk or exposure to hazards that is significant (as defined by the National Environmenta l Policy Act) and that “appreciably exceeds or is likely to appreciably exceed the risk or rate to the general population or ot her appropriate comparison group.” (EPA, 1996). This guidance outlines EPA’s Environmental Justice Strategy and discusses environmental justice issues, concerns, and goals id entified by EPA and environmental justice advocates in relation to regulatory actions. The plywood and composite wood products rule is expected to provide health and welfare benefits to populations around the United States, regardless of race or income.

1.3.6 Executive Order 13045
Executive Order 13045, “Protection of Children from Environmental Health Risks and Safety Risks,” directs Federal agencies developing health a nd safety standards to include an evaluation of the health and safety effects of the regulations on child ren. Regulatory actions covered under the Executive Order include rulemakings that are economically significant under Executive Order 12866 as amended by Executive Order 13258, and that concern an environmental health risk or safety risk that the agency has reason to believe may disproportionately affect child ren. EPA has developed internal guidelines for implementing E.O. 13045 (EPA, 1998).
The plywood and composite wood products rule is a “significant economic action,” because the annual costs are expected to exceed $100 million. Exposure to the HAPs whose emissions will be reduced by this rule are known to affect the health of children and other sensitive populations. However, this rule is not expected to have a disproportionate impact on children.

1.3.7 Executive Order 13211
Executive Order 13211, “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use,” was published in the Federal Register on May 22, 2001 (66 FR 28355). This executive order requires Federal Agencies to wei gh and consider the effect of regulations on supply, distribution, and use of energy. To comply with this executive order, Federal Agencies are to prepare and submit a “Statement of Energy Effects” for “signi ficant energy actions.” The executive order defines “significant energy action” as the following:1-5 1) an action that is a significant regulatory action under Executive Order 12866 or any successor order, and
2) is likely to have a significant adverse effect on the supply, distribution, or use of energy; or
3) that is designated by the Administrator of th e Office of Information and Regulatory Affairs as a significant energy action.
An analysis of the effects of this rule on supply, distribution, and use of energy is summarized in Chapter 4.

1.4 Other Federal Programs
The only other federal program that may have an effect on these sources is the wood building products surface coating NESHAP, a rulemaking promul agated in February, 2003. However, the overlap of coverage of these rules will be minimal. The wood furniture manufacturing operations NESHAP, a rule signed in December 1995, may apply to some facilities that will be affected by the plywood and composite wood products rule, but there are no overl apping requirements for individual process units.

1.5 Organization of the Regulatory Impact Analysis
This report includes six chapters and an appendi x that present a description of the industry, the costs associated with the regulatory control options and compliance alternatives associated with the NESHAP, results of the economic impact analysis, and a summary of impacts on small businesses.
• Chapter 2 profiles the plywood and composite wood products industries. • Chapter 3 summarizes the approach to estimating the costs of the NESHAP, presents the results of the cost analysis, and provide the emissions reductions for the final rule. • Chapter 4 summarizes the approach to performi ng the economic impact analysis of the NESHAP and presents the results of the analysis. An analysis of impacts on energy distribution, supply, or use is also in this chapter. • Chapter 5 includes the results of the anal yses of the NESHAP’s impact on small businesses. • Chapter 6 presents a qualitative assessment of the benefits associated with this final rule. • Appendix A presents impacts associated with a de listed low-risk subcategory that could allow various PCWP sources to not have to put on controls to comply with the final rule.

Throughout this report, a distinction is made between “affected” and “unaffected” facilities and firms. Affected facilities are those that w ill incur compliance costs (control and monitoring, recordkeeping, and reporting ) to comply with the rule . In general, unaffected facilities and firms have no compliance costs. However, of the group of unaff ected facilities, 51 of these will incur costs associated with monitoring, reporting, and record keeping (MRR). MRR costs are estimated to be $25,194 per year. The distinction between affected and unaffected facilities and firms will be noted throughout the document.2-6 1.6 References
Federal Register, 1993. Executive Order 12866, Regulatory Planning and Review. Vol. 58, October 4, 1993, pg. 51735.
U.S. Environmental Protection Agency, 1996. Guidance for Providing Environmental Justice Concerns in EPA’s NEPA Compliance Analyses (Review Draft). Office of Federal Activities, Washington, D.C., July 12, 1996.
U.S. Environmental Protection Agency, 1996. Memorandum from Trovato and Kelly to Assistant Administrators. Subject: “Implementation of Executive Order 13045, Protection of Children from Environmental Health and Safety Risks.” April 21, 1998.
Federal Register, 2001. Executive Order 13211, Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use. Vol. 66, May 22, 2001, pg. 28355.
Federal Register, 2002. Executive Order 13258, Amending Executive Order 12866 - Regulatory Planning and Review. Vol.67 , February 28, 2002, pg. 9385.

2 PROFILE OF THE PLYWOOD AND COMPOSITE WOOD PRODUCTS INDUSTRIES

2.1 Introduction
Through a 1998 information collection request (ICR), the EPA identified plants potentially impacted by the NESHAP. This profile presents in formation on several industries that comprise the plywood and composite wood source category because they will be impacted by the regulation in some way. These industries fall into three categories based on their Standard Industrial Classification (SIC) or North American Industry Classification System (NAICS) classifications.2-1 • Softwood plywood and veneer • Reconstituted wood products • Structural wood members
The industries are represented by the three SIC codes and four NAICS codes presented in Exhibit 2-1. The NAICS codes replaced SIC codes in federa l statistical data beginning in 1997. The SIC code for Structural Wood Members, Not Elsewhere Classified (n.e.c.) was divided into two NAICS codes for Engineered Wood Members and Truss Manufacturing. The ICR surveyed 416 potentially impacted facilities (EPA, 1998) , and an additional 15 facilities we re identified that either did not respond to the survey or have commenced operation since the date of the survey. The Agency determined that of these 431 facilities, 223 were impacted facilities, owned by 52 firms.
EPA expects this rule to primarily impact certain facilities engaged in the manufacturing of softwood plywood, reconstituted wood products, and structural wood members. Exhibit 2-1 shows, for each of the three industry categories, the number of facilities EPA expects will experience compliance costs as a result of this MACT standard and the to tal number of facilities. The total estimated capital costs associated with the new MACT standard ar e $479 million. The annualized costs for affected facilities are $139 million on an annual basis, including monitoring, reporting, and record keeping costs (in 1999 dollars). Some unaffected facilities will also have monitoring, reporting, and record keeping costs of approximately $4 million per year. Therefore, the total annualized compliance costs are $143 million (1999 dollars).
Including costs associated with monitoring, reporting, and record keeping requirements, EPA expects 88 softwood plywood and veneer facilities to experience approximately 22 percent of the costs, 38 oriented strandboard facilities to experience appr oximately 18 percent of the costs, 82 other wood composite (including medium density fiber (MDF), particle board (PB), and hardboard (HB)) to experience approximately 58 percent of costs, a nd engineered wood product facilities to bear the remaining 2 percent. Most of the discussions c ontained in this profile will emphasize the softwood plywood and reconstituted wood produc ts industries because facilities in these industries will experience the greatest impacts associated with the new MACT st andard. A discussion of the affected EWP facilities is presented in Section 4.4 of this chapter.2 See section 2.4.3.1 for a description of how primar y SIC codes were assigned to the surveyed facilities.

2-2 Exhibit 2-1: SIC & NAICS Codes for the Plywood and Composite Wood Industries

SIC Code SIC Description NAICS Code NAICS Description Impacted Facilities* Total Facilities in

Category 2436 Softwood Veneer and Plywood 321212 Softwood Veneer and Plywood 66 155

2493 Reconstituted Wood Products 321219 Reconstituted Wood Products Total: 97 317 OSB: 23 PB/MDF: 56 HB: 18 2439 Structural Wood Members, Not Elsewhere Classified 321213 Engineered Wood Members (Except Truss) 3 53

321214 Truss Manufacturing 0 992

* Does not include number of facilities with MRR costs only. Sources: MRI (1999), U.S. Environmental Protection Agency (1998), Dun & Bradstreet (1999a), U.S. Department of Commerce (1999a).
Producers of plywood and composite wood products also engage in additional manufacturing activities including furniture and wholesale timber production. In some cases, their primary SIC code 2 may be one other than those listed in Exhibit 2-1. The facilities with a primary SIC codes other than for plywood and wood composite manufacturers are shown in Exhibit 2-2. The operations related to these other SIC codes are unlikely to be affected by the MACT standard. In addition, the number of facilities identified as potentially affected by this rule relative to the total number of establishments in all categories is extremely small (under one percent for all categori es). Therefore, this profile focuses on the SIC and NAICS listed in Exhibit 2-1. In particular, the pr ofile will focus on the softwood plywood and veneer and reconstituted wood products industries. All facilities that are impacted by the MACT standard are included in these analyses, regardless of their primary SIC or NAICS code.2-3 Exhibit 2-2: Other Primary SIC and NAICS Code s for the Plywood and Composite Wood Industries

SIC Description NAICS NAICS Title Facilities in ICR Impacted Facilities Total Facilities in

Category

2421 Sawmills and Planning Mills, General 321113 321912 321918 321999 Sawmills Cut Stock, Resawing Lumber, & Planning Other Millwork (including Flooring) All Other Miscellaneous Wood Product Manufacturing 32 13 5,815

2426 Hardwood Dimension and Flooring Mills 321113 321912 321918 387215 Sawmills Cut Stock, Resawing Lumber, & Planning Other Millwork (including Flooring) Showcase, Partition, Shelving, and Locker Manufacturing 5 0 833

2448 Wood Pallets and Skids 321920 Wood Container and Pallet Manufacturing 1 0 1,929

2499 Wood Products, Not Elsewhere Classified 321920 333414 339999 321999 Wood Container and Pallet Manufacturing Heating Equipment Manufacturing All Other Miscellaneous Manufacturing All Other Miscellaneous Wood Product Manufacturing 4 0 2,760

2511 Wood Household Furniture, Except Upholstered 337122

337215 Non-upholstered Wood Household Furniture Manufacturing Showcase, Partition, Shelving, and Locker Manufacturing 13 0 2,785

Sources: MRI (1999), U.S. Environmental Protection Agency (1998), Dun & Bradstreet (1999a), U.S. Department of Commerce (1999a).
Section 2.2 of this chapter describes the supply side of the affected industries and characterizes the production process, the products concerned, and the costs of production. Section 2.3 examines the demand side of the affected industries, product u ses, and consumers. Section 2.4 characterizes the facilities and firms that comprise the industry, their or ganization, and their fina ncial conditions. Finally, Section 2.5 describes the markets and discusses domes tic production and consum ption, international trade, and prices.
2.2 The Supply Side
The following section contains information c oncerning the supply of plywood and composite wood products. This section describes the production pr ocesses of each of the aforementioned industries. It then presents the products, by-products, and co-p roducts of each industry. Lastly, the costs of production for each of the three industries are presented. Factors, such as industry shipments, costs of materials, fuels and electricity, payroll, capital expe nditures, and materials consumed are all examined.3 The descriptions contained in this section rely pr imarily on U.S. EPA’s Lumber and Wood Products Sector Notebook (1995).

2-4 2.2.1 Production Process
This section discusses three categories of plyw ood and composite wood production: plywood and veneer; particleboard, strand and fiber composites; and structural wood members. The construction of plywood, consists basically of combining an odd numbe r of layers of veneer, with each layer having one or more plies. Hardwood plywood is generally made by applying a hardwood veneer to the face and back of a softwood plywood, MDF, or particleboard panel. The differences between the hardwood and softwood processes occur because of different inputs a nd markets. Particleboard, oriented strandboard, fiberboard, and hardboard are all processed similarl y. These three types of reconstituted wood products are manufactured by combining fragmented pieces of wood and wood fiber into a cohesive mat of wood particles, fibers, and strands. Structural wood members are the products of multiple manufacturing techniques. This section describes the production of glue-laminated timber and the three types of structural composite lumber: laminated veneer lu mber, parallel strand lumber, and laminated strand lumber.
2.2.1.1 General Considerations for Plyw ood and Composite Wood Product Manufacturing
Release of hazardous air pollutants (HAPs) is primarily associated with drying and pressing processes in the manufacturing of plywood and co mposite wood products. Coating processes are intrinsically related to the manufacturing process and result in further emissions through drying and pressing. Conventional composite wood products are ge nerally made with a thermosetting or heat-curing resin or adhesive that holds wood fiber together. Commonly used resin-binder systems include phenolformaldehyde, urea-formaldehyde, melamine-form aldehyde, and propionaldehyde. A number of additives are used in the manufacturing of wood co mposites as well. Most notably, wax is used to provide finished products with resistance to water pe netration. Other additives include preservatives, fire retardants, and impregnating resins.
While there is a broad range of plywood and com posite wood products and ma ny applications for such products, this section of the profile groups the production processes of these products into three general categories: plywood and ven eer; particle board, strand and fibe r composites; and structural wood members. Further descriptions of the production processes for each of these categories are provided in this section.
2.2.1.2 Plywood and Veneer 3
Construction of plywood relies on combining an odd num ber of layers of veneer. Layers consist of one or more than one ply with the wood grain r unning in the same direction. Outside plies are called faces or face and back plies, while the inner plies are called cores or centers. Layers may vary in number, thickness, species, and grade of wood. To distinguish the number of plies (individual sheets of veneer in a panel) from the number of layers (number of times the grain orientation changes), panels are sometimes described as three-ply, three-layer, or four-ply, three-layer.
As described above, veneer is one of the main components of plywood. Most softwood plants produce plywood veneer for their own use. Of fac ilities reporting drying of veneer, 86 percent of the veneer produced was used for in-facility plywood pr oduction. Only approximately 7 percent of the2-5 facilities in the ICR survey produced veneer solely for outside sales and non-internal plywood use (EPA, 1998).
The general processes for making softwood includes: log debarking, log steaming and/or soaking, veneer cutting, veneer drying, veneer preparation, glue application, pressing, panel trimming, and panel sanding. Softwood plywood is genera lly made with relatively thick faces (1/10 inch and thicker) and with exterior or intermediate glue. This glue provides protection in cons truction and industrial uses where moderate delays in providing weather protecti on might be expected or conditions of high humidity and water leakage may exist. Figure 2-1 below presents a diagram of the plywood production process.
Logs delivered to a plant are sorted, then deba rked and cut into peeler blocks. Almost all hardwood and many softwood blocks are heated prior to peeling the veneer to soften the wood. The peeler blocks are heated by steaming, soaking in hot water, spraying with hot water, or combinations of these methods. Heated blocks are then conveyed to a ve neer lathe. The block, gripped at either end and rotated at high speed, is fed against a stationary knife parallel to its length. Veneer is peeled from the block in continuous, uniform sheets. Depending on its intended use, veneer may range in thickness from 1/16 to 3/16 (1.6mm to 4.8mm) for softwood and much thinner for hardwood and decorative plywood uses (Youngquist, 1999). Slicing methods are also used to produce hardwood decorative veneers generally in thicknesses of 1/24 inch and thinner.
After peeling, the continuous sheets of veneer ar e transported by conveyor to a clipping station where it is clipped. In softwood mills and some hardwood mills, high-speed clippers automatically chop the veneer ribbons to usable widths and defects ar e removed. In many hardwood mills, clipping may be done manually to obtain the maximum amount of clear material. Wet clipped veneer is then dried. Proper drying is necessary to ensure moisture cont ent is low enough for adhesives to be effective.
Dryers
Two types of dryers are used in softwood veneer mills: roller resistant dryers, heated by forced air; and “platen” dryers, heated by steam. In ol der roller dryers, also still widely used for hardwood veneer, air is circulated through a zone parallel to th e veneer. Most plants built in recent years use jet dryers (also called impingement dryers) that direct a cu rrent of air, at a velocity of 2,000 to 4,000 feet per minute, through small tubes on the surface of the veneer. Veneer dryers may be heated indirectly with steam, generated by a separate boiler, which is circulat ed through internal coils in contact with dryer air. Dryers may also be heated directly by the combusti on gases of a gas- or wood-fired burner. The gas-fired burner is located inside the dryer, whereas combustion gases from a wood-fired burner are mixed with recirculating dryer air in a blend box outside the dryer and then transported into the dryer. Veneer dryers tend to release organic aerosols, gaseous organic compounds, and small amounts of wood fiber into the atmosphere. Once dried, veneer is sorted and graded for particular uses.2-6 Figure 2-1: Flow Diagram of Veneer and Plywood Production Figure 2-1:

Source: U.S. EPA (1995).4 The descriptions in this section rely primarily on Chapter 10 of the USDA’s Forest Products Laboratory Wood Handbook (Youngquist, 1999).

2-7 Adhesives
Plywood manufacturing begins with the veneer sen t to a lay-up area for adhesive application. Various adhesive application systems are used includi ng hard rolls, sponge rolls, curtain coaters, sprayers, and foam extruders. The most common application for softwood plywood is an air or airless spray system, which generally uses a fixed-head applicator capable of a 10-foot wide spray at a nozzle pressure of 300 pounds per square inch (psi). The phenol-formalde hyde (PF) adhesives typical in softwood plywood manufacturing is made from resins synthesized in regional plants and shipped to individual plywood mills. At the mills, the resins are combined with ex tenders, fillers, catalysts, and caustic to modify the viscosity of the adhesive. This glue mixing has sev eral additional effects: allowing the adhesive to be compatible with the glue application method (curta in, roll, spray, foam); allowing for better adhesive distribution; increasing the cure rate; and lowering cost.

Presses
Following the application of glue, the panels must be pressed. The purpose of the press is to bring the veneers into close contact so that the glue layer is very thin. At this point, resin is heated to the temperature required for the glue to bond. Most pl ywood plants first use a cold press at lower pressure prior to final pressing in the hot press. This allows the wet adhesive to "tack" the veneers together, permits easier loading of the hot-press, and prevents shifting of the veneers during loading. Pressing is usually performed in multi-opening presses, which can produce 20 to 40 4x8-foot panels in each two- to seven-minute pressing cycle.
Finishing
After pressing, stationary circular saws trim up to one inch from each side of the pressed plywood to produce square-edged sheets. Approximately 20 percent of annual softwood plywood production is then sanded. As sheets move through enclosed auto matic sanders, pneumatic co llectors above and below the plywood continuously remove the sander dust. Sa wdust in trimming operations is also removed by pneumatic collectors. The plywood trim and sawdust are burned as fuel or sold to reconstituted panel plants.
2.2.1.3 Particle, Strand, and Fiber Composites 4
This group of products falls into the SIC or NAICS code category of reconstituted wood products. The impacted facilities in this category manufacture the following products (MRI, 1999).
• Medium density fiberboard • Oriented stand board • Particleboard • Hardboard
All particle, strand and fiber composites are pr ocessed in similar ways. Raw material for particleboard, oriented strandboard (O SB), fiberboard, and hardboard is obtained by flaking or chipping wood. The general process then includes wood drying, adhesive application, and forming a mat of wood2-8 particles, fibers, or strands. The mat is then pr essed in a platen-type press under heat and pressure until the adhesive is cured. The bonded panel is finally cooled and further processed into specified width, length, and surface qualities. Specific details re garding the production processes for different products are provided below.

Particleboard
Generally, particleboard is produced by mech anically reducing wood materials into small particles, applying adhesive to the particles, and c onsolidating a loose mat with heat and pressure into a panel product. Particleboard is typi cally made in three layers with the faces consisting of finer material and the core using coarser material. Particleboard can also be made from a variety of agricultural residues, including kenaf core, jute stick, cereal st raw, and rice husks dependi ng on the region. EPA does not expect facilities that produce particleboard made from agricultural residues, also called agriboard, to experience compliance cost impact s associated with the new MACT standard. EPA expects only one facility that produces molded particleboard to experience compliance cost impacts (MRI, 1999).
The raw materials, or "furnish," that are used to manufacture reconstituted wood products can be either green or dry wood residues. Green residues include planer shavings from green lumber and green sawdust. Dry process residues include shavings fro m planing kiln-dried lumber, sawdust, sander dust, and plywood trim. The wood residues are ground into particles of varying sizes using flakers, mechanical refiners, and hammermills, and are then classified according to their physical properties.
After classification, the furnish is dried to a low mo isture content (two to seven percent) to allow for moisture that will be gained by the adding of r esins and other additives during blending. Most dryers currently in operation in particle and fiber compos ite manufacturing plants use large volumes of air to convey material of varied size through one or more passes within the dryer. Rotating drum dryers requiring one to three passes of the furnish are most common. The use of triple-pass dryers predominates in the United States. Dryer temperatures may be as high as 1,100 - 1,200° F with a wet furnish. However, dry planer shavings require that drye r temperatures be no higher than 500° F because the ignition point of dry wood is 446° F. Many dryers are directly heated by dry fuel suspension burners. Others are heated by burning oil or natural gas. Direct-fired rotary drum dryers release emissions such as wood dust, combustion products, fly ash, and organic compounds evaporated from the extractable portion of the wood. Steam-heated and natural gas-fired dryers will have no fly ash.
The furnish is then blended with synthetic adh esives, wax, and other additives distributed via spray nozzles, simple tubes, or atomizers. Resin may be added as received (usually as an aqueous solution), or mixed with water, wax emulsion, catal yst, or other additives. Waxes are added to impart water repellency and dimensional stability to the boa rds upon wetting. Particles for particleboard are mixed with the additive in short retention time blenders, through which the furnish passes in seconds. The furnish and resin mixture is then formed into ma ts using a dry process. This procedure uses air or a mechanical system to distribute the furnish onto a moving caul (tray), belt, or screen. Particleboard mats are often formed of layers of different sized particles, with the larger particles in the core, and the finer particles on the outside of the board. The mats are hot pressed to increase their density and to cure the resin. Most plants use multi-opening platen presses. Though more popular in Europe, the continuous press is currently being used in par ticleboard plants in the United States.
Primary finishing steps for all reconstituted wood pa nels include cooling or hot stacking, grading, trimming/cutting, and sanding. Cooling is important for UF-resin-cured boards since the resin degrades at high temperatures after curing. Boards bonded using PF resins may be hot-stacked to provide additional2-9 curing time. Secondary finishing steps include filling, painting, laminating, and edge finishing. The vast majority of manufacturers do not apply secondary finishes to their panels; panels are finished primarily by end-users such as cabinet and furniture manufacturers. Panels are also finished by laminators who then sell the finished panels to furniture and cabinet manufacturers.
Oriented Strandboard (OSB)
OSB is an engineered structural-use panel ma nufactured from thin wood strands bonded together with waterproof resin under heat and pressure. OS B manufacturing begins with debarked logs usually heated in soaking ponds sliced into wood strands typically measuring 4.5 to 6 inches long (114 to 152mm). Green strands are stored in wet bins and th en dried in a traditional triple-pass dryer, a singlepass dryer, a combination triple–pass/single-pass drye r, or a three-section dryer. A recent advance in drying technology is a continuous chain dryer, in whic h strands are laid between two chain mats so the strands are held in place as they move through the dryer.
After drying, blending and mat formation take pl ace, blending of strands with adhesive and wax takes place in separate rotating blenders for face and core strands. Different resin formulations are typically used for face and core layers. Face resi ns may be liquid or powdered phenolics, while core resins may be phenolics or isocyantes. Mat formers take on a number of confi gurations to align strands along the length and width of the panel. Oriented la yers of strands are dropped sequentially (face, core, face, for example), each by a different forming head. The mat is then transported by conveyer belt to the press. Hot pressing involves the compression of the loose layered mat of oriented strands under heat and pressure to cure the resin. Most plants utilize multi-opening presses that can form as many as sixteen 12- by 24-ft (3.7- by 7.3m) panels simultaneously. Recent development of a continuous press for OSB can consolidate the oriented and layer mat in 3 to 5 minutes.
Fiber Composites
Fiber composites include hardboard, medium-den sity fiberboard (MDF), fiberboard, and insulation board. In order to make fibers for th ese composites, bonds between the wood fibers must be broken. This is generally done through refining of the material, which involves grinding or shearing of the material into wood fibers as it is forced between rotating disks. Refining can be augmented by water soaking, steam cooking (digesting), or chemical treatments as well.
Fiber composites are classified by density and can involve either a wet process or a dry process. High and medium density boards, such as hardboard and MDF, apply a dry process. Wet processes can be used for high-density hardboard and low-density insulation board (fiberboard). Dry process involves adhesive-coated fibers that are dried in a tube dryer and air-laid into a mat for pressing.
Wet processes differ from the dry processes. This process involves the utilization of water as a distributing medium for fibers in a mat. Further di fferences lie in the lack of additional binding agents in some wet processes. The technology is very much like paper manufacturing in this pulp-based aspect. Natural bonding in the wood fibers occurs in this pr ocess. Refining in this process relies on developing material that can achieve this binding with a de gree of “freeness” for removal from mats. The wet process involves a continuously moving mesh screen, ont o which pulp flows. Water is drawn off through the screen and through a series of press rolls. The wet fiber mats are dried in a conveyor-type dryer as they move to the press. Wet process hardboard is then pressed in multi-open presses heated by steam. Fiberboard is not pressed.5 The descriptions in this section rely primarily on Chapter 11 of the USDA’s Forest Products Laboratory Wood Handbook (Moody and Liu, 1999).

2-10 Manufacturers use several treatments alone or together to increase dimensional stability and mechanical performance of both wet and dry process hardboards. Heat treatment exposes pressed fiberboard to dry heat, reducing water absorption and improving fiber bonding. Tempering is the heat treatment of pressed boards preceded by the addition of oil. Humidification is the addition of water to bring board moisture content into equilibrium with the air.

2.2.1.4 Structural Wood Members 5
Structural wood members, such as glue-laminated timbers and structural composite timber, are manufactured using a number of methods. Glue-laminat ed timber, or glulam, is an engineered product formed with two or more layers of lumber glued together in which the grain of all layers, called laminations, is oriented parallel to the length of the lumber. Glulam products also include lumber glued to panel products, such I-joists and box beams. Stru ctural composite lumber consists of small pieces of wood glued together into sizes common for solid-sawn lumber.
Glue-Laminated Timber (Glulam)
Glulam is a material that is made from suitably selected and prepared pieces of wood, either straight or curved, with the grain of all pieces essentia lly parallel to the longitudinal axis of the member. The manufacturing process for glulam involves four major steps: (1) drying and grading, (2) end jointing, (3) face bonding, and (4) finishing and fabricating.
Structural Composite Lumber
The are three major types of structural compos ite lumber: laminated veneer lumber, parallel strand lumber, and laminated strand lumber. Each is described in more detail below, however, the general manufacturing process for these composites is similar.
Laminated veneer lumber (LVL) is manufactured by laminating veneer with all plies parallel to the length. This process utilizes veneer 1/8 to 1/10 inches. (3.2 to 2.5 mm) thick, which are hot pressed with phenol-formaldehyde adhesive to form lumber of 8 to 60 feet (2.4 to 18.3 m) in length. The veneer used for LVL must be carefully selected to achieve the proper design characteristics. Ultrasonic testing is often used to sort veneer required for LVL. On ce the veneer has been sel ected, end jointing occurs followed by adhesive applica tion and continuous pressing.
Parallel strand lumber (PSL) is a composite of wood strand elements with wood fibers primarily oriented along the length of the member. PSL is manuf actured using veneer about 1/8 inch (3 mm) thick, which is then clipped into 3/4 inch (19 mm) wide strands. The process can utilize waste material from a plywood or LVL operation. Strands are coated with a waterproof structural adhesive, and oriented using special equipment to ensure proper placement and distribution. The pressing operation results in densification of the material. Adhesives are cure d using microwave technology. As with LVL, the continuous pressing method is used.
Laminated strand lumber (LSL) is produced using an extension of the technology used to produce oriented strandboard structural panels. LSL uses longer strands than those commonly used in OSB2-11 manufacturing. LSL is pressed into a billet several inches thick in a steam-injection press, as opposed to an OSB panel pressed in a multi-opening platen press. The product also requires a greater degree of alignment of the strands at higher pressures, which result in increased densification.
2.2.2 Products, By-Products, and Co-Products
Exhibit 2-3 presents products, corresponding SIC a nd NAICS codes, and product examples of the plywood and composite w ood products industry.
The plywood and composite wood products indus tries have unique manufacturing processes in their use of waste wood products as an input for add itional products. Planer shavings, sawdust, edgings, and other wood by-products are inputs to many wood composites. Structural wood members were developed in response to the increasing demand for hi gh quality lumber when it became difficult to obtain this type of lumber from forest resources. Theref ore, many of the by- and co-products from one process may be used in another.2-12 Exhibit 2-3: SIC and NAICS Codes and Products Product Description SIC NAICS Example Products

Softwood Veneer and Plywood 2436 321212 Panels, softwood plywood Plywood, softwood Softwood plywood composites Softwood veneer or plywood Veneer mills, softwood

Reconstituted Wood Products 2493 321219 Board, bagasse Flakeboard Hardboard Insulating siding, broad-mitse Insulation board, cellular fiber or hard pressed Lath, fiber Medium density fiberboard (MDF) Particleboard Reconstituted wood panels Strandboard, oriented Wafer-board Wall tile, fiberboard Wallboard, wood fiber

Structural Wood Members, Not Elsewhere Classified 2439 321213 Arches, glue-laminated or pre-engineered wood Fabricated structural wood members Finger joint lumber manufacturing I-joists, wood Laminated structural wood members Laminated veneer lumber Parallel strand lumber Structural wood members (except trusses) 321214 Floor trusses, wood, glue-l aminated or pre-engineered Roof trusses, wood, glue-l aminated or pre-engineered Source: U.S. Department of Labor, OSHA (no date).

Exhibit 2-4 provides ratios of specialization and coverage (product mix) calculated by the U.S. Census Bureau for the last three Censuses of Manufact urers. The Census assigns a “primary” SIC code to each establishment which corresponds to the SIC code for the largest (by value) single type of product shipped by the establishment. The products shipped from that establishment that are classified in the same industry as the establishment are considered “p rimary,” and all other products shipped by the establishment are considered “secondary.” The Census then calculates various measures to illustrate the product mix between primary and secondary products in each industry. The specialization ratio represents the ratio of total primary product shipme nts to total product shipments for all establishments classified in the industry. The coverage ratio repr esents the ratio of primary products shipped by the establishments classified in the industry to the total shipments of these products shipped by all establishments classified in all industries.2-13 As Exhibit 2-4 illustrates, all three industries ha ve specialization ratios well above 80 percent and coverage ratios above 90 percent. This implies that most establishments with these SIC codes are highly specialized, and that most product shipments of each type originate in establishments with these SIC codes. Therefore, the Census data on these SI C and NAICS industries provide information on the primary production of facilities engaged in plywood and composite wood products manufacturing. These ratios have been stable over time.

Exhibit 2-4: Specialization and Coverage Ratios, 1982 - 1997 SIC NAICS Description 1982 1987 1992 1997 2436 321212 Softwood Veneer and Plywood Primary products specialization ratio 87 87 84 88 Coverage ratio 96 95 94 95 2493 321219 Reconstituted Wood Products Primary products specialization ratio 96 97 96 97 Coverage ratio 97 95 95 97 2439 321213 Structural Wood Members, N.E.C./Engineered Wood Members Primary products specialization ratio 96 97 96 95 Coverage ratio 95 97 97 96 2439 321214 Structural Wood Members, N.E.C./Truss Manufacturing Primary products specialization ratio 96 97 96 96 Coverage ratio 95 97 97 94 Source: U.S. Department of Commerce (1999a and 1995b)

. 2.2.3 Costs of Production
Exhibit 2-5 provides information on the overall value of shipments (VOS) and production costs (a component of operating expenses) by SIC code as reporte d by the Bureau of the Census. Typical of many intermediate goods, the cost of materials is the largest portion of production costs, with payroll constituting 15-20 percent of VOS. In particular, timbe r supply plays a large role in industry costs. In this decade, reductions in public timber supply, especi ally reductions in National Forest timber harvests, combined with the economy’s continued demands for wood has led to substantial increases in the cost of timber (Spelter, 1997).2-14 Exhibit 2-5: Summary of Annual Costs and Shipments, 1992 -1997 (Thousands of 1997 Dollars) 1992 1993 1994 1995 1996 1997 % Change Softwood Veneer and Plywood (SIC 2436, NAICS 321212) Industry Shipments 7,321,641 6,400,683 6,755,571 7,725,037 6,525, 702 5,748,047 -21.5% Cost of Materials 4,169,048 3,671,638 4,097,921 4,736,984 4,330,167 3,795,985 -8.9% Fuels & Electricity 220,039 178, 592 178,601 183,507 176,759 161,239 -26.7% Payroll 1,112,158 897,839 883,819 1,047,092 1,006,792 912,613 -17.9% Ratio of Costs to Shipments 75% 74% 76% 77% 84% 85% Reconstituted Wood Products (SIC 2493, NAICS 321219) Industry Shipments 5,350,565 4,951,902 5,517,234 5,827,821 5,561,099 5,278,809 -1.3% Cost of Materials 2,400,670 2,144, 060 2,342,362 2,582,565 2, 697,471 2,633,139 9.7% Fuels & Electricity 327,706 250, 814 268,934 316,876 321,390 350,950 7.1% Payroll 825,718 699,627 707,179 810,753 855,237 798,767 -3.3% Ratio of Costs to Shipments 66% 62% 60% 64% 70% 72% Structural wood members (SIC 2439, NAICS 321213 and 321214) Industry Shipments 3,367,525 3,281,578 4,295,002 4,739,339 5, 096,809 5,112,873 51.8% Cost of Materials 1,958,576 1,966, 635 2,584,765 2,863,098 3, 154,297 3,007,103 53.5% Fuels & Electricity 35,486 33,406 34,585 39,595 42,621 42,090 18.6% Payroll 692,377 604,180 740,318 867,510 947,403 954,694 37.9% Ratio of Costs to Shipments 80% 79% 78% 80% 81% 78% All dollars adjusted to 1997 using Producer Price Index for Lumber and Wood Products (SIC 24). Source: U.S. Department of Census (1999a).
From these data, one can estimate the sector-wide ratio of production costs to VOS. The ratio of costs (materials, fuels and electricity, and payro ll) to the VOS has been increasing over the 1992 to 1997 period for softwood plywood and ven eer and reconstituted wood products. The data in Exhibit 2-5 show that 1997 cost to shipment ratios range between 72 percent (reconstituted w ood products) and 85 percent (softwood veneer and plywood). This measure indi cates the proportion of the revenues received for the goods produced that are associated with production expen ses (materials, fuel and electricity, and payroll). Figures 2-2 and 2-3 present cost and VOS data for the softwood plywood and reconstituted wood products industries, respectively.2-15 Figure 2-2: Softwood Plywood and Veneer Value of Shipments and Production Costs, 1992 - 1997

- 2,000,000 4,000,000 6,000,000 8,000,000Thousands of Dollars (1997)

1992 1993 1994 1995 1996 1997 

### Year VOS - Total Costs

Payroll

Fuels & Electricity

Cost of Materials

Source: U.S. Department of Commerce (1999a)

. Note: Total costs in this figure is the sum of payroll, fuels & electricity, and materials costs.2-16 Figure 2-3: Reconstituted Wood Products Value of Shipments and Production Costs, 1992 - 1997

- 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000Thousands of Dollars (1997)

1992 1993 1994 1995 1996 1997
Year VOS - Total Costs

Payroll

Fuels & Electricity

Cost of Materials

Source: U.S. Department of Commerce (1999a)

. Note: Total costs in this figure is the sum of payroll, fuels & electricity, and materials costs.
The cost to shipment ratio does not reflect other operating expenses such as non-payroll employment expenses, taxes, interest, or depreciati on. Nor does it indicate whether the expenses are of a variable or fixed nature. However, it does provide an approximate measure of how much cash, at a gross level, the industries are generating to cover all ope rating expenses, use for capital investment, and provide a return to owners. While this measure is somewhat crude, it indicates that the impacts of the rule may potentially be more significant for the softwood plyw ood and veneer industry than for reconstituted wood products.
Exhibit 2-6 and Exhibit 2-7 provide informati on on materials consumed by kind in 1997 for the three sectors. In softwood plywood and veneer manufacturing, 81.6 percent of material costs result from timber and veneer purchasing. Glues and adhesives re present 5.7 percent of the material costs in the softwood plywood and veneer industry.2-17 Exhibit 2-6: Materials Consumed By Kind for Softwood Plywood and Veneer, 1997

Materials Consumed Delivered Cost ($1,000)* % of Total Materials Stumpage cost (cost of timber, excluding land, cut and consumed at same establishment) 346,854 9.4% Hardwood logs and bolts 64,617 1.7% Softwood logs and bolts 2,218,800 60.0% Hardwood veneer 27,355 0.7% Softwood veneer 363,583 9.8% Glues and adhesives 210,105 5.7% All other materials 471,717 12.7% TOTAL 3,703,031 100% * Excludes costs of resales and contract work. Source: U.S. Department of Commerce (1999a).
Figure 2-4 shows the percentage materials cons umed by kind by the softwood plywood and veneer industry in 1997.
Figure 2-4: Materials Consumed by Softwood Plywood and Veneer Products, 1997

Softwood veneer 9.8%
Glues & adhesives 5.7%
All other materials 12.7% Softwood logs & bolts 60.0% Hardwood veneer 0.7%

Hardwood logs & bolts 1.7%

Stumpage cost 9.4%

Source: U.S. Department of Commerce (1999a)

.2-18 Exhibit 2-7: Materials Consumed by Kind for Reconstituted Wood Products, 1997
Material Consumed Delivered Cost ($1,000)* % of Total Materials Logs and bolts 80,891 3.2% Pulpwood 400,579 15.7% Chips, slabs, edgings, sawdust, and other wood waste, and planer shavings 399,446 15.7%

Hardboard, MDF, and particleboard 346,052 13.6% Paints, varnishes, lacquers, stains, shellacs, enamels, and allied products 69,488 2.7%

Adhesives and resins 548,553 21.5% Petroleum wax 61,173 2.4% Vinyl and paper overlays 101,405 4.0% All other materials, components parts, containers and supplies 538,183 21.2%

TOTAL 2,545,770 100% * Excludes costs of resales and contract work. Source: U.S. Department of Commerce (1999a).
As with the plywood industry, timber products are the largest portion of costs for the reconstituted wood product industry. Logs, pulpwood, wood material s, and other wood products account for a combined 48.2 percent of material costs. Unlike plywood and veneer manufacturing, reconstituted wood products have higher material costs for adhesiv es and resins, compromising 21.5 percent of costs. Figure 2-5 shows the percentage of materials c onsumed by kind by the reconstituted wood products industry for 1997.2-19 Figure 2-5: Materials Consumed by Reconstituted Wood Product Producers, 1997

Hardboard, MDF, & particleboard 13.6% Chips, slabs, edgings, sawdust, & other wood waste, & planner shavings

15.7%

Paints, varnishes, lacquers, stains, shellacs, enamels, & allied products 2.7% Adhesives & resins 21.5% All other materials, components' parts, containers & supplies 21.2% Pulpwood 15.7% Logs & bolts 3.2%

Vinyl & paper overlays 4.0%

Petroleum wax 2.4%

Source: U.S. Department of Commerce (1999a)

. Wood costs for plywood and composite wood pr oduct manufacturing vary according to plant location, wood species, and facility efficiency. Wh ile there may be considerable variability in wood prices across regions, the last decade has seen subs tantial increase in wood prices across all regions. Wood use efficiency depends on wood species used, log temperature, speed of cutting, board compaction, and other process variables. Next to wood, adhesiv es and wax play an important role in industry costs, especially for the production of reconstituted wood products such as OSB, particleboard, and MDF (Spelter et al, 1997).
In 1995, sixteen percent of the output from the adhesive and sealant industry, SIC 2891, went to the wood products market. As such, a MACT standard that greatly reduces the demand for adhesives and sealants (or coatings) could potentially have a signifi cant impact in the adhesive and sealant industry (Abt Associates Inc., 1997). The response on the part of the softwood plywood and veneer and reconstituted wood products industries will depend on the final requirements of the MACT standard and the attractiveness of comparable resin, adhesive and sealant products that do not contribute to HAP emissions. There will be many constraints on the ability of the impacted industries to switch away from current adhesives, as their products generally must m eet certain requirements related to building codes. These properties are discussed in the next section.2-20 2.3 The Demand Side
The following section contains information c oncerning the demand for plywood and veneer, reconstituted wood products, and stru ctural wood members. The characteristics of plywood and wood composites are examined first, highlighting the numerous uses of these types of wood products. The consumers and users of plywood and composite wood pr oducts are then examined, specifically analyzing the distribution of consumption. Substitution possibilities are addressed, looking at both wood and nonwood options. Lastly, the elasticities of demand of the plywood and composite wood products industries are discussed.

2.3.1 Product Characteristics
Plywood and composite wood produc ts provide a more stable product over solid wood by reducing the variations between wood species, among trees of the same species, and even between wood from the same tree. Unlike solid wood which is evaluate d at a cellular level, composite wood is evaluated at fiber, particle, flake, or veneer level. Properties of products can be changed by combining, reorganizing, or stratifying these different elements. Control of the size of particles used in producing composite wood products provides the chief mean s by which materials can be produced with predetermined properties (Youngquist, 1999).
Strength is a crucial factor in determining the applicability of plywood and composite wood products to structural and other manufacturing uses. Stiffness and strength properties of a wood product depend primarily on the constituents from which these products are made. The basic wood elements can be made in a great variety of sizes and shapes, and may utilize any number of wood species. Plywood can be manufactured from over 70 species of wood. The choices available for composite wood products are almost unlimited. Types of adhesives and bonding-ag ents also play an important role in the strength of a composite wood product.
Durability will also determine the market for co mposite wood products. Pa nels used for exterior applications will have a fully wa terproof bond and are designed for permanent exposure to weather and moisture. Interior panels may lack the waterproof bond and be manufactured w ith glue products designed for interior use.
Depending on the composite wood pr oduct, a range of sizes and thicknesses are available. The range of structural applications for which th ese products are used requires production of several standardized sizes as well as custom-made pieces. Sizes and thicknesses will depend on the type of wood composite product and the market for which it is primarily produced.
Wood panels and other composite wood structures are subject to performance-type standards as outlined by various industry organizations. A num ber of organizations including American Plywood Association - The Engineered Wood Association, Composite Panel Association (CPA), American Hardboard Association, and others monitor products produced by their member firms to assure highquality production and industry conformity with testing and performance standards.

2.3.2 Consumers and Uses
Exhibit 2-8 shows industry output by SIC code. Output of plywood and veneer goes mainly to the construction sector, primarily to the residential housing and repair industries. Almost one third of plywood goes to the manufacturing sector, part of which is used as an input for other plywood2-21 production, and part of which goes for furniture a nd other durable goods manufacturing. The “Other” category is made up of foreign trade, inventor y change, and wholesale trade. The outputs for reconstituted wood products, including particleboard, are more evenly split between construction and manufacturing, The “Other” category for reconstitute d wood products is made up of sales to state and local government, foreign trade, and services (Gale Business Resources, 1999).

Exhibit 2-8: Consumption of Industry Outputs, by SIC Code SIC SIC Description Construction Manufacturing Other 2436 Softwood veneer and plywood 63.5% 27.9% 8.6% 2493 Reconstituted wood products 45.7% 47.6% 6.7% 2439 Structural wood members 94.8% 0.6% 4.6% Source: Gale Business Resources (1999).
The major use of structural panel products is for construction activities. Pa nel products include those products such as plywood, OSB, particleboard, and others formed as a panel. These products may be used for floor systems, exterior walls, roofing, and exterior siding. Figure 2-6 shows the industry outputs by percentage for the softwood plywood and veneer industry.
Figure 2-6 Industry Outputs of Softwood Plywood and Veneer Industry

Manufacturing 27.9%

Other 8.6% Construction 63.5%

Source: Gale Business Resources (1999).2-22 Figure 2-7 shows the industry outputs by percenta ge for the reconstitute d wood products industry.
Figure 2-7: Industry Outputs of Reco nstituted Wood Products Industry

Manufacturing 47.6%

Other 6.7% Construction 45.7%

Source: Gale Business Resources (1999). MDF and particleboard are two produc ts of the reconstituted wood products industry. Exhibits 2-9 and 2- 10 below show the downstream uses of MDF and par ticleboard in 1997. For each of the products, about 20 percent of the output is used for household furn iture, and the remainder is used for construction, shelving, cabinetry and other customized applications.

Exhibit 2-9: MDF Shipments by Downstream Market, 1997 Downstream Use Million ft 2 Percent Household Furniture 247.8 19% Custom Laminators 208.6 16% Stocking Distributors 286.9 22% Kitchen and Bath 65.2 5% Molding 130.4 10% Millwork 65.2 5% Partitions and fixtures 65.2 5% All Other 182.6 14% Other (n.e.c.) 52.2 4% Total 1,304.0 100% Source: Composite Panel Association (1998).2-23 Exhibit 2-10: Particleboard Shipments by Downstream Market, 1997
Downstream Use Million ft 2 Percent Household Furniture 889.0 20% Custom Laminators 711.2 16% Stocking Distributors 755.7 17% Kitchen and Bath 711.2 16% Flooring Products 400.1 9% Office Furniture 266.7 6% Door Core 177.8 4% All Other 400.1 9% Other (n.e.c.) 133.4 3% Total 4,445.2 100% Source: Composite Panel Association (1998).

Construction Activities
Over sixty percent of the softwood plywood a nd veneer industry output and approximately 50 percent of the reconstituted wood products industry output goes to the construction sector, primarily to the construction, remodeling and repair of single a nd multiple family dwellings. The majority of the work performed by the construction sector is associ ated with single family dwellings, and the largest share of their costs is associated with materials su ch as wood-based materials. As Exhibit 2-11 shows, housing starts have been quite strong since 1996 and are expected to continue through at least this year. Housing start activity is closely linked to general economic conditions, employment, income, and interest rates. Renovation and remodeling e xpenditures have declined in real terms, as would be expected. Generally, more renovation and rem odeling takes place during periods when fewer new houses are being constructed (U.S. Department of Commerce, 1995a).

Exhibit 2-11: Housing Market Indicators, 1988 - 1997 Year New Housing Units (thousand) Renovation and Remodeling Expenditures (million current $) Renovation and Remodeling Expenditures (million 1992 $) 1988 1,706 101,117 110,874 1989 1,574 100,891 106,425 1990 1,381 106,773 109,175 1991 1,185 97,528 98,813 1992 1,411 103,734 103,734 1993 1,542 108,304 104,339 1994 1,761 115,030 106,411 1995 1,694 111,683 99,362 1996 1,838 114,919 99,756 1997 1,828 118,423 99,431 Source: Howard (1999).2-24 Because economic conditions can vary between regi ons in the U.S., the impact of housing starts on demand for wood-based construction materials can vary . This regional variation is further amplified by differing local preferences, housing codes, a nd availability of specific wood-based products.
Wood Furniture Industry
The wood furniture industry produces output for a high value added market. Exhibit 2-12 below shows the value of shipments from the household furn iture sector. Wood household furniture is a portion of this sector. Domestic shipments and appare nt consumption of household wood furniture have experienced modest growth since 1989, indicating that the shipments from the softwood plywood and veneer and reconstituted wood products industries to the furniture sector has had limited experience for growth.

Exhibit 2-12: Trade for Househ old Furniture (SIC 251), 1989 -1996 (Millions of 1997 Dollars)*

1989 1990 1991 1992 1993 1994 1995 1996 % Change Value of product shipments 23,056 22,477 21,521 21,949 22,823 24,038 24,355 na 6 Value of imports 3,301 3,200 3,117 3,368 3,723 4,201 4,586 5,047 53 Value of exports 565 884 1,091 1,252 1,298 1,385 1,361 1,342 237 Apparent Consumption 25,792 24, 793 23,547 24,065 25,248 26,854 27,580 na 7 *Values adjusted to 1997 dollars using PPI for Furniture and Household Durables Source: U.S. Department of Commerce (1999a).
Wood furniture manufacturers constitute a large porti on of the demand, 20 to 30 percent, of the woodbased products other than structural panels and struct ural members. Much of the growth in retail demand is being met by imports. This translates into a larg e lost opportunity for domestic furniture manufacturers, as well as for their suppliers, including the industries th at are the subject of this profile. The potential causes for this increase in imports are lower material and labor costs in exporting countries, and declining availability of timber products to domestic producers (CINTRAFOR, 1999 and Dirks, 1991).
The 1992 Census of Manufacturers showed that 21 pe rcent of the delivered cost of materials in the manufacture of wood household furniture is asso ciated with plywood and composite wood products. As a result, significant price changes in the cost of plywood and composite wood products have the potential to affect production costs of wood house hold furniture. As the demand for wood household furniture is highly elastic with respect to price (see discussion in section 2.3.4), increased input costs could affect both the demand for wood household furniture and for plywood and composite wood products supplied to furniture manufacturers.

2.3.3 Substitution Possibilities

The basic substitution in these industries is between different wood products, although non-wood substitutes exist as well for some applications. Co mposite wood products were originally manufactured in response to the growing demand for wood products as the availability of larger sized timber declined. As new wood composites products were developed, they further replaced sawn lumber and other types of wood products. Plywood and veneer production lost market share during the late 1980s and early 1990s2-25 to new products that are categorized as recons tituted wood products, largely as a result of several challenges: legislation protecting federal timber lands; recession in the early 1990s; price increases and instability; and supply shortages. To provide an i ndication of the structural uses of wood panel products and substitutes, Exhibit 2-13 outlines the use of vari ous products in new single-family and multi-family residential construction in the United States.2-26 Exhibit 2-13: Use of Wood and Non-wood Products in Residential Construction 1976 - 1995

Application Incidence of Use (%) Single-family houses Multi-family houses 1976 1988 1995 1976 1988 1995 Floor Sheathing Lumber 1 5 - 2 6 - Structural Panels 51 56 55 51 52 54 Softwood Plywood 51 48 31 51 46 24 OSB 0 9 24 0 7 30 Nonstructural Panels 12 9 9 10 9 7 Lightweight Concrete 0 0 0 5 7 3 Concrete Slab 30 30 35 32 26 36 Exterior Wall Sheathing Lumber - 2 - - - - Structural Panels 16 33 52 17 40 43 Softwood Plywood 16 26 19 17 28 10 OSB 0 7 33 0 12 33 Fiberboard 34 13 6 32 11 5 Foamed Plastic 7 22 29 2 18 34 Foil-faced kraft - 17 3 0 13 1 Gypsum, other 18 8 2 18 15 8 None 25 5 8 31 5 9 Roof Sheathing Lumber 14 6 1 11 2 1 Structural Panels 85 91 98 87 94 94 Softwood Plywood 84 70 37 87 78 19 OSB 1 21 61 1 16 75 Other 1 3 0 2 4 5 Exterior Siding Lumber 10 12 7 9 16 2 Structural Panels 22 23 9 32 15 4 Softwood Plywood 22 23 4 32 15 2 OSB - - 5 0 - 2 Hardboard 16 16 6 7 11 5 Non-wood 52 49 77 49 58 89 Vinyl 14 15 29 12 14 41 Masonry, stucco 38 34 48 37 44 48 Other 0 0 1 3 - - Source: Spelter et al. (1997).

Structural wood panels hold the majority of the market share for floor, exterior wall, and roof sheathing in single and multi-family housing construction. The majo r substitution effect in this market has occurred between OSB and softwood plywood, with OSB capturing much of the market from softwood plywood by 1995. Much of the trade-off between softwood plywood and OSB is due to lower cost for OSB.2-27 However, questions of exterior durability with OS B have led many builders to continue plywood use despite higher initial costs.

Fiberboard has also seen reduction in market sh are for exterior wall systems due to increases in OSB use. Non-wood products, mainly masonry, have captured 77 percent of the market for exterior siding, greatly reducing the market share of structur al panels in this market. Other major substitutes include concrete slab for floor sheathing and foamed plastic, which gained major shares of the exterior wall sheathing market from wood-based structural panels.

2.3.4 Demand Elasticities
The price elasticity of demand is the percentage change in the quantity of product demanded by consumers divided by the percentage change in price. Demand curves slope downward, signifying a negative response (less demand) to an increase in price. If demand is elastic (an absolute value of greater than one) a small price increase will lead to a relativ ely large decrease in demand. Conversely, if demand is inelastic with respect to price, or an absolu te value less than one, the quantity demanded will change very little relative to a change in price.
For the purposes of performing an economic analysis, short-term price elasticities are relevant as impacts of the regulation fall directly on the entities owning facilities faced with compliance responsibilities. In appropriating compliance costs to facilities impacted by this rule, the economic analysis assumes that these facilities have a fixed capita l stock in the short term. This method allows an evaluation of the severity of impacts using static measures of profit and loss. This short-term analysis approach, which is described in more detail in Chap ter 4, differs from other behavioral approaches that take into account adjustments made by producers, such as changing input mixes, that can generally affect the market environment in which they operate over the longer term.
In the case of plywood and reconstituted wood pr oduction that is going to the construction industry, the overall price elasticity of demand for th ese products is relatively inelastic. This is because the wood product component of constr uction is fixed once the decision to construct has been made. The other factors that contribute to the inelastic nature of demand for structural wood panels include local building codes, home buyer and home owner preferences, and building industry investment in the training and infrastructure required to construct w ith wood panels as opposed to a substitute.
The demand for each individual type of product may differ, depending on several factors, including the product’s own-price elasticity, the ava ilability and price of other wood based and non-wood products with comparable characteristics, and the ava ilability and price of imported products. Cross price elasticities are often difficult to identify or estimate. However, if available, cross price elasticities of substitutes and imports might be considered when deve loping an approach to the economic analysis. For example, analysis of the softwood plywood market ma y incorporate the cross-price elasticity of OSB, a major substitute for plywood. When analyzing the OSB market, the converse would also be true. Even if such cross price elasticities were available, other considerations would also determine whether the economic analysis incorporates the market substitution dynamic.
We examined several recent and historical studies of price elasticities of demand. Most of these studies were concerned with the softwood lumber sect or, most likely due to the limited availability of relevant price and consumption information at a di saggregated product level. Our review focused on the 1996 study by Joseph Buongiorno, a forestry economist, who noted that previous econometric studies of the wood products sector have produced estimates of demand elasticities for softwood lumber, a product6 The majority of studies reviewed estimated price el asticity of demand as being between -0.15 and -0.4.

2-28 with similar demand drivers, inputs, input costs, and uses, between zero and -0.9 6 . Buongiorno also reported that other studies have estimated the cross elasticity of lumber with respect to the price of plywood to be between 0.5 and zero. Buongiorno developed a model using a price-endogenous linear programming system (PELPS) that endeavored to address the entire wood products market using a system dynamics approach. The results of this model incl uded short-term price elasticities of demand for woodbased products, as shown in Exhibit 2-14.

Exhibit 2-14: Demand Elasticities Product Price Elasticity of Demand Plywood -0.16

Fiberboard -0.10

Particleboard -0.27 Source: Buongiorno (1996 ).

Buongiorno’s results provide the basis for imputi ng price elasticities for the other products that are the subject of this MACT standard. In add ition, further review of identified studies may produce information useful in the final determination of appr opriate elasticities for use in the economic analysis of the impacts of a MACT standard on the softw ood plywood and reconstituted wood products industries.
In the case of softwood plywood and recons tituted wood production going to the furniture industry, the price elasticity of demand is highly elastic . This is because the price elasticity of demand for wood furniture is highly elastic itself and the softwood plywood and recons tituted wood component of production costs for wood furniture is also quite high, over twenty percent. The EPA’s study of the economic impacts of alternative NESHAPS on the w ood furniture industry estimated the price elasticity of demand for wood furniture as -3.477 (U.S. EPA, 1992). This result forms the basis for a derived price elasticity of demand for use in the economic analysis of the impacts of the MACT standard.

2.4 Industry Organization
The following section contains information pert aining to the organization of the plywood and veneer, composite wood , and structural wood member s industries. This section will provide the basis for understanding the following.
• The industry structure • The characteristics of the manufacturing facilities • The characteristics of the firms that own the manufacturing facilities
A detailed examination of these three topics is essen tial, as it provides the basis for much of the approach to estimating economic impacts of the MACT standard. In addition, this section also provides detailed information about facilities and firms that are important inputs to the analysis itself as well as to analysis of how the MACT standard might affect firms of different sizes.2-29 2.4.1 Industry Structure
Exhibit 2-15 shows concentration ratios by SIC code for the three census years, 1982, 1987, and 1992. The m-firm concentration ratios are equal to th e sum of the market shares for the largest m number of firms in the industry. A market is generally cons idered highly concentrated if the 4-firm concentration ratio is greater than 50 percent. Exhibit 2-15 also shows the Herfindahl-Hirschman (HH) index, which is an alternative measure of concentration equal to th e sum of the squares of the market shares for the 50 largest firms in the industry. The higher the index, th e more concentrated the industry is at the top. The U.S. Justice Department uses 1,000 as a benchmark fo r the presence of market concentration, where any industry with a Herfindahl-Hirschman index less than 1,000 is considered to be unconcentrated (Arnold, 1989).

Exhibit 2-15: Concentration Ratios by SIC Code, 1982-1992*

Year Number of Companies in Industry Percent of value of industry shipments shipped by the largest (in terms of shipment value) HerfindahlHirschman Index** 4 Companies 8 Companies 20 Companies 50 Companies Softwood Veneer and Plywood (SIC 2436)

1982 135 41 56 74 92 619 1987 131 38 56 74 93 571 1992 123 47 66 82 96 797 Reconstituted Wood Products (SIC 2493)

1982 N/A 1987 158 48 65 82 95 743 1992 193 50 66 81 94 765 Structural wood members (SIC 2439)

1982 649 15 22 35 50 104 1987 831 13 18 30 44 92 1992 830 19 25 34 46 166 *The latest year for which data is currently available. **The index is based on the 50 largest companies in each SIC code. Source: U.S. Department of Commerce (1992).
The concentration ratios presented in Exhib it 2-15 show very little evidence of market concentration in the plywood and composite wood products industries. Four-firm concentration ratios for the three sectors are below 50 with the exception of reconstituted wood products (classified as “General” in the ICR survey) which is 50. The HH indices for all SIC codes are well below the benchmark of 1000. While concentration appears to have increased in general between 1982 and 1992, there is no clear trend as all appear to have been less concentrated in 1987.
2.4.2 Manufacturing Plants
Through an ICR, the U.S. Environmental Protection Agency identified plants potentially affected by this rule. EPA categorized the surveyed facilities according to their production processes and developed estimates of compliance costs for each fac ility. Exhibit 2-16 below presents information on the7 Map developed based on original survey database dated July 23, 1999.

2-30 number of potentially impacted facilities, and thei r corresponding primary SIC code. The exhibit also shows the percent of potentially impacted fac ilities as a percent of total facilities for each SIC.

Exhibit 2-16: Facilities with Compliance Cost Impacts Facilities SIC Code Description Impacted* Total in SIC % of Total 2436 Softwood Veneer and Plywood 66 155 42.6%

2493 Reconstituted Wood Products Total 97 317 30.6% OSB 23 PB/MDF 56 HB 18 2439 Structural Wood Members 3 53 5.7% * Does not include number of facilities with MRR costs only. Note: Percentages represent survey facilities’ share of total facilities in the category. Sources: U.S. Environmental Protection Agency ( 1998), U.S. Department of Commerce (1999a), MRI (1999).

2.4.2.1 Location
Nationally, facilities that produce softwood plywood and reconstitute d wood products are clustered in distinct geographic regions of the Sout h, Pacific Northwest, and the upper Mid-West of the U.S. Based on the 1997 Census of Manufacturers, the softwood plywood and veneer facilities have the highest employment in Oregon, Washington and Louisi ana. The Census showed that reconstituted wood product facilities had the highest employment in Oregon, California, North Carolina, Texas, and Michigan (source: U.S. Department of Commerce, 1999a).
Figure 2-8 7 is a map of locations of impacted and total ICR facilities as identified by EPA (MRI, 1999, EPA, 1998). For this figure, all types of facilities are combined. The map shows the state-by-state distribution of the potentially impacted facilities relative to the total ICR facilities in the state. The states with the greatest number of potentially impacted facilities are Oregon (36), Louisiana (16), Georgia (8), Mississippi (7), Virginia (10), Texas (8), and Nort h Carolina (7). Major producing states where impacted facilities constitute a significant portion of all facilities in the state include Louisiana (66 percent), Oregon (57 percent), Washington (77 percent), Geor gia (38 percent) and Texas (44 percent).2-318 of 184 of 54 of 121 of 10 of 10 of 15 of 70 of 11 of 10 of 11 of 10 of 15 of 1236 of 630 of 12 of 58 of 211 of 110 of 133 of 252 of 126 of 200 of 60 of 30 of 57 of 417 of163 of 114 of132 of 616 of240 of1710 of 256 of 150 of 30 of 2Impacted Facilities01 - 910 - 1819 - 2728 - 36StatesFigure 2-8: Plywood and Wood Composite Facility Locations(Potentially Impacted Facilities and Total ICR Facilities by State)Sources: U.S. Environmental Protection Agency (1998), MRI (1999)2-32 2.4.2.2 Production Capacity and Utilization
Exhibit 2-17 shows the capacity utilization rates by SIC code and for all manufacturing industries for 1992 through 1997. The rates for softwood plywood and veneer, and recons tituted wood products are significantly higher than the average for all lumber and wood products and for a ll industries. Capacity utilization for structural wood members is below industry averages but has increased over the 1992 - 1997 period.

Exhibit 2-17: Full Production Capacity Utilization Rates, Fourth Quarters, 1992 - 1997 SIC SIC Description 1992 1993 1994 1995 1996 1997 Change

2436 Softwood Veneer and Plywood 87 92 95 95 86 84 -3.4%
2493 Reconstituted Wood Products 87 92 92 88 86 82 -5.7%
2439 Structural Wood Members 65 66 66 74 77 72 10.8%

24 All Lumber and Wood Products 80 81 80 77 78 75 -6.3% 2000-3999 All Manufacturing Industries 77 78 80 76 76 75 -2.3% Source: U.S. Department of Commerce (1997).
Figure 2-9 presents the capacity utilization rates of softwood plywood and ven eer and reconstituted wood products from 1992-1997.
Figure 2-9: Full Production Capacity Utilization, Fourth Quarters, 1992-1997

1992 1994 1996 74 76 78 80 82 84 86 88 90 92 94 96Utilization Rate(percent)

Year 

### Softwood, plywood &
veneer

Reconstituted wood products

Source: U.S. Department of Commerce (1997).
The capacity utilization for softwood plywood and veneer, and reconstituted wood peaked in 1994, consistent with utilization peaks for all manufacturi ng industries. Interestingly, utilization rates for reconstituted wood product facilities declined, while softwood plywood and veneer was unchanged in2-33 1995, the year that shows the highest value of shipments for all (see Exhibit 2-17). This may be explained, in part, by capacity expansions driv en by the increased capital expenditures by softwood plywood and veneer producers in 1994 and subsequent years.
The ICR provided further information on capacity utilization. A sample of general facilities responding to questions regarding their production processes reported production and capacity. From this data, capacity utilization for general facilities was 78 pe rcent, slightly below the figures in Exhibit 2-17
2.4.2.3 Employment
Exhibit 2-18 provides information on employment at the softwood plywood veneer and reconstituted wood products faciliti es responding to the ICR in 1998.

Exhibit 2-18a: 1998 Employment at Facilitie s with Expected Comp liance Cost Impacts

Softwood Plywood and Veneer Oriented Strandboard Medium Density Fiberboard/ Particleboard

Number of Employees Facilities in Size Category % of All Impacted Facilities Facilities in Size Category % of All Impacted Facilities Facilities in Size Category % of All Impacted Facilities Not reporting 2 3.0% 0 0.0% 0 0.0% <50 0 0.0% 0 0.0% 1 1.8% 50 to 99 0 0.0% 0 0.0% 12 21.4% 100 to 249 18 27.3% 21 91.3% 30 53.6% 250 to 499 34 51.5% 1 4.3% 2 3.6% 500 to 999 11 16.7% 1 4.3% 8 14.3% 1,000 to 1,499 1 1.5% 0 0.0% 2 3.6% >1,500 0 0.0% 0 0.0% 1 1.8% TOTAL 66 100% 23 100% 56 100% Sources: U.S. Environmental Prot ection Agency (1998), MRI (1999).

Exhibit 2-18b: 1998 Employment at Facilitie s with Expected Comp liance Cost Impacts

Hardboard Engineered Wood Products Total Facilities

Number of Employees Facilities in Size Category % of All Impacted Facilities Facilities in Size Category % of All Impacted Facilities Facilities in Size Category % of All Impacted Facilities Not reporting 0 0.0% 0 0.0% 2 1.2% <50 0 0.0% 0 0.0% 1 0.6% 50 to 99 1 5.6% 0 0.0% 13 8.0% 100 to 249 8 44.4% 1 33.3% 77 47.2% 250 to 499 4 22.2% 2 66.7% 41 25.1% 500 to 999 5 27.8% 0 0.0% 25 15.3% 1,000 to 1,499 0 0.0% 0 0.0% 3 1.8% >1,500 0 0.0% 0 0.0% 1 0.6% TOTAL 18 100% 3 100% 166 100% Sources: U.S. Environmental Prot ection Agency (1998), MRI (1999).2-34 Potentially impacted facilities engaged in the production of plywood and composite wood products tend to be small- to medium-sized. Just over half of the facilities reported having less than 250 employees. Softwood plywood producers tend to ha ve larger facilities, while facilities producing reconstituted wood products tend to be smaller.
2.4.2.4 Facility Population Trends
Plant age may be of particular significance to potential regulatory impacts. Older plants may be less efficient as compared with newer plants utilizing technological improvements in production efficiency. One example mentioned earlier is the development of the continuous press, enabling recently constructed plants to produce more panel products in less time than older manufacturers. Newer plants may utilize better volatile organic compound emissi on control technologies and have adapted their processes to meet indoor air quality requirements.
While specific age information for all facilities is not available, an analysis performed by Spelter et al. (Spelter, 1997) provides insights into the ch anging nature of plywood a nd composite wood facilities over time. In their analysis, they traced the number of mills, average mill capacity, and capacity utilization over the course of 20 or more years. The analysis does not present information on specific plant closures and openings over time, but presents th e total number of operating mills, which reflects the net change resulting from both closures and openings. Exhibit 2-19 provides information on the results of the analysis for selected years from 1977 to 1997, us ing census years to provide some comparison to overall industry figures presented elsewhere in this chapter.2-35 Exhibit 2-19: Number of Mills, Average Capacity and Utilization, 1977 - 1997 1977 1982 1987 1992 1997 % Change Softwood Plywood
Number of Mills 62 69 58 56 57 -8% Average Mill Capacity (1000 m 3 ) 110 138 180 201 215 95% Capacity Utilization 97 79 99 95 97 0%
Oriented Strandboard
Number of Mills 8 21 39 44 66 725% Average Mill Capacity (1000 m 3 ) 88 115 148 187 259 194% Capacity Utilization 44 90 99 84 91%
Particleboard
Number of Mills 54 43 44 45 45 -17% Average Mill Capacity (1000 m 3 ) 137 151 168 181 196 43% Capacity Utilization 86 87 89 89 97 13% Medium-density Fiberboard
Number of Mills 12 13 17 17 26 117% Average Mill Capacity (1000 m 3 ) 95 105 122 141 151 59% Capacity Utilization 69 66 87 91 86 25%
Laminated Veneer Lumber
Number of Mills 2 6 12 17 750% Average Mill Capacity (million m 3 ) 0.078 0.075 0.063 0.085 9% Capacity Utilization 73 60 75 93 27% Engineered Joists
Number of Mills 12 12 18 35 192% Average Mill Capacity (million meters) 3459 200% Capacity Utilization 69 73 90 58 -16% *Information not available for some years. For softwood plywood, particleboard, and MDF, 1997 figures are from 1996. For particleboard, 1984 figures are used for 1982. Source: Spelter et al. (1997).
Average facility capacity has shown substantia l increases over the last twenty years for all product groups. While the number of softwood plyw ood facilities declined by 8 percent between 1977 and 1997, the average mill capacity increased substan tially, nearly 100 percent. Particleboard has experienced some capacity growth while the number of plants has declined.
The OSB industry has shown the largest increase in per facility capacity, 194 percent, along with large net additions of facilities. Most notably, ther e were nine more OSB plants than softwood plywood plants in 1997, whereas in 1977 plywood plants outnumbe red OSB plants nearly 8 to one. Recent facility additions for OSB and MDF show these sectors have newer facilities, while the softwood plywood and particleboard industries are generally composed of older facilities.2-36 A review of recent capital investment trends provides some insights into the facility population trends of the softwood plywood and reconstituted w ood products industries. Exhibit 2-20 shows capital expenditures by industry sector. Capital expenditur es have seen substantial overall increases in the last five years for all three sectors, indicating increasing investment, particularly in the reconstituted wood product and structural wood members sectors. However, investment by the softwood plywood and veneer and reconstituted wood products sectors declin ed sharply from 1996 to 1997. This trend indicates the connection between declining capital expenditures and the sharp increase in products costs’ share of the value of shipments (as shown in Exhibit 2-5) that began after 1995. If such conditions in the baseline continue into the future, it is possible that cer tain firms may experience difficulty accessing capital to cover these costs in addition to compliance costs associated with the MACT standard.

Exhibit 2-20: Summary of Capital Expenditures, 1992 - 1997 (Thousands of 1997 Dollars) 1992 1993 1994 1995 1996 1997 % Change Softwood Plywood & Veneer 110,125 128,490 159,685 192,090 212,277 168,142 52.7% Reconstituted Wood Products 159,330 185,452 353,665 367,057 583,659 329,744 107.0% Structural Wood Members* 47,420 70,659 220,523 143,523 108,889 138,880 192.9% All dollars adjusted to 1997 using GDP Deflator. * 1997 figure is sum of capital expenditures for NAICS 321213 and 321214. Source: U.S. Department of Commerce (1999a).
For softwood plywood, the level of capital investme nt constitutes only 3 percent of the industry’s total value of shipments. With the number of m ills in decline and average mill capacity growing, it appears that the majority of capital expenditures made by the softwood plywood industry occur at existing plants. This c onclusion is supported by U.S. Industry & Trade Outlook ‘99 , which reported that only one new softwood plywood facility has opened in the last 10 years (U.S. Department of Commerce, International Trade Administration, 1999).
Conversely, results of the growing capital inv estments made by the reconstituted wood products industry can be observed in the large increases in the number of OSB and MDF plants, and the rising average plant capacities of reconstituted wood products producers. As a group, these producers invested 6 percent of the value of shipments in 1997, twice the investment rate of the softwood plywood producers. For example, in September of 1999, Willamette Industries announced that it will build an $85 million particleboard plant in South Carolina. The plant will have a capacity of 210 million square feet per year and will be in operation in late 2001.

2.4.3 Firm Characteristics
Several factors will likely be of importance in de termining the distribution of impacts generated by the proposed MACT standard on companies. Size ma y play a role in a company’s ability to absorb an increase in compliance costs. Ownership is a second factor that may play a role. Because firms have different legal and financial guide lines based on ownership, their approaches to complying with the MACT standard may vary. Vertical and horizontal integration, or lack there of, in plywood and composite wood product firms may affect the manner in which they absorb the potential costs of the MACT standard. Lastly, the overall financial cond ition of the plywood and composite wood industries is assessed, attempting to determine the industry’ s ability to withstand adverse conditions.2-37 2.4.3.1 Size Distribution
Firm size is likely to be a factor in the dist ribution of the impacts of the proposed MACT on companies. Under the Regulatory Flexibility Act (RFA) and its 1996 amendment, SBREFA, SBA definitions are used to designate which businesses are considered to be small. The SBA has set size standards under the NAICS system, using various thr esholds for the number of employees or revenues. In determining the size of a company, the SBA treats a facility that has a substantial portion of its assets and/or liabilities shared with a parent company as part of that company. In this analysis, the company’s primary NAICS code is used to dete rmine the appropriate SBA threshold.
Exhibit 2-21 provides information on firm size for plywood and wood composite firms owning facilities with expected compliance cost impacts. In the ICR, facilities were asked to provide information on employment size for domestic parent firms. Many facilities did not report information on the ultimate domestic parent . For this reason, information on ultimate domestic parent primary SIC and NAICS code and employment size were obtained from Dun and Brad street’s DUNS Database. Exhibit 2-21 shows the number of firms and the facilities owned by the firms in the first two data columns. In the absence of Dun & Bradstreet information on the owner, the f acility’s primary SIC and NAICS code from Dun & Bradstreet was used to determine the appropriate SBA threshold. Based on this SIC code, facility employment information from the ICR was used to ma ke a size determination. Exhibit 2-21 shows the number of firms and the facilities owned by the firms in the third and fourth data columns. In the absence of facility primary SIC code from DUNS, the standa rd for lumber and wood products (all SIC 24 codes) of 500 employees was used as the threshold. A full list of the facilities and their size determination is provided in the economic impact analysis for this proposed rule.

Exhibit 2-21: Size Distribution of Firms Owning Facilities with Expected Compliance Cost Impacts

Size SIC Based on DUNS SIC Based on ICR Other Sources Total

Firms Facilities Owned by

Firms* Firms Facilities Owned by

Firms* Firms Facilities Owned by

Firms* Firms % Facilities Owned by

Firms* %

Small 8 10 5 5 6 7 19 35.2% 22 8.4% Large 29 231 4 8 2 2 35 64.8% 241 91.6% Total 37 241 9 13 8 9 54 100% 263 100% * Includes all facilities reported, impacted and non-impacted. Sources: U.S. Environmental Protection Agency (1998) , MRI (1999). SBA Size Standards from SBA website: http://www.sba.gov/regul ations/siccodes/.
While over 35 percent of firms in the industry ar e considered small, 91 percent of facilities are owned by large firms. Given the concentration ratio s presented in Exhibit 2-15, there does not appear to be any significant market power to these larger firms. However, the ability of larger firms to deal with compliance costs, as compared to smaller firms, may have impacts on the industry organization.
The larger parent firms have both impacted and non-impacted facilities. Firms such as GeorgiaPacific (43 ICR facilities), Louisiana-Pacific (32 ICR facilities), Willamette Industries (23 ICR facilities), Columbia Forest Products (13 ICR facilities), Weyerhaeuser (19 ICR facilities), and Boise-Cascade (12 ICR facilities) may be able to make trade-offs be tween facilities and shift production to more efficient facilities in response to compliance cost s associated with the MACT standard.2-38 2.4.3.2 Ownership
The form of firm ownership has a set of legal and financial characteristics that may influence a firm’s regulatory compliance alternatives. The lega l form of ownership impacts the cost of capital, availability of capital, and effective tax rate faced by the firm. Debt-equity issues for these firm types will play a role in financing capital-intensive controls. Firm ownership may generally be one of three types.
• Sole proprietorships (companies with a private single-owner) • Partnerships (non-corporate firms with more than one owner) • Corporations (publically or privately ow ned companies formed through incorporation)
Exhibit 2-22 provides information on ownership ty pe for the lumber and wood products industry. While specific information by 4-digit SIC or 5-digit NAICS is not available, the table provides a general sense of ownership types in the industry, assuming th at ownership structure for the three industries profiled is similar to that of the ove rall lumber and wood products industry.

Exhibit 2-22: Types of Firm Ownership for Lumber and Wood Products (SIC 24/NAICS 321), 1992

Corporation Sole Proprietorship Partnerships Other/ Unknown Single-Facility Firms 1,291 14,909 Multi-Facility Firms 17,617 61 All Firms 18,908 10,447 2,336 2,187 Source: U.S. Dept. of Commerce (1992).
Over ninety percent of single facility wood and lumber products firms are owned by sole proprietorships, partnerships, or some other/unknown entity. Nearly all multi-facility firms are owned by corporations. Just over half of a ll lumber and wood products firms are a corporation, while the remainder are sole proprietorships (30 percent) , partnerships (7 percent), or othe r (6 percent). These data support the conclusion that single-facility firms owned by sole pr oprietors are more likely to be classified as small businesses, while multi-facility firms owned by corporations are more likely to be classified as large businesses.
2.4.3.3 Vertical and Horizontal Integration
The data presented in Section 2.2 on concentra tion and specialization ratios for the plywood and composite wood industries, combined with the in formation on establishment size and ownership type demonstrate that the majority of firms in the three industries examined in this profile are predominantly not, or minimally, vertically or horizontally integrated. However, there are several exceptions to this conclusion. The six largest firms that own multiple facilities are for the most part both vertically and horizontally integrated. These firms, described in more detail below, are large multi-billion dollar concerns that are vertically integrated through th eir ownership of timberland, their production facilities, and their involvement in product distribution. Their horizontal integration is attributed to their other product lines, generally pulp and paper.
Georgia-Pacific, a large, horizontally and vertically integrated firm, manufactures and distributes building products, pulp and paper, and resins. The company’s wood product line includes wood panels, plywood, and hardboard. It also produces lumber, gyps um products, chemicals, and packaging. GeorgiaPacific grows and sells timber, and participates in sev eral other activities related to forestry management. Its 1998 net sales revenues exceeded $13 billion, and it has 45,000 employees at 400 locations. Its building products division reported r ecord profits during the second quarter of 1999. It currently has2-39 plans to build an OSB plant in Arkansas and recen tly merged with Unisource, a major distributor of imaging paper and supply systems (Financial Times, 1999b; PR NewsWire, 1999b).
Louisiana-Pacific is principally a manufacturer of building products, but also produces pulp and building insulation, and owns almost one million acres of timberland. Its sales of structural lumber, industrial panels, and exterior bu ilding products made up nearly 75 percent of the company’s revenues, which reached $2.3 billion in 1998. The company manufactures OSB, I-joists, LVL, MDF, fiberboard, particleboard, hardboard, softwood plywood and hardwood veneer. Louisiana-Pacific has been involved in a series of mergers and acquisitions that include Le Goupe Forex of Cana da, Evans Forest Products, and ABT Building Products (Louisiana-Pacific, 1999; Financial Times, 1999c).
Willamette Industries, a forest products manufacturing company, has three main lines of business: brown paper, white paper, and building products. The building products division manufactures plywood, lumber, particleboard, MDF, OSB, LVL and I-joists, among others. Approximately one third of the company’s $3.7 billion in total revenue is from its building materials segment. Most of Willamette’s recent merger and acquisition activity has been with fi rms in France and Mexico. It also owns plants in Ireland and 1.8 million acres of timberland in the U. S. (Financial Times, 1999d; PR NewsWire, 1999c, 1998, 1997).

Columbia Forest Products describes itself as Nort h America’s largest manufacturer of hardwood veneer, and laminated products. They sell their products through a network of wholesale distributors, mass merchandisers and major original equipment manufacturers (OEMs). Their products include decorative, interior veneers and panels used in hi gh-end cabinetry, fine furniture, architectural millwork and commercial fixtures. Columbia Forest Products is an employee-owned company with 13 plants in the U.S. and four in Canada (Columbia Forest Products, 1999).
Weyerhaeuser is an integrated international forest products company. It is involved in growing and harvesting timber, and the manufacturing and dist ributing of several categories of forest products. Among its wood products are plywood, OSB, and wood composites. The company bills itself as the world’s largest private owner of saleable softwood tim ber and the country’s largest producer of softwood lumber and pulp. In addition, it is the top U. S. exporter of forest products. The company has approximately 36,000 U.S. and Canadian employees a nd sales of $11 billion, ten percent of which comes from exports (Weyerhaeuser, 1999).
Boise Cascade, an integrated international pape r and forest products company, manufactures and distributes paper and wood products, distributes office products and building materials, and owns and manages over 2 million acres of timberland. Its building products include lumber, plywood, particleboard, veneer, and engineer ed wood products. Sales of these pr oducts constitute 27 percent of the company’s $6.2 billion annual revenue (Fin ancial Times, 1999a; PR NewsWire, 1999a).

2.4.3.4 Financial Condition
The financial condition of an industry’s firms will affect the incidence of impacts of the costs associated with complying with a new MACT standa rd. While information necessary to determine which specific firms might experience adverse impacts is not available, one can examine industry-wide indicators of financial condition. Each year, Dun & Bradstreet (D&B) publishes Industry Norms & Key Business Ratios , which reports certain financial ratios for a sam ple of firms in the industry. This section focuses on measures of profitability and solvency.2-40 Profitability Ratios
The return on sales ratio, also known as the net profit margin, is an indicator of a firm’s ability to withstand adverse conditions such as falling prices, ri sing costs, and declining sales, and is calculated by dividing net profit after taxes by annual net sales.
Return on assets is calculated by dividing a firm’s net profit after taxes by its total assets. This ratio is a key indicator of both profitability and opera ting efficiency by comparing operating profits to the assets available to earn a return. According to Dun & Bradstreet, companies that use their assets efficiently will have a relatively higher return on assets than those firms that do not use their assets efficiently.
The return on equity shows the profitability of the company’s operations to owners, after income taxes, and is calculated by dividing net profit after ta xes by net worth. According to Dun & Bradstreet, this ratio is looked to as a ‘final criterion’ of profitab ility, and a ratio of at least 10 is regarded as desirable for providing dividends plus funds for future growth.
Solvency Ratios
The current ratio is calculated by dividing a firm’s current assets by its current liabilities. This is a measure of liquidity that gauges the ability of a comp any to cover its short-term liabilities. The standard guideline for financial health is 2. The quick ratio is slightly different than the current ratio, because it does not include inventories, advances on inventories, marketable securities, or notes receivables. The quick ratio measures the protection afforded creditors in cash or near-cash assets. Any time this ratio is 1 or greater, the firm is said to be in a liquid condition.

Exhibit 2-23 shows various measures of the fi nancial condition of the plywood and composite wood industry over the period 1995 to 1997. The trends shown in Exhibit 2-23 confirm that the softwood plywood and reconstituted wood products industries have experienced a profit squeeze due to increasing costs and falling prices in recent years.

Exhibit 2-23: Indicators of Financial Condition, 1995-1997 *

Indicator Softwood Plywood and Veneer Reconstituted Wood Products Structural Wood Members 1995 1996 1997 1995 1996 1997 1998 Return on Sales 5.8 3.6 1.7 3.8 3.1 3.5 5.0 Return on Assets 15.7 13.5 6.0 7.8 5.9 3.5 13.0 Return on Equity 28.7 22.9 8.7 15.2 10.0 5.7 NA Current Ratio 3.2 2.6 2.7 2.8 2.7 1.7 2.3

Quick Ratio 1.1 1.3 1.2 1.8 1.2 1.1 1.3
*Includes 1998 data for Structural Wood Member s, the only data reported for this sector. Source: Dun & Bradstreet (1999). Indicator values ar e based on median values of the industrial sample. For SIC 2436, there were 14 establishments in the sample in 1995, 15 in 1996, and 11 in 1997. For SIC 2493, there were 28 establishments in the sample in 1995, 30 in 1996, and 31 in 1997. For SIC 2439, there were 135 establishments in 1998.
The softwood plywood and veneer industry has not maintained its relatively strong degree of financial health, with many of its profitability i ndicators significantly lower in 1997 than in 1995. In particular, the softwood plywood and veneer industry experienced 60 to 70 percent declines in all three profitability ratios. The falling profitability of this industry is now at a level that indicates the presence of firms that are not using their assets efficiently, are not providing the cash needed for future growth, and2-41 may more acutely experience adverse conditions associat ed with MACT standard compliance costs. The currently low net profit margin is indicative of an industry that is experiencing increasing production costs as a percentage of its value of shipments a nd falling capacity utilization (Exhibits 2-5 and 2-18).
The reconstituted wood products industry also saw fairly dramatic decreases in its financial indicators over the time period shown, resulting in a relatively low return on assets and return on equity, as well as a current ratio lower than generally consid ered healthy. These indicators are consistent with recent trends in the industry associated with in creases in production costs relative to the value of shipments (Exhibit 2-5), rapid expansion of produc tion capacity (Exhibit 2-20) and competitive pressures on prices from overseas producers. This industry also includes firms that are not using their assets efficiently or providing the cash needed for future growth. The reconstitute d wood products industry’s profit margin is also somewhat low, but typical of all firms in the lumber and wood products sector (Dun and Bradstreet, 1999b).
In the fall 1999 issue of Engineered Wood Produc ts Journal, industry analyst Evadna Lynn discussed investor response to the industry’s current financial performance (APA, 1999c). Lynn attributes several recent trends to stockholde r pressure for improved financial performance.
• Separating timber assets • Corporate restructuring • Cost control through consolidation
These trends have contributed to a dynamic market st ructure in recent years. By selling or otherwise spinning off timber assets, forest products companies are converting them to cash and improving financial performance. Restructuring activities have focu sed on gaining higher returns from core business activities through the closure or divestiture of less profitable facilities or products. Some of the divested facilities, particularly plywood mills, have been re opened by new owners as sawmills. The industry has seen several major corporate mergers and acquisiti ons in the late 1990s, including: Weyerhaeuser and MacMillan Bloedel, International Paper and Union Ca mp, and Louisiana Pacific and Le Groupe Forex (of Canada). Most post-merger cost reductions are ga ined from streamlining operations, including closure of production facilities (APA, 1999c; International Paper, 1998).

2.5 Markets
This chapter discusses general market conditi ons for the plywood and composite wood products industries. In particular, this chapter discusses ma rket structure, provide background on current market volumes, prices, and international trade. It also presents information on future market volumes, prices and international trade. The purpose of this chapter is to describe the current status of the industry and to support the development and implementation of the econom ic impact analysis that is summarized in this RIA.

2.5.1 Market Structure
Based on the data, background and analyses reviewed while preparing this industry profile, it is reasonable to conclude that these industries exhibit clear signs of a competitive market for the products that are the subject of this MACT standard. There are several reasons for this conclusion. First, as discussed in section 2.4.2, the plywood and compos ite wood products industries are unconcentrated. There is little concentration of market power evid enced by each separate industrial category having a 4- firm concentration ratio of 50 or below (often well below) and HH indices below the 1000 benchmark. Next, the output of several of the production sectors are substitutes for each other, putting competitive pressures on suppliers. There are also competitive pr essures from alternative products, either traditional sawn lumber or non-wood materials. This chapter w ill focus on other factors of the competitive nature of8 1995 is the latest year for which data is available.

2-42 these industries. For the most part, the markets for these goods also experience competitive pressures by the presence of imported products. Finally, several i ndustry experts have observed trends where prices of the products respond negatively to the presence of ex cess capacity. The remainder of this chapter will provide additional details related to these observations on industry competitiveness.

2.5.2 Market Volumes
This section will present a discussion of market consumption and production volumes for the three industrial sectors examined in this study. For the most part, this discussion will rely on the data contained in Exhibit 2-24 and Exhibit 2-25. Exhibit 2-24 show s the value of product shipments by product class for the period 1989 to 1995 8 as reported by the International Trade Administration of the U.S. Department of Commerce. Note that value of shipments data for St ructural Wood Members is not available for inclusion in this table. Exhibit 2-25 shows the physical vol ume of output produced, traded and consumed between 1988 and 1997 for selected products as reported by Spe lter et al. in their 1997 statistical report. International trade is discussed later in the section.

Exhibit 2-24: Trade Balance and Select ed Statistics, Thousands of 1997 Dollars

1989 1990 1991 1992 1993 1994 1995 % Change Softwood Veneer and Plywood (SIC 2436, NAICS 321212) Value of product shipments 7,125 6,887 6,185 6,422 5,643 5,885 6,671 -6% Value of imports 81 69 55 79 82 100 111 37% Value of exports 452 509 428 452 391 333 375 -17% Trade Surplus (Deficit) 371 440 373 372 310 234 263 -29% Apparent Consumption 6,755 6, 447 5,812 6,050 5,333 5,651 6,407 -5% Ratio of Imports to Consumption 0.01 0.01 0.01 0.01 0.02 0.02 0.02 45% Ratio of Export to Product Shipments 0.06 0.07 0.07 0.07 0.07 0.06 0.06 -11% Ratio of Imports to Exports 0.18 0.14 0.13 0.18 0.21 0.30 0.30 65% Reconstituted Wood Products (SIC 2493, NAICS 321219) Value of product shipments 5, 013 4,761 4,743 5,359 4,940 5,511 5,772 15% Value of imports 461 409 364 540 616 861 1,080 134% Value of exports 261 334 350 328 271 301 345 32% Trade Surplus (Deficit) (200) (75) (14) (212) (345) (560) (735) 268% Apparent Consumption 5,213 4,836 4,757 5,572 5,285 6,070 6,507 25% Ratio of Imports to Consumption 0.09 0.08 0.08 0.10 0.12 0.14 0.17 88% Ratio of Export to Product Shipments 0.05 0.07 0.07 0.06 0.05 0.05 0.06 15% Ratio of Imports to Exports 1.76 1.22 1.04 1.65 2.27 2.86 3.13 77% Source: U.S. Department of Commerce, International Trade Administration (1998).2-43Exhibit 2-25: Production, Trade and Consumption Volumes for Selected Products (1988-1997)1988 1989 1990 1991 1992 1993 1994 1995 1996 1997%ChangeSoftwood Plywood(M ft3, 3/8 in basis)Product shipments 22,089 21,385 20,919 18,652 19,332 19,315 19,368 19,367 19,181 17,963 -19%Imports 96 49 38 28 47 41 47 60 85 104 8%Exports 1,004 1,442 1,613 1,322 1,442 1,409 1,211 1,267 1,248 1,548 54%Apparent Consumption 21,181 19,991 19,34417,358 17,937 17,946 18,474 18,160 18,018 16,519 -22%Other Structural Panels(M ft3, 3/8 in basis)Product shipments 4,604 5,105 5,418 5,613 6,653 7,002 7,486 7,903 9,314 10,534 129%Imports 815 1,111 1,313 988 1,5722,163 2,588 3,214 4,414 5,272 547%Exports 57 49 60 78 82 157 167 193%*Apparent Consumption 5,416 6,213 6,728 6,544 8,176 9,105 9,995 11,036 13,572 15,639 189%Particleboard/Medium Density Fiberboard(M ft3, 3/4 in basis)Product shipments 4,768 4,828 4,856 4,730 5,046 5,402 5,793 5,307 5,705 5,916 24%Imports 1,634 425 363 293 405 572 775 840 814 963 -41%Exports 163 333 373 369 394 318 297 319 154 188 15%Apparent Consumption 6,239 4,920 4,746 4,654 5,057 5,656 6,271 5,828 6,365 6,691 7%Hardboard(M ft3, 1/8 in basis)Product shipments 5,118 5,196 5,025 4,895 5,273 5,248 5,206 4,930 5,280 4,501 -12%Imports 633 718 689 571 571 639 1,119 1,152 1,183 1,306 106%Exports 322 427 552 606 836 917 1,190 1,377 1,426 1,259 291%Apparent Consumption 5,429 5,487 5,1624,860 5,008 4,970 5,135 4,705 5,037 4,548 -16%Source: Spelter et al. (1997).* since 19912-44 2.5.2.1 Domestic Production
As Exhibit 2-24 shows, the value of shipment s (representing production) of softwood plywood and veneer was slightly lower in 1995 than it was in 1989. During the period, production reached its lowest level in 1993 and then began to climb, in res ponse to meeting demand from rising expenditures for renovation and remodeling and new housing starts. The value of shipments of reconstituted wood products rose 15 percent between 1989 and 1995, linked to the underlying growth in the construction sector and the growth in market share of structural panel products over softwood plywood.
Figure 2-10 compares the value of product shipments of softwood plywood and veneer to reconstituted wood products from 1989-1995.
Figure 2-10: Value of Product Shipments, 1989-1995

1989 1990 1991 1992 1993 1994 1995 - 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,0001997 Dollars ($1,000,000)

Year 

### Softwood plywood &
veneer

Reconstituted wood products

Source: U.S. Department of Commerce, International Trade Administration (1998).
Trends in product shipments by volume (Exhibit 2-25) have been mixed for this group of industries. A statistical report produced by the U.S. Forest Se rvice’s Forest Products Laboratory (Spelter et al., 1997) focused on production of softwood plywood, Other Structural Panels (OSB and waferboard), particleboard and MDF as a group, a nd hardboard. Production by the Ot her Structural Panels category experienced high growth during the period, with 1997 production almost 130 percent greater than it was in 1988. Most of this increase can be attributed to the rapid increase in OSB’s share of the structural panel market in recent years. Particleboard a nd MDF production grew a moderate 24 percent, while production of softwood plywood and ha rdboard declined by 19 percent and 12 percent respectively. Historically, softwood plywood production made a c ontinuous steady climb through the late 1980's. At that point, the product began losing market share to OSB and production leveled off. This trend was accompanied by a certain amount of mill attrition (Spelter et al., 1997).
2.5.2.2 Domestic Consumption2-45 Domestic, or apparent, consumption is the sum of domestic production and imports, less exports. The dollar value of apparent consump tion (Exhibit 2-25) for softwood plywood and veneer was slightly lower in 1995 than it was in 1989. During the period, demand for softwood plywood and veneer dropped slightly in the early 1990s and reached its lowest le vel in 1993 and then began to climb. The value of domestic consumption of recons tituted wood products followed a si milar pattern, increasing by 25 percent overall between 1989 and 1995. Drivers of c onsumption trends described here are the same as those presented in the previous section on producti on (increased demand for renovation, remodeling and new housing starts).
Figure 2-11 compares the apparent consumption of softwood plywood and veneer to reconstituted wood products from 1989-1995.
Figure 2-11: Apparent Consumption, 1989-1995

1989 1990 1991 1992 1993 1994 1995 0 1,000 2,000 3,000 4,000 5,000 6,000 7,0001997 Dollars ($1,000,000)

Year Softwood plywood &
veneer

Reconstituted wood products

Source: U.S. Department of Commerce, International Trade Administration (1998)
Further examination of consumption volumes (Exhib it 2-25) shows the following trends for softwood plywood, other structural panels, partic leboard and MDF as a group, and hardboard.
• By volume, apparent consumption of softwood plywood fell by over 20 percent in the last 10 years. • At the same time, consumption of other structural panels increased by almost 200 percent. • Particleboard and MDF were consumed at a sli ghtly higher level in 1997 than they were in 1988, following a decline that ended in 1992. • Hardboard consumption has fluctuated during th e same 10 years, with a 16 percent decline from 1988.2-46 Demand for softwood plywood and OSB combined experi enced an annual average growth rate of 2-3 percent from 1970 to 1996 (Spelter et al., 1997). Most of this demand was met by increased production of OSB by both domestic and imported producers.

2.5.2.3 International Trade
Imports
Import value trends during the 1989-1995 period (Exhi bit 2-24) show the constant dollar value of softwood plywood and veneer imports grew by 37 percen t, particularly during the later years when the price for the commodity was rising rapidly and supplies of timber were declining. The ratio of imports to consumption of softwood plywood and veneer, while only 0.02, grew by 45 percent. The trade surplus for softwood plywood and veneer fell by 37 percent. Imports of reconstitute d wood products more than doubled from 1989 to 1995 and the value of imports’ shar e of consumption grew by almost 90 percent and the trade deficit nearly quadrupled.
Looking at import volumes (Exhibit 2-25) for so ftwood plywood, other structural panels, particleboard and MDF as a group, a nd hardboard, imports have made the biggest gains in the other structural panel category, taking advantage of the overall growth in demand for those products. Imports now supply over a third of the other structural panel ma rket. Imports of hardboard have also grown, more than doubling in volume since 1988. There was a slight increase in imports of softwood plywood over the 10 years, and a decline of 40 percent in imports of particleboard and MDF. Exhibit 2-26 shows U.S. imports of by major region and trading partner.

Exhibit 2-26: 1997 U.S. Wood Products Imports by Region and Major Trading Partner

Trade Areas Value* ($millions) Share NAFTA 8,128 85.1
Latin America 541 5.7 Western Europe 234 2.5 Japan/Chinese Economic Areas 35 0.4
Other Asia 458 4.8
Rest of World 150 1.6 World Total 9,554 100.0

Top 5 Countries Canada 7,991 83.6
Indonesia 340 3.6
Brazil 303 3.2
Mexico 137 1.4
Chile 108 1.1 *Includes Sawmills (SIC 2421), Softwood Plywood and Veneer (SIC 2436), Reconstituted Wood Products (2435), and Hardwood Plywood and Veneer (SIC 2435). Source: U.S. Department of Commerce, International Trade Administration (1999).2-47 Exhibit 2-26 shows that a vast majority, 85.1 per cent, of U.S. imported wood products originated in the North American Free Trade Agreement (NAFTA) tr ade zone, of which only 1.5 percent originates in Mexico. The U.S. is also importing a significantly greater value of wood products than it is exporting. In 1997 the U.S. exported about $3,683 million of wood products while it imported $9,554 million.
Imports of softwood plywood and veneer grew by 24 percent from 1996 to 1997. Seventy-seven percent of U.S. softwood plywood and veneer imports are from Canada. This gr owth is consistent with the strong demand for softwood plywood and veneer during this period. The overall penetration of imports into the U.S. market is quite small (2 percent) , which is attributed to the efficiency and low costs of U.S. softwood plywood and veneer producers (U.S . Department of Commerce, International Trade Administration, 1999).
Imports of reconstituted wood pr oducts grew by seven percent from 1996 to 1997. Seventy-eight percent of U.S. reconstituted wood products imports are from Canada. The overall penetration of imports into the U.S. market is significant (18 percent), which is attributed to recent capacity additions by Canadian reconstituted wood products producers (U.S. Department of Commerce, International Trade Administration, 1999).

Exports
Export trends during the 1989-1995 period (Exhibit 2- 24) show the value of softwood plywood and veneer exports fell by 17 percent, particularly dur ing the later years when the price for the commodity was rising rapidly and supplies of timber were dec lining. Economic crises in several Asian economies and the falling value of the Canadian dollar relative to the U.S. dollar played a role in this trend. The ratio of exports to value of shipments of softw ood plywood and veneer fell by 11 percent. Exports of reconstituted wood products grew by 32 percent from 1989 to 1995 and the proportion of exports to shipments grew by almost 15 percent.
Export volumes (Exhibit 2-25) of hardboard qua drupled between 1988 to 1997, and constitute a significant portion of the total shipments from this industry. Exports of softwood plywood grew by 50 percent, and have become an increasingly important part of the sector’s overall production. While total exports of other structural panels grew signifi cantly, this market still remains a small portion of production. Exports of partic leboard and MDF grew significan tly through 1992 but have dropped steadily in recent years and are now just 15 percent hi gher than they were seven years ago. Exhibit 2-27 shows U.S. exports by majo r region and trading partner.2-48 Exhibit 2-27: 1997 U.S. Wood Product Exports by Region and Major Trading Partner

Trade Areas Value* ($millions) Share NAFTA 1,001 27.5
Latin America 203 5.6 Western Europe 1,230 33.8 Japan/Chinese Economic Areas 837 23.0
Other Asia 205 5.6
Rest of World 161 4.4 World Total 3,638 100.0

Top 5 Countries
Canada 800 22.0 Japan 636 17.5 Germany 292 8.0 United Kingdom 244 6.7
Mexico 202 5.5 *Includes Sawmills (SIC 2421), Softwood Plywood and Veneer (SIC 2436), Reconstituted Wood Products (SIC 2493), and Hardwood Plywood and Veneer (SIC 2435). Source: U.S. Department of Commerce, International Trade Administration (1999).
By region, the U.S. exports its largest share ( 33.8 percent) of wood products to Western Europe. However, no single country in Europe imports the mo st significant share of U.S. wood products. Canada imports the largest share, 22 percent, due to two reasons. First, Canada’s economy has strengthened. Second, on January 1, 1998 Canada co mpleted its final stage of tariff removal as directed under the U.S.- Canada Free Trade Agreement. For the two af orementioned reasons, U.S. wood product exports to Canada increased 21 percent to $800 million in 1997 (U .S. Department of Commerce, International Trade Administration, 1999).
Continued growth in U.S. expor ts of wood products is dependent on an As ian economic revival, particularly in Japan’s economy. In 1996, prior to the economic crisis, Japan was the largest importer of U.S. wood products. By 1997, Japan’s share of U. S. wood product exports fell to 17 percent, a 24 percent decrease from the previous year. To further exacerbate the problem, U.S. exports to Japan are expected to decline an additional 30 percent in 1998 and 1999. Japan has undertaken several steps to revitalize its economy, such as the implementati on of the Enhanced Initiative on Deregulation and Competition Policy. However, an increase in the Jap anese consumption tax from 3 percent to 5 percent in 1996 is believed to have canceled out the potentia l gains of the Policy, resulting in the expected continuing decline in Japanese demand for U.S. plywood and wood products (U.S. Department of Commerce, International Trade Administration, 1999).
In 1997, exports of softwood plywood and veneer accounted for about 10.6 percent of wood product exports from the U.S. This was a 24 percent increase from the previous year, raising the total value of softwood plywood and veneer exports to $392 million, th e highest level in eight years. Exports to the United Kingdom, Canada, and Germany, the top three importers of U.S. softwood plywood and veneer, experienced strong gains in 1997. A healthy Eur opean market has increased the demand for softwood plywood and veneer. In particular, the construc tion sector throughout Europe has seen an increase in2-49 activity. However, the recent strong performance of softwood plywood and veneer is not expected to continue due to an increasing international accepta nce of OSB, and increasing competition from Canada, Brazil, and Indonesia (U.S. Department of Comme rce, International Trade Administration, 1999).
Reconstituted wood products account ed for about 9.75 percent of U.S. wood product exports in 1997. Both the value and volume of reconstitute d wood product exports increased by 15 percent from the previous year. Canada, the United Kingdom, Mexi co, and Japan are the largest export markets for U.S. reconstituted wood. The continuing increase in exports is mainly attributable to a growing international acceptance of OSB. Exports are expected to continue to grow in the upcoming years, but at a slower rate than they did in 1997 (U.S. Departme nt of Commerce, International Trade Administration, 1999).

2.5.3 Prices
An index of the change in producer prices for lu mber and wood products is shown below in Exhibit 2-28 This index was compiled by the Bureau of Labor Statistics.

Exhibit 2-28: Lumber and Wood Products Producer Price Index, 1988-1997 (1982 = 100) 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 88-97 Lumber and wood

products (SIC 24) 122.1 125.7 124.6 124.9 144.7 183.4 188.4 173.4 179.8 194.5

Change from Previous year 2.9% -0.9% 0.2% 15.9% 26.7% 2.7% -8.0% 3.7% 8.2% 59.3%

Source: U.S. Bureau of Labor Statistics (1999).
The biggest annual price increases for lumber a nd wood products occurred in 1992 and 1993 and the overall price increase between 1988 and 1997 was nearly 60 percent. Another source, the Forest Products Laboratory (FPL), that is part of the U.S. Department of Agriculture, provides a statistical report with disaggregated price indices presented in E xhibit 2-29. Note that the base year of the BLS index is 1982 while the base year for the FPL data is 1992.

Exhibit 2-29: Producer Price Indices of Plywood and Composite Wood Products (1992 =100) Year 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 88-97 Softwood Plywood 74.2 84.5 81.4 82.2 100.0 115.4 120.3 128.0 118.3 119.3

Change from Previous year 0000000001

Particleboard 103.4 106.0 96.7 96. 5 100.0 114.8 128.5 128.4 123.3 117.6 Change from Previous year 0000000000

Hardboard 100.8 100.9 98.6 96.7 100.0 106.5 109.1 113.2 115.8 119.0 Change from Previous year 0000000000
Source: Howard (1999).2-50 Softwood plywood experienced the biggest price increase, 61 percent over the 1988 to 1997 period, with volatile price changes within the period w ith the biggest annual increases came in 1992 and 1993. Overall prices for particleboard rose 14 percent, but the large price increases in 1993 and 1994 have been offset by price declines in the last three years pr esented. Hardboard prices grew by 18 percent, with mostly steady annual price increases from 1994 on.

The market conditions and the factors that aff ect softwood plywood prices, supply and demand are somewhat analogous to those that affect prices for so ftwood lumber. For example, the cost of timber and transportation, foreign supply and demand, inventory levels as well as construction-driven demand are factors that affect market prices for softwood lumber, as well as softwood plywood and other structural panels.
A recent study produced by WEFA (Wharton Economic Forecast Associates) on trends in the softwood lumber market provides some clues about th e future of the three industries examined here. Softwood lumber prices have climbed steadily sin ce November of 1998. This climb included some higher than expected price increases in the early su mmer of this year. The WEFA report cites strong domestic demand related to hous ing construction as one underlying cause of the price increases in softwood lumber. Current price conditions are par tially explained by the expectation that housing demand has peaked while remaining strong, exports to Asia will increase as those economies recover, and imports from Canada will decrease.
For the most part, the WEFA report indicates that the construction industry has responded to climbing prices by switching to “just-in-time” buyi ng of products. Buyers are hoping that prices will begin falling and are postponing inve ntory build-up during this period of climbing prices. Another short-run factor affecting prices during the second quarter of this year was a constraint on truck and rail transportation availability. WEFA concludes that th e market has reached equilibrium for the moment, although this could change if inventories increase at the same time that construction-driven demand levels off or falls (WEFA, 1999).
Exhibit 2-30 presents the industry-reported free on board (f.o.b.) prices of southern plywood, OSB and particleboard from 1989 to 1996. These are the pr oduct prices prior to shipping costs and distributor mark-ups. On an adjusted basis, these prices reflect the trends demonstrated in the previous exhibit, with large price increases during early 1992, falling back to or below 1989 levels by 1996.2-51 Exhibit 2-30: F.O.B. Prices of Southern plywood, OSB, and Particleboard ($ per cubic meter) Year Southern plywood OSB Particleboard As Reported Adjusted $1997 As Reported Adjusted $1997 As Reported Adjusted $1997 1989 184 229 166 206 129 160 1990 168 200 124 148 122 145 1991 175 201 144 165 120 138 1992 226 252 208 232 129 144 1993 257 279 227 247 152 165 1994 274 291 252 268 171 182 1995 267 277 242 251 173 180 1996 231 235 184 187 165 168 89-96 2.8% -10.1% 4.5% Prices adjusted by the GDP deflator. Source: Spelter, et al. (1997).
Softwood Plywood
Long-term price trend data presented in the report “Review of the Wood Panel Sector in the U.S.” showed a fairly stable price pattern for softw ood plywood between 1977 and 1991. At that point, prices increased steadily from 1992 to their peak in 1994. Prices declined over 15 percent from 1994 to 1996. The report authors observe that with softwood plyw ood prices at their current high levels, producers will have a difficult time competing against the newer, mo re cost effective OSB producers. However, the authors note that softwood plywood producers may be able to hang on to market share and justify the higher prices by differentiating their product as a pr emium construction material (Spelter et al., 1997).

Oriented Strand Board

The “Review of the Wood Panel Sector in the U. S.” report presents OSB price data over time that shows a 27 percent decline in price during 1995 a nd 1996, after a continuous trend of price increases since 1977. The report’s authors attribute this weak ening to a rapid increase in capacity that contributed to an increase in production, putting downward pressu re on prices. Due to the ability of users to substitute plywood for OSB, these low OSB prices have only added to the growing market share enjoyed by OSB. Falling prices have cut into the net revenues of OSB producers, after a period from 1992 to 1995 where the industry enjoyed excellent cost/pri ce margins, drawing more investment to OSB production capacity (Spelter et al., 1997).

Particleboard
Particleboard price data from 1984 to 1992 presente d in the report, “Review of the Wood Panel Sector in the U.S.” show some variation within a relatively small range, with a substantial price increase in the years 1993 to 1995, declining slightly in 1996. The price trend for particleboard from 1977 to 1996 is very similar to that of plywood. One reas on for this similarity is the close relationship of particleboard input costs to the plywood manufact uring industry. About 25 percent of industry production cost is for wood inputs, which are prim arily made up of wastes from lumber and plywood production (Spelter et al., 1997).2-52 Medium Density Fiberboard (MDF)
Producer-reported MDF prices were $235 per ton in September of 1996 and declined by 15 percent to $205 per ton as of April, 1997. Despite this drop, there continues to be a price gap between MDF and less costly particleboard, although increasingly narro w. The price drop was attributed to MDF production capacity expansions that resulted in an increase in supply, putting pressure on the profits of MDF producers (Spelter et al., 1997).

Structural Wood Members
Producer-reported prices for I-joists reach a high in 1994 and have been declining since that time. Recent price conditions have made I-joists more co mpetitive with traditional 2" by 10" lumber on an installed cost basis, typically for floor framing appli cations. In particular, I-joists are price competitive with lumber when lumber prices are high. Howeve r, precise estimates of market prices are difficult to obtain. The authors found that prices varied de pending on whether the product was being sold under a brand name, on sale, or under a volume discount. Lami nated veneer lumber, presented in the Review at $550/m 3 f.o.b., is generally more expensive than 2" by 10" lumber, and is used mostly for structural applications or as an input to I-joists (Spelter et al., 1997).

2.5.4 Market Forecasts
Production and Consumption
A study published by WEFA in the summer of 1999 examined housing starts and concluded that housing starts will decline throughout 1999, resulti ng in a decline in lumber demand (WEFA, 1999). However, housing starts continue to remain strong well into 1999, keeping demand for lumber and other wood products for construction strong as well. The WEFA study also noted that another factor affecting demand for softwood lumber is interest rates and c oncluded that rising interest rates could have a dampening effect on demand. Higher interest rat es will not only affect the affordability of new homes, but also will curtail purchases of existing homes and mortgage refinancing activity, both major sources of demand for materials used in home remodeling. Based on the relationship between housing starts, purchases of existing homes, and remodeling and renovation (the construction-based demand for plywood and other products examined in this profile), this decline in demand can be expected to affect the plywood and composite wood industries, as 60 to 70 percent of their output goes to the construction sector. WEFA expects the industry to experience most of this decline in 2000 (WEFA, 1999).
The most recent wood products market outlook published by APA - The Engineered Wood Association (APA) shows U.S. housing starts exceed ing expectations in 1999 (APA, 1999d). Similar to the WEFA study, the forecast expects higher interest rat es in the future to play a role in reducing future housing demand in the period from 2000 to 2002. The report also forecasts the same trends for residential improvements and repairs, but notes the long-term outlook for remodeling to be good as home ownership increases. Figure 2-12 below provides information from the APA on U.S. housing starts. The APA forecast also reports the industr ial outlook is good for other wood-consuming sectors. The APA expects demand for furniture and fixtures to re main healthy, but not at peak levels as existing home sales will be declining from the current peak ra tes. Nonresidential construction is forecasted to peak in 1999 and 2000 with declines in 2001 and 2002. Increased school construction will be a driving factor in the upward trend for nonr esidential construction (APA, 1999d).9 While the report does not specify whether the forecast is exclusively for softwood plywood or includes hardwood plywood, it is assumed to cover softwood plywood only, as hardwood plywood is typically not used for structural panels.

2-53 

### 0 500 1000 1500 2000

1997 1998 1999 2000 2001 2002
US Single Family US Multi-Family Figure 2-12: APA Projected Housing Starts (000s)

Source: APA (1999d).
In addition to providing overall forecasts for the market demand, the APA outlook includes detailed forecasts of the demand for and production of struct ural panels, specifically softwood plywood and OSB. 9 These forecasts, summarized in Exhibit 2-31, show the demand from each of the major markets for structural panels, in order of their share of ma rket demand: new residentia l construction, remodeling, industrial uses including furniture and materials, nonr esidential construction, a nd foreign demand. The industrial use category will have the largest dom estic demand increase over the forecast period, 8 percent. Foreign demand shows significant increase of 78 percent. However, reductions in U.S. production as imports gain a large market share point to increased pressure from imports.

Exhibit 2-31: APA Forecasted Structural Panel Production and Demand (million sq. ft. 3/8" basis) 1999 2000 2001 2002 % Change New Residential 18,415 17,715 17,585 18,435 0.00 Remodeling 7,440 7,440 7,475 7,550 1% Industrial/Other 6,575 6,720 6,875 7,085 8% Nonresidential 3,800 3,800 3,735 3,670 -3% Domestic Demand 36,230 35,675 35,670 36,740 1% Foreign Demand 990 1,275 1,705 1,760 78% Total Demand 37,220.00 36,950.00 37,375.00 38,500.00 3% Imports (Canada only) (7,345) (7,400) (8,300) (9,330) 27% Total Domestic Production 29,875.00 29,550.00 29,075.00 29,170.00 -2% Plywood 18,135 17,450 16,575 16,295 -10% OSB 11,740 12,100 12,500 12,875 10% Source: APA (1999d).2-54 The APA forecasts for panel capacity and producti on provide additional insight into substitution between softwood plywood and OSB. Exhibit 2-32 below shows these projected trends. Softwood plywood shows significant decreases in capacity (dow n 24 percent) and production (down 16 percent) from 1992 to 2002. Meanwhile, OSB has shown significant increases in capacity and production and is projected to continue to capture the market for structural panels. The relatively constant capacity utilization in the plywood sector with significant decreases in production supports the forecast of expected plant closures in the future, while the oppos ite is true for OSB with expected increases in the number of facilities.

Exhibit 2-32: APA Actual and Forecasted Structural Panel Capacity and Production (million Sq Ft, 3/8" Basis) Plywood OSB Capacity Production Utilization Capacity Production Utilization

1992 23,700 19,332 82% 7,040 6,653 95%

1993 23,300 19,315 83% 7,560 7,002 93% 1994 21,875 19,638 90% 7,920 7,486 95% 1995 22,070 19,367 88% 8,830 7,903 90% 1996 21,150 19,181 91% 11,285 9,314 83% 1997 19,275 17,965 93% 11,575 10,534 91% 1998 19,075 17,776 93% 12,050 11,227 93% 1999 19,275 18,135 94% 12,250 11,740 96% 2000 18,835 17,450 93% 13,120 12,100 92% 2001 18,260 16,575 91% 13,725 12,500 91% 2002 18,010 16,295 90% 14,380 12,875 90%

% Change -0.24 -0.16 1.04 0.94 Shaded areas represent estimated values. Source: APA (1999d).
The spring edition of the APA’s on-line Engineered Wood Journal reports that the expectation of overall production of structural panels in 1999 would be roughly the same as it was in 1998 (APA, 1999b). However, the long term prospects for the softwood plywood and veneer sector indicates that the industry is in for a difficult time. APA members are bracing for a battle to preserve market share, a particularly challenging goal in the face of expected declines in housing starts. Further, the APA’s spring journal focuses on the multiple pressures on its market share. A primary source of pressure is from the expanding sentiment that wood products are not environmentally sensitive. They are concerned that environmental advocacy groups are becoming increasingly successful at convincing major corporations that the use of wood products should be curtailed in order to preserve trees and forested land (APA, 1999b).
Shipments of reconstituted wood products are expected to increase 4 percent in 1998 and 1999 according to the U.S. Industry and Trade Outlook 1999. Strong demand in the furniture market has proved beneficial to particleboard , MDF, and hardboard producers. For reconstituted wood products, the forecast predicts an increase in growth of 3.3 pe rcent per year from 1998 to 2003 as furniture markets2-55 and residential construction remain healthy (U.S . Department of Commerce, International Trade Administration, 1999).
In their article, “A Look at the Road Ahead for Structural Panels, ” authors Spelter and McKeever compare the situation of the OSB industry in 1996 to that of the MDF industry in the 1970's. The MDF industry experienced a major upheaval in the 1970's when an economic slump hit the U.S. right when the industry had added a significant amount of capacity. In this article, Spelter looks at whether the OSB industry is in danger of experiencing the same pr ocess. While the OSB industry’s capacity additions reflect those of the MDF industry, the economic conditi ons in the late 1990's lead the author to conclude that the OSB industry conditions probably will not l ead to closures like those experienced by the MDF sector in the seventies. However, Spelter does not e xpect that the OSB producers will continue to enjoy the gains in market share they have experienced ove r the last 10 to 15 years. He cites the near 100 percent market share held by OSB in the northeast and the Midwest as the peak of growth opportunity in those markets. Further, the market share split in the south and west may have stabilized due to the entrenchment of softwood plywood in those areas (Spelter and McKeever, 1996).
At the same time, manufacturers of substitutes fo r wood-based construction such as steel, cement and plastic, are aggressively pushing their products ha rd on the construction industry using the argument that their products are environmentally friendly, and have advantages in the areas of price stability, quality, and performance. In-roads by these competi ng non-wood substitutes are expected to continue as overall costs for wood-based products continue to climb and the underlying price advantage that woodproducts have traditionally held is undermined. Ot her concerns expressed the Engineered Wood Journal include having adequate supply of timber in th e long run to meet producers’ needs (APA, 1999b).

International Trade
The hope for the plywood and composite wood produc ts export markets is that declining domestic prices and economic recovery, particularly of the Asian economies, will boost the demand for U.S. produced wood-based products. This is of partic ular importance to the softwood plywood industry, as they are currently exporting approximately 10 percent of their production. Another international driver of demand for domestically produced wood-based buildi ng products is the effect of regulatory changes in countries such as Japan and Korea to promote wood-based housing construction. WEFA attributes most of the increases in exports from North Ameri ca during 1999 to the U.S. rather than Canada. Continued growth in this market is limited by expected falling housing starts in Japan (WEFA, 1999). Any future changes in the U.S.-C anadian exchange rate will likely have a positive effect on exports in the short-term (in the next 2-3 years), as will any modifications to tariff structures in place for U.S. exports.

The APA outlook includes an international forecast that projects a positive outlook for wood product exports from 2000 to 2002. This projection is based on expectation that the markets in Europe, Mexico, South America, and Japan will pick up in 2000, cau sing a weaker dollar and better overall climate for exports as (APA, 1999d). The strength of the dollar in 1999 placed U.S. wood products at a disadvantage in world markets, but APA projects significant increases in exports from 2000 to 2002 (see Exhibit 2-31 for structural panel export forecast). The 1999 fall edition of the APA’s Engineered Wood Journal pointed to continuing pressures on U.S. exports coming from recent increases in European production capacity as posing a sizeable challenge to st ructural wood panel products in the U.S. (APA, 1999c).

The U.S. Industry & Trade Outlook notes growth in European markets and removal of tariff barriers throughout the world as contributing to modest growth in the wood products industry. At the same time, the report cautions that economic conditions in Asia, especially Japan, may be of some concern. While OSB is making significant strides in residential c onstruction in Japan and elsewhere, an Asian recession2-56 could threaten this progress. Softwood plywood is still considered the material of choice in many markets unfamiliar with OSB. Nontraditional mark ets such as South America, eastern Europe, and China could provide significant opportunity for gr owth in the wood products industry, especially softwood plywood (U.S. Department of Commerce, International Trade Administration, 1999).

Prices
The recently published WEFA report on softwood lumb er forecasts a 5 percent increase in the price index for those products during the third quarter of 1999 from the previous quarter. Because of the expected leveling off or decline in construction, pr ices are expected to decline during the year’s fourth quarter. Based on WEFA’s forecast, overall annual pr ices in 1999 are expected to be about 8 percent higher than they were in 1998. Year 2000 prices are forecast to rise only marginally over 1999.

The “Review of the Wood Panel Sector in the U. S. and Canada” presents a forecast for structural wood panels (softwood plywood and OSB combined). In the 1997 report, Spelter and his co-authors assume that the long run average annual growth in demand for softwood plywood and OSB combined will continue at the historical 3 percent rate. Using that assumption, these industries will have excess capacity until 2001, when capacity utilization reaches 95 percent (Spelter et al., 1997).
This forecast concluded that current and pl anned production capacity will exceed demand until 2001. This excess capacity will continue to put dow nward pressure on prices, a trend that began in 1996. The report authors expect that this price pressu re will result in a market correction, requiring both the plywood and the OSB sectors to adjust capacity through the closure of some high cost, low productivity plants.2-57 2.6 References

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American Plywood Association - The Engineered W ood Association. 1999a. Web page information on product characteristics and manufacturing. Tacoma, WA: APA - The Engineered Wood Association. http://www.apawood.org/
American Plywood Association - The Engineered Wood Association. 1999b. Engineered Wood Journal Online . Tacoma, WA: APA - The Engineered Wood Association. Spring. http://www.apawood.org/news/journal/spring99.html
American Plywood Association - The Engineered Wood Association. 1999c. Engineered Wood Journal Online . Tacoma, WA: APA - The Engineered Wood Association. Fall. http://www.apawood.org/news/journal/fall99.html
American Plywood Association - The Engineered Wood Association. 1999d. Market Outlook. Lumber, Structural Panels, and Engi neered Wood Products: 2000 - 2002. Tacoma, WA: APA - The Engineered Wood Association.
American Plywood Association - The Engineered Wood Association. 1998. Engineered Wood Journal Online . Tacoma, WA: APA - The Engineered Wood Association. Fall. http://www.apawood.org/news/journal/fall98.html
American Plywood Association - The Engineered Wood Association. 1997. Design/Construction Guide: Residential & Commercial . Tacoma, WA: APA — The Engineered Wood Association.
Bentley, Jerome T., C. C. Lawson, and D. Crocker (Mathtech, Inc.) 1992. Economic Impacts of Alternative NESHAPS on the Wood Furniture Industry . Prepared for U.S. Environmental Protection Agency, Cost and Economic Impact Section, Emissions Standards Division, office of Air Quality Planning and Standards. September.
Buongiorno, Joseph. 1996. “Forest sector modeling: a synthesis of econometrics, mathematical programming, and system dynamics methods. International Journal of Foresting , 12, pp. 329-343.

CINTRAFOR. 1999. “Asian Crisis Hits PN W: Export Revenues Down 27% Between 1998-1998.” Fact Sheet #29. January. http://www.cintrafor.org/FS29.htm
Columbia Forest Products. 1999. “About our Company.” Portland, OR. www.columbiaforestproducts.com
Composite Panel Association. 1998. 1997 Annual Shipments Report & Downstream Market Survey: U.S./Canada Particleboard & Medium Density Fiberboard Industry . Gaithersburg, MD: Composite Panel Association. http://www. pbmdf.com/pubs/shipments97.html
Dirks, John. 1991. Perspectives on Wood Furniture Production, Marketing and Trade: A Survey of Research Results . CINTRAFOR Special Paper #1. http://www.cintrafor.org/SP01.htm
Dun & Bradstreet. 1999a. D-U-N-S Number Database. Murray Hill, NJ: Dun & Bradstreet. May 24. http://www.dnb.com/dunsno/dunsno.htm2-58 Dun & Bradstreet. 1999b. Industry Norms & Key Business Ratios 1998-1999 , Information for SIC Codes 2435, 2436, 2439, and 2493.
Eastin, Ivan, C. Lane, T. Waggener, R. Fight, J Barbour. 1996. An Assessment of the Market for Softwood Clearwood Lumber Products . CINTRAFOR Working Paper No. 59. http://www.cintrafor.org/WP59.htm

Financial Times Limited. 1999a. “Boise Cascade Cor poration.” Company Briefs/Company Financials. http://www.ft.com
Financial Times Limited. 1999b. “Georgia-P acific Corporation.” Company Briefs/Company Financials. http://www.ft.com

Financial Times Limited. 1999c. “Louisiana-P acific Corporation.” Company Briefs/Company Financials. http://www.ft.com

Financial Times Limited. 1999d. “Willamette Industr ies, Inc.” Company Briefs/Company Financials. http://www.ft.com

Gale Business Resources. 1999. Online business data base. Essays by industry SIC code downloaded from http://www.gale.com.
Howard, James L. 1999. U.S. Timber Production, Trade Cons umption, and Price Statistics 1965-1997. General Technical Report FPL-GTR-116. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory, 76p. July.
International Paper. 1998. “Int ernational Paper, Union Camp Cor poration Announce Merger.” Release, November 24. http://www.internationalpaper.com/ca/page/p ress_releases.cgi?funcs=links&ID=493957&back=arch ive
Louisiana-Pacific Corporation. 1999. “Headquarters: Product Lines Overview” http://www.lpcorp.com/hq/products.html “Louisiana-Pacific Corp. Successfully Completes Tender Offer for ABT Building Products Corp.” Release No.: 112-2-9. February 24. http://www.lpcorp.com/pressrel/19990224_gen_pr.html “Louisiana-Pacific to Acquire Evans Forest Products, Ltd.” Release No.: 138-8-9. August 24. http://www.lpcorp.com/pressrel/19990824_gen_pr.html “Louisiana-Pacific Corp. Successfully Completes Te nder Offer for Le Groupe Forex.” Release No.: 140-9-9. September 10. http://www.lpcorp.com/pressrel/19990910_gen_pr.html
McKeever, Davis B. 1997. Engineered Wood Products: A Response to the Changing Timber Resource

. Pacific Rim Wood Market Report, November.

Midwest Research Institute. 1999. Memorandum fro m Becky Nicholson and Melissa Icenhour to Mary Tom Kissell and Larry Sorrels, U.S. EPA: “Preliminary facility-specific cost estimates for implementation of the plywood and compos ite wood products NESHAP.” October 20.
Moody, Russell C. and J. Y. Liu. 1999. “Chapter 11: Glue Structural Members,” Wood handbook--Wood as an engineering material . Gen. Tech. Rep. FPL-GTR-113. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory.

PR NewsWire. 1999a.2-59 “Boise Cascade to Acquire Furman.” June 15. “Boise Cascade Reports Sharply Increased Second-Quarter Earnings.” July 15. http://www.prnewswire.com/gh/cnoc/comp/109525.html

PR NewsWire. 1999b. “Georgia-Pacific Group Reports Fourth Quarter and 1998 Results.” January 26. “Georgia-Pacific to Construct Oriented Strand Board Plant in Arkansas.” February 23. “Georgia-Pacific Group Reports Improved First Quar ter Earnings and All-Time Quarterly Record for Building Products.” April 22. “Georgia-Pacific Completes Merger with Unis ource Worldwide, Appoints Key Leadership; Sets Target for Resumption of Share Repurchases.” July 6. http://www.prnewswire.com

PR NewsWire. 1999c. “Willamette Industries Reports Fourth Quarter Earnings.” January 20. “Willamette Industries Completes Darbo Acquisition.” June 22. “Willamette Industries to Build Particle board Plant; Name New CFO.” August 5 http://www.prnewswire.com/comp/971763.html

PR NewsWire. 1998. “Willamette Industries Fi nalizes Purchase of French Plant.” March 4. http://www.prnewswire.com/gh/cnoc/comp/109525.html

PR NewsWire. 1997. “Willamette Industries to Acquire Mexico City Box Plant.” December 15. http://www.prnewswire.com/comp/971763.html
Spelter, Henry. 1998. Substitution , Timber Processing, March.
Spelter, Henry, D. McKeever, and I. Durbak. 1997. Review of Wood-Based Panel Sector in United States and Canada , General Technical Report FPL-GTR-99. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory. 45p.
Spelter, Henry. 1996. “Emerging Nonwood Build ing Materials in Residential Construction.” Forest Products Journal , 46(7/8).
Spelter, Henry and T. McKeever. 1996. “A Look at th e Road Ahead for Structural Panels.” C. C. Crow Publications, Inc., 11(5). October.
Spelter, Henry. 1995. “Capacity Changes in U.S. Particleboard, Southern Pine Plywood, and Oriented Strandboard Industries.” Canadian Journal of Forest Resources , 25: 614-620.

U.S. Bureau of Labor Statistics. 1999. Web site. http://stats.bls.gov/ppihome.htm
U. S. Department of Commerce. 1999a. 1997 Census of Manufactures, Industry Series : Hardwood Veneer and Plywood , EC97M-3212A Softwood Veneer and Plywood , EC97M-3212B Engineered Wood Member (Except Truss) Manufac turing, 1997 Economic Ce nsus, Manufacturing Industry Series , EC97M-3212C Truss Manufacturing , EC97M-3212D Reconstituted Wood Pr oducts Manufacturing , EC97M-3212E
U. S. Department of Commerce. 1999b. 1997 Census of Manufactures, Industry Series : Adhesive Manufacturing , EC97M-3255B2-60 Wood Office Furniture Manufacturing , EC97M-3372A
U.S. Department of Commerce. 1997. Current Industrial Reports, Survey of Plant Capacity, 1997.
U.S. Department of Commerce. 1995a. 1992 Census of Construction Industries, Industry Series: General Contractors — Single-Family Houses , Industry 1521. CC92-I-1. Washington, D.C.: U.S. Government Printing Office. June.
U. S. Department of Commerce. 1995b. 1992 Census of Manufactures, Industry Series, Millwork, Plywood, and Structural Wood Members, Not El sewhere Classified, Industries 2431, 2434, 2435, 2436, and 2439. MC92-I-24B. Washington, D.C.: U.S. Government Printing Office.
U. S. Department of Commerce. 1995c. 1992 Census of Manufactures, Industry Series, Household Furniture, Industries 2511, 2512, 2514, 2515, 2517, and 2519. MC92-I-25A. Washington, D.C.: U.S. Government Printing Office.
U. S. Department of Commerce. 1992. Census of Manufactures, Subject Series: General Summary , MC92-SC-1.
U.S. Department of Commerce. No date. Census of Manufactures : Industry 2435, Hardwood Veneer and Plywood Industry 2436, Softwood Veneer and Plywood Industry 2439, Structural Wood Members, N.E.C. Industry 2493, Reconstituted Wood Products
U.S. Department of Commerce, International Trade Administration. 1999. U.S. Industry &Trade Outlook.
U.S. Department of Commerce, International Trad e Administration. 1998. “Outlook Trend Tables.” http://www.ita.doc.gov/industry/otea/usito98/tables.htm.
U.S. Department of Labor, Occupati onal Safety and Health Administrati on. No date. SIC descriptions. http://www.osha.gov/oshstats/sicser.html.
U.S. Environmental Protection Agency. 1998. Industry Specific Information Collection Request (ICR) for the Development of Plywood and Particle board Maximum Achievable Control Technology (MACT) Standards

. U.S. Environmental Protection Agency. 1995. Lumber and Wood Products , Office of Compliance Sector Notebook Project.
U.S. Environmental Protection Agency. 1992. “Economic Impacts of the Alternative NESHAPS on the Wood Furniture Industry.”

U.S. Small Business Administration. 1999. Small Business Size Standards Matched to SIC Codes , http://www.sba.gov/regulations/siccodes/siccodes.html.

WEFA. 1999. Informational Web site on softwood lumber. http://www.wefa.com/news/stories/99/lumber.cfm

### 3-61 Weyerhaeuser. 1999a. “Weyerhaeuser Completes Ac quisition of MacMillan Bloedel; Haskayne to Join Weyerhaeuser Board of Directors. Release. November 1. http://www.weyerhaeuser.com/news/mb/default.asp
Weyerhaeuser. 1999b. “Facts About Weyerhaeuser .” Tacoma, WA: Weyerhaeuser Company. http://www.weyerhaeuser.com/facts/weyer.htm
Willamette Industries, Inc. 1999. “Willamette Industries to Build $85 Million Facility in South Carolina.” Release. http://www.wii.com/newsexp.htm
Youngquist, John A. 1999. “Chapter 10: Wood- Based Composite and Panel Products.” Wood handbook--Wood as an engineering material. Gen. Tech. Rep. FPL-GTR-113. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory.

3 REGULATORY ALTERNATIVES, EMISSIONS, EMISSION REDUCTIONS, AND CONTROL AND ADMINISTRATIVE COSTS

### 3-1 3.1 Regulatory Alternatives
3.1.1 Background

Section 112 of the Clean Air Act (CAA) requires that EPA establish NESHAP for the control of hazardous air pollutants (HAP) from both new and existing major sources. A major source of HAP is defined as any stationary source or group of sta tionary sources within a contiguous area and under common control that emits or has the potential to em it, considering controls, in the aggregate, 10 tons per year or more of any single HAP or 25 tons per year of combined HAP. The CAA requires the NESHAP to reflect the maximum degree of reduction in emissions of HAP that is achievable. This level of control is commonly referred to as the maximu m achievable control technology, or MACT. The MACT floor is the minimum control level allowed fo r NESHAP and is defined in Section 112 (d) (3) of the CAA.
The requirements for new sources are potentially more stringent than those for existing sources. For new sources, Section 112(d)(3) of the CAA requires EPA to set standards for each category or subcategory that are at least as stringent as “the emi ssion control that is achieved in practice by the best controlled similar source.” For existing sources, S ection 112(d)(3) requires the HAP standards to be no less stringent than “the average emission limitation achieved by the best-performing 12 percent of the existing sources” for source categories or subcategories with at least 30 sources and “the average emission limitation achieved by the best-performing fi ve sources” for source categories or subcategories with fewer than 30 sources. 1
In a previous rulemaking, the EPA promulgate d a final rule (59 FR 29196) that presented the Agency’s interpretation of the statutory langua ge regarding the basis of the MACT floor. 2 The EPA’s interpretation of the “average emission limitation” is th at it means a measure of central tendency, such as the median. If the median is used when there are at least 30 sources, then the emission level achievable by the source and its control system that is at th e bottom of the top 6 percent of the best-performing sources (i.e., the 94th percentile) then becomes the MA CT floor. For example, assume that there are 100 sources, and HAP emissions from approximately 15 of these sources (15 percent nationwide) are controlled using thermal oxidizers and the HAP emissions from the remainder of the sources are uncontrolled. In this example, the 94th percentile is represented by the control system applied to the source ranked at number 6 (6/100 = 6 percent). Howe ver, in this example, the same type of add-on control technology used by the source at the 94th pe rcentile (thermal oxidizer) is used by sources ranked below the 94th percentile. Assuming that there are no significant design or operational differences between the different thermal oxidizers that would affect their performance, all 15 sources equipped with thermal oxidizers would be considered representative of the MACT floor. Thus, when determining the performance level of the MACT floor technology, EPA w ould evaluate the available data for any and all of the sources equipped with thermal oxidizers.
When there are less than 30 sources, the emission level achievable by the source and its control system that is the median of the 5 sources represen ts the MACT floor. For example, if there are 10 sources nationwide and the emissions from 2 of these sources are controlled with thermal oxidizers and the emissions from the remaining 8 are uncontrolled, then the MACT floor is “no emission reduction” because the top 5 sources include the 2 that are controlle d, plus 3 that are uncontrolled. In this example, the median source (the source ra nked “number 3”) is uncontrolled.

### 3-2 3.1.2 Control Technologies and Practices in MACT Floor Determination
Control systems in use in the plywood and co mposite wood products (PCWP) industry include add-on control systems and incineration of process e xhaust in an onsite combustion unit. The potential for pollution prevention also exists in the PCWP industry; however, there are no known and demonstrated pollution prevention techniques that can be universally applied across the industry. The emissions from PCWP process units are associated with the wood and/or resin processed. Thus, switching to alternative fuels (e.g., switching from wood fuel to natural gas) would not significantly reduce emissions and would not be economical for many facilities that use their wood waste as fuel. Facilities cannot readily switch wood types (e.g., from softwoods to hardwoods) for several reasons: (1) equipment at each facility is often designed for a pa rticular wood type; (2) product characteristics would change; and (3) PCWP facilities are located near th eir wood source. Over the past decades, the PCWP industry and its resin suppliers have responded to pressure to reduce the HAP content of resins. It is expected that this trend will continue into the future (e.g., resins with lower HAP content are likely to be developed). Resin reformulation is a slow, trial-a nd-error process that must be completed by individual facilities and their resin suppliers so that product quality is maintained. At this time, no information is available to determine the degree of emission reducti on that can be achieved through resin reformulation. The achievable emission reduction would be very fac ility-specific, and may not be comparable to the emission reduction achievable with add-on control systems because emissions from the wood would remain. At the present time, few (if any) fac ilities use pollution prevention measures to achieve an emission reduction comparable to that of add-on inci neration-based control systems. Therefore, this analysis focuses on add-on control devices.
Available data on control device performance were reviewed to determine which add-on control systems are best at reducing HAP emissions. Because total hydrocarbons (THC), formaldehyde, and methanol are the most prevalent pollutants emitte d from the PCWP industry and represent the majority of the available data on control device performance, the control systems were analyzed based on their ability to reduce emissions of these three pollutants. Although THC is not a HAP, control systems that are effective in reducing THC emissions are gene rally effective in reducing HAP emissions.
The available control device performance data fo r the PCWP industry shows that only two types of add-on air pollution control devices consiste ntly and continuously reduce HAP emissions: incineration-based controls (including regenerativ e thermal oxidizers [RTOs], regenerative catalytic oxidizers [RCOs], and incineration of pollutant s in onsite process combustion equipment [process incineration]) and biofilters. For control systems that use onsite process combustion equipment (e.g., power boilers or fuel cells) to reduce emissions, onl y those systems that route 100 percent of the process unit’s exhaust to the combustion equipment are include d in the “incineration-based controls” category. Several of the process incineration systems are fully integrated systems that combine heat/energy recovery with pollution control. Systems that only incinerate a portion of the process unit exhaust stream (e.g., less than 75 percent) are referred to as “semi-incineration” and are not included in the incineration-based controls category.
Those PCWP facilities that practice semi-incineration take a portion of the exhaust stream and then route these emissions to a burner for use as com bustion air. In those situations, the HAP emissions in the slip stream are actually combusted. However, some facilities with direct-fired dryers (i.e., dryers that receive hot exhaust air directly from combustion source) that practice semi-incineration may also use the dryer exhaust gas slip stream (or fresh air) to cool the exhaust gas from the burners in “blend chambers.” 3 When the exhaust gas is routed to the ble nd chamber, the HAP in the exhaust gas are not combusted in the dryer, and if the dryer emissions are uncontrolled, these HAP are ultimately emitted to the atmosphere. The amount of exhaust gas recycled either to the burner or to the blend chamber can

### 3-3 vary over time. Decisions about how much of the recycled exhaust stream are used as combustion air and when and how much exhaust air is used in a blend chamber generally are made by the equipment operators and are affected by process conditions su ch as the moisture content of the incoming wood furnish (which affects the target dryer operating te mperature) and the desired amount of water removal. 4 Thus, semi-incineration is used to maintain the heat balance in the drying system (e.g., combustion unit and dryer). There is a lack of detailed information on how the semi-incineration process works at each facility, and thus, the actual HAP emission reductions that are achieved at PCWP facilities that practice semi-incineration cannot be determined/verified. Inaddition, it may not be possible to retrofit semiincineration onto existing process units, and therefor e, semi-incineration may not be an option for process units that were not originally designed to in corporate semi-incineration. For the reasons statedabove and for the purpose of establishing MACT floors for the PCWP source category, semiincineration is not considered a verified control technique for reducing HAP emissions. However, as explained later in the technical support document for the cost analysis, there are only two process unit groups (bagasse fiberboard mat dryers and hardwood ve neer dryers) where semi-incineration is the only available candidate for the MACT floor technology.
The available control device efficiency data show that control devices installed for particulate matter (PM) abatement had no effect on gaseous HAP or THC emissions. 5 These control devices include cyclones, multiclones (or multicyclones), baghouses (or fabr ic filters), and electrified filter beds (EFBs). The performance data for wet electrostatic precip itators (WESPs) and wet scrubbers installed for PM control also showed no effect on HAP and THC em issions. These wet systems may achieve short-term reductions in THC or gaseous HAP emissions, howev er, the HAP and THC control efficiency data, which range from slightly positive to negative values, indicate that the ability of these wet systems to absorb water-soluble compounds (such as formaldehy de) diminishes as the recirculating scrubbing liquid becomes saturated with these compounds. 5 One wet scrubbing system, a combination water tray tower/high energy venturi scrubber that uses treated wa ter and is designed to minimize emissions of both PM and odorous compounds from a hardboard press, did achieve notable HAP and THC emissions reductions. This system reduces formaldehyde and methanol emissions by 65 percent and 50 percent, respectively, and reduces THC emissions by 86 percent. 5
The THC, methanol, and formaldehyde contro l device performance data for incineration-based control and biofilters are presented in the MA CT floor memo included in the public docket. 6 The information in this memo was extracted from a separate memorandum which provides information on the available control device performance data for th e various types of control devices applied to PCWP process units. The performance data for the incinera tion-based controls and bi ofilters showed methanol and formaldehyde emission reductions equal to or greater than 90 percent, except in some cases where the pollutant loadings of the emission stream en tering the control systems were very low. The performance data for THC showed that incineration- based control systems could achieve THC emission reductions equal to or greater than 90 percent. The THC emission reductions achieved with biofilters varied somewhat, with THC reductions ranging from 73 percent to 90 percent. Although biofilters are effective in reducing the HAP compounds emitted from process units in the PCWP industry, they can be less effective in reducing some of the less wate r-soluble non-HAP compounds, such as pinenes, that can make up a portion of the THC measurements.
The MACT floor technology for the process units was either determined to be no emission reduction or equivalent to the emission reduction ach ievable with incineration-based control systems or biofilters. Although some process units are equipped with add-on controls that perform at a level somewhere between zero (no control) and the pe rformance level achievable with incineration-based controls and biofilters, none of these control sy stems were identified as MACT floor control technologies because they (1) do not reduce HAP emissions (e.g., bag houses) or (2) do not reduce HAP

### 3-4 emissions on a consistent basis (e.g., wet electrostatic precipitators), or (3) achieve lower HAP emission reductions than biofilters and incineration-based c ontrols (e.g., semi-incineration). Therefore, the MACT floor analysis focused on incine ration-based controls and biofilters.
For the purpose of establishing the performance leve l of the MACT floor control systems, all available data on incineration-based controls a nd biofilters were grouped together. This “group approach” was used because some of the control systems treat HAP emissions from multiple types of process units, such as primary tube dryers, r econstituted panel presses, and board coolers.
Determinations of the performance of the contro l system on emissions from each type of process unit were not possible. Also, for some process unit groups, limited data were available for the control systems applied to the process units in that group. By considering all of the performance data for incineration-based controls and biofilters together , the amount of available data upon which the MACT floor level of performance was based was maximized.

The available data for incineration-based contro ls and biofilters (provided in the MACT floor memo) 6 shows variability in performance from process unit to process unit and over time. In some cases, it was not possible to directly compare the pe rformance of different control systems because data were not available for the same pollutant (i.e., not a ll test reports included data for THC, methanol, and formaldehyde). Comparison of the performance of the different types of incineration-based control systems with other incineration-based controls and with biofilters was also hampered by the fact that the uncontrolled emissions being treated by the different control systems varied with respect to pollutant loading (inlet concentration) and pollutant type. Because the control device efficiency is somewhat dependent on the amount of HAP entering the device, the variability in the uncontrolled emissions from process units both within and among the different process groups meant that the control device efficiencies also varied. With a few exceptions, wh en the concentration of methanol, formaldehyde, or THC in the uncontrolled emission stream was greater than 10 parts per million dry volume (ppmvd), the associated HAP emission reductions ranged from 90 to 99 pe rcent. In general, lower control efficiencies were achieved when the inlet pollutant concentr ations were below 10 ppmvd; however, in some cases, the control efficiency exceeded 90 percent even at the lower inlet concentrations.
To account for the variability in the type and amount of HAP in the uncontrolled emissions from the various process units and the effect of this variability on control system performance, it is recommended that the MACT floor performance level be based on all three of the pollutants analyzed and include maximum concentration levels in the outlet of the control systems as an alternative to emission reductions. The MACT floor performance le vel is a 90 percent reduction in THC or methanol or formaldehyde emissions. The maximum concentra tion level in the outlet of the MACT floor control system is 20 ppmvd for THC, or 1 ppmvd for methanol, or 1 ppmvd for formaldehyde. The 20 ppmvd is recommended as the alternative maximum concen tration for THC because 20 ppmvd represents the practical limit of control for THC. The 1 ppmvd is recommended as the maximum outlet concentration for both methanol and formaldehyde because this con centration is achievable by the MACT floor control systems and the method detection limits for these compounds using the National Council of the Paper Industry for Air and Stream Improvement (NCASI) impinger/canister emission test method (NCASI Method IM/CAN/WP-99.01) are less than 1 ppmvd. 7
3.1.3 MACT Floor Options
The six recommended options for representing the MACT floor are shown in Exhibit 3-1. These six options reflect the emission reductions and maxi mum outlet pollutant concentrations achievable at the MACT floor for all process units with a MACT floor technology represented by incineration-based

### 3-5 controls or biofilters. As shown in Exhibit 3-1, it is recommended that a restriction be placed on the use of the outlet concentration options for methanol and formaldehyde. The restriction would be that the concentration of the pollutant (methanol or formalde hyde) entering the MACT control system must be at least 10 ppmvd for the facility to use the outlet concen tration option. The purpose for this restriction is that some process units may have very low uncontrolle d methanol or formaldehyde emissions, while still emitting significant quantities of HAP, and facilities with these process units could claim that they are achieving MACT floor levels of control without doi ng anything to reduce HAP emissions. All of the MACT floor control systems evaluated can meet at l east one of the six control options for add-on control devices, based on the available data. Only a few of the MACT floor control systems evaluated can meet all six options; in those cases, the control system s tend to be applied to process units with both moderately high HAP emissions and moderately hi gh THC emissions, which would allow them to meet the outlet concentration-based options for methanol and formaldehyde as well as the percent reduction options. Therefore, it is recommended that facilities be required to meet only one of the six emission options in Exhibit 3-1.

Exhibit 3-1. MACT FLOOR CONTROL OPTIONS

Pollutant Reduce by OR achieve emissions # methanol 90 percent 1 ppm a

...OR... formaldehyde 90 percent 1 ppm a

...OR...

THC b 90 percent 20 ppm

a This option would only be applicable to units w ith uncontrolled emissions of that HAP that are $ 10 ppm.
b Mills will be allowed to adjust THC measurements to subtract methane.

3.1.4 Summary of MACT for Existing and New Process Units
Exhibit 3-2 summarizes MACT for each type of process unit at new and existing PCWP facilities. The MACT represents the level of cont rol that would be required by the PCWP NESHAP. The technologies listed below achieve that control level.

### 3-6 Exhibit 3-2. SUMMARY OF MACT FOR PCWP PROCESS UNITS AT NEW AND EXISTING SOURCES

Process unit MACT for process units at existing

sources MACT for process units at new

sources Tube dryers; Rotary strand dryers; Conveyor strand dryers; Green particle rotary dryers; Hardboard ovens; Softwood veneer dryers; Pressurized refiners emission reduction achievable with incineration-based control a emission reduction achievable with incineration-based control a

Reconstituted wood product presses emission reduction achievable with incineration-based control a or biofilter emission reduction achievable with incineration-based control a or biofilter Fiberboard mat dryers (wood); Hardboard press preheat ovens No emission reduction emission reduction achievable with incineration-based control a Reconstituted wood product board coolers No emission reduction emission reduction achievable with incineration-based control a or biofilter Rotary agricultural fiber dryers; Dry particle rotary dryers; Paddle-type particle dryers; Hardboard humidifiers Fiberboard mat dryers (bagasse); Veneer kilns; Radio-frequency veneer redryers; Hardwood veneer dryers; Particleboard press molds; Particleboard extruders; Engineered wood products presses; Agriboardpresses; Plywood presses; Standalone digesters; Atmospheric refiners; Blenders; Formers; Sanders Saws; Fiber washers; Chippers; Log vats; Lumber kilns No emission reduction No emission reduction

a Incineration-based control includes RTOs, RCOs, TCOs, TO s, and incineration of process exhaust in combustion

unit.

3.1.5 Beyond the MACT Floor Options and Related Technologies
Because the control devices that represent MACT le vels of control are the same for all process units that have a controlled MACT floor for bot h new and existing units, the only beyond the floor options considered were for existing process unit gr oups that had MACT floors equal to “no emission reduction.” The annual total HAP emissions from the following equipment are very low compared to the emissions from other process units used in the PCWP industry:

C agriboard dryers C particleboard press molds

### 3-7 C dry particle rotary dryers C particleboard extruders

C paddle-type particle dryers C engineered wood products presses

C hardboard humidifiers C agriboard presses

C bagasse fiber mat dryer C atmospheric refiners

C veneer kilns C lumber kilns

C RF veneer redryers C resin storage tanks

C hardwood veneer dryers C other miscellaneous equipment (formers, sanders, saws, fiber washers, chippers, and log vats)

No beyond-the-floor control options were c onsidered for these equipment because emissions from these process units would not be cost-effective to control. In addition, no beyond-the-floor analyses of wastewater operations, wastewater tanks, and miscellaneous coating operations were conducted because sufficient information is not availabl e to make beyond-the-floor determinations and it is not known (or expected) that emissions from these operations would justify control.
Based on a review of the HAP emissions data for process units with MACT floors of no emission reduction, blenders and stand-alone di gesters were selected for a beyond-the-MACT-floor analysis because these equipment emit higher levels of HAP emissions relative to other process units. Beyond-the-floor analyses were also conducted for process units with a MACT floor of no emission reduction for existing units and a MACT floor re presented by the emission reduction achievable with incineration-based controls for new units. These process units include fiberboard mat dryers, press preheat ovens, and reconstituted wood products board coolers.
This analysis of beyond-the-floor options was based on the industry average exhaust flow for each process unit, the typical number of each process unit per plant, the industry average amount of HAP emitted from the process units, and assuming that an RT O would be used to control emissions from each process unit. The average exhaust flow rates and typical number of process units per plant were determined using the results from EPA’s MACT su rvey. The average HAP emissions and emission reductions were determined using the methodology described in the baseline emissions memo. 9 The annualized RTO cost was calculated based on flow ra te using the methodology described later in this chapter. The cost per ton values were calculated by di viding the total annualized cost (TAC) for the RTO by the HAP reduction. This analysis assumes th at facilities will not be able to route the emissions from process units to an existing control device or to a new control device installed to meet the PCWP standards (i.e., that a separate RTO must be purch ased to handle the additional flow from the process units). Exhibit 3-3 below presents the results of this analysis.

Exhibit 3-3. Cost-Effectiveness Analysis Of Beyond-The-Floor Control Options

### 3-8 Process Unit Average flow, dscfm Typical

no. per plant RTO TAC Average HAP emitted, tpy Tons HAP reduced, tpy Cost effectiveness $/ton (1998

dollars) Fiberboard mat dryer at FB plant 49,389 1 $471,187 8 7.6

Fiberboard mat dryer at w/d HB plant 19,491 1 $370,952 12 11

Fiberboard mat dryers (average) 34,440 1 $421,070 10 9.3 $30,076

Press preheat oven - w/d HB plant 21,812 1 $377,904 15 14 $26,520

Board cooler - PB 41,423 1 $442,096 5 4.8 Board cooler - MDF 79,483 1 $599,447 3 2.9 Board cooler (average) 60,453 1 $520,772 4 3.9 $133,531 Stand-alone digester - FB 7,587 2 $358,359 14 13 Stand-alone digester - HB 7,587 2 $358,359 14 13 Stand-alone digester (average) 7,587 2 $358,359 14 13 $26,944 Blender - PB 13,590 2 $394,486 45 43 Blender - OSB 13,590 2 $394,486 11 10 Blender (average) 13,590 2 $394,486 28 27 $14,610

In all cases, the emission reductions that coul d be achieved from requiring controls for these existing units did not appear to be justified by th e cost. Many of the existing control devices at wellcontrolled facilities would not have the additional capacity to treat the emissions from these process units, and thus, these facilities would have to install new controls.
For more information, refer to the MACT memo for this rule and the BID. 8

3.1.6 Considerations of Possible Risk-Based Alternatives to Reduce Impacts to Sources

### 3-9 The Agency has made every effort in developing this rule to minimize the cost to the regulated community and allow maximum flexibility in compliance options consistent with our statutory obligations. However, we recognize that the rule may still require so me facilities to take costly steps to further control emissions even though their emissions may not result in exposures which could pose an excess individual lifetime cancer risk greater than one in one million or which exceed thresholds determined to provide an ample margin of safety for protecting public health and the environment from the effects of hazardous air pollutants. We are, therefore, on whether there are further ways to structure the rule to focus on the facilities which pose significant risks and avoid the imposition of high costs on facilities that pose little risk to public health and the environment.
Industry representatives provided EPA with descripti ons of three mechanisms that they believed could be used to implement more cost-effective reduc tions in risk. The docket for today’s rule contains “white papers” prepared by industry that outlin e their proposed approaches (see docket number A-98-44, Item # II-D-525). The Agency has taken comment on th ese approaches. We believe that one of the three suggested approaches warrant consideration. We belie ve it could be used to focus regulatory controls on facilities with significant risks and avoid the imposition of high costs on facilities that pose little risk to public health or the environment. This approach, subcategorization and delisti ng, would be implemented under the authority of CAA sections 112(c)(1) a nd 112(c)(9). The maximum achievable control technology, or MACT, program outlined in CAA secti on 112(d) is intended to reduce emissions of HAP through the application of MACT to major sources of t oxic air pollutants. Section 112(c)(9) is intended to allow EPA to avoid setting MACT standards for categor ies or subcategories of sources that pose little risk to public health and the environment.
3.1.6.1 Subcategory Delisting Under Section 112(c)(9)(B) of the CAA
EPA is authorized to establish categories and s ubcategories of sources, as appropriate, pursuant to CAA section 112(c)(1), in order to facilitate the deve lopment of MACT standards consistent with section 112 of the CAA. Further, section 112(c)(9)(B) allows EPA to delete a category (or subcategory) from the list of major sources for which MACT standards are to be developed when the following can be demonstrated: 1) in the case of carcinogenic pollutants, that "no source in the category . . . emits [carcinogenic] air pollutants in quantities which may cau se a lifetime risk of cancer greater than one in one million to the individual in the population who is most exposed to emissions of such pollutants from the source”; 2) in the case of pollutants that cause adver se noncancer health effects, that "emissions from no source in the category or subcategory . . . exceed a leve l which is adequate to protect public health with an ample margin of safety"; and 3) in the case of pollutant s that cause adverse environmental effects, that “no adverse environmental effect will result from emissions from any source.”
Given these authorities and the suggestions from the white paper prepared by industry representatives (see docket number A-98-44, Item # II-D -525), EPA has considered whether it would be possible to establish a subcategory of facilities within the larger PCWP category that would meet the riskbased criteria for delisting. Since each facility in such a subcategory would be a low-risk facility (i.e., if each met these criteria), the subcategory could be de listed in accordance with section 112(c)(9), thereby limiting the costs and impacts of the MACT rule to only those facilities that do not qualify for subcategorization and delisting. Facilities seeking to be included in the delisted subcategory would be responsible for providing all data requi red to determine whether they are eligible for inclusion. Facilities that could not demonstrate that they are eligible to be included in the low-risk subcategory would be subject to MACT and possible future residual risk standards.
Establishing that a facility qualifies for the low-risk subcategory under section 112(c)(9) will necessarily involve combining estimates of pollutant emissions with air dispersion modeling to predict10 “ A Tiered Modeling Approach for Assessing the Risks due to Sources of Hazardous Air Pollutants.” EPA-450/4-92-001. David E. Guinnup, Office of Air Quality Planning and Standards, USEPA, March 1992.



### 3-10 exposures. The EPA will promote a tiered analytical approach for these determinations. A tiered analysis involves making successive refinements in modeling methodologies and input data to derive successively less conservative, more realistic estimates of polluta nt concentrations in air and estimates of risk.
As a first tier of analysis, EPA developed a seri es of simple look-up tables based on the results of air dispersion modeling conducted using conservative input assumptions. By specifying a limited number of input parameters, such as stack height, distance to property line, and emission rate, a facility could use these look-up tables to determine easily whether th e emissions from their sources might cause a hazard index limit to be exceeded.
A facility that does not pass this initial con servative screening analysis could implement increasingly more site-specific but more resource-inte nsive tiers of analysis using EPA-approved modeling procedures, in an attempt to demonstrate that thei r facility does not exceed the hazard index limit. The EPA’s guidance could provide the basis for conducting such a tiered analysis. 10
Another approach would be to define a subcate gory of facilities within the PCWP source category based upon technological differences, such as differen ces in production rate, emission vent flow rates, overall facility size, emissions characteristics, processes, or air pollution control device viability. If it could then be determined that each source in this technologically-defined subcategory presents a low risk to the surrounding community, the subcategory coul d then be delisted in accordance with 112(c)(9).
With the adoption of this his section 112(c)(9) approach, EPA indicates that the rule does not apply to any source that demonstrates, based on a tiered approach that includes EPA-approved modeling of the affected source’s emissions, that it belongs in a subcategory which has been delisted under section 112(c)(9).

3.2 Emissions and Emission Reductions
As mentioned in Chapter 1, the U.S. Envir onmental Protection Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP) for the plywood and composite wood products source category. This part of the RIA presents emission reductions expected to occur from compliance with the final (MACT floor) alternative.
3.2.1 Some Results in Brief
The plywood and composite wood products N ESHAP will reduce HAP emissions by about 11,000 tons in the third year after its issuance. 9 The major HAP reduced, as mentioned in the rule preamble, are acrolein, acetaldehyde, formaldehyde, phenol, propionaldehyde, and methanol. In addition, nearly 27,000 tons of VOC (reported as total hydrocarbon) emissions will be reduced. Nearly 11,000 tons of CO emission reductions will occur, along with 13,000 tons of PM (coarse) emission reductions. There will also be 2,400 tons of additional NOx emissions and 4,000 tons of SO 2 emissions added to the atmosphere due to the additional in cineration-based controls that may be necessary for affected facilities to meet the MACT floor alternative.

### 3-11 3.2.2 General Approach
The methodology used to estimate the HAP emi ssion reductions associated with this rule is summarized in this section. Before the emissions reductions could be estimated, the baseline emissions level for each pollutant had to be determined. Th is was conducted by first estimating emissions without considering current air pollution controls, and then cal culating the emissions levels with current controls applied. The first, uncontrolled emission estim ates, are developed without consideration of air pollution controls currently in use at wood products plants. Baseline estimates reflect the level of pollution control that is presently used. The rema inder of this section discusses the general methodology used to estimate uncontrolled and baseline emissions.
Estimating uncontrolled and baseline emissions involves the following four steps:
(1) Identification of hazardous air pollutant (HAP) emission sources, (2) Characterization of emission sources (e.g., assignment of throughput and other characteristics), (3) Application of emission factors, and (4) Calculation of emissions.
3.2.2.1 Identifying Emission Sources
Emission sources were identified based on responses to the EPA’s maximum achievable control technology (MACT) surveys and available emissions test data. The EPA gathered plant-specific information with three MACT surveys. The results of the three surveys are documented in separate memoranda. 10,11,12 Available emissions test data include data from nearly 100 test reports collected through EPA’s MACT survey, data from EPA’s Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (commonly referred to as AP-42), and extensive data from the industry-sponsored test program performed by the National Council of the Paper Industry for Air and Stream Improvement (NCASI). Emissions were estim ated for sources that were identified in the EPA’s MACT survey (e.g., dryers, presses, board cooler s) and for additional miscellaneous sources (e.g., digesters, refiners, fiber washers) for which applicab le emission test data were available. Process flow diagrams submitted with the MACT surveys provi ded information about the presence (or absence) of miscellaneous sources at plants. The EPA’s MACT survey also provided information on the control devices used for most unit operations.
Some plants have begun operation and other plants have added equipment and controls since EPA conducted the MACT survey. Such changes ha ve been accounted for in the nationwide emission estimates. A separate memorandum summarizes the cha nges to plants that have occurred following the EPA’s MACT survey. 13
3.2.2.2 Characterizing Emission Sources
After the emission sources were identified, each source was assigned a throughput and further characterized. In most cases, plant-specific dryer and press throughput was provided in EPA’s MACT survey. If the dryer or press throughput was claimed confidential or was not provided, then a default throughput was assigned. For dryers, the default throughput was the average throughput for the same type dryers for the product manufactured. 10,11,12 If available, plant production (or capacity if production

### 3-12 was unavailable) was used as the default throughput for presses; otherwise, presses were assigned the average press throughput for the product manufactured.
Throughput for miscellaneous equipment was based on either dryer or press throughput, depending on the units of measure for the applicab le emission factor (e.g., pounds per oven dry ton [lb/ODT] or pounds per thousand square feet [lb/MSF] ). Collective throughputs for digesters, refiners, fiber washers, blenders, and formers were genera lly approximated as the total dryer throughput (ODT/yr) for the plant. Board cooler, sander, and saw th roughput was generally approximated as the total press throughput (MSF/yr) for the plant. By assigning either the total dryer or press throughput to miscellaneous processes, no assumption about the numbe r of miscellaneous opera tions (e.g., number of refiners) at each plant was necessary.
Following assignment of throughput for each emission source, sources were further characterized (as necessary for application of emi ssion factors) based on wood species, resin type, or other characteristics. Further characterization of emission sources is discussed in the baseline emissions memo for this rule. If characterization of an emission source was not possible due to claims of confidentiality or missing information in the survey r esponse, then default characterizations were applied based on practices most commonly observed at other plants.

3.2.2.3 Applying Emission Factors
As emission sources were characterized, the av ailable emission factors were reviewed for applicability to each emission source. The emission factors used in developing the nationwide estimates are documented in a separate memorandum. 14 Emissions were generally estimated for total hydrocarbon as carbon (THC as C , referred to as “THC” in this RIA) and the following HAP’s as shown in the following table:
acetaldehyde methyl isobutyl ketone (MIBK) acrolein phenol benzene propionaldehyde cumene styrene formaldehyde toluene methanol m,p-xylene methylene chloride o-xylene methyl ethyl ketone (MEK)
When used in this document, the terminology “comp lete set” refers to the set of emission factors for the above list of HAP’s, THC, and any other add itional HAP’s that may have been measured at levels above a test method detection limit.

Total HAP was taken to be the sum of the individua l HAP’s. If all test data for a pollutant at a source were below the test method detection limit (de noted as “BDL” in reference 5), then the emission factor was treated as zero. For a few specific s ources, HAP’s other than the ones listed above were tested for and detected. These HAP were included in the total HAP estimate for that source. Exhibit 3-4 illustrates how the total HAP emission factors were developed.

### 3-13 Exhibit 3-4. ILLUSTRATION OF TOTAL HAP CALCULATION FOR AN EMISSION SOURCE HAP Emission Factor (from reference 5) acetaldehyde 0.0012
acrolein BDL a benzene BDL
cumene BDL formaldehyde 0.015
methanol 0.076 methylene chloride BDL
MEK BDL
MIBK BDL phenol 0.0047 propionaldehyde BDL styrene BDL toluene BDL m,p-xylene BDL o-xylene BDL
Total HAP 0.0012 + 0.015 +0.076 + 0.0047 = 0.097

a BDL (below detection limit); all test runs for this polluta nt and this source were below the test method detection limit.

Test data were not available for all of the HAP ’s considered for some sources (i.e., a complete set of emission factors was not available). In some cases, it was necessary to apply emission factors for one source to a similar source for which factors were not available. In other situations, it was necessary to group emission factors so that emissions of all th e likely pollutants could be estimated for a particular emission source. Grouped emission factors were calculated from emission test averages using the methodology described in the emission factor memo that is in the public docket for this rule 14 . Specific application of the emission factors for each unit ope ration is discussed in the baseline emissions memo for this rule.
3.2.2.4 Calculating Emissions
Applicable emission factors were used to estimate uncontrolled emissions from each unit operation as follows:

E = EF x T / 2000

where: E = annual emissions (ton/yr) EF = emission factor (lb/ODT or lb/MSF-specified basis) T = process throughput (ODT/yr or MSF/yr-specified basis)

### 3-14 To estimate baseline emissions, the emission reduction achieved by air pollution control devices (APCD’s) in place on unit operations was taken into account. Control devices that achieve significant reduction of HAP and THC include biofilters and inci neration-based controls (e.g., regenerative thermal oxidizers [RTO’s], regenerative catalytic oxidizers [RCO’s], thermal oxidizers [TO’s], and thermal catalytic oxidizers [TCO’s]). Emission factors were available for several, but not all, of the unit operations that are presently controlled with biofilters and incineration-based controls. If a complete set of emission factors based on inlet and outlet test data for a single control device was available, the set of emission factors was used to estimate baseline emissi ons. Otherwise, the achievable percent reduction in emissions for the control device was used as follows:
E = EF x T / 2000 x (1-R)

where: R = percent reduction achievable with the control device (see table below)

Control device HAP reduction THC reduction
Biofilter 95% 80% RTO, RCO, TO, & TCO 95% 95%

If only a portion of an exhaust stream was cont rolled (e.g., as with semi-incineration where only a portion of the exhaust is routed to a combustion un it), then controlled emissions were estimated for the controlled portion of the exhaust a nd uncontrolled emissions were estimated for the remaining exhaust. Because plant-specific capture effici ency information is not readily available, presses and board coolers without a permanent total enclosure that are routed to an APCD were assumed to operate with 50 percent capture efficiency.
Following estimation of uncontrolled and baselin e emissions for each unit operation, annual emissions for each facility were totaled. If ther e were facilities with no available information was available (e.g., plants that claimed their entire MACT survey confidential or plants that never responded to the survey), then the averag e facility-specific emissions for plants making the same product was used to approximate the emissions from plants with no available information. The emissions from all facilities were summed to obtain nationwide emission estimates.

3.2.3 Nationwide HAP Emission Estimates
Exhibit 3-5 presents the total nationwide uncontrolled and baseline emission estimates for each product type. Uncontrolled emissions are the emissi ons that occur before the application of a HAP emission control device. Baseline emission estimates take into account the HAP emission controls currently in place on HAP sources in the industry. Exhibits 3-6 and 3-7 present the nationwide uncontrolled and baseline speciated HAP emission estimates for each product type.

### 3-15 To estimate the emissions and emission reduc tions associated with compliance with this proposed rule, it is necessary to determine the number of major sources that may be subject to the rule. Major sources are facilities with the potential to emit 10 or more tpy of any single HAP or 25 or more tpy of any combination of HAP. The number of major sources was approximated using the uncontrolled emission estimates (scaled up to reflect potential to emit) for each facility.
The emission estimates presented in this chapte r are based on equipment throughput at plant production levels. Plant capacity typically exceeds pl ant production. Thus, a facility’s potential to emit may be greater than the emissions estimated for each facility at plant production levels. To account for this, an average ratio of plant production to plant capacity was determined based on the non-CBI responses to EPA’s MACT survey. On average, plywood (hardwood and soft wood) and reconstituted wood products plants were found to operate at around 75 percent of their plant capacity. Engineered wood products plants were found, on average, to opera te at 60 percent of their capacity. For purposes of determining which facilities may be major sources based on potential to emit, the uncontrolled emission estimates for each facility were scaled up by 25 or 40 percent before comparison to the 10- or 25-tpy major source thresholds. Exhibit 3-8 presents the estimated number of major sources by product type.
Because of the uncertainty in the emission estim ates and lack of knowledge about the specific operations at facilities the numbers of major sources presented in Exhibit 3-8 are merely estimates. Major source determinations depend on the types of ope rations at a facility and facility-specific factors. There may be operations and HAP emission sources at wood products facilities that have not been accounted for in the emission estimates (e.g., plan ts that manufacture furniture in addition to particleboard). Plants with a dditional onsite operations may be major sources regardless of their plywood and composite wood products operations. Then again, there may be plants that were determined to be major sources in this analysis th at are not major sources due to uncertainty in the emission estimates or potential to emit. The purpose of the analyses discussed in this document is to estimate – on a nationwide scale – emissions from pl ywood and composite wood pr oducts plants and the number of major sources. On a nationwide scale, it is unlikely that the uncertainties in the emission estimates or number of major sources will have a significant impact on the direction of the plywood and composite wood products rulemaking.

The reduction in emissions of total HAP and TH C is the difference between baseline emissions and the emissions expected to remain following im plementation of the MACT floor level of control identified for the PCWP standards. Baseline emissions reflect the level of air pollution control that is currently used at PCWP plants. The MACT floor c ontrol level reflects the level of control that will be used following implementation of the PCWP standa rds. The following assumptions were used when estimating emissions at the MACT floor control le vel: (1) plants will install RTO on all process units that require controls to meet the MACT floor; (2 ) presses at conventional particleboard, MDF, OSB, and hardboard plants will be fully enclosed by a PTE that captures and routes 100 percent of the emissions from the press area to an RTO; and (3) WESP will be installed upstream of RTO for new RTO installations on rotary strand dryers. The nati onwide HAP and THC emission reduction was calculated by subtracting the emissions remaining at the MACT floor control level from the baseline emissions. Exhibit 3-9 presents the nationwide HAP and THC emissions reduction. 14

3.2.4 Nationwide Emission Estimates - Non-HAP Species
As mentioned earlier in this chapter, there ar e reductions in pollutants other than HAPs as a result of compliance with this rule. There are reductions of coarse particulate matter (PM 10 ), volatile organic compounds (VOC), and carbon monoxide (CO) , and increases in nitrogen oxides (NOx), and

### 3-16 sulfur dioxide (SO 2 ). The reductions of PM 10 are estimated at 13,000 tons, the reductions of VOC (reported as total hydrocarbon) are estimated at 27,000 tons (see Exhibit 3-9), and the reductions of CO are estimated at 11,000 tons. The increase of NOx emissions is estimated at 2,400 tons, and there are potentially as many as 4,000 tons of additional SO 2 emissions. All emission estimates are estimated for the fifth year after the issuance of the rule. The methodology used to prepare these estimates is contained in the BID for this rule. 153-17Exhibit 3-5. UNCONTROLLED AND BASELINE HAP EMISSIONS ESTIMATESNo. ofplantsaUncontrolled emissions, ton/yrbBaseline emissions, ton/yrcProduct Total HAP THC as C Total HAP THC as CMDF 24 4,000 8,200 2,400 4,800Particleboardd51 5,700 13,000 5,400 13,000Hardboard 18 3,500 5,800 3,300 5,500Fiberboard 7 78 400 78 400OSB 37 7,100 19,000 3,500 5,400Softwood plywood 105 4,000 24,000 3,700 20,000Hardwood plywood 166 150 640 150 640EWP 39 310 990 290 790Nationwide totale447 25,000 73,000 19,000 50,000aSome plants make multiple products and are counted once for eachproduct they make (e.g., a particleboard and softwood plywoodplant).bUncontrolled emissions represent the emissions that occurbefore the application of HAP emission control devices.cBaseline emissions reflect the application of HAPemission controls in the industry as of April 2000.dIncludes conventional and molded particleboard.eNationwide emission totals may not exactly match sum due to rounding.3-18Exhibit 3-6. SPECIATED NATIONWIDE UNCONTROLLED HAP EMISSIONSBY PRODUCT TYPEProductEstimated HAP’s emitted, ton/yrAcetaldehyde Acrolein Formaldehyde Methanol Phenol Propionaldehyde Other HAPaTotalfMDF 48 1 1,700 2,200 93 1 27 4,000Particleboardb230 56 1,300 3,800 150 20 160c5,700Hardboard 320 76 580 2,100 99 250 52d3,500Fiberboard 9 1 17 45 1 0 6 78OSB 1,500 540 890 3,500 340 88 280e7,100Softwoodplywood450 26 280 2,900 150 24 170 4,000Hardwoodplywood20 0 11 81 15 0 22 150EWP 53 4 36 140 46 8 19e310Totalf2,600 700 4,800 15,000 890 390 730 25,000aOther HAP’s include benzene, cumene, methylene chloride,MEK, MIBK, styrene, toluene, m,p-xylene, and o-xylene.bIncludes conventional and molded particleboard.cIncludes HAPs listed in footnote “a” plus acetophenone, biphenyl, bis-(2-ethylhexyl phthalate), bromomethane, carbon disulfide,carbon tetrachloride,chloroform, chloromethane, di-n-butyl phthalate, ethyl benzene, hydroquinone, n-Hexane, 1,1,1-trichloroethane, and 4-methyl-2-pentanone.dIncludes HAPs listed in footnote “a” plus chloroethane, chloromethane, ethyl benzene,m.p-cresol, and o-cresol.eIncludes HAPs listed in footnote “a” plus MDI.fTotals may not exactly match sum due to rounding.3-19Exhibit 3-7. SPECIATED NATIONWIDEBASELINE HAP EMISSIONSBY PRODUCTProductEstimated HAP’s emitted, ton/yrAcetaldehyde Acrolein Formaldehyde Methanol Phenol Propionaldehyde Other HAPaTotalfMDF 29 1 1,000 1,300 51 0 17 2,500Particleboardb200 50 1,200 3,700 140 18 150c5,400Hardboard 270 61 570 2,100 96 200 48d3,300Fiberboard 9 1 17 45 1 0 6 78OSB 570 200 370 2,000 210 32 69e3,500Softwoodplywood390 20 230 2,700 130 17 150 3,700Hardwoodplywood20 0 11 81 15 0 22 150EWP 47 4 30 140 46 7 16e290Totalf1,500 330 3,400 12,000 690 270 480 19,000aOther HAP’s include benzene, cumene, methylene chloride,MEK, MIBK, styrene, toluene, m,p-xylene, and o-xylene.bIncludes conventional and molded particleboard.cIncludes HAPs listed in footnote “a” plus acetophenone, biphenyl, bis-(2-ethylhexyl phthalate), bromomethane, carbon disulfide,carbon tetrachloride,chloroform, chloromethane, di-n-butyl phthalate, ethyl benzene, hydroquinone, n-Hexane, 1,1,1-trichloroethane, and 4-methyl-2-pentanone.dIncludes HAPs listed in footnote “a” plus chloroethane, chloromethane, ethyl benzene,m.p-cresol, and o-cresol.eIncludes HAPs listed in footnote “a” plus MDI.fTotals may not exactly match sum due to rounding.3-20Exhibit 3-8. ESTIMATED NUMBER OFMAJOR SOURCESBY PRODUCTProduct No. of plantsaNo. of major sourcesbNo. of potentiallynon-major sourcesbMDF 24 24 0Particleboardc51 42 9Hardboard 18 18 0Fiberboard 7 3 4OSB 37 37 0Softwood plywood 105 87 18Hardwood plywood 166 0 166EWP 39 12 27Total 447 223 224aSome plants make multiple products and are counted once for eachproduct they make (e.g., a particleboard and softwood plywoodplant).bMajor sources are defined as facilities with the potential to emit10 or more tons per year (tpy) of any single HAP or 25 or more tpy of any combination ofHAP. Sources with HAP emissions estimatedto be below the 10/25 thresholds in this analysis are labeled as potentially non-major sources. The emissionestimation methodology described in this document does not accountfor onsite operations (e.g., furniture manufacture) not included in the plywood andcomposite wood products source category.cIncludes conventional and molded particleboard. Five of thepotentially non-major particleboard sources manufacture molded particleboard.3-21Exhibit 3-9. ESTIMATED NATIONWIDE REDUCTION IN TOTAL HAP AND THCProduct typeTotal HAP (ton/yr) THC (ton/yr)BaselineaMACT floor Reduction BaselineaMACT floor ReductionSoftwood plywood/veneer 3,700 3,043 657 19,631 9,709 9,922Hardwood plywood/veneer 161 161 0b640 640 0bMedium density fiberboard 2,469 345 2,124 4,763 572 4,191Oriented strandboard 3,513 753 2,760 5,362 1,755 3,607Particleboardc5,377 2,787 2,590 12,632 6,724 5,908Hardboard 3,291 752 2,539 5,478 2,103 3,374Fiberboard 78 78 0b398 398 0bEngineered wood products 298 230 68 793 617 176TOTAL 18,933 8,196 10,737 49,706 22,529 27,178aThe baseline emissions presented in this table may differ slightly from the values presented in Exhibits 3-4 through 3-6 because of slight differences incalculation procedures (i.e., use of a total HAP emission factor instead of summing speciated HAP emissions) and rounding.bThere is no impact because no plants are impacted bythe PCWP standards at the MACT floor control level.cIncludes conventional and molded particleboard.

### 3-22 3.3 Control Equipment and Costs

Traditional add-on pollution control devices are expected to be the types of control measures that firms will choose in order to comply with th e rule. Add-on air pollution control devices that are most likely to be used to comply with th e plywood and composite wood products rule include incineration-based controls. Among these types of controls are regenerative thermal oxidizers (RTO), regenerative catalytic oxidizers (RCO), and process in cineration. Biofilters is another add-on control that may be applied. The control device most commonly used to control emissions from plywood and composite wood products plants is the RTO. Theref ore, it was assumed that most plants would install RTO’s to comply with the rule. A number of RCO’s and biofilters are also presently used by plywood and composite wood products plants, and plants may choose to install these technologies to comply with the plywood and composite wood products rule. Th ere may be cost advantages to using RCO’s or biofilters instead of RTO’s for some plants. Howe ver, the cost analyses focus on use of RTO’s for simplicity (e.g., to minimize the number of cost algor ithms developed and to a void judgements regarding which plants may choose a particular technology).
Several facilities with large capacity heat energy systems currently use process incineration as a method of emissions control. Facilities may elect to use process incineration to comply with the rule. However, the applicability of process incineration is limite d to those plants that have or may later install large onsite heat energy systems. The capital and operating costs of process incineration are expected to be significantly lower than the costs of add-on controls.
The plywood and composite wood products rule c ontains emissions averaging provisions and production-based emission limits. It may be possible for some plants to reduce their control costs by complying with either the emissions averaging provisions or production-based emission limits. However, because there is no way to predict which plants might use the emissions averaging provisions or production-based emission limits, the cost estimates did not account for these options. Instead, the control cost estimates were developed assuming that all facilities would install RTO(s) to meet the 90 percent HAP reduction emission limit in the plywood and composite wood products rule.
Oriented strandboard plants typically install wet electrostatic precipitators (WESP’s) upstream of rotary dryer RTO’s to protect the RTO media from plugging. Thus, the capital and annual costs associated with WESP’s were modeled for rotary strand dryers.
Enclosures must be installed around presses in order to ensure capture of the press emissions that are routed to a control device. Thus, the capita l costs of permanent total enclosures (PTE’s) were included in the costing analyses. Annual costs associated with PTE’s (if any) were assumed to be minimal and were not included in the cost analyses.
This chapter presents the estimated nationwide capital and annualized costs for compliance with the PCWP rule. Compliance costs include the cost s of installing and operating air pollution control equipment and the costs associated with demons trating ongoing compliance (i.e., emissions testing, monitoring, reporting, and recordkeeping costs). Section 3.3.1 discusses the estimated air pollution control costs. Cost estimates associated with tes ting, monitoring, reporting, and recordkeeping are discussed in the Paperwork Reduction Act submissi on for the PCWP standards and are summarized in Section 3.4.

3.3.1 Basis For Control Costs

### 3-23 As discussed above, add-on air pollution control devices most likely to be used to comply with the PCWP rule include incineration-based contro ls (e.g., RTO, RCO, and process incineration) or biofilters. The control device most commonly used to control emissions from PCWP plants is the RTO. Therefore, for costing purposes, it was assumed that most plants would install RTO’s to comply with the rule. A number of RCO’s and biofilters are also presently used by PCWP plants. In addition, several plants with large capacity heat energy systems currently use process incineration. However, the applicability of process incineration is limited to those plants that have, or may later install, large onsite heat energy systems. There may be cost advantages to using RCO’s, biofilters, process incineration, other add-on control devices, or pollution prevention m easures instead of RTO’s for some plants. Plants may elect to use any of these technologies to comply with the rule, provided the technology limits HAP emissions to the levels specified in the rule. Howeve r, the cost analyses describ ed in this chapter focus on use of RTO’s due to their prevalence in the i ndustry and to minimize the number of cost algorithms developed and to avoid judgement s regarding which plants may choose a particular technology.
Oriented strandboard plants typically install W ESP’s upstream of rotary dryer RTO’s to protect the RTO media from plugging. Thus, the capital a nd annualized costs associated with WESP’s were modeled for rotary strand dryers. Available information indicates that WESP’s are not necessary for protecting RTO’s installed of other types of dryers (e.g., tube dryers) or on presses. 16 Therefore, with the noted exception of OSB dryers without WESP’s, the existing particulate abatement equipment on process units was assumed to be sufficient for protecting the RTO media. 17
Enclosures must be installed around presses to en sure complete capture of the press emissions before routing these emissions to a control device. Thus, the capital costs of permanent total enclosures (PTE’s) were included in the costing analyses. Annualized costs associated with PTE’s were assumed to be minimal and were not included in the cost analyses.
The following sections discuss the RTO, WESP, and PTE costs. Section 3.3.1.4 describes how plant-by-plant control costs were estimated, a nd Section 3.3.1.5 summarizes the nationwide control costs.

3.3.1.1 RTO Costs
An RTO cost algorithm was developed based on: (1) information from an RTO vendor with numerous RTO installations at PCWP plants, and (2 ) the costing methodology described in the EPA Air Pollution Control Cost Manual. 18,19 The RTO cost algorithm was used to determine RTO total capital investment (TCI) and total annualized cost (TAC) b ased on the exhaust flow to be controlled and annual operating hours. Development of the algorithm is discussed in Sections 3.4.1.1.1 and 3.4.1.1.2.

RTO Total Capital Investment

. 18,19
Equipment costs (including equipment, installa tion, and freight) were provided by the RTO vendor for four sizes of RTO’s. The 1997 equipmen t costs were not escalated because the Vatavuk Air Pollution Control Cost Index (VAPCCI) for 1997 (107.9) was slightly greater than the preliminary VAPCCI for RTO’s in fourth quarter 1999 (107.8). 20 According to the EPA Air Pollution Control Cost Manual, instrumentation is typically 10 percent of equipment cost (RTO and auxillary equipment); sales tax is typically 3 percent of the equipment cost; and freight is typically 5 percent of the equipment cost. Figure 3-1 presents the purchased equipment costs (PEC) supplied by the RTO vendor (minus freight), and shows that the equipment costs vary linearly w ith gas flow rate. The regression equation presented in Figure 3-1 was included in the RTO cost algorith m to calculate the equipment cost for the oxidizer

### 3-24 y = 8.5101x + 499194 R 2 = 0.991

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000

0 50,000 100,000 150,000 200,000 250,000 Flow rate , ds cfmPurchased Equipment Cost, $



### Figure 3-1. Variation in RTO purchased equipment cost with flow rate. and auxillary equipment for various gas flow rates. Instrumentation, sales tax, and freight were added to the calculated equipment costs to obtain the total PEC.
Direct installation costs for handling and erec tion, electrical, and piping were included in the equipment cost provided by the RTO vendor. Start-up costs were also included in the equipment cost provided by the RTO vendor. These costs are typically 22 percent of the PEC. Thus, these costs were subtracted from the PEC before further calcula tions based on the PEC were performed. Direct installation costs including foundation and support, in sulation for ductwork, and painting were estimated

according to the procedures in the EPA Air Polluti on Control Cost Manual. Because PTE’s were costed separately, no enclosure building was costed in the RTO algorithm. Site preparation costs and indirect installation costs (e.g., engineering, field expense, contractor fees, performance tests, and contengencies) were estimated according to the procedures in the EPA Air Pollution Control Cost Manual. The TCI was calculated by summing the PEC, direct and indirect installation costs, and site preparation cost.

RTO Total Annualized Cost
Total annualized costs consist of operating and maintenance labor and material costs, utility costs, and indirect operating costs (including capital recovery). Operating and maintenance labor and material costs were estimated based on th e RTO vendor information because the RTO vendor assumptions led to higher costs than the EPA Air Po llution Control Cost Manual and were assumed to be more representative of the PCWP industry. The ope rator labor rate supplied by the RTO vendor was $19.50 per hour.

### 3-25 y = 0.1479e 2E-05x R 2 = 0.9981

0 2 4 6 8

0 50000 100000 150000 200000 250000 Flow rate, dscfmMMBTU/HR



### Figure 3-3. Relationship between RTO natural gas consumption and flow rate. y = 0.0052x + 3.283 R 2 = 1 0 500 1000 1500

0 50000 100000 150000 200000 250000 Flow rate, dscfmkW



### Figure 3-2. Relationship between RTO el ectricity consumption and flow rate. The RTO electricity use and natural gas use was provided by the RTO vendor for the four RTO sizes. Figures 3-2 and 3-3 present the relationships betw een flow rate and electricity and flow rate and natural gas use, respectively. As shown in the figures, there is a linear relationship between RTO electricity consumption and flow rate, and an e xponential relationship between RTO fuel consumption and flow rate.

### 3-26 Electricity costs were estimated by the RTO vendor at $0.045 per kilowatt-hour (kWh). The RTO vendor estimated natural gas costs at $3 per m illion British thermal units (MMBtu). Both of these energy prices match closely with currently published nationwide average prices. 21,22 Thus, the electricity and natural gas prices supplied by the RTO vendor were used in the cost algorithm.
Indirect operating costs were estimated using the methodology described in the EPA Air Pollution Control Cost Manual. The capital recove ry cost was estimating assuming an RTO equipment life of 15 years (based on the RTO vendor information) and a 7-percent interest rate. The TAC was calculated by summing the direct and indirect annual operating costs.
Application of the RTO Cost Algorithm to Estimate Capital and Annualized Costs.
The complete RTO cost algorithm, which pr edicts RTO capital and annualized costs as a function of operating hours and flow rate, was r un several times assuming 8,000 operating hours per year and various flow rates. The 8,000-hr operating time was selected based on the results of the EPA’s MACT survey, which show industry average operating hours of slightly less than 8,000 hr/yr. 10 Although several plants operate process lines more than 8,000 hr/yr, their equipment and control devices may or may not be operated for more than 8,000 hr/yr. Thus, 8,000 hr/yr was selected as the control device operating time for purposes of costing.
The TCI and TAC values generated for each fl ow rate using the RTO cost algorithm are presented in the BID for this rule. A regression e quation was developed based on the calculated TCI and TAC for each flow rate. Figures 3-4 and 3-5 presen t the relationships between flow rate and RTO capital costs and flow rate and annualized costs, respectively, and the associated regression equations.

3.3.1.2 WESP Costs
A WESP cost model was developed based on: (1) information from a WESP vendor with many WESP installations at wood products plants, and (2) the costing methodology described in the EPA Air Pollution Control Cost Manual for electrostatic precipitators (ESP’s). 19,23 The cost model was used to determine TCI and TAC for WESP’s used to control pa rticulate emissions from OSB rotary dryers. The WESP vendor provided cost information for a WESP sized to treat 27,650 dry standard cubic feet per minute (dscfm) of OSB rotary dryer exhaust. This flow rate matches closely with the flow rates for

### 3-27 y = 317394e 8E-06x
R 2 = 0.9887

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000

- 50,000 100,000 150,000 200,000 250,000 300,000 350,000 Flow rate, dscfmTAC ($)



### Figure 3-5. Variation in RTO total annualized cost with flow. y = 13.797x + 809310 R 2 = 1

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

- 50,000 100,000 150,000 200,000 250,000 300,000 350,000 Flow rate, dscfmTCI ($)



### Figure 3-4. Variation in RTO total capital investment with flow. uncontrolled OSB. Thus, the model TCI and TAC could be applied for each dryer to be controlled (i.e.,

the model need not calculate different costs for vary ing flow rates). The WESP cost model is presented in the BID for the rule. Developm ent of the model is discussed below.
WESP Total Capital Investment.
The WESP and auxiliary equipment costs (which makeup the PEC) were provided by the WESP vendor. These PEC include the cost of the WESP; pumps, piping, and tanks ; ducting (including the quench); fans; and a 1-gallon per mi nute (gpm) blowdown solids removal system. Instrumentation costs were also provided by the WESP vendor. Sales tax a nd freight were added into the total PEC based on the methodology described in the EPA Air Pollution Control Cost Manual.

### 3-28 The direct installation costs such as foundation and support, handling and erection, electrical, piping, insulation for ductwork, and painting were included in the PEC provided by the WESP vendor. It was assumed that no building would be necessary for the WESP and that there would be no additional site preparation costs. Several indirect costs were also included in the equipment cost supplied by the WESP vendor, including engineering, construction and field expense, start-up, and contingencies. Because WESP’s are already widely used at OSB plants, it was assumed that no model study would be necessary for the WESP although the EPA Air Pollution Control Cost Manual mentions model-study costs for ESP’s.
The cost of a performance test was included in th e WESP cost model. According to the EPA Air Pollution Control Cost Manual, the performance test is typically 1 percent of the PEC. Thus, 1 percent of the model PEC (minus the direct and indirect in stallation costs included in the PEC) was used as the cost of the performance test. The direct and indir ect costs were summed to arrive at the WESP TCI.

WESP Total Annualized Cost
The direct annualized costs include operating and maintenance labor and materials, utilities, and waste disposal. The operating labor cost was based on 1,146 hr/yr (provided by the WESP vendor) at $19.50/hr (the labor rate used in the RTO cost algorithm). The annual cost of operating materials, including caustic and defoamer, was provided by th e WESP vendor. The maintenance labor rate was estimated as 110 percent of the operating labor rate . The maintenance hours per year were estimated based on information supplied WESP vendor. The cost of maintenance materials (including replacement of one pump seal per year, and one voltage controlle r every 4 years, and miscellaneous materials) was supplied by the WESP vendor.
The electricity necessary to power the WESP components (approximately 2,076,000 kWh/yr for all WESP components) was based on information provided by the WESP vendor. An electricity cost of $0.045/kWh was used (the same as used in the RTO co st algorithm). A $0.20/gal cost for makeup water was used based on the EPA Air Pollution Control Co st Manual. The WESP water recirculation rate, makeup water addition rate, and bl owdown generation rates were pr ovided by the WESP vendor. The EPA Air Pollution Control Cost Manual indicated that wastewater treatment costs may range from $1.30 to $2.15 /1,000 gallons. Methods of WESP wastewater treatment and disposal could include evaporation from settling ponds, discharge to a municipal water treatment facility, or spray irrigation. The wastewater treatment and disposal cost for the blowdown was assumed to be $2.15 per gallon. The wastewater percent solids of 7.6 percent was b ased on the average from th e MACT survey responses. 11 It was assumed that the solids would ultimately be disposed in a landfill (although they could be burned onsite or used for soil amendment). The trucking cost for hauling sludge to landfill was estimated to be $0.20 yd3-mi. 22 The landfill was assumed to be 20 miles away, and a $20/ton landfill tipping fee was used. 22 The density of the solids was assumed to be 0.5 ton/yd3 for wet wood particulate (given that the density of water is 0.84 ton/yd3 and the density of wood is from 30 to 50 percent of the density of water).
The indirect operating costs were estimated b ased on the methodology described in the EPA Air Pollution Control Cost Manual. The capital recove ry cost was estimated assuming a WESP equipment life of 20 years (based on the EPA Air Pollution Control Cost Manual and WESP vendor information) and a 7-percent interest rate. The TAC was calcu lated by summing the direct and indirect annual operating costs.

### 3-29 3.3.1.3 Permanent Total Enclosure (PTE) Costs
The capital costs associated with installation of a PTE were based on available information in the project files on the capital cost of PTE’s for particleboard, MDF, and OSB presses. 24 These costs included the following elements:
• installed cost of the PTE (including fan system) • ductwork • instrumentation and wiring • fire suppression (in some cases) • site supervision • start-up and testing
Based on the available cost information, the fo llowing algorithm was developed to estimate the PTE costs for various exhaust flowrates: TCI PTE = 1.2031 x Q dscfm + 425,760 where: TCI PTE = the total capital cost of the permanent total enclosure, $ Q dscfm = design exhaust flow rate from PTE, dr y standard cubic feet per minute

Available information on actual exhaust flow rates from PTE’s installed around reconstituted wood product presses was used to develop model flow rates for the various press applications. 25 Information on press vent flow rates from unenclosed presses was available, but not used, because unenclosed press flow rates are altered when a PTE is installed around a press. 26 The cost algorithm was then applied to the model flow rates to estimate the capital costs of the model PTE’s as shown in Exhibit 3-10. The costs were rounded to the nearest $1,000. In the case of the particleboard press PTE, the cost was set at $485,000 (instead of $481,000, which is the value derived from the cost algorithm) because the PTE model flow rate was similar to those for the MD F and hardboard presses, and applying the same cost to all three types of press PTE’s simplified the costing analyses. Annualized costs were not developed for PTE’s because the annualized cost of the fans is al ready accounted for in the estimated costs of the RTO’s.

Exhibit 3-10. PRESS ENCLOSURE EXHAUST FLOW RATES AND CAPITAL COSTS Equipment type Flow rate, dscfm PTE capital cost Particleboard press 45,524 $485,000 OSB press 97,509 $543,000 MDF or dry/dry hardboard press 49,413 $485,000 Wet/dry or wet/wet hardboard press 49,209 $485,000

3.3.2 Plant-by-Plant Costing Approach

The control costs associated with the PCWP st andards were estimated for each plant and were summed to arrive at a nationwide estimate of control costs. The PCWP standards apply only to major sources of HAP emissions. Therefore, cost estimates were developed for only those plants that were assumed to be major sources. 15 The information used to estimate the plant-by-plant control costs is described below.

### 3-30 3.3.2.1 Application of Control Costs to Process Units

The cost models discussed in Section 3.3.1 were applied to each plant that would likely need to install air pollution controls in order to meet the PCWP standards. Plant-specific information on process units (e.g., dryers, presses) and controls was taken from the MACT survey responses. 10,11,12 In addition, information about the presence of PTE’s on presses was taken from the MACT survey responses. 10 If information about press enclosures was not provided in the MACT survey responses, or was claimed confidential, the press was assumed to be unenclosed if it was uncontrolled or enclosed if it was controlled for purposes of costing.
Some plants have begun operation and other plants have added e quipment or controls since EPA conducted the MACT survey. Such changes were acc ounted for in the nationwide cost estimates. A separate memorandum summarizes the changes to plan ts that have occurred following the EPA’s MACT survey. 13
The process units and controls present at each plan t were reviewed to determine which of the assumed what control equipment (i.e., RTO, WESP, or PTE) the plant would need to install to meet the PCWP standards based on the MACT floor control leve ls. The MACT floor control levels are based on the information presented in the BID for this rule. 6 Exhibit 3-2 summarizes the process units for which control equipment would be required to meet the MA CT floor and the control equipment costed for these process units. At each plant, the exhaust gas flow rates from the applicable uncontrolled process units listed in Exhibit 3-11 were summed to yield a plan t-wide uncontrolled exhaust gas flow rate. Process units already equipped with controls to meet th e MACT floor were not included in the plant-wide uncontrolled gas flow rate estimates. The procedur es for estimating the uncontrolled gas flow rates from process units and the application of the cost algorithms is discussed in the following section.

### 3-31 Exhibit 3-11. CONTROL EQUIPMENT COSTED FOR PROCESS UNITS WITH CONTROLLED MACT FLOOR Existing process units with control requirements Control equipment costed Notes Tube dryers (primary and secondary) RTO Tube dryers are located at particleboard, MDF, and hardboard plants Rotary strand dryers WESP and RTO Rotary strand dryers are located at OSB and LSL plants. Assumed that the WESP is not needed for plants that already have an RTO without a WESP. Assumed that plants that currently operate an EFB or multiclone alone (i.e., with no RTO) would install a WESP with the RTO. Conveyor-type strand dryers RTO Conveyor strand dryers are located at OSB and LSL plants.

Rotary green particle dryers RTO Rotary green pa rticle dryers are located at particleboard, MDF, or hardboard plants and process furnish with >30% (dry basis) inlet moisture content at dryer inlet temperature of >600°F Hardboard ovens RTO Includes bake and tempering ovens Softwood veneer dryers RTO Softwood veneer dryers are located at softwood plywood, hardwood plywood, LVL, and PSL plants and dry $ 50% (by volume, annually) softwood veneer

Pressurized refiners None The exhaust from pressurized refiners typically passes through a tube dryer and exits through the tube dryer control device. Therefore, it was not necessary to cost separate control equipment for pressurized refiners. Pressurized refiners are located at MDF and hardboard plants.

Reconstituted wood products presses PTE and RTO Reconstituted wood products presses are located at hardboard, MDF, OSB, and particleboard plants

Exhaust Flow Rate to Be Controlled
If provided in the non-confidential MACT surv ey responses, process-unit specific exhaust flow rate, temperature, and percent moisture were used to determine the dry standard flow rate for each process unit. If sufficient information was not provide d in the MACT survey response to determine dry standard flow rates (or the information was claimed confidential), then default values were used for the flow rate. The default values were based on the av erage value for other similar process units at plants that provided enough non-confidential information to calcu late the dry standard flow rate. Exhibit 3-12 summarizes the default flow rates used in the cos ting analyses. The average flow rates from press enclosures are described in Section 3.3.1 and were used for all presses.

### 3-32 Exhibit 3-12. DEFAULT FLOW RATES Process line Equipment type Flow rate (dscfm) Particleboard Rotary green particle dryer 35,731 Tube dryer 14,955 OSB Rotary strand dryer 32,478 Conveyor-type strand dryer 37,810 MDF Primary tube dryer (single-stage or first stage of staged dryer) 79,173

Secondary tube dryer (second stage of staged dryer) 18,195

Plywood Softwood veneer dryer 12,062 Hardboard Bake oven 4,742
Tempering oven 4,055 Primary tube dryer (single-stage or first stage of staged dryer) 37,436

Secondary tube dryer (second stage of staged dryer) 31,728

Several plants have multiple process units requi ring controls. The flow rates for these process units were summed and divided across control equipment as necessary. In most cases, the total dryer flow was assumed to be routed to one or more RTO’ s dedicated to controlling dryer exhaust and the total press flow was assumed to be routed to one or more RTO’s dedicated to controlling press exhaust. Because RTO fuel costs increase exponentially with gas flow rate, RTO sizes were assumed to remain less than about 150,000 dscfm. (The largest RTO in mentioned in the MACT survey responses was around 150,000 dscfm.)
In some cases, dryers and presses were assumed to be routed to the same RTO, provided that the total dryer and press flow remained under 150,000 dscfm. For example, two RTO’s (103,500 dscfm each) would be costed for a MDF plant with 2 dryers (79,000 each) and 1 press (49,000) assuming that the flow for both dryers and the press could be comb ined and split equally across the two RTO’s. This approach seems reasonable given that several MDF plan ts currently route dryer and press exhaust to the same RTO.

### 3-33 Calculation of Nationwide Control Costs
The total plant-by-plant control cost was cal culated by summing the control cost associated with each RTO, WESP, and PTE costed for each plant. The number of control devices at each plant depended on the number of process units and the exhaust flow to be controlled at the plant. In some cases, only one control device was costed, while in ot her cases, multiple control devices were costed for a plant.
Some plants claimed all relevant portions of their MACT survey responses confidential. In addition, a MACT survey response was not available fo r a few plants likely to be impacted by the PCWP standards. Without a non-confidential MACT survey response, information was not available to develop plant-specific cost estimates. Therefore, the aver age cost for all other plants manufacturing the same product was used to approximate the costs for pl ants for which there was no non-confidential plantspecific information.
The nationwide capital and annualized control co sts were determined by summing the total plant-specific costs.
3.3.3 Summary of Nationwide Control Costs
Exhibit 3-13 summarizes the nationwide control costs for different product types. The nationwide total capital cost for control equipment is estimated to be $473 million and the nationwide total annual cost for control equipment is es timated as $139 million (1999 dollars). Exhibit 3-14 presents the dollars of total annualized costs per ton of HAP and THC reduced.
3.4 Testing, Monitoring, Reporting, And Recordkeeping Costs
Compliance with the PCWP standards must be demonstrated through performance testing, ongoing monitoring of process or control device operati ng parameters or emissions, periodic reporting to the government agency that implements the PCWP rule, and recordkeeping. There are capital and annualized costs associated with these testing, m onitoring, reporting, and recordkeeping activities. These costs, which are estimated and documented in the supporting statement for the Paperwork Reduction Act submission, and are summarized in this section. 273-34Exhibit 3-13. ESTIMATEDNATIONWIDE CONTROL COSTS FOR THE PCWPINDUSTRYProduct type No. of plantsaNo. of plantsimpacteda,bProcess units impacted Control equipmentTotal capitalcosts, $MMTotal annualcosts, $MMSoftwood plywood/veneer 105 66 softwood veneer dryers RTO $87.1 $28.4Hardwood plywood/veneer 166 0 N/A no control $0.0 $0.0Medium density fiberboard 24 18 dryers, presses RTO for dryers andPTE/RTO for presses$71.3 $21.5Oriented Strandboard 37 23 dryers, presses WESP/RTO for dryers andPTE/RTO for presses$94.6 $26.5Particleboard(conventional and molded)51 38 green rotary particledryers, pressesRTO for dryers andPTE/RTO for presses$125.2 $34.2Particleboard (agriboard) 5 0 N/A no control $0.0 $0.0Hardboard 18 18 tube dryers, presses,ovensRTO for dryers andPTE/RTO for presses$84.4 $24.5Fiberboard 7 0 N/A no control $0.0 $0.0Engineered wood products 41 3 softwood veneer dryers,strand dryersRTO for veneer dryers andWESP/RTO for strand dryers$10.3 $3.2TOTAL: 454 166 $473 $139aSome plants manufacture more than one product type. These plants are listed once for each product type manufactured.bThe number of plants impacted may be different from the number of plants nationwide for one of the following reasons: (1) someplants are not major sources;(2) some plants already have all of the necessary control equipment; or (3) a few plants are major sources but do not operate any process units for which thereare control requirements (e.g., glu-lam plants).

### 3-35 Exhibit 3-14. DOLLARS (IN TOTAL ANNUALIZED COSTS) PER TON OF HAP AND THC REDUCED Product type HAP, $/ton THC, $/ton Softwood plywood/veneer $43,000 $2,900 Hardwood plywood/veneer NA NA Medium density fiberboard $10,000 $5,100 Oriented Strandboard $9,200 $7,100 Particleboard (all types) $13,000 $5,800 Hardboard $9,300 $7,000
Fiberboard NA NA Engineered wood products $47,000 $18,000 Overall industry $13,000 $5,000

The annual costs associated with testing, mon itoring, reporting, and recordkeeping activities include reporting and recordkeeping labor; annualized capital for monitoring equipment, file cabinets, and performance tests; and the operation and maintena nce costs associated with monitoring equipment. The capital costs include capital for monitoring e quipment, file cabinets and performance tests. Performance tests are considered to be capital costs b ecause plants will typically hire a testing contractor to conduct the performance tests.
The total nationwide capital cost associated with testing, monitoring, reporting, and recordkeeping is estimated to be $5.8 million and the total nationwide annualized cost is estimated to be $5.6 million (1999 dollars). These costs were deve loped based on the information presented in the Paperwork Reduction Act submission for the first 3 year s following the effective date of the PCWP rule. The costs apply for the 223 PCWP plants that are e xpected to be major sources. There are 57 facilities that incur monitoring, recordkeeping, and reporting costs but do not incur control costs from compliance with this rule.

3.5 REFERENCES

### 3-36 1. United States Congress. Clean Air Act, as amended October 1990. 42 U.S.C. 7401 et seq. Washington, DC. U.S. Government Printing Office.
2. U. S. Environmental Protection Agency. National Emission Standards for Hazardous Air Pollutants for Source Category: Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry and Other Pro cesses Subject to the Negotiated Regulation for Equipment Leaks; Determination of MACT “Floor.” 59 FR 29196. Washington, DC. U.S. Government Printing Office. June 6, 1994.
3. Memorandum from K. Hanks and B. Nicholson, MRI, to P. Lassiter, EPA/ESD. April 16, 1998 (Finalized 5/28/98). Trip report for February 12, 1998 site visit to Timber Products Company particleboard and hardwood plyw ood plant in Medford, Oregon.
4. R. Nicholson, MRI, to D. Word, NCASI. February 17, 2000 (Confirmed via Email on 9/7/00). Contact report to (1) find out if oxygen measu rement data were available from the NCASI MACT emissions test program, and (2) to get some information on typical oxygen concentrations in dryer and press exhaust at plywood and composite wood products plants.
5. Memorandum from R. Nicholson, MRI, to M. Kissell, EPA/ESD. May 26, 2000. Control Device Efficiency Data for Add-on Control Devices at PCWP Plants.
6. Memorandum from K. Hanks and B. Nicholson, MRI, to M. Kissell, EPA/ESD. July 13, 2000. Determination of MACT floors and MACT for the Plywood and Composite Wood Products Industry.
7. National Council of the Paper Industry for Air and Stream Improvement (NCASI) Method IM/CAN/WP-99.01, Impinger/Canister Source Sampling Method for Speciated HAPs at Wood Products Facilities. 1999.

8. Reference 6.

9. Memorandum from K. Hanks and D. Bullock, MRI, to M. Kissell, EPA/ESD. June 9, 2000. Baseline Emission Estimates for the Plywood and Composite Wood Products Industry.

10. Memorandum from D. Bullock, K. Hanks, and B. Nicholson, MRI to M. Kissell, EPA/ESD. April 28, 2000. Summary of Responses to the 1998 EPA Information Collection Request (MACT Survey) -- General Survey.
11. K. Hanks, B. Threatt, and B. Nicholson, MRI to M. Kissell, EPA/ESD. May 19, 1999. Summary of Responses to the 1998 EPA Information Collection Request (MACT Survey) -- Hardwood Plywood and Veneer.

### 3-37 12. K. Hanks, B. Threatt, and B. Nicholson, MRI to M. Kissell, EPA/ESD. January 20, 2000. Summary of Responses to the 1998 EPA Information Collection Request (MACT Survey) -- Engineered Wood Products.
13. Memorandum from K. Hanks, MRI, to Project Files. April 18, 2000. Changes in the population of existing plywood and composite wood produc ts plants and equipment following the information collection request.
14. Memorandum from D. Bullock and K. Hanks, MR I, to M. Kissell, EPA/ESD. April 27, 2000. Documentation of Emission Factor Development for the Plywood and Composite Wood Products Manufacturing NESHAP.
15. Background Infomation Document for the Proposed Plywood and Composite Wood Products NESHAP. U.S. EPA/OAQPS, September 2000.

16. Suchsland, O., and G. Woodson, Fiberboard Manufacturing Practices in the United States , John Wiley & Sons, New York, 1991, pp. 151-153.

17. K. Corrigan, North Dakota Department of Hea lth, Division of Environmental Engineering. February 11, 1997. Performance Test Report Review: Primeboard, Inc.

18. Facsimile from J. Seiwert, Smith Environmental Corporation, to L. Kesari, EPA/OECA. October 31, 1997. Revised emissions abatement systems RTO pricing (Smith Proposal BO7-95- 156-1, Trinity Consultants)
19. EPA Air Pollution Control Cost Manual (Sixth Edition), U.S. Environmental Protection Agency, April 26, 2002. EPA -452/B-02-001. Found on the Internet at www.epa.gov/ttn/catc/products.html#cccinfo.
20. Vatavuk Air Pollution Control Cost Indexes (VAPCCI), Chemical Engineering , March 2000, p. 150.
21. Energy Information Administration, Form EIA-826, “Monthly Electric Utility Sales and Revenue Report with State Distributions.”
22. Energy Information Administration, Natural Gas Monthly , February 2000, p. 60.
23. Letter and attachments from S. Jaasund, Geoenergy International Corporation, to B. Nicholson, MRI. March 28, 2000. Geoenergy WESP Capital and Operating Costs.

### 3-38 24. Memorandum from B. Nicholson, MRI, to Pl ywood and Composite Wood Products Project File. July 31, 2000. Cost of Permanent Total Enclosures. (Confidential Business Information)
25. Memorandum from B. Nicholson, MRI, to Pl ywood and Composite Wood Products Project File. July 31, 2000. Exhaust Gas Flowrate Inform ation for Enclosed Presses. (Confidential Business Information)
26. Memorandum from D. Bullock and K. Hanks, MR I, to P. Lassiter, EPA/ESD. October 27, 1998. Trip report for visit to Temple-Inland Forest Products plant in Diboll, Texas.
27. Paperwork Reduction Act Submission, Suppor ting Statement, Plywood and Composite Wood Products, 2000.4-1 

## 4 ECONOMIC IMPACT ANALYSIS

4.1 Results in Brief
This economic impact analysis presents the results of modeling the effects of the plywood and composite wood products NESHAP upon affected faciliti es, firms, markets, and industries. The analysis shows that product prices increase for each of the four industry sectors included in the economic model, from 0.9 percent for the softwood plywood i ndustry to 2.5 percent for the particleboard and medium density fiberboard industry. Output is expected to decrease from 0.1 percent for the softwood plywood industry to 0.7 percent for the particleboard and medium density fiberboard industry. Exports of these products are expected to decline by no more than 0.7 percent for these four industries, while imports are expected to rise. Only one product line closure at an affected facility is expected, and employment at affected firms is expected to declin e by only 0.3 percent. In addition, an analysis of effects of this rule on the supply, distribution, or u se of energy finds that these effects are not significant.

The economic and energy impacts depending on e ligibility of sources to become part of a delisted low-risk subcategory can be found in Appendix A of this RIA.

4.2 Introduction

This NESHAP addresses the emissions of hazar dous air pollutants (HAPs) from facilities that produce plywood and composite wood products. As describ ed in Chapter 3, the rule will result in some facilities in this industry incurring costs associated with controlling HAP emissions. The addition of these control costs will directly affect the indi vidual facilities because their costs of production will increase. In addition, the addition of compliance cost s may also have an effect on the overall markets for plywood and composite wood products through market price changes. Depending on market conditions, these changes could occur if facilities with complian ce costs increase their prices, reduce their output, or cease operations altogether.
This chapter presents the result of the Economic Impact Analysis (EIA) performed to estimate the economic changes that are expected to occu r as a result of the NESHAP for the plywood and composite wood products industry U. S. EPA, 1999a). The goal of the assessment is to develop estimates of the following impact measures.
• Market price changes • Market quantity changes • International trade effects • Size and distribution of social costs4-2 Chapter 2 presented a profile of the different sectors within the plywood and composite wood industry, which provides market information n ecessary to design and implement the EIA for this industry. The plywood and composite wood products manufacturing industry affected by the proposed NESHAP rule includes five distinct market sectors.
• Softwood Plywood and Veneer (SWPW) • Oriented Strandboard (OSB) • Other Wood Composites (OWC), including • Particleboard and Medium De nsity Fiberboard (PB/MDF) • Hardboard (HB) • Engineered Wood Products (EWP)
For all but the EWP market sector, the Agency applied partial equilibrium (P/E) modeling techniques to estimate the economic impacts of the NESHAP rule for plywood and composite wood products. For reasons presented in Section 4.4 belo w, developing an estimate of the economic impacts of the rule on the EWP sector required a qualitative approach.
Section 4.3 presents the inputs for the P/E economic analysis, including producer characterization, market characterization, and complia nce costs of the regulation. Section 4.4 describes the approach to estimating the economic impacts on the SWPW, OSB, PB/MDF, and HB industry sectors, and Section 4.5 presents the results of the economic impact analysis. Section 4.6 presents the qualitative analysis of the EWP market sector. The economic analysis methodology and inputs are described more fully in the EIA.
4.3 Economic Impact Analysis Inputs

The first step of an impact assessment is deve loping information used to characterize the baseline conditions of the industry. Key information needed for EIA inputs is used to characterize the following.
• Individual producers • Product markets • Compliance costs

4.3.1 Producer Characterization
The primary source of baseline data on individual producers used in the EIA is a database developed using the data collected by 1998 ICR described in Chapter 2 (U.S. EPA, 1998). The information in the facility database allowed the char acterization of facilities according to several features needed for the analysis, including major products (SWPW, OSB, etc), baseline production volumes, and facility capacity. The baseline year for the analys is is 1997 as it corresponds to the year for which plywood and composite wood producers provi ded this information for the ICR.11 As mentioned in Chapter 1, some facilities in the “unaffected” category have monitoring, reporting, and record keeping costs of $25,194 per year.

4-3 For certain facilities, production and capacity information was not available, and was supplemented by additional research. Those fac ilities without specific production and capacity data were assigned an estimate based on the average produc tion and capacity data for facilities within the same market sector and size category (as determined by employment).

4.3.2 Plywood and Composite Wood Markets
The Plywood and Composite Wood Products industr y is a broad category encompassing the four distinct markets listed above: (1) SWPW, (2) OSB, (3) OWC, and (4) EWP. For reasons discussed in the EIA, the OWC sector is decomposed into two markets: PB/MDF and HB. The Agency developed P/E models representing each of these four markets.
Market level data used in this EIA are presen ted in Exhibit 4-1. The market prices and elasticities for each of the four markets were obt ained from various industry market reports and economic literature as described in Chapter 2. Tota l market volumes used in the models for each product are the sum of the production of all identified U.S. facilities (from the facility database) and imports from foreign producers. Total U.S. production for each market is the total production of all facilities identified in the EPA’s facility database. The producti on was also separated in to two subsets - the total production of affected facilities and the total production of unaffected facilities. 11 The source of foreign trade data on exports and imports of these products was presented in Chapter 2.4-4 Exhibit 4-1: Baseline Characterization of Plywood and Composite Wood Markets: 1997

Softwood Plywood Oriented Strandboard “Other Composites” PB/MDF HB Market price (1997$/cubic meter) $235 $185 $169 $1,322 Price Elasticity of Demand Construction -0.1034 -0.1034 -0.1149 -0.1149 Manufacturing/Other -0.2585 n/a -0.2872 -0.2872 Price Elasticity of Supply 0.42 0.42 0.42 0.42 Market quantity (thousand cubic meters) 17,568,254 9,595,121 11,646,227 1,768,930
Domestic production 17,568, 162 9,590,456 11,644,523 1,768,545 Affected 11,680,778 4,691,645 9,670,639 1,768,545 Unaffected 5,887,384 4,898,811 1,973,884 n/a Exports 1370 148 333 371 Imports 92 4,666 1,705 385 Sources: U.S. EPA facility database; Section 2; and Appendix B of the Economic Impact Analysis.

4.3.3 Facility Compliance Costs
As described in Chapter 3, the Agency devel oped compliance costs estimates for those facilities that must control HAP emissions in accordance with the regulatory requirements of the NESHAP rule. The EIA uses these costs to develop a “with regulati on” market equilibrium scenario used to estimate changes in individual facility production, total market volumes, market price, and social costs. Typically, the Agency adjusts th e compliance cost estimates from nom inal dollars to baseline dollars using the plant cost indices to be consistent with the baseline industry characterization of the economic model (U.S. EPA, 1999b). In this case, there was virtually no change in the plant cost indices between the baseline year of 1997 and current period, so no adjustment was made to the costs used in this analysis.

4.4 Economic Impact Analysis Methodology
The following section presents a summary of the approach used to assess the economic impacts of the NESHAP . The EIA contains a more detaile d description of the methodology used to analyze the economic impact of this regulation on each of the mark ets analyzed. The purpose of the EIA is to model the responses of individual producers and the overall ma rket to the imposition of compliance costs. For this EIA, the agency used a market-based economic model that reflects the production choices producers make in the face of changes in their individual production costs and changes in overall market prices.4-5 The economic model used in this analysis simu lates the short run decisions of the producers in response to operating cost and price changes within a given market. For each of the four markets, the model used in this analysis assumes that the mark et is perfectly competitive, based on the conclusions drawn from the information in the industry profile. In a competitive market, each individual facility takes the price as determined by th e market because they do not have the power to set the market price of the product. The approach used for this EIA assum es that the competitive market for each of the four products determines both prices and quantities (U.S. EPA, 1999b).
In the short run, a firm with an existing plan t will decide, based on the market price, how much output to produce with its capital stock (e.g., fixed inv estment in the plant and equipment) considered as constant. In this decision, the firm considers the costs of inputs that vary with output levels, such as materials and labor (U.S. EPA, 1999b). When the market price is equal to the average variable (operating) costs, the firm is only recouping the cost of its variable inputs. When the price is less than the firm’s variable costs, it will no longer produce output because it cannot recover all of its variable costs in the short run. When the ma rket price exceeds variable costs, th e firm can also recover a part of its fixed investment in the plant and equipment. In the long run, the firm must cover all of its fixed investment in the plant and equipment. Under this more stringent condition, the market price must exceed its average total costs, which include capital and variable input costs. In this analysis, which is short-run in timeframe, the model assumes that all firms wish to maximize its profits and will produce output using their existing plants as long as the market price even marginally ex ceeds their variable costs of producing output. The short-run focus for this an alysis is appropriate since full implementation with this rule is required by 3 years from promulgation. Thus, implementation by affected firms must occur by 2007. Most of the economic impacts associated w ith this rule are therefore likely to occur between promulgation and 2007. In addition, the statutes and Executive Orders that call for economic impact analyses for regulations implicitly call for an assessement of impacts on current producers and consumers. Therefore, a long-run approach has some weaknesses in addressing the requirements that an analysis like this one must adhere to. Thus, shor t-run modeling of the economic impacts of this rule, which means presuming the capital stock as a constant, is a reasonable approach.
The market model developed by the Agency for this EIA is based on a series of equations that represent the market supply and demand functions for a given product. The demand functions use baseline price, total domestic production, import, and export data, as well as estimates of the price elasticity of demand for a given product as inputs. The market supply function is based on an estimated supply function for each plywood or composite wood product at all production facilities. The Agency developed a spreadsheet model for each of the four markets to represent the c onceptual model described below. The EIA provides a description of this process.
Figure 4-1 shows a generalized upward-sloping s upply function that characterizes the production function of each facility included in the analysis (a ffected and unaffected). In the EIA model, this function represents the marginal cost curve for each supplier of the product within the market. The minimum constraint on this function is zero, and th e maximum constraint is each facility’s capacity. If the market price is above a given facility’s averag e variable cost, the facility will produce output up to the point where production equals the facility’s production capacity. If a given facility’s marginal production cost is above the market price, it will produce zero output (EPA, 1999b).4-6 

### $/lb S

lbs/year Figure 4-1. Supply Curves for Affected Facilities

Source: U.S. EPA, 1999b. The model then aggregates the supply functions of the individual facilities within a market to

represent the market level supply curve. Next, the model equilibrates the market demand curve and the market supply curve according to th e baseline market price and quantity values. Figure 4-2 shows that market prices and quantities are set in the baselin e according to the intersection of the supply and demand curves in the baseline (the period prior to the imposition of compliance costs on affected facilities). The baseline scenario equilibrium mark et price and quantity (P, Q) are the points on the graph’s axes points where the downward-sloping market demand curve (D M ) intersects with the upwardsloping market supply curve (S M ). In the baseline, at price P, the industry produces total output, Q, with affected facilities producing the amount q a and unaffected facilities producing q u (EPA, 1999b).
Next the same facility-specific supply functions in the model are recalculated after taking into account the increase in production costs associated w ith the imposition of annual compliance costs on some producers. The costs are expresses in terms of dollars per unit of output in the baseline (in this case per thousand cubic meter of product). Figure 4-1(b) show the effect of the compliance costs: the supply curve for the affected producers shift upward S a to S a ' . This raises the point at which market price must cover variable production costs from p a to p a '. The supply curve S u for the unaffected facilities remain the same. When the supply curv es for the affected and unaffected facilities are aggregated to represent the market level supply curv e, the market supply curve also shifts upward from S M to S M' . Using the original market demand curve, D M , the new equilibrium price increases from P to P' and market output declines from Q to Q'. This reduction in market output is the net result from reductions at affected facilities and increases at unaffected facilities (EPA, 1999b).4-74-8 p S a

q a q u Q

Affected Facilities S u S M

D M p p 

### + =

Unaffected Facilities Market

a) Baseline Equilibrium

p

q ′ a q u Q ′

Affected Facilities S u S M ′

D M p p 

### + =

Unaffected Facilities Market

b) With Regulation Equilibrium p ′ S a

q a q ′ u Q S M

p ′ p ′ S ′ a



### Figure 4-2. Market Equilibrium Without and With Regulation

Source: U.S. EPA, 1999b.
4.5 Economic Impact Analysis Results
The following section presents the results of th e Agency’s implementation of the EIA models described in the previous section. The results ar e presented at three levels: market, industry, and societal. The market level results present the impact s in terms of changes in price and quantity for each of the four markets. The industry level impacts include changes in revenues, production, employment, and number of operating production lines.

4.5.1 Market-Level Results
Exhibit 4-2 presents the expected impacts of th e regulation at the market-level. These changes include the new price and quantity for each product and changes in foreign trade. In each market, prices4-9 increase and production quantities decrease due to the imposition of compliance costs on the affected producers. The reduction in market quantities of each product reflect reductions in domestic production (including production for exports) and increases in foreign imports. The reduction in domestic production reflects production decreases by affected producers and increases by unaffected producers (EPA, 1999b).
For softwood plywood, the market price is exp ected to increase by 0.9 percent, while market quantity declines by 0.1 percent, or 26,207 thousand cubic meters (or M cubic meters) per year. For oriented strandboard, the market price is expected to increase by 1.3 percent, while market quantity declines by 0.1 percent, or 12,945 M cubic meters per year. For particleboard and medium density fiberboard, the market price is expected to increase by 2.5 percent, while market quantity declines by 0.7 percent, or 78,595 M cubic meters per year. Finally , for hardboard, the market price is expected to increase by 1.0 percent, while market quantity will d ecline by 0.3 percent, or 4,727 M cubic meters per year. Generally, increases in market price result in ch anges in foreign trade of these products: exports decrease and imports increase. Exhibit 4-2 shows that exports of softwood plywood from the United States are expected to decline by 0.2 percent (or 2 M cubic meters per year); exports of oriented strandboard are expected to decline by 0.1 percen t (or 0.2 M cubic meters per year); exports of particleboard and medium density fi berboard are expected to decline by 0.7 percent (or 2 M cubic meters per year); and exports of hardboard are expected to decline by 0.2 percent (or 1 M cubic meter per year). Imports of each of these products to the United St ates are expected to increase as follows: SWPW by 685 percent (or 630 M cubic meters per year), OS B by 28.82 percent (or 1,345 M cubic meters per year), PB/MDF by 85 percent (or 1,451 M cubic me ters per year), and HB by 100 percent (or 387 M cubic meters per year).

Exhibit 4-2. Market-Level Impacts of the NESHAP

Industry Sector Baseline With Regulation Changes from Baseline Absolute Percent Softwood Plywood Market price (1997$/cubic meter) $235 $237.20 $2.20 0.9% Market output (M cubic meters /yr) 17,568,254 17,542,048 -26,206 -0.1% Domestic production 17,568,162 17,541,326 -26,837 -0.2% Affected Facilities 11,680,778 11,629,258 -51,520 -0.4% Unaffected Facilities 5,887,384 5,912,067 24,683 0.4% Exports 1,370 1,368 -2 -0.2% Imports 92 722 630 685.1% Oriented Strandboard Market price (1997$/cubic meter) $185 $187.43 $2.43 1.3% Market output (M cubic meters /yr) 9,595,121 9,582,176 -12,945 -0.1% Domestic production 9,590,456 9,576,165 -14,291 -0.1%Exhibit 4-2. Market-Level Impacts of the NESHAP

Industry Sector Baseline With Regulation Changes from Baseline Absolute Percent

4-10 Affected Facilities 4,691,645 4,654,117 -37,528 -0.8% Unaffected Facilities 4,898,811 4,922,048 23,237 0.5% Exports 147.8 147.6 -0.2 -0.1% Imports 4,666 6,011 1,345 28.8%Exhibit 4-2. Market-Level Impacts of the NESHAP

Industry Sector Baseline With Regulation Changes from Baseline Absolute Percent

4-11 Particleboard and Medium Density Fiberboard Market price (1997$/cubic meter) $169 $173.29 $4.29 2.5% Market output (M cubic meters /yr) 11,646,228 11,567,633 -78,595 -0.7% Domestic production 11,644,523 11,564,477 -80,046 -0.7% Affected Facilities 9,670,639 9,553,510 -117,129 -1.2% Unaffected Facilities 1,973,884 2,010,967 37,083 1.9% Exports 333 331 -2 -0.7% Imports 1,705 3,156 1,451 85.1%
Hardboard Market price (1997$/cubic meter) $1,322 $1,335.17 $13.17 1.0% Market output (M cubic meters /yr) 1,768,930 1,764,203 -4,727 -0.3% Domestic production 1,768,545 1,763,431 -5,114 -0.3% Affected Facilities 1,768,545 1,763,431 -5,114 -0.3% Unaffected Facilities n/a n/a 0 n/a Exports 371 370 -1 -0.2% Imports 385 772 387 100.5%
4.5.2 Industry-Level Results
Industry impacts associated with the NESHAP for the plywood and composite wood industry are presented in Exhibit 4-3. Industry-level impact s include changes in revenue, production, numbers of operating product-lines, and changes in employment. The estimates for changes in production lines and employment are described in Section 4.5.3 below.
The EIA model estimates the change in prices a nd production levels after the imposition of the compliance costs on the affected facilities. Exhib it 4-3 shows that overall revenues for each industry increase slightly. Industry revenues increase becau se demand elasticities for these four markets mean that the change in price (in percentage terms) is greater than the percentage reduction in output. Affected facilities will experience an increase in revenu es due to the increase in the market price, but this effect is likely to be offset by the increase in pr oduction costs. Changes in profits, however, could not be estimated due to lack of information on production costs at the facility level.4-12 Exhibit 4-3. Industry-Level Impacts of the NESHAP

Baseline With Regulation Changes from Baseline Absolute Percent Softwood Plywood Revenues ($ million/yr) $4,128.5 $4,161 $32.4 0.78% Production (M cubic meters/y r) 17,568162 17,541,326 -26,836 -0.15% Operating product lines (#) 108 107 -1 -0.93% Employment* 36,877 36,821 -56 -0.15% Oriented Strandboard Revenues ($ million/yr) $1,774.2 $1,794.9 $20.7 1.17% Production (M cubic meters/yr) 9,590,456 9,576,164 -14,292 -0.15% Operating product lines (#) 38 38 0 0.00% Employment* 6,681 6,671 -10 -0.15% Particleboard & Medium Density Fiberboard Revenues ($ million/yr) $1,967.9 $2,004.0 $36.1 1.83% Production (M cubic meters/yr) 11,644,523 11,564,477 -80,046 -0.69% Operating product lines (#) 83 83 0 0.00% Employment* 20,424 20,284 -140 -0.69%
Hardboard Revenues ($ million/yr) $2,338.0 $2,354.5 $16.5 0.71% Production (M cubic meters/yr) 1,768,545 1,763,431 -5,114 -0.29% Operating product lines (#) 18 18 0 0.00% Employment* 6,271 6,252 -18 -0.29% *Baseline employment estimates are based total production and employment of all facilities in each market as reported in the EPA facility database. Average pr oduction per employee was calculated using the sum of facility-specific production and employment. Because facilities reported employment as a range, they are assigned an employment estimate using the mid-point of the reported range. Post-regulation employment was then estimated by dividing post-regulation production by the baseline production per employee.
4.5.3 Distribution of Impacts
The distribution of regulatory impacts is presented in Exhibit 4-4. This table presents the same information as in Exhibit 4-3, but provides details on how the rule impacts affected and unaffected facilities differently.
One important result from the EIA model is the projection of process line closures that could occur following promulgation of the NESHAP. The model’s estimate of process line closures may be sensitive to the accuracy of the base line characterization of the facilities. Characteristics such as baseline production levels, revenues (as a function of produc tion and price), the underlying supply function that4-13 represents production costs, and the compliance cost es timates are all factors that affect the distribution of the rule’s impacts.

Exhibit 4-4: Distribution of Industry-Level Impacts of the NESHAP: Affected and Unaffected Producers

Baseline With Regulation Changes From Baseline Absolute Percent Softwood Plywood Affected Process Lines Revenues ($ million/yr) $2,745.0 $2,758.5 $13.5 0.49% Production (M cubic meters/yr) 11,680,778 11,629,258 -51,520 -0.44% Operating process lines (#) 66 65 -1 -1.52% Employment* 24,519 24,411 -108 -0.44% Unaffected Process Lines Revenues ($ million/yr) $1,383.5 $1,402.4 $18.9 1.37% Production 5,887,384 5,912,067 24,683 0.42% Operating process lines (#) 42 42 0 0.00% Employment* 12,358 12,410 52 0.42% Oriented Strandboard Affected Process Lines Revenues ($ million/yr) $868.0 $872.3 $4.4 0.50% Production (M cubic meters/yr) 4,691,645 4,654,117 -37,528 -0.80% Operating process lines (#) 20 20 0 0.00% Employment* 3,268 3,242 -26 -0.80% Unaffected Process Lines Revenues ($ million/yr) $906.3 $922.6 $16.3 1.80% Production 4,898,811 4,922,048 23,237 0.47% Operating process lines (#) 18 18 0 0.00% Employment* 3,413 3,429 16 0.47% Particleboard & Medium Density Fiberboard Affected Process Lines Revenues ($ million/yr) $1,634.3 $1,655.6 $21.2 1.30% Production (M cubic meters/yr) 9,670,639 9,553,510 -117,129 -1.21% Operating process lines (#) 53 53 0 0.00% Employment* 16,962 16,756 -205 -1.21% Unaffected Process LinesExhibit 4-4: Distribution of Industry-Level Impacts of the NESHAP: Affected and Unaffected Producers

Baseline With Regulation Changes From Baseline Absolute Percent

4-14 Revenues ($ million/yr) $333.6 $348.5 $14.9 4.47% Production 1,973,884 2,010,967 37,083 1.88% Operating process lines (#) 30 30 0 0.00% Employment* 3,462 3,527 65 1.88%Exhibit 4-4: Distribution of Industry-Level Impacts of the NESHAP: Affected and Unaffected Producers

Baseline With Regulation Changes From Baseline Absolute Percent

4-15 Hardboard Affected Process Lines Revenues ($ million/yr) $2,338.0 $2,354.5 $16.5 0.70% Production (M cubic meters/yr) 1,768,545 1,763,431 -5,114 -0.29% Operating process lines (#) 18 18 0 0.00% Employment* 6,271 6,252 -18 -0.29% Unaffected Process Lines Revenues ($ million/yr) n/a n/a n/a n/a Production n/a n/a n/a n/a Operating process lines (#) n/a n/a n/a n/a Employment* n/a n/a n/a n/a
Total Affected Process Lines Revenues ($ million/yr) $7,585.3 $7,640.9 $55.6 0.73% Production (M cubic meters/yr) 27,811,607 27,600,316 -211,291 -0.76% Operating process lines (#) 157 156 -1 -0.64% Employment* 51,020 50,662 -358 -0.70% Unaffected Process Lines Revenues ($ million/yr) $2,623.4 $2,673.4 $50.1 1.91% Production 12,760,079 12,845,082 85,003 0.67% Operating process lines (#) 90 90 0 0.00% Employment* 19,233 19,366 133 0.69% All Process Lines (net) Revenues ($ million/yr) 10,209 10,314 $105.6 1.03% Production 40,571,686 40,445,398 -126,288 -0.31% Operating process lines (#) 247 246 -1 -0.40% Employment* 70,252 70,028 -225 -0.32% n/a = not applicable *Baseline employment estimates are based total production and employment of all facilities in each market as reported in the EPA facility database. Average pr oduction per employee was calculated using the sum of facility-specific production and employment. Because facilities reported employment as a range, they are assigned an employment estimate using the mid-point of the reported range. Post-regulation employment was then estimated by dividing post-regulation production by the baseline production per employee.4-16 Exhibit 4-4 shows that one softwood plywood production line is expected to prematurely cease operations. The model does not predict any closures in all of the other product markets. The affected entity that closes following adoption of the regulation is a small SWPW producer that incurs higher control costs per unit of production than other SWPW production lines. This facility, with one process line, did not respond to the EPA’s ICR survey. Therefore, it was necessary to estimate baseline production and compliance costs based on very little facility-specific information. Total baseline production of SWPW by the facility that closes was roughly 9,500 M cubic meters per year, or less than 0.05 percent of the 17,568,162 M cubic meters of SWPW produced by all SWPW facilities during 1997.
As a result of the closure and reductions in produc tion at other affected facilities, the EIA model estimates a total net loss in employment of 225 employees (0.3 percent) attributable to the NESHAP across all four market sectors. Affected facilities experience employment loss of 358, which is offset by employment gains at unaffected facilities of 133. Overall the four sectors together experience a 1 percent increase in revenues, and a 0.3 percent decrease in production.
4.5.4 Social Costs of the NESHAP
The social costs of a regulation are measure d according to the impacts that it has on both consumers and producers. The NESHAP, because it is e xpected to result in changes in both market price and market quantity, will impact the consumer s and producers of softwood plywood and composite wood products. Social costs, also called welfare impacts, are the measure of overall gains and losses experienced by the two groups that may result from the imposition of costs associated with the regulatory requirements.
The economic benefits producers experience when participating in a market is called producer surplus. Producers experience impact s when their revenues change eith er because of a new market price, increased production costs, or both. These impacts cha nge the amount of producer surplus relative to the baseline. Likewise, the economic benefits consumer s experience is called consumer surplus. Consumer surplus changes when consumers e xperience impacts when the amount of product they consume or the product price changes. The economic principles behi nd the measurement of social costs are presented in detail in the EIA.

The estimate of the social cost of the NESHAP , presented in Exhibit 4-5, is the sum of the change in producer and consumer surplus. The EIA model estimates the social cost of the proposed NESHAP as $135.1 million annually (1999 dollars). These costs are distributed across both consumers and producers of plywood and compos ite wood products according to projected changes in market price and quantity associated with the NESHAP.
Consumer surplus is reduced by $136.1 million annually due to the increase in prices and reductions in consumption. Consumers of soft wood plywood are worse off by $38.7 million annually; consumers of oriented strandboard are worse off by $23.3 million annually; c onsumers of particleboard and medium density fiberboard and of hardboard are worse off annually by $49.8 million and $23.3 million, respectively.4-17 Producers (in aggregate) are slightly better off because of the imposition of the NESHAP, with an increase in producer surplus of just under $1 m illion annually. Essentially all of this is change associated with domestic producers. Because th e market prices for these products increase, certain individual domestic producers gain at the expense of their competitors. The size of this gain at any given facility depends on how much their production co sts change (as a result of new compliance costs) relative to the change in market price and quantity that increases revenues. The benefit to foreign producers associated with higher market prices is quite small, under $100,000.

Exhibit 4-5: Distribution of Social Costs Associated with the NESHAP

Stakeholder Change in Value ($ million -1999 dollars) Social Costs of Regulation (Change in consumer surplus + Change in producer surplus) $-135.1
Total Change in Consumer Surplus $-136.1 SWPW Consumers $-38.7 OSB Consumers $-23.3 PB/MDF Consumers $-49.8 HB Consumers $-23.3 Total Change in Producer Surplus $0.9 Softwood Plywood Producer Surplus, total $8.3 Domestic producers $8.3 Affected Facilities $-4.1 Unaffected Facilities $12.4 Foreign producers $0.0
Oriented Strandboard Producer surplus, total $-1.4 Domestic producers $-1.4 Affected Facilities $-12.9 Unaffected Facilities $11.5 Foreign producers $0.0 Particleboard & Medium Density Fiberboard Producer surplus, total $-5.2 Domestic producers $-5.2 Affected Facilities $-13.5 Unaffected Facilities $8.3 Foreign producers $0.0Exhibit 4-5: Distribution of Social Costs Associated with the NESHAP

Stakeholder Change in Value ($ million -1999 dollars)

4-18 Hardboard Producer surplus, total $-0.8 Domestic producers $-0.8 Affected Facilities $-0.8 Unaffected Facilities n/a Foreign producers $0.0

4.5.5 Energy Impact Analysis
Executive Order 13211, “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use” (66 FR 28355, May 22, 2001), provides that agencies shall prepare and submit to the Administrator of the Office of Inform ation and Regulatory Affairs, Office of Management and Budget, a Statement of Energy Effects for certa in actions identified as “significant energy actions.” Section 4(b) of Executive Order 13211 defines “signifi cant energy actions” as “any action by an agency (normally published in the Federal Register ) that promulgates or is expected to lead to the promulgation of a final rule or regulation, including notices of inquiry, advance notices of proposed rulemaking, and notices of proposed rulemaking: (1) (i) that is a significant regulatory action under Executive Order 12866 or any successor order, and (ii) is likely to have a significant adverse effect on the supply, distribution, or use of energy; or (2) that is designa ted by the Administrator of the Office of Information and Regulatory Affairs as a significant energy action.” The rule is not a “significant energy action” because it is not likely to have a significant adverse effect on the supply, distribution, or use of energy. The basis for the determination is as follows.
As stated in Chapter 2, this rule affects manufacturers in the softwood veneer and plywood (NAICS 321212), reconstituted wood products ( NAICS 321219), and engineered wood products (NAICS 321213) industries. There is no crude oil, fuel, or coal production from these industries. Hence, there is no direct effect on such energy producti on related to implementation of this rule. In fact, as mentioned in section IV.D. of this preamble, ther e will be an increase in energy consumption, and hence an increase in energy production, resulting fro m installation of regenerative thermal oxidizers (RTOs) and wet electrostatic precipitators (WESPs) likely needed for sources to meet the requirements of the rule. This increase in energy consumpti on is equal to 718 million killowatt-hours/year (kWh/yr) for electricity and 45 million cubic meters/year (m 3 /yr) for natural gas. These increases are equivalent to 0.012 percent of 1998 U.S electricity producti on and 0.000001 percent of 1998 U.S. natural gas12 U.S. Department of Energy, Energy Informati on Administration. Annual Energy Review, End-Use Energy Consumption for 1998. Located on the Internet at http://www.eia.doe.gov/emeu/aer/enduse.html.

13 Ibid.

14 U.S. Department of Energy, Energy Inform ation Administration. 1998 Manufacturing Energy Consumption Survey. Located on the Internet at http://www.eia.doe.gov/emeu/mecs/mecs98/ datatables/contents.html.

15 U.S. Environmental Protection Agency. “Ener gy Impact Analysis of the Proposed Plywood and Composite Wood Products NESHAP.” July 30, 2001.

4-19 production. 12 It should be noted, however, that the reduction in demand for product output from these industries may lead to a negative indirect effect on such energy production, for the output reduction will lead to less energy use by these industries and thus some reduction in overall energy production.
For fuel production, the result of this indirect effect from reduced product output is a reduction of only about 1 barrel per day nationwide, or a 0.00001 percent reduction nationwide based on 1998 U.S. fuel production data 13 . For coal production, the resulting indirect effect from reduced product output is a reduction of only 2,000 tons per year nationwide, or only a 0.00001 percent reduction nationwide based on 1998 U.S. coal production data. For electricity production, the resulting indirect effect from reduced product output is a reduction of 42.8 million Kilo watt-hours per year (kWh-yr), or only a 0.00013 percent reduction nationwide based on 1998 U.S. electri city production data. Given that the estimated price increase for product output from any of the affected industries is no more than 2.5 percent, there should be no price increase for any energy type by more than this amount. The cost of energy distribution should not be affected by this proposal at all since the rule does not affect energy distribution facilities. Finally, with changes in net exports being a minimal percentage of domestic output (0.01 percent) from the affected industries, ther e will be only a negligible change in international trade, and hence in dependence on foreign energy supp lies. No other adverse outcomes are expected to occur with regards to energy supplies. Thus, the net effect of this rule on energy production is an increase in electricity output of 0.012 percent compar ed to 1998 output data, and a negligible change in output of other energy types. All of the results presented above account for the passthrough of costs to consumers, as well as the cost impact to producers. These results also account for how energy use is related to product output for the affected industries. 14 More detailed information on the estimated energy effects and the methodology employed to estimated them are in the background memo 15 that provides such details for the proposed rule.
Therefore, we conclude that the rule when implemented is not likely to have a significant adverse effect on the supply, distribution, or use of energy.

4.6 Analysis of Economic Impacts on Engineered Wood Products Sector

4.6.1 Overview4-20 The engineered wood products (EWP) sector is much different than the other four sectors examined in this analysis. Due to both the nature of the products and their markets as mentioned in Section 4.6.4 below, and the limited availability of data, a quantitative analysis was not performed.
EWP products are characterized by differentiated structural beam products, although some can also be used as columns. EWPs are produced by firms using differentiated production systems. There are a number of large firms with market power, allowing them to set prices. Although many of the products in this market sector can be substituted for one another to an extent, each product’s design usually provides it with an advantage over others in the design of final structures. Product differentiation allows each product to dominate particular market niches, but also makes many of the products complements as well as substitutes. Even wh en substitution is possible, some large firms use their market power to influence purchase decisions and persuade consumers to purchase their products. Consequently, these products are not standard co mmodities as are products in the other plywood and composite wood sectors. Therefore, commodity prices and other standard information that is characteristic of competitive markets are not availabl e. These factors limit the ability of EPA to quantify the impact of the NESHAP on this sector usi ng the same quantitative method applied to the other sectors.
Three of the fifty-three EWP facilities in the U.S. will have compliance costs are a result of the NESHAP. This includes the country’s two LSL pl ants, and one of the country’s two PSL plants. Weyerhaeuser, Inc. purchased these four plants when they acquired Trus Joist MacMillan. (Weyerhaeuser-Trus Joist MacMillan will be referred to as W/TJM for the remainder of this report.) W/TJM is currently the only manufacturer of LSL and PSL in the world.
4.6.2 Characteristics of EWP Products
EWPs include laminated veneer lumber (LVL), laminated strand lumber (LSL), parallel strand lumber (PSL), wood I-joists (I-J), and glue lami nated timber (GL). These are value added lumber products designed to be used in applications that are not suitable for ordinary framing lumber. The design and composition of each of these products di ffer, providing them with different strength, stiffness, cost, and dimensional properties. Strengt h properties allow products to carry heavier loads without breaking. Strength is particularly important for uses such as carrying beams in floors or bridge girders, which are used to support structures. S tiffness prevents materials from shaking as objects are moved over them. This is particularly important in floors and bridge decks where structure shakes or squeaks are uncomfortable or dangerous. Each produc t’s strength and stiffness is partially a function of its dimensional characteristics. For example, I-J ar e strong, stiff and typically less expensive than the other products. However, their structural integrity does not hold beyond certain lengths.

Laminated-Strand Lumber16 LSL bending strength = 1700psi; stiffness (modul us of elasticity or MOE) = 1.3-1.5E.

4-21 W/TJM introduced LSL in 1992. Its dimensional characteristics match nominal 2x4 and 4x4 framing lumber, but it provides greater and more uniform strength and stiffness properties. 16 Unlike many of the other EWPs, one of the primary uses of LSL is in vertical applications, as a stud or column. PSL is also used in vertical applications, but its primary uses are in horizontal applications, as a beam. The uses of LSL are summarized in Exhibit 4-6.

Exhibit 4-6: Primary Uses and Substitutes for LSL Application Uses Substitutes Columns or studs Wall, window, and door framing Framing lumber, PSL, solid sawn lumber, steel Headers Garage door, other wide span doors and windows Framing lumber, GL, LVL, PSL, steel

Beams Light applications, low load bearin g Solid sawn lumber, GL, LVL, PSL, I-J Rim Board Floor systems, nailing surface for sheathing, decks and siding Plywood

Source: http://www.trusjoist.com
Because W/TJM is the sole producer of LSL, very little information is available about their costs or profits. Exhibit 4-7 below identifies the production in formation that is known. Note that neither plant operates near full capacity. The two plants combined operate at less than 50 percent of their combined capacity (EWP survey). This may be due to a decline in demand or an immature market.

Exhibit 4-7: Characteristics of LSL Plants
Location Item Deerwood, MN Capacity Production Capacity Employees Plant Age 7,900,000 ft 3 /yr 4,900,000 ft 3 /yr 62% 100-249 1992 (estimate) Chavies, KY Capacity Production Capacity Employees Plant Age 14,900,000 ft 3 /yr 5,400,000 ft 3 /yr 36% 250-499 1992 (estimate) Source: EPA facility survey, 1998.

Parallel-Strand Lumber17 PSL bending strength = 2900psi; stiffness = 2.0E.

18 GL bending strength = 2400-3000psi; stiffness = 1.8 - 2.1E

4-22 PSL is a slightly older technology than LSL. It was introduced to the market in the mid-1980’s by W/TJM. PSL is a high performance beam and header product that can also be used as a column. It is designed with exceptional strength, stiffness character istics that is capable of spanning much longer distances than most other EWPs. 17 Only GL can match or beat PSL’ s ability to carry heavy loads over long spans. 18 Furthermore, PSL is a balanced beam, which means it has no top or bottom. This property is particularly desirable to the residentia l framing industry. Balanced beams save on labor costs due to lower skill required to install the product, providing PSL with an edge over GL for a number of years. However, Anthony Forest Products recen tly developed a line of balanced GL beams with comparable strength and stiffness properties to PSL, and a number of other GL manufacturers have since done the same. This has lead to a competitive more environment. However, PSL still maintains a share of the residential market. Exhibit 4-8 summarizes the uses of PSL.

Exhibit 4-8: Primary Uses and Substitutes for PSL Application Uses Substitutes Columns or studs Wall framing, street li ghts Steel, solid sawn lumber, steel Headers Garage door, other wide span doors and windows GL,LVL, steel

Beams Heavy applications, high load bearing GL, steel, solid sawn lumber, LVL
Because W/TJM has been the only producer of th is product, very little is known about their production costs and profits. Exhibit 4-9 below id entifies the production information that is known about the two U.S. PSL production facilities.

Exhibit 4-9: Characteristics of PSL Plants
Location Item Colbert, GA (affected by rule) Capacity Production Capacity Factor Employees Plant Age 3,000,000ft 3 /yr 2,770,000ft 3 /yr 92% 250-499 mid-1980s (estimate) Buckhannon, WV (not affected by rule) Capacity Production Capacity Factor Employees Plant Age 2,500,000ft 3 /yr 1,929,000ft 3 /yr 77% 250-499 mid-1980s (estimate) source: EPA facility survey, 1998.4-23 Since PSL does compete directly with GL in some a pplications, there is slightly more information available on it than on LSL. There is one published source of EWP prices that includes some retail PSL delivered prices: Engineered Lumber Trends produ ced by The Irland Group in Winsor, ME. Exhibit 4- 10 presents a comparison of retail prices for PSL and GL. However, it is not possible to estimate firm revenue using these prices because they are retail pr ices and there is considerable markup from the producer to retail level. The prices listed in the tabl e below show that PSL is more expensive than GL.

Exhibit 4-10: Retail Prices of GL and PSL Beams Delivered to Los Angeles
Beam* Width (inches) Depth (inches) Price per linear foot
PSL (strength = 2900psi stiffness = 2.0E) 3-1/2 11-7/8 $8.16

GL (strength = 2400psi stiffness = 1.8E) 3-1/8 12 $5.90

GL ** (strength = 3000psi stiffness = 2.1E) 3-1/8 12 $7.08

Source: Engineered Lumber Trends (December 1999) *Beam bending strength measured in pounds per square inch and stiffness the beams modulus of elasticity or E **Price of the 3000-psi GL is estimated by marking up the 2400psi GL by 20% based on conversations with GL manufacturers
W/TJM has stated that PSL could be manufactured using waste material from plywood and LVL. Other industry members dispute this due to the high quality material required for the product. They feel that there is actually considerable wasted material in the production process in order to acquire the high-quality wood fiber. Consequently, there ar e two conflicting arguments why PSL is able to sell their product at the higher price.
• Consumers view it as a superior product despite the availability of substitutes, providing it with a higher profit margin. • W/TJM has used strategic behavior to maintain the price it requires to provide its product on the market.
4.6.3 Comparison to Other EWP Products
Substitution among EWPs is a complicated dynamic. While the products can be viewed as distinct commodities, they are integral components in the engineering design of a structure. Therefore, it is possible for two EWP products to be both substitutes and complements. This is particularly true for4-24 W/TJM’s products because they sell both the individual products and entire framing systems that include either LSL or PSL, or both.
LSL is more comparable to framing lumber and solid sawn lumber than most other engineered wood products. As a header it competes with LVL, GL, and PSL. However, as a column or stud, it is fairly unique. It is also a very new technology, which may partially explain why competing firms have not developed comparable products to date. Furthermore, LSL is marketed as a complementary product to W/TJM’s other engineered wood products (I-J, LV L, PSL) in various structures they design.
As an individual product, PSL has more direct substitutes than LSL. In shorter spanning applications (such as headers or floor joists) LV L, I-J, GL, or LSL can be substituted for each other depending on the application. In longer spanni ng applications, PSL competes with GL and steel. W/TJM also designed PSL to complement their other products in pre-designed framing systems. If an architect or engineer purchases the pre-designed fra ming system, PSL will be specified in the system. This eliminates the possibility of substitutes in th ese applications. These characteristics are discussed in greater detail below.

4.6.4 Market Characterization
The EWP sector is characterized by imperfect competition among firms, particularly. In the case of LSL and PSL, W/TJM is a monopoly producer because it operates all four facilities that produce products affected by the rule. Although a number of other products can be substituted for both LSL and PSL at the commodity level, W/TJM has a monopoly on these two products. In addition, they have some ability to control material choice within the residential framing market because they produce Computer Automated Design (CAD) programs used by architects, engineers, and lumber product distribution companies to design structures. The individual using the program is actually purchasing a complete architectural design, which competes with other architectural designs on the basis of total design cost. Other EWP companies have not devel oped such programs to the same extent that W/TJM has.
By pre-specifying its products as material i nputs in these design packages, W/TJM assures that they are used in the structure. Moreover, the individual product prices are less important to W/TJM because the price the buyer using the program is con cerned with is the price of the whole structure. Further, because W/TJM makes all the products used in the design, they can sell any one of the components at a loss provided the loss is made up by pr ofits on the whole structure. In addition, W/TJM also sells pre-designed floor, roof, and wall systems that incorporate its EWP products.
Therefore, W/TJM is a price setter in both these markets. The high price of PSL allows producers of comparable GL a substantial markup ove r its costs. However, GL manufacturers offered the opinion that PSL could not raise its price without suffering a loss in demand . Those same producers believe that PSL is already selling at a loss to promote the sale of its other products, although this information cannot be confirmed. Another complicating factor is the purchase of TJM by Weyerhaeuser, Inc. Even if TJM had been selling PSL at a loss, Weyerhaeuser may not be willing to do this, particularly if costs increase due to the NESHAP.4-25 4.6.5 Appropriateness of Partial Equilibrium Economic Analysis for the EWP Market
It is not appropriate to use a partial equilibrium analysis to quantify the impact of the rule on the EWP sector. The EWP facilities that will have complia nce costs due to the rule are not part of a competitive market. W/TJM has a monopoly on both PSL and LSL because they are the only company in the world producing both these products. Although th e products compete to an extent with other EWPs, W/TJM is able to use its market power to influence consumer purchasing decisions and prices. Also, W/TJM may be able to absorb cost increases on one product with profits from another.

4.6.6 Analysis
The estimated total annual compliance costs fo r the three impacted EWP facilities are $3.2 million, which is only 2.4 percent of the overall co mpliance cost of the rule of $142 million per year. Moreover, the costs are incurred by one of the largest wood products companies in the world. The costs incurred by W/TJM are less than 1 percent the cor poration’s total annual revenues, which now include revenues from the facilities purchased from TJM. Although the specific impact on W/TJM’s profitability cannot be determined, it is likely that W/TJM can afford the costs at the corporate level.
The Agency cannot be certain of the impact th at these cost increases will have on the markets for LSL and PSL. W/TJM could decide use their price setting power to increase the price of PSL and/or LSL. This could lead to a decrease in consumer surplus. However, it is important to note the distributional impact of this potential price increase. EWPs are often used in high end residential and commercial construction. They typically provide l uxury features, such as squeak proof floors, large open rooms with high ceilings and no support columns.
Alternatively, W/TJM may choose not to raise the prices of PSL and LSL. For example, PSL is already more expensive than GL, a substitute produc t. A rise in PSL prices could lead to a loss in market share. Furthermore, production data show ed that the PSL market is functioning at about 50 percent of its full capacity. These factors indicate that a PSL price increase may not be favorable to W/TJM. W/TJM could choose to absorb the cost increase with profits from its other products in the short run. In the long run they could abandon produc tion of these products. In order to meet the demand for their pre-designed structural systems, they coul d either produce or buy a substitute product to use in the structural systems.
If W/TJM chooses to shut down these plants, ther e may be a number of unfavorable short run impacts. First, the closures could mean the lo ss of 600-1250 jobs, spread over three communities. EPA expects that the reduction in employment at these facilities would be offset by an increase in employment at a competing firm, but the community impacts may remain.
The impact of the NESHAP on both consumers and the individual facilities and firms will depend upon corporate strategy. Given the acquis ition of Trus Joist MacMillan by Weyerhaeuser,4-26 corporate decisions and long term strategy are more influential than what could be represented in a model.

4.6.7 Conclusions
Although the specific impacts to the EWPs sector cannot be determined, it is unlikely that substantial economic losses will result. The cost burde n of this sector is minimal in comparison to the other sectors. Furthermore, the affected faciliti es are all owned by W/TJM, which has sufficient resources to handle the compliance costs. Even if W/TJM passes this cost on to consumers, the price increase is likely to be minimal as substitute products are available.4-27 4.7 References

Abt Associates Inc. 1999. Profile of the Plywood and Wood Composite Industries. Prepared for Larry Sorrels, Innovative Strategies and Economic Gr oup, Air Quality Strategies and Standards Division, Office of Air Quality Planning and Sta ndards, U.S. Environmental Protection Agency, Research Triangle Park, NC. December

Abt Associates Inc. 2000. Economic Analysis Methodology for the Plywood and Wood Composite Industries. Prepared for Larry Sorrels, Innovative Strategies and Economic Group, Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC. March.
U.S. Environmental Protection Agency. 1998. Industry Specific Information Collection Request (ICR) for the Development of Plywood and Particle board Maximum Achievable Control Technology (MACT) Standards . Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
U.S. Environmental Protection Agency. 1999a. OAQPS Economic Analysis Resource Document . Air Quality Strategies and Standards Division, Offi ce of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
U.S. Environmental Protection Agency. 1999b. Economic Impact Analysis for the Polymers & Resins III NESHAP . Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.5-1 

## 5 SMALL BUSINESS IMPACTS

Under the requirements of the Regulatory Flex ibility Act (RFA) of 1980, Federal regulatory agencies must give special consideration to small entities that are affected by regulatory actions. In 1996, amendments to the RFA under the Small Business Regulatory Enforcement Fairness Act (SBREFA) added certain requirements associated with analyses and procedures associated with determining whether a regulatory action will have a significant impact on a substantial number of small entities (U.S. EPA, 1999a, 1999b).

5.1 Results in Brief
The screening analysis of small business impacts presented in this EIA chapter indicates that 17 of the 83 businesses affected by this rule are small. Of these 17 small firms, ten have annual compliance costs of 1 percent or greater of their sales. Of these 10 firms, three have annual compliance costs of 3 percent or greater of their sales. Of the 32 facilities owned by these 17 small firms, only one facility is predicted to close in order to avoid incurring cost s associated with compliance with the rule. This analysis supports a certification of no significant impact on a substantial number of small entities (SISNOSE) for this rule because, while a few small firms may experience significant impacts, there will not be a substantial number incurring such a burden.
The small business impacts depending on the eligibility of sources to become part of a delisted low-risk subcategory can be found in Appendix A of this RIA.

5.2 Introduction
The NESHAP for the plywood and composite wood industries will affect the owners of the facilities that will incur compliance costs to control their HAP emissions. The owners, either firms or individuals, are the entities that will bear the financ ial impacts associated with these additional operating costs. The rule has the potential to impact all firm s owning affected facilities, both large and small. This section presents the results of EPA’s small business imp act analysis of the impact the NESHAP for the Plywood and Composite Wood Industries on small bus inesses. The analysis was performed in two stages: a screening-level analysis, and an examin ation of impacts on small businesses developed using the models described in Chapter 4.5-2 The screening analysis provides EPA with a preliminary estimate of the magnitude of impacts the NESHAP may have on the ultimate domestic parent companies that own facilities EPA expects to be impacted by the standard. The analysis focused on small firms because they may have more difficulty complying with a new regulation or affording the co sts associated with meeting the new standard. This section first describes the data sources used in th e screening analysis, the methodology we applied to develop estimates of impacts, the results of the anal ysis, and conclusions about the results. The results of the impact assessment specific to small businesses that own affected facilities follows. Detailed documentation of the screening analysis presented in this section is contained in the economic impact analysis (EIA).
5.3 Screening Analysis Data Sources
The screening analysis was based on the following information:
• Industry Specific Information Request (ICR) fo r the Development of Plywood and Particleboard MACT Standards (U.S. EPA, 1998). • Profile of the Plywood and Composite Wood Products Industries (Abt Associates, January 2000). • Estimated Nationwide Costs of Control: Pl ywood and Composite Wood Products (MRI, April 14, 2000). • Dun & Bradstreet, Ward’s Business Directory, and Internet research on facility and firm employment and sales.

5.4 Screening Analysis Methodology
Cost Analysis
After summing annual compliance costs for each aff ected facility associated with a given parent firm, EPA developed ratios of firm-level compliance cost s to firm-level sales. The preparation of cost to sales ratios is a typical part of screening analyses such as this one. The analysis incorporated firm level compliance costs from the most recent facility complian ce cost estimates for all affected facilities. The firm sales data for the majority of the firms with affected facilities was obtained through a search of the Dun & Bradstreet (D&B) company database. Th e information obtained from D&B was supplemented with data from firm web sites and several other business databases available through the Internet (e.g., Zapdata, Hoover’s Online, Thomas’ Regi ster, and Lycos Companies Online).

Profitability Analysis5-3 For the second step in the screening analysis, EPA reviewed the profitability of only those firms with affected facilities with a cost to sales ratio (C/S) greater than 1 percent. Specifically, EPA examined a measure of profitability called the net profit margin, also known as the return on sales ratio (R/S), calculated by dividing net profit after taxes by annual net sales. Profitability data is not publicly available for those affected firms with cost /sal es ratios greater than 1 percent because they are all privately held firms. EPA estimated profitab ility according to industry-wide average profitability measures available from public sources. Exhibit 5-1 presents the profitability measure of R/S by product category.

Exhibit 5-1: Net Profit Margins by Product Type Product Category 1997 Return on Sales Ratio Softwood, Plywood, and Veneer 1.7
Oriental Strandboard 3.5 Other Wood Composites 3.5 Engineered Wood Products* 5.0 Multiple Processes** 2.6

Notes: Source: Dun & Bradstreet (1999). Indicator values are based on median values of the industrial sample. *Includes 1998 data for Structur al Wood Members, the only data reported for this sector. **Firms with multiple product lines were assigned an R/S ratio based on the average of the R/S ratios for firms with Softwood Plywood and Other Wood Composite product lines.
5.5 Screening Analysis Assumptions
Because there were certain gaps in the data , EPA had to make assumptions regarding some affected firms’ employment and sales data as follows.
• For those affected facilities for which no parent company data were available, EPA assumed that the facility represents the ultimate parent. EPA then assumed that the employees or the sales associated with the facility were the same for the parent firm. • For 8 affected firms for which Dun & Bradstreet, Ward’s, or Internet sales data was not available at the firm or facility level, EPA applied a sales estimate based on the average sales for firms in the same product and employee size category. • For one affected firm, EPA obtained employment information for all three of its identified facilities and sales information for two of the thr ee. EPA extrapolated the sales data on a dollar19 Medium density fiberboard, hardboard, conventi onal particle board and molded particleboard.

5-4 per employee basis from the two facilities with complete data to the facility with only employment data and added those sales to estimate the firm’s total sales.
5.6 Screening Analysis Results
Cost Analysis
Based on the results of the C/S ratio test, EPA developed the following summary information.
• The total number and percent of affected firms with C/S ratios greater than 3 percent. • The total number and percent of affected sma ll firms with C/S ratios greater than 3 percent. • The total number and percent of affected firms with C/S ratios greater than 1 percent. • The total number and percent of affected sma ll firms with C/S ratios greater than 1 percent. • The median and mean C/S ratios for the following groups of firms: • All firms. • Small firms. • Firms owning affected softwood plywood and veneer facilities. • Firms owning affected oriented strand board facilities. • Firms owning affected other wood composite products facilities. 19 • Firms owning affected engineered wood product facilities. • Firms owning affected facilities that make multiple products.
The screening analysis showed that of the 52 firms that own facilities incurring both capital and monitoring, recordkeeping , and reporting (MRR costs), 17 of them (33 percent) are small firms according to the U.S. Small Business Administra tion’s “Small Business Size Standards Matched to NAICS Codes” (U.S. SBA, 2000). Small firms with affected facilities had a median C/S of 1.22 percent. The remaining 35 firms (67 percent) are large, with a median C/S ratio of 0.33 percent. Overall, the weighted median C/S ratio for all firms is 0.62 percent. Exhibit 5-2 summarizes this information, along with the mean, maximum and minimum C/S by firm size category.20 Firms categorized according to the process types asso ciated with the affected facilities. Firms owing facilities with more than one process type were assigned to the “Multiple Processes” category.

5-5 Exhibit 5-2: Affected Firms by Size

Firm Size 1 Number of Affected Firms 2 Percent of Total Affected Firms Median C/S Ratio Mean C/S Ratio Maximum C/S Ratio Minimum C/S Ratio
Small 17 33.0% 1.2% 2.3% 8.3% 0.53% Large 35 67.0% 0.3% 0.6% 5.1% 0.01%

Total/ Weighted Average 52 100.0% 0.6% 1.2% 8.3% 0.01%

Notes:
1 For those firms for which firm size information was not available, EPA assumed a typical firm size within the product type category.

2 Based on affected facilities only. Includes the firm that has capital costs but no annual costs.

When screened by process type, 20 EPA found that the affected softwood plywood and veneer firms (40 percent of all firms), other composite w ood firms (25 percent of all firms) and firms with multiple processes (29 percent of all firms) make up the majority of affected firms. The firms owning facilities that produce softwood plywood have the highest median C/S ratio, 0.82 percent, followed by the owners of other composite wood facilities, with a mean C/S ratio of 0.41 percent. See Exhibit 5-3 for a summary of the data by process type, including mean, maximum and minimum C/S ratios.5-6 Exhibit 5-3: Affected Firms by Process Type

Process Type 1 Number of Affected Firms 3 Percent of Total Affected Firms Median C/S Ratio Mean C/S Ratio Maximum C/S Ratio Minimum C/S Ratio Softwood Plywood/Veneer 21 40.4% 0.8% 1.1% 8.3% 0.01%

Oriented Strand Board 3 5.8% 0.2% 0.7% 1.9% 0.01% Other Wood Composites 2 13 25.0% 0.4% 2.1% 8.2% 0.03% Engineered Wood Products 0 0.0% n/a n/a n/a n/a Multiple Processes 15 28.8% 0.4% 0.6% 2.0% 0.01% Total/Weighted Average 3 52 100.0% 0.6% 1.2% 8.3% 0.01%

Notes:
1 Firms categorized according to the process types associat ed with the affected facilities. Firms owing facilities with more than one process type were assigned to the “Multiple Processes” category.

2 Includes Medium Density Fiberboard, Hardboard , and Particleboard (conventional and molded).
3 Based on affected facilities only (facilities incurring capita l and MRR costs). Includes one firm that has capital costs but no annual costs.

Of the four firms with C/S ratios of 3 percent or greater, three are small. Ten small firms have C/S ratios of one percent or greater out of 16 in this category. One large firm has a C/S ratio of 3 percent or greater and six of them have C/S ratios of one percent or greater. The other wood composite category has the most firms with C/S ratios of 3 percent or greater (three out of the four). The softwood plywood has seven firms followed by other wood composites w ith five firms with C/S ratios of one percent or greater (out of 16). The C/S screening results are presented in Exhibits 4 and 5, below. These tables also compare the number of affected firms (i.e., firms with facilities incurring only MRR costs as well as those incurring capital and MRR costs) to the estimated total number of firms nationally.5-7 Exhibit 5-4: Affected Firms with C/S Ratios of 3 Percent or Greater

Category Number of Firms Nationwide* Number of Affected Firms Firms as a Percent of National Firms Firms as a Percent of Affected Firms
Firm Size
Small 38 3 7.9% 17.6% Large 42 1 2.4% 2.9%
Undetermined 3 n/a n/a n/a Total/Weighted Average 83 4 4.8% 7.7% Process Type Softwood Plywood/Veneer 30 1 3.3% ??
Oriented Strand Board 2 0 0.0% ?? Other Wood Composites 19 3 15.8% ?? Engineered Wood Products 11 n/a n/a n/a Multiple Processes 21 0 0.0% ?? Total/Weighted Average 83 4 4.8% 7.7%
Notes: See notes to Exhibits 5-2 and 5-3 above. * Estimate.21 That is, firms with C/S ratios greater than one percent.

5-8 Exhibit 5-5: Affected Firms with C/S Ratios of 1 Percent or Greater

Category Number of Firms Nationwide* Number of Firms Firms as a Percent of National Firms Firms as a Percent of Affected Firms by Category
Firm Size
Small 38 10 26.3% 58.8% Large 42 6 14.3% 17.1%
Undetermined 3 n/a n/a n/a Total/Weighted Average 83 16 19.3% 30.8% Process Type Softwood Plywood/Veneer 30 7 23.3% ??
Oriented Strand Board 2 1 50.0% ?? Other Wood Composites 19 5 26.3% ?? Engineered Wood Products 11 0 0.0% n/a Multiple Processes 21 3 14.3% ?? Total/Weighted Average 83 16 19.3% ??
Notes: See notes to Exhibits 5-2 and 5-3 above. * Estimate. In a few cases, a firm’s process type changed when all facilities were taken into account.

Profitability Analysis
Based on the results of the profitability analys is performed as described above, EPA developed the following information.
• The total number and percent of affected firms 21 whose C/S ratio: 1) exceeds their profitability ratio by 50 percent or more; 2) is between zero and 50 percent; or 3) is less than or equal to their profitability ratio. • The total number and percent of affected small firms whose C/S ratio: 1) exceeds their profitability ratio by 50 percent or more; 2) is between zero and 50 percent; or 3) is less than or equal to their profitability ratio.22 Research indicates that one of the small firms with particularly high impacts, Dominance Industries (d.b.a. Pan Pacific Products) is a single location private corpora tion owned Philip Ling. However, Dr. Ling is also the owner of a group of companies around the world and is the chairman of Malaysian-based Pan Pacific Asia Berhad, an investment holding company that also provides manage ment services. Pan Pacific Asia’s 1998 sales were $88 million (U.S.). The group manufactures and distributes tim ber logs and timber moldings. Other activities of the company are stockbroking and investment holding. While th is information is not necessarily applicable to the ultimate domestic parent of Dominance Industries’ affected facility, is indicates that the facility’s owner has access to financial capital beyond what the sales from the facility generate.

5-9 When EPA compared the C/S ratio to the R/S ratio for those firms with C/S ratios greater than one percent, EPA found that in 14 of the 16 cases, the C/ S ratio exceeded the R/S by over 50 percent. Two firms’ C/S ratio exceeded their R/S ratio by betw een zero and 50 percent. Exhibit 5-6 presents these results in tabular form.

Exhibit 5-6: C/S to R/S comparison for firms with C/S of one percent or greater
C/S exceeds R/S by over 50 percent C/S exceeds R/S by between 0 and 50 percent C/S is less than or equal to R/S

Firm Size Number of Firms Percent of Total Firms with Costs Number of Firms Percent of Total Firms with Costs Number of Firms Percent of Total Firms with Costs
Small 10 ?? 1 ?? 0 n/a Large 4 ?? 1 ?? 0 n/a

Total/ Weighted

Average 14 ?? 2 ?? 0 n/a

Notes: See notes to Exhibits 5-2 and 5-3 above.

EPA focused its review of the results for the 16 firms with C/S ratios greater than one percent. For 4 of the 10 small firms in this category, no sales data were available. EPA developed sales estimates for these firms according to the av erage sales for firms with the same number of employees in the same product category. It is possible that in reality, these firms have parent-level sales that differ from those assumed in the current analysis. However, based on extensive research into domestic parent-level employment and sales data, EPA expects that this in formation is not publicly available for these firms. 22 For the remaining 6 small firms with C/S ratios great er than one percent, EPA assumed that the domestic parent firm sales information obtained from D&B, Ward s, or the other Internet sources are reliable for the purpose of this analysis.
EPA assumed that the firm size and sales data are reliable for 5 of the 6 large firms with C/S ratios greater than 1 percent. One firm, Sierra Pine (a California Limite d Partnership), should be5-10 regarded as a special case. Sierra Pine recently purchased three affected facilities from Weyerhaeuser, greatly increasing the total costs associated with Sierra Pine. However, Sierra Pine’s sales data is from a query of D&B data performed in late 1999. As a result, the sales associated with recent acquisition of the three plants are not reflected in Sierra Pine’s sales data. If, for instance, Sierra Pine’s total compliance costs were prorated to exclude the cost s attributed to the plants previously owned by Weyerhaeuser, Sierra Pine’s C/S would ch ange from 4.9 percent to 1.7 percent.
EPA also tested the sales estimates applied to la rge firms. The one large firm for which EPA assumed sales had a C/S ratio well below one percent. In this case, the firm’s actual sales would have to be approximately half of the assumed sales in order for the firm’s C/S ratio to exceed one percent. EPA believes that while the assumed sales are potentially hi gher than the actual sales of this firm, it is less likely that the firm has actual sales that w ould result in a C/S ratio over one percent.
EPA used industry-wide measures of profitability because such information is not available for privately held firms. Because all the affected firms with C/S ratios above one percent are privately held, firm-specific information regarding R/S is not publicly available. If firm specific profitability measures were available, it is likely that a comparison of firms’ C/S ratio to their R/S ratio would produce significantly different results. It should be noted that while overall industry return on sales may be low, it is not necessarily the case for any given firm.
All ten small firms with C/S ratios of one percen t or greater had a C/S ratio that exceeded the industry profitability measure of return on sales. Fo r the three small firms whose C/S ratios were three percent or greater, the comparison of compliance cost s and profitability measures showed that their C/S ratios exceeded the industry R/S by over 100 percent. This divergence between the C/S ratios for these firms and the industry R/S is an indicator that th ese three firms may experience high impacts as a result of incurring the costs of compliance associated with the rule. However, the results of the economic impact analysis show that the affected facilities owned by these firms will continue to operate after controls have been applied to comply with the rule. Therefore, the impact on these firms, while relatively high, are not enough to lead them to cease operations at these facilities.

5.7 Screening Analysis Conclusions
The Regulatory Flexibility Act (RFA) generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and sm all governmental jurisdictions.5-11 For purposes of assessing the impacts of today’s rule on small entities, small entity is defined as: (1) a small business according to Small Business Admi nistration size standards by 5-digit NAICS code of the domestic parent owning entity (in this case, 500 employees); (2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and (3) a small organization that is any not-for-profit enterprise which is independently owned and operated a nd is not dominant in its field.
After considering the economic impact of today’s rule on small entities, we certify that this action will not have a significant impact on a substa ntial number of small entities. In accordance with the RFA, we conducted an assessment of the standard on small businesses in the industries affected by the rule. Based on SBA size definitions for the a ffected industries and reported sales and employment data, the Agency identified 17 of the 52 companies, or 32 percent, owning affected facilities as small businesses. These facilities incur capital and MRR costs associated with the rule. There 31 other firms that only incur MRR costs; and all of these firms are small. Although small businesses represent 32 percent of the affected companies w ithin the source category, they are expected to incur only 6 percent of the total industry compliance costs of $143 million. There are only three small firms with compliance costs equal to or greater than 3 percent of their sales. In addition, there are seven small firms with costto-sales ratios between 1 and 3 percent.
We performed an economic impact analysis to estimate the changes in product price and production quantities for the firms affected by this ru le. The analysis shows that of the 32 facilities owned by affected small firms, only one would be e xpected to shut down rather than incur the cost of compliance with the rule. Although any facility closur e is cause for concern, it should be noted that the baseline economic condition of the facilities predicted to close affects the closure estimate provided by the economic model. Facilities which are already e xperiencing adverse economic conditions for reasons unconnected to this rule are more vulnerable to the impact of any new costs than those that are not.
This analysis indicates that therule should not generate a significant impact on a substantial number of small entities for the coatings manufacturing source category for the following reasons. First, of the 10 small firms that have compliance costs great er than 1 percent of sales, only 3 have compliance costs of greater than 3 percent of sales. Second, th e results of the economic impact analysis show that only 1 facility owned by a small firm out of the 32 facilities owned by affected small firms may close due to the implementation of this rule

. The facility that may close rather than incur the cost of compliance appear to have low profitability levels curre ntly. It also should be noted that the estimate of compliance costs for this facility is likely to be an overestimate due to the lack of facility-specific data available to assign a precise control cost in this case. In sum, this analysis supports today’s certification under the RFA because, while a few small firms may e xperience significant impacts, there will not be a substantial number incurring such a burden.
Although this rule will not have a significant ec onomic impact on a substantial number of small entities, we minimized the impact of this rule on sm all entities in several ways. First, we considered5-12 subcategorization based on production and throughput level to determine whether smaller process units would have a different MACT floor than larger pr ocess units. Our data show that subcategorization based on size would not result in a less stringent leve l of control for the smaller process units. Second, in light of cost considerations, we chose to set the emission limitation at the MACT floor control level and not at a control level more stringent than the MACT floor control level. Thus, the control level specified in the PCWP rule is the least stringent a llowed by the CAA. Third, the rule contains multiple compliance options to provide facilities with the flex ibility to comply in the least costly manner while maintaining a workable and enforceable rule. The compliance options include emissions averaging and production-based emission limits which allow inherently low-emitting process units to comply without installing add-on control devices and facilities to use innovative technology and pollution prevention methods. Fourth, the rule includes multiple test method options for measuring methanol, formaldehyde, and total HAP.
5.8 Economic Impact Analysis Results for Small Businesses
Exhibit 5-7 provides a summary of the economic impact on small businesses associated with the estimated market adjustments due to compliance w ith the NESHAP. As shown, the Agency’s economic analysis indicates that the 17 small businesses that own 18 affected process lines will be affected as follows:

Exhibit 5-7: Economic Impacts on Small Businesses Associated with Projected Market Adjustments*

Changes from Baseline

Baseline With Regulation Absolute Percent Revenues ($ thousands/yr)** 394,393 387,229 7,164 -1.82

Production (million

m 3 /yr) 1,791,408 1,737,969 53,439 -2.98

Compliance Costs ($ thousands/yr) 0 9,194 9,194 n/a

Operating Process Lines 18 17 1 -5.56

Employment loss (FTEs) 3,621 3,513 108 -2.985-13 Notes: * Does not include small businesses that own facilities with MRR costs only. ** Estimated using production and price data in economic impact model FTEs = full-time equivalents

The one process line closure predicted by the economic impact model is owned by a small business. This results in a 5.6 percent decrease in the number of process lines owned by small business. Overall, the small businesses’ revenues decrease by just under 2 percent, their production decreases by just under 3 percent, and their total employment decreases by just under 3 percent, or 108 FTEs. The estimate of employment loss assumes that the production per employee at the affected facilities owned by small firms is the same as the industry average.

5.9 References

Abt Associates Inc. 2000a. Small Business Screening Analysis for the Plywood and Wood Composite Industries: Revised Draft. Prepared for Larry Sorrels, Innovative Strategies and Economic Group, Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC. June.
Abt Associates Inc. 2000b. Corporate employment and sales data collected through Internet business information resources, including Dun & Bradstr eet, Hoover’s On-line, Lycos Companies Online, Thomas’ Register, Ward’s Business Directory, and Zapdata.com.

Abt Associates Inc. 1999. Profile of the Plywood and Wood Composite Industries. Prepared for Larry Sorrels, Innovative Strategies and Economic Gr oup, Air Quality Strategies and Standards Division, Office of Air Quality Planning and Sta ndards, U.S. Environmental Protection Agency, Research Triangle Park, NC. December.

Midwest Research Institute. 1999. Memorandum fro m Becky Nicholson and Melissa Icenhour to Mary Tom Kissell and Larry Sorrels, U.S. EPA: “Preliminary facility-specific cost estimates for implementation of the plywood and compos ite wood products NESHAP.” October 20.
Midwest Research Institute. 2000. “Estimated Nationwide Costs of Control: Plywood and Wood Composite Products.” April 14.
U.S. Environmental Protection Agency. 1998. Industry Specific Information Collection Request (ICR) for the Development of Plywood and Particle board Maximum Achievable Control Technology5-14 (MACT) Standards . Air Quality Strategies and Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
U.S. Environmental Protection Agency. 1999a. OAQPS Economic Analysis Resource Document . Air Quality Strategies and Standards Division, Offi ce of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.

U.S. Small Business Administration. 2000. “Small Business Size Standards Matched to NAICS Codes.”

### 6-15 6 QUALITATIVE ASSESSMENT OF BENEFITS OF EMISSION REDUCTIONS

### 6-1 The emission reductions achieved by this envi ronmental regulation w ill provide benefits to society by improving environmental quality. This ch apter provides information on the types and levels of social benefits anticipated from the plyw ood and composite wood products (PCWP) NESHAP, including the health and welfare effects associat ed with the HAPs and other pollutants emitted by affected sources.
In general, the reduction of HAP emissions r esulting from the regulation will reduce human and environmental exposure to these pollutants and thus, re duce potential adverse health and welfare effects. This chapter provides a general discussion of the va rious components of total benefits that may be gained from a reduction in HAPs through this NESHAP. The rule will also achieve reductions of coarse particulate matter (PM 10 ), volatile organic compounds (VOC), and carbon monoxide (CO). There will also be emissions increases in nitrogen oxides (NOx) and sulfur dioxide (SO 2 ) associated with the use of incineration-based controls. The bene fits and disbenefits of the PM, NOx, and SO 2 emissions reductions and increases are presented separately from th e benefits associated with HAPs and CO. The benefits and disbenefits associated with PM, NOx, and SO 2 , along with the benefits associated with HAPs and CO are presented in this chapter.
6.1 Identification Of Potential Benefit Categories
The benefit categories associated with the emi ssion reductions predicted for this regulation can be broadly categorized as those benefits which are a ttributable to reduced exposure to HAPs, which are also VOCs, and those attributable to reduced exposur e to other pollutants. Some of the HAPs associated with this regulation have been classified as probabl e or possible human carcinogens. As a result, one of the benefits of the regulation is a reduction in th e risk of cancer. Other benefit categories include: reduced incidence of neurological effects and i rritants associated with exposure to noncarcinogenic HAPs, reduced incidence of cardiovascular and central nervous system problems associated with CO. In addition to health impacts occurring as a result of reductions in HAP and CO emissions, there are welfare impacts which can also be identified. In general, welfare impacts include effects on crops and other plant life, materials damage, soiling, and acidification of estuaries. Each category is discussed separately in the following section.
6.2 Qualitative Description Of Air Related Benefits - HAPs and CO
The operation of plywood and composite wood product sources produces emissions of acetaldehyde, acrolein, benzene, formaldehyde, ma nganese, methanol, methylene chloride, and phenol. The qualitative health and welfare benefits of these HAPs, and CO reductions are summarized separately in the discussions below.

6.2.1 Benefits of Reducing HAP Emissions

### 6-2 According to emission estimates, the regulation will reduce approximately 11,000 tons of emissions of HAPs such as acetaldehyde, acrolein, benzene, formaldehyde, manganese, methanol, methylene chloride, and phenol at all affect ed plywood and composite wood products sources.
Human exposure to these HAPs may occur directly through inhalation or indirectly through ingestion of food or water contaminated by HAPs or through dermal exposure. HAPs may also enter terrestrial and aquatic ecosystems through atmosphe ric deposition. HAPs can be deposited on vegetation and soil through wet or dry deposition. HAPs may also enter the aquatic environment from the atmosphere via gas exchange between surface wate r and the ambient air, wet or dry deposition of particulate HAPs and particles to which HAPs adso rb, and wet or dry depos ition to watersheds with subsequent leaching or runoff to bodies of water. 1 This analysis is focused only on the air quality benefits of HAP reduction.

6.2.1.1 Health Benefits of Reduction in HAP Emissions

. The HAP emission reductions achieved by this rule are expected to reduce exposure to ambient concentrations of acetaldehyde, acrolein, benzen e, formaldehyde, manganese, methanol, methylene chloride, and phenol, which will reduce a variety of adverse health effects considering both cancer and noncancer endpoints. Acrolein is classified as a possible human carcinogen, according to the Integrated Risk Information System (IRIS) 2

, an EPA system for classifying chemicals by cancer risk. This means that there is some evidence to indicate that exposur e to this chemical could cause an increased risk of cancer in humans. Acrolein may also cause genera l respiratory congestion and upper respiratory tract irritation. Formaldehyde and acetaldehyde are classified as probable human carcinogens, according to IRIS. Therefore, a reduction in human exposure to acrolein, formaldehyde, and acetaldehyde could lead to a decrease in cancer risk and ultimat ely to a decrease in cancer mortality.
The remaining HAP emitted by plywood and co mposite wood products sources, phenol and methanol, have not been shown to cause cancer. Ho wever, exposure to these pollutants may still result in adverse health impacts to human and non-human popul ations. In particular, methanol has been shown to be an irritant causing dizziness, headaches, and slight visual impairment.
For the HAPs covered by the NESHAP, evidence on the potential toxicity of the pollutants varies. However, given sufficient exposure cond itions, each of these HAPs has the potential to elicit adverse health or environmental effects in the expo sed populations. It can be expected that emission reductions achieved through the NESHAP will decrease the incidence of these adverse health effects.

6.2.1.2 Welfare Benefits of Reduction in HAP Emissions

. The welfare effects of exposure to HAPs have received less attention from analysts than the health effects. However, this situation is changi ng, especially with respect to the effects of toxic substances on ecosystems. Over the past ten years, ecotoxicologists have started to build models of ecological systems which focus on interrelationships in function, the dynamics of stress, and the adaptive potential for recovery. This is c onsistent with the observation that chronic sub-lethal exposures may affect the normal functioning of individual species in ways that make it less than competitive and therefore more susceptible to a variety of factors including disease, insect attack, and decreases in habitat quality. 3 All of these factors may contribute to an overall change in the structure (i.e., composition) and function of the ecosystem.

### 6-3 The adverse, non-human biological effects of HAP emissions include ecosystem and recreational and commercial fishery impacts. Atmospheric depositi on of HAPs directly to land may affect terrestrial ecosystems. Atmospheric deposition of HAPs also contributes to adverse aquatic ecosystem effects. This not only has adverse implications for individual wildlife species and ecosystems as a whole, but also the humans who may ingest contaminated fish and waterfowl. In general, HAP emission reductions achieved through the NESHAP should reduce the associated adverse environmental impacts.

6.2.2 Benefits of Reduced CO Emissions Due to HAP Controls
As is mentioned above, controls that will be required on plywood a nd composite wood products sources to reduce HAPs will also reduce emissions of CO. The EPA Staff Paper for CO provides a summary of the health effects info rmation pertinent to the NAAQS for CO 4 . This information is a summary of information from the CO Criteria Document (CD) 5 , which provides a critical review of a wide variety of health effects studies, including a lim ited number of newer health effects studies, as well as older studies. Some were conducted at extremely high levels of CO (i.e. much higher than typically found in ambient air); however, the focus of this Staff Paper is on tho se key controlled-exposure laboratory studies and newer epidemiology studies, which were conducted with human subjects at COHb levels that are most relevant to regulatory decision making.
Based on the CD, staff concludes that human h ealth effects associated with exposure to CO include cardiovascular system and central nervous syst em (CNS) effects. In addition, consideration is given in the CD to combined exposure to CO, other pollutants, drugs, and the influence of environmental factors. Cardiovascular effects of CO are directly related to reduced oxygen content of blood caused by combination of CO with Hb to form COHb, resulti ng in tissue hypoxia. Most healthy individuals have mechanisms (e.g. increased blood flow, blood vessel dilation) which compensate for this reduction in tissue O 2 , although the effect of reduced maximal exerci se capacity has been reported in healthy persons at low COHb levels. Several other medical c onditions such as occlusive vascular disease, chronic obstructive lung disease, and anemia can increase susceptib ility to potential adverse effects of CO during exercise.
Effects of CO on the CNS involve both behavioral and physiological changes. These include modification of visual perception, hearing, mo tor and sensorimotor performance, vigilance, and cognitive ability. Developmental toxicity effects of low-level ambient CO exposures, though not well studied in humans, may pose a threat to the fetu s. Finally, environmental factors (e.g. altitude, temperature), drug interaction, and pollutant interacti on also can play a role in the public health impact of ambient CO exposure. There is little new information on these effects.
Exhibit 6-1 is a summary of key health effect s and studies which have been identified as being most pertinent to a regulatory decision on the NAAQS for CO 6 . Each of the key studies is considered in light of limitations discussed in the CD and the Sta ff Paper. For example, epidemiological studies are limited by factors such as exposure uncertainties and confounding variables, and many of the controlled exposure studies of CO health effects have b een hampered by uncertainties regarding COHb measurements, relatively small sample sizes, and lack of “real world” exposure conditions.

### 6-4 Exhibit 6-1. Key Health Effects Of Exposure To Ambient Carbon Monoxide Target Organ Health Effects a,b Tested Population c References Lungs Reduced maximal exercise duration with 1-h peak CO exposures resulting in $ 2.3% COHb (GC) Healthy individuals Drinkwater et al. (1974) Raven et al. (1974b) Horvath et al. (1975) Heart Reduced time to ST segment change of the ECG (earlier onset of myocardial ischemia) with peak CO exposures resulting in $ 2.4% COHb (GC) Individuals with coronary artery disease Allred et al. (1989a,b; 1991)

Heart Reduced exercise dur ation because of increased chest pain (angina) with peak CO exposures resulting in $ 3% COHb (CO-Ox) Individuals with coronary artery disease Anderson et al. (1973) Sheps et al. (1987) Adams et al. (1988) Kleinman et al. (1989, 1998*) Allred et al. (1989a,b; 1991) Heart Increased number and complexity of arrhythmia (abnormal heart rhythm) with peak CO exposures resulting in $ 6% COHb (CO-Ox) Individuals with coronary artery disease and high baseline ectopy (chronic arrhythmia) Sheps et al. (1990)

Heart Increased hospital admissions associated with ambient pollutant exposures Individuals >65 years old with cardiovascular disease Schwartz and Morris (1995*) Morris et al. (1995*) Schwartz (1997*) Burnett et al. (1997*) Brain Central nervous sy stem effects, such as decrements in hand-eye coordination (driving or tracking) and in attention or vigilance (detection of infrequent events), with 1-h peak CO exposures ( . 5 to 20% COHb) Healthy individuals Horvath et al. (1971) Fodor and Winneke (1972) Putz et al. (1976, 1979) Benignus et al. (1987)

a The EPA has set significant harm levels of 50 ppm (8 -h average), 75 ppm (4-h average), and 125 ppm (1-h average). Exposure under these conditions could result in COHb levels of 5 to 10% and cause significant health effects in sensitive individuals.
b Measured blood COHb level after CO exposure.

c Fetuses, infants, pregnant women, elderly people, a nd people with anemia or with a history of cardiac or respiratory disease may be particularly sensitive to CO.

d This table is a reproduction of Table 6- 7 of the CD (p. 6-36, U.S. EPA, 1999a).
*Newer studies, published since comple tion of the last CO NAAQS review.

### 6-5 Although acute poisoning induced by CO can be lethal and is probably the best known health endpoint of CO, this only occurs at very high c oncentrations of CO (greater than 100 ppm, hourly average), which are not pertinent to the setting of the NAAQS. In the ambient air, exposures to lowerlevels of CO predominate. Very little data are ava ilable demonstrating human health effects in healthy individuals caused by or associated with exposures to low CO concentrations. Decrements in maximal exercise duration and performance in healthy individua ls have been reported at COHb levels of > 2.3% an d > 4.3% (GC), respectively; however, these decrements are small and likely to affect only athletes in competition. No effects were seen in healthy individuals during submaximal exercise, representing more typical daily activities, at levels as high as 15 to 20 % COHb 7 . Most recent evidence of CNS effects induced by exposure to CO indicates that behavioral impairments in healthy individuals should not be expected until COHb levels exceed 20% (CO-Ox), we ll above what would be caused by typical ambient air levels of CO 8 . Evidence of CO-induced fetal toxicity or of interactions with high altitudes, drugs, other pollutants, or other environmental stresses rema ins uncertain or suggests that effects of concern will occur in healthy individuals only with exposure to much higher levels of CO than are likely for offsite receptors for these facilities 9

.

6.3 Qualitative Description of Effects from Re ductions and Increases in Emissions from Other Pollutants Due to HAP Controls

As is mentioned above, controls that will be required on PCWP sources to reduce HAPs will also reduce emissions of other pollutants, namely: PM 10 , PM 2.5 , and increase NOx and SO 2 emissions. For more information on these non-HAP emissions a nd emission reductions, please refer to Chapter 3 of this RIA, the preamble for this rule, and the docket. The effects associated with exposure to PM (both coarse and fine), NOx, and SO 2 emissions are presented below.

6.3.1 Effects of NOx and Ozone Emissions.

Emissions of NO
x produce a wide variety of health and welfare effects. Nitrogen dioxide can irritate the lungs at high occupati onal levels and may lower resistance to respiratory infection, although the research has been equivocal. NO
x emissions are an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. Atmos pheric deposition of nitrogen leads to excess nutrient enrichment problems (“eutrophication”) in the Chesapeake Bay and several nationally important estuaries along the East and Gulf Coasts. Eutrophication can produce multiple adverse effects on water quality and the aquatic environment, including incr eased algal blooms, excessive phytoplankton growth, and low or no dissolved oxygen in bottom waters. Eutrophication also reduces sunlight, causing losses in submerged aquatic vegetation critical for hea lthy estuarine ecosystems. Deposition of nitrogencontaining compounds also affects terrestrial ecosystem s. Nitrogen fertilization can alter growth patterns and change the balance of species in an ecosystem.
Nitrogen dioxide and airborne nitrate also cont ribute to pollutant haze (often brown in color), which impairs visibility and can reduce residential property values and the value placed on scenic views.

NO x in combination with volatile organic compounds (VOC) also serves as a precursor to ozone. Based on a large number of recent studies, EPA has id entified several key health effects that may be

### 6-6 associated with exposure to elevated levels of oz one. Exposures to ambient ozone concentrations have been linked to increased hospital admissions and em ergency room visits for respiratory problems. Repeated exposure to ozone may increase susceptibility to respiratory infection and lung inflammation and can aggravate preexisting respiratory disease, such as asthma. Repeated prolonged exposures (i.e., 6 to 8 hours) to ozone at levels between 0.08 and 0.12 ppb, over months to years may lead to repeated inflammation of the lung, impairment of lung defe nse mechanisms, and irreversible changes in lung structure, which could in turn lead to premature aging of the lungs and/or chronic respiratory illnesses such as emphysema, chronic bronchitis, and asthma.
Those who work , play, or otherwise are ac tive outdoors have the highest ozone exposures. Children who are active playing outdoors during the su mmer have particularly high exposures. Further, children are more at risk than adults from the eff ects of ozone exposure because their respiratory systems are still developing. Adults who are outdoors and m oderately active during the summer months, such as construction workers and other outdoor workers, al so are among those with the highest exposures. These individuals, as well as people with respirator y illnesses such as asthma, especially children with asthma, may experience reduced lung function and in creased respiratory symptoms, such as chest pain and cough, when exposed to relatively low ozone levels during periods of moderate exertion. In addition to human health effects, ozone adversely affects crop yield, vegetation and forest growth, and the durability of materials. Ozone causes noticeable fo liar damage in many crops, trees, and ornamental plants (i.e., grass, flowers, shrubs, and trees) and causes reduced growth in plants.
Particulate matter (PM) can also be formed from NO
x emissions. Secondary PM is formed in the atmosphere through a number of physical and chemical processes that transform gases such as NO
x , SO 2 , and VOC into particles. A discussion of the effects of PM on human health and the environment are discussed further below. Overall, emissions of NO
x from PCWP sources can lead to some of the effects discussed in this section - either those directly related to NO
x emissions, or the effects of ozone and PM resulting from the combination of NO
x with other pollutants.

6.3.2 Benefits of PM Reductions.
Scientific studies have linked PM (alone or in combination with other air pollutants) with a series of health effects 10 . Fine particles (PM 2.5 ) can penetrate deep into the lungs to contribute to a number of the health effects. These health effects include decreased lung function and alterations in lung tissue and structure and in respiratory tract defe nse mechanisms which may be manifest in increased respiratory symptoms and disease or in more sever e cases, increased hospital admissions and emergency room visits or premature death. Children, the elderly, and people with cardiopulmonary disease, such as asthma, are most at risk from these health effects.
PM also causes a number of adverse effects on the environment. Fine PM is the major cause of reduced visibility in parts of the U.S., including many of our national parks and wilderness areas. Other environmental impacts occur when particles deposit onto soil, plants, water, or materials. For example, particles containing nitrogen and sulfur that depos it onto land or water bodies may change the nutrient balance and acidity of those environments, lead ing to changes in species composition and buffering capacity. Particles that are deposited directly ont o leaves of plants can, depending on their chemical composition, corrode leaf surfaces or interfere with plant metabolism. Finally, PM causes soiling and erosion damage to materials.

### 6-7 Thus, reducing the emissions of PM and PM precursors from PCWP sources can help to improve some of the effects mentioned above - eith er those related to primary PM emissions, or the effects of secondary PM generated by the combination of NO
x or SO 2 with other pollutants in the atmosphere.

6.3.3 Effects of SO 2 Emissions.
Very high concentrations of sulfur dioxide (SO 2 ) affect breathing and ambient levels have been hypothesized to aggravate existing respirator y and cardiovascular disease. Potentially sensitive populations include asthmatics, individuals with bronc hitis or emphysema, children and the elderly. SO 2 is also a primary contributor to acid deposition, or acid rain, which causes acidification of lakes and streams and can damage trees, crops, historic buildings and statues. In addition, sulfur compounds in the air contribute to visibility impairment in large parts of the country. This is especially noticeable in national parks.

PM can also be formed from SO 2 emissions. Secondary PM is formed in the atmosphere through a number of physical and chemical processes that transform gases, such as SO 2 , into particles. Overall, emissions of SO 2 can lead to some of the effects discussed in this section - either those directly related to SO 2 emissions, or the effects of ozone and PM resulting from the combination of SO 2 with other pollutants.

6.4 Lack Of Approved Methods To Quantify HAP Benefits
The most significant effect associated with the HAPs that are controlled with the rule is the potential incidence of cancer. In previous analyses of the benefits of reductions in HAPs, EPA has quantified and monetized the benefits of pot ential reductions in the incidences of cancer 11,12 . In some cases, EPA has also quantified (but not monetized) reductions in the number of people exposed to noncancer HAP risks above no-effect levels 13

.
Monetization of the benefits of reductions in cancer incidences requires several important inputs, including central estimates of cancer risks, estimates of exposure to carcinogenic HAPs, and estimates of the value of an avoided case of cancer (fatal and non -fatal). In the above referenced analyses, EPA relied on unit risk factors (URF) developed through risk assessment procedures. The unit risk factor is a quantitative estimate of the carcinogenic potency of a pollutant, often expressed as the probability of contracting cancer from a 70 year lifetime con tinuous exposure to a concentration of one : g/m 3 of a pollutant. These URFs are designed to be conserva tive, and as such, are more likely to represent the high end of the distribution of risk rather than a best or most likely estimate of risk.
In a typical analysis of the expected health be nefits of a regulation (e.g., the Interstate Air Quality Rule benefit analysis), health effect s are estimated by applying changes in pollutant concentrations to best estimates of risk obtained from epidemiological studies. As the purpose of a benefit analysis is to describe the benefits most lik ely to occur from a reduction in pollution, use of highend, conservative risk estimates will over-estimate of th e expected benefits of the regulation. For this reason, we will not attempt to quantify the health benefits of reductions in HAPs unless best estimates of risks are available. While we used high-end risk estimates in past analyses, recent advice from the EPA Science Advisory Board (SAB) and internal methods reviews have suggested that we avoid using high-

### 6-8 end estimates in current analyses. EPA is work ing with the SAB to develop better methods for analyzing the benefits of reductions in HAPs.
While not appropriate for inclusion in our primar y quantified benefits analysis, to estimate the potential baseline risks posed by the PCWP source category and the potential impact of applicability cutoffs, EPA performed for the proposal a “rough” risk assessment for 185 of the 223 facilities in the PCWP source category. There are large uncertainties regarding all components of the risk quantification step, including location of emission reductions, emi ssion estimates, air concentrations, exposure levels and dose-response relationships. However, if these uncertainties are properly identified and characterized, it is possible to provide upper bound estimates of the potential reduction in inhalation cancer incidence associated with this rule. It is important to keep in mind that these estimates will not cover non-inhalation based cancer risks and non-cancer health effects.
The HAP included in this “rough” risk assessment at the proposal were acetaldehyde, acrolein, benzene, formaldehyde, manganese, methanol, methylene chloride, and phenol. Of these HAP, four are presently not considered to have thresholds: acet aldehyde, benzene, formaldehyde, and methylene chloride.
Of the 185 facilities assessed, 148 facilities were found to pose cancer risks equal to or greater than 1 in 1,000,000 to their surrounding population. Forty-six facilities were predicted to pose cancer risks of 1 in 100,000 or greater, and two PCWP facilities were found to pose cancer risks equal to or greater than 1 in 10,000.
If this rule is implemented at all PCWP f acilities, annual cancer incidence would be reduced from about 0.09 cases/year to about 0.02 cases/year, while the number of people at or above a cancer risk level of 1 in a million would be reduced from about 900,000 to 150,000. In addition, the number of people exposed to hazard index (HI) values equal to or greater than 1 was estimated to be reduced from about 270,000 to about 30,000, and the number of peopl e exposed to HI values of 0.2 or greater was predicted to decrease from about 1,500,000 to about 250,000. (Details of these analyses are available in the docket).
EPA has prepared a more refined risk assessment for the final rule as part of evaluating the development of a low-risk subcategory of sources wh ich could be delisted and thus not have to put on controls associated with the rule 14 . This more refined assessment included 26 HAPs, and these HAPs include those that were in the “rough” risk assessment plus: antimony, arsenic, beryllium, cadmium, chromium, cobalt, cumene, ethylbenzene, lead, mercury, methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), methylene diphenyl diisocyanate, ni ckel, selenium, styrene, toluene, and xylene.

There were 181 facilities included in this more refined risk assessment. Twenty-four facilities were found to pose cancer risks equal to or greater than 1 in 1,000,000 to their surrounding population. No facilities were predicted to pose cancer risks of 1 in 100,000 or greater. The reduction in annual cancer incidence and the number of people to particul ar HI levels were not estimated in among affected populations, and these reductions were not estimated since the focus of the more refined assessment was on affected PCWP sources.

EPA has not tried to monetize this reduced inci dence of inhalation cancer for several important technical reasons. The primary reasons include the lack of information on the latency period for the

### 6-9 onset of the disease and the fact that we have no information on the proportion of fatal versus nonfatal cancers which may occur. These factors pr event us from providing monetized estimates.
For non-cancer health effects, previous analy ses have estimated changes in populations exposed above the reference concentration level (RfC). Ho wever, this requires estimates of populations exposed to HAPs from controlled sources. Due to data lim itations, we do not have sufficient information on emissions from specific sources and thus are una ble to model changes in population exposures to ambient concentrations of HAPs above the RfC. As a result, we are unable to place a monetary value of the HAP related benefits associated with this rule.

6.5 Summary
The HAPs that are reduced as a result of implementing the plywood and composite wood products NESHAP will produce a variety of benefits, some of which include: a possible reduction in the incidence of cancer to exposed populations, neurotoxic ity, irritation, and crop or plant damage. The rule will also produce benefits associated with reductions in CO. Human health effects associated with exposure to CO include cardiovascular system and central nervous system (CNS) effects. Although we are unable to place a monetary value on these benefits, the information on the variety of effects associated with these pollutants and the level of re ductions anticipated from the NESHAP indicate that the benefits of the rule will be substantial.

### 6-10 6.6 REFERENCES

1. U.S. Environmental Protection Agency. Regulatory Impact Analysis for the National Emissions Standards for Hazardous Air Pollutants for Source Categories: Organic Hazardous Air Pollutants from the Synthetic Organic Chemi cal Manufacturing Industry and Seven Other Processes. Draft Report. Office of Air Quality Planning and Standards. Research Triangle Park, NC. EPA-450/3-92-009. December 1992.

2. U.S. Environmental Protection Agency. Integrated Risk Information System; website access available at www.epa.gov/ngispgm3/iris.
3. Reference 1. p. 3-5.

4. U.S. Environmental Protection Agency. Ecological Exposure and Effects of Airborne Toxic Chemicals: An Overview. EPA/6003-91/001. Environmental Research Laboratory. Corvallis, OR. 1991.
5. U.S. Environmental Protection Agency; Staff Paper for the Carbon Monoxide NAAQS; Office of Air Quality Planning and Standards, Research Triangle Park, N.C.; 2000.
6. U.S. Environmental Protection Agency; Criteria Document for Carbon Monoxide; Office of Air Quality Planning and Standards, Research Triangle Park, N.C.; 1999.

7. Reference 6..

8. Reference 6.

9. Reference 6.
10. US Environmental Protection Agency, 1996. Review of the National Ambient Air Quality Standards for Particulate Matter: Assessment of Scientific and Technical Information. Office of Air Quality Planning and Standards, Research Triangle Park, NC EPA report no. EPA/4521R96-013.

11. Reference 10.
12. U.S. Environmental Protection Agency. 1992. Draft Regulatory Impact Analysis of National Emissions Standards for Hazardous Air Pollutant s for By Product Coke Oven Charging, Door Leaks, and Topside Leaks. Office of Air Quality Planning and Standards, Research Triangle Park, NC.
13. U.S. Environmental Protection Agency. 1995. Regulatory Impact Analysis for the Petroleum Refinery NESHAP. Revised Draft for Promulgation. Office of Air Quality Planning and Standards, Research Triangle Park, NC.

### A-11 14. U.S. Environmental Protection Agency. 2004. Risk Assessment for the Final Maximum Achievable Control Technology (MACT) Rule for the Plywood and Composite Wood Products (PCWP) Source Category. Office of Air Qua lity Planning and Standards, Research Triangle Park, NC.

### A-1 Appendix A: Summary of Impacts Associated with the Delisted Low-Risk Subcategory

Background
One of the compliance alternatives to the final rule is allowing PCWP sources to demonstrate that their HAP emissions are sufficiently low-risk to avoid being subject to the MACT compliance requirements. Such sources would then be part of a low-risk subcategory and can be delisted.
For your affected source to be part of the delis ted low-risk subcategory, you must have a lowrisk demonstration approved by EPA, and you must then have federally-enforceable conditions reflecting the parameters used in your EPA-approved demonstration incorporated into your title V permit to ensure that your affected source remains low-ri sk. Low-risk demonstrations for eight facilities were conducted by EPA and no further dem onstration is required for them, and they will now need to obtain title V permit terms reflecting their status. (We will provide these sources and their title V permitting authorities with the necessary parameters for estab lishing corresponding permit terms and conditions.) These facilities are listed in the preamble. Other fac ilities may demonstrate they are low risk to EPA by using the look-up tables in appendix B to subpart DDDD or conducting a site-specific risk assessment as specified in appendix B to subpart DDDD. Appe ndix B to subpart DDDD also specifies which process units and pollutants must be included in your low -risk demonstration, emissions testing methods, the criteria for determining if a affected source is low risk, risk assessment methodology (look-up table analysis or site-specific risk analysis), contents of the low-risk demonstration, schedule for submitting and obtaining approval of your low -risk demonstration, and methods for ensuring that your affected source remains in the low-risk subcategory. If you de monstrate that your affected source is part of the delisted low-risk subcategory of PCWP manufacturing facilities, then your affected source is not subject to the MACT compliance options, operating requirement s, and work practice requirements in the final PCWP rule (subpart DDDD).

Low-risk Criteria We may approve your affected source as eligib le for membership in the delisted low-risk subcategory of PCWP sources if we determine that it is low risk for both carcinogenic and noncarcinogenic effects. To be considered low risk , the PCWP affected source must meet the following criteria: (1) the maximum off-site individual lifetim e cancer risk at a location where people live is lessthan one in one million for carcinogenic chronic inhalation effects; (2) every maximum off-site targetorgan specific hazard index (TOSHI) at a location wh ere people live is less than or equal to 1.0 for non-carcinogenic chronic inhalation effects; and (3 ) the maximum off-site acute hazard quotients for acrolein and formaldehyde are less than or equal to 1.0 for noncarcinogenic acute inhalation effects. These criteria are built into the look-up tables included in appendix B to subpart DDDD. Facilities conducting site-specific risk assessments must explic itly demonstrate that they meet these criteria. Facilities need not perform site-specific multipathway human health risk assessments or ecological risk assessments since EPA performed a source category- wide screening assessment which demonstrates that these risks are insignificant for all sources.

More details on the delisted low-risk s ubcategory can be found in the preamble.

### A-2 Number of Affected Facilities
Facilities with estimated potential to emit 25 tons or more of total HAP or 10 or more tons of an individual HAP are major sources of HAP and are subject to the final rule. Approximately 223 PCWP major source facilities nationwide are expected to meet the applicability criteria defined in today’s final rule. These major source facilities generally manuf acture one or more of the following products: softwood plywood, softwood veneer, medium density fiberboard (MDF), oriented strandboard (OSB), particleboard, hardboard, la minated strand lumber, and laminated veneer lumber. However, only 212 of these facilities have equipment that is subject to the control requirements of the final rule. In addition, there are approximately 34 major source sawmill fac ilities that produce kiln-dried lumber; although these major source sawmill facilities meet the applicability criteria in the final rule, there are no control requirements for any of the equipment located at the sawmills.
The number of impacted facilities was determined based on the estimated potential to emit (i.e., uncontrolled HAP emissions) from each facility, whethe r each facility has any process units subject to the compliance options, whether or not the facility already operates control systems necessary to meet the final rule, and whether or not the facility is cu rrently eligible (or may later demonstrate eligibility) for inclusion in the delisted low risk subcategory. Of the 223 major source facilities, an estimated 162 are expected to install add-on control systems to reduce emissions. The remaining facilities already have installed add-on controls, do not have any process un its subject to the compliance options, are expected to comply with work practice requirements only, or are one of the eight facilities currently eligible for inclusion in the delisted low-risk subcategory. We estimate that eventually as many as 147 of the 223 major source PCWP facilities may demonstrate eligibility for the low-risk subcategory, leaving 58 facilities expected to install add-on control system s to reduce emissions. Some of the 147 facilities expected to eventually be included the low-risk subcategory were not e xpected to install controls to meet MACT because they either already have the necessary controls or do not have process units subject to the compliance options in today’s final rule.
The impacts presented in this appendix to the RIA represent the estimated impacts for the range of facilities, from 58 facilities estimated to be impacted following completion of eligibility demonstrations for the low-risk subcategory, to 162 facilities estimated to be impacted today. The impact estimates were based on the use of RT O (or in some cases a combination WESP and RTO) because RTO are the most prevalent HAP emissions control technology used in the PCWP industry. However, technologies other than RTO could be used to comply with today’s final rule. For a facility that we feel already achieves the emissions reduc tions required by today’s final rule, only testing, monitoring, reporting and recordkeeping cost impacts were estimated.

Emission Reductions
We estimate nationwide baseline HAP emissions from the PCWP source category to be 17,000 Mg/yr (19,000 tons/yr) at the current level of c ontrol. We estimate that today’s final rule will reduce total HAP emissions from the PCWP source category by about 9,900 Mg/yr (11,000 tons/yr). In addition, we estimate that today’s final rule w ill reduce VOC emissions (approximated as THC) by about 25,000 Mg/yr (27,000 tons/yr) from a baseline level of 45,000 Mg/yr (50,000 tons/yr). Depending on the number of facilities eventually demonstrating elig ibility for the low-risk subcategory, these emission

### A-3 reductions could change to 5,900 Mg/yr (6,600 t ons/yr) for HAP or 13,000 Mg/yr (14,000 tons/yr) for VOC.
In addition to reducing emissions of HAP and VOC , today’s final rule will also reduce emissions of criteria pollutants, such as carbon monoxide (CO) from direct-fired emission sources and particulate matter less than 10 microns in diameter (PM 10 ). We estimate that today’s final rule will reduce CO emissions by about 9,500 Mg/yr (10,000 tons/yr). We also estimate that the final rule will reduce PM 10 emissions by about 11,000 Mg/yr (12,000 tons/yr). Depending on the number of facilities eventually demonstrating eligibility for the low-risk subcate gory, these emission reductions could change to 7,600 Mg/yr (8,400 tons/yr) for CO and 5,300 Mg/yr (5,900 tons/yr) for PM 10 . Combustion of exhaust gases in an RTO generates some emissions of nitrogen oxides (NO X ). We estimate that the nationwide increase in NO X emissions due to the use of RTO will be about 2,100 Mg/yr (2,400 tons/yr). This estimated increase in NO X emissions may be an overestimate because some plants may select control technologies other than RTO to comply with today’s final rule. Depending on the number of facilities eventually demonstrating elig ibility for the low-risk subcategory, the estimated NO X emission increase could fall to 1,100 Mg/yr (1,200 tons/yr)

. Secondary air impacts of today’s final rule would result from increased electricity usage associated with operation of control devices. The secondary air emissions of NO X , CO, PM 10 , sulfur dioxide (SO 2 ) depend on the fuel used to generate electricity. Assuming as a worst-case that PCWP plants will purchase electricity from a coal-fired utility plant, we estimate that the final rule may increase secondary emissions of PM 10 by 99 Mg/yr (110 tons/yr), SO 2 by 4,000 Mg/yr (4,500 tons/yr), NO X by 2,000 Mg/yr (2,200 tons/yr), and CO by 66 Mg/yr ( 72 tons/yr). Depending on the number of facilities eventually demonstrating eligibility for the low-ri sk subcategory, these emission increases could fall to 52 Mg/yr (57 tons/yr) for PM 10 , 2,200 Mg/yr (2,400 tons/yr) for SO 2 , 1,000 Mg/yr (1,100 tons/yr) for NO X , and 35 Mg/yr (39 tons/yr) for CO. However, The EPA believes SO 2 emissions may not increase from electric generation since that the requirements of the Acid Rain trading program will keep power plants from increasing their SO 2 emissions. Furthermore, we believe that NOx emissions increases from power plants may be limited. The EPA expects the emissions trading program that is part of the NOx SIP call will likely keep NOx emissions in th e eastern United States from increasing as result of additional power genera tion to operate RTOs.

Wastewater impacts

Wastewater is produced from WESP blowdown, w ashing out of RTO, and biofilters. We based all of our impact estimates on the use of RTO (with or without a WESP upstream depending on the process unit). We estimate that the wastewater generated from WESP bl owdown and RTO washouts will increase by about 100,000 cubic meters per year (m 3 /yr) (27 million gallons per year (gal/yr)) as a result of today’s final rule. Depending on the numbe r of facilities eventually demonstrating eligibility for the low-risk subcategory, the wastewater impacts could fall to 89,000 cubic meters per year (m 3 /yr) (24 million gallons per year (gal/yr)). According to the data in our MACT survey, this nationwide increase in wastewater flow is within the range of water flow rates handled by individual facilities. Facilities would likely dispose of this wastewater by sending it to a municipal treatment facility, reusing it onsite (e.g., in log vats or resin mix), or hauling it offsite for spray irrigation. In addition, we are amending the effluent limitations, guidelines for th e timber products processing point source category to

### A-4 allow facilities (on a case-by-case basis) to obtain a permit to discharge wastewaters from APCD installed to comply with today’s final rule.

Impacts on Solid Waste

Solid waste is produced in the form of solids from WESP and by RTO or RCO media replacement. We estimate that 4,500 Mg/yr (5,000 tons /yr) of solid waste will be generated as a result of today’s final rule. Depending on the number of fac ilities eventually demonstrating eligibility for the low-risk subcategory, the solid waste increase c ould change to 2,800 Mg/yr (3,000 tons/yr). Some PCWP facilities have been able to use RTO or RCO media as aggregate in onsite roadbeds. Some facilities have also been able to identify a benefici al reuse for wet control device solids (such as giving them away to local farmers for soil amendment).
Additional Energy Use from Control Equipment Applications
The overall energy demand (i.e., electricity and natu ral gas) is expected to increase by about 4.3 million gigajoules per year (GJ/yr) (4.1 trillion Britis h thermal units per year (Btu/yr)) nationwide under today’s final rule. The estimated increase in the en ergy demand is based on the electricity requirements associated with RTO and WESP and the fuel re quirements associated with RTO. Electricity requirements are expected to increase by about 711 gigawatt hours per year (GWh/yr) under today’s final rule. Natural gas requirements are expected to increase by about of 44 million m 3 /yr (1.5 billion cubic feet per year (ft 3 /yr)) under the final rule. Depending on the number of facilities eventually demonstrating eligibility for the low-risk subcate gory, these energy estimates could fall to 2.3 million GJ/yr (2.2 trillion Btu/yr) for overall energy demand, 378 GWh/yr for the increase in electricity requirements, and 23 million m 3 /yr (0.8 billion ft 3 /yr) for the increase in natural gas requirements.

Compliance Cost Estimates
The cost impacts estimated for today’s final rule represent a high-end estimate of costs. Although the use of RTO technology to reduce HAP emissions represents the most expensive compliance option, we based our nationwide cost es timates on the use of RTO technology at all of the impacted facilities because: (1) RTO technology can be used to reduce emissions from all types of PCWP process units; and (2) we could not accurate ly predict which facilities would use emissions averaging or PBCO or install add-on control devices that are less costly to operate, such as RCO and biofilters. Therefore, our cost estimates are likely to be overstated as we anticipate that owners and operators of impacted sources will take adva ntage of available cost saving opportunities.
The high-end estimated total capital costs of t oday’s final rule are $471 million. Depending on the number of facilities eventually demonstrating e ligibility for the low-risk subcategory, the capital costs could fall to $240 million. These capital costs apply to existing sources and include the costs to purchase and install both the RTO equipment (and in some cases, a WESP upstream of the RTO) and the monitoring equipment, and the costs of performan ce tests. Wood products enclosure costs are also included for reconstituted wood products presses.

### A-5 The high-end estimated annualized costs of th e final standards are $140 million. Depending on the number of facilities eventually demonstrating elig ibility for the low-risk subcategory, the annualized costs could fall to $74 million. The annualized co sts account for the annualized capital costs of the control and monitoring equipment, operation and maintenance expenses, and recordkeeping and reporting costs. Potential control device cost sav ings and increased recordkeeping and reporting costs associated with the emissions averaging provisions in today’s final rule are not accounted for in either the capital or annualized cost estimates.

Economic Impacts
The economic impact analysis shows that the e xpected price increases for affected output would range from only 0.4 to 1.3 percent as a result of th e NESHAP for PCWP manufacturers. The expected change in production of affected output is a reducti on of 0.06 to 0.4 percent for PCWP manufacturers as a result of today’s final rule. No plant closures are expected out of the 223 facilities affected by the final rule. Therefore, it is likely that there is no adver se impact expected to occu r for those industries that produce output affected by the final rule, such as hardboard, softwood plywood and veneer, engineered wood products, and other composite wood products.
The economic impact analysis for the final rule estimates effects upon employment and foreign trade for the industries affected by the rule. The total reduction in employment for the affected industries is 0.3 percent of the current employment level (or 225 employees). This estimate includes the increase in employment among firms in these industries that do not incur any cost associated with the final rule. There is also minimal change in the fo reign trade behavior for the firms in these industries since the level of imports of affected composite wood products only increases by less than 0.1 percent. There will be reductions in effects on the national economy associated with eligibility of sources for the delisted low-risk subcategory. The employment level will now be reduced by 126 employees, which is 99 fewer than the reduction estimated for the final rule . The increase in the level of imports is half as large as that for the final rule.

Social Costs and Benefits

Our assessment of costs and benefits of today’s fi nal rule is detailed in the “Regulatory Impact Analysis for the Plywood and Composite Wood Products MACT.” The Regulatory Impact Analysis (RIA) is located in Docket number A-98-44 and Docket number OAR-2003-0048.
It is estimated that 3 years after implementati on of the final rule requirements, reductions of formaldehyde, acetaldehyde, acrolein, methanol, phenol and several other HAP from existing PCWP emission sources would be 5,900 Mg/yr (6,600 tons /yr) to 9,900 Mg/yr (11,000 tons/yr), depending on how many affected sources are in the low-risk sub category. The health eff ects associated with these HAP are discussed earlier in this preamble.
As for social costs, the high-end estimated annua lized social costs of the final standards are $135.1 million. Depending on the number of facilities ev entually demonstrating eligibility for the lowrisk subcategory, the annualized social costs could fall to $75 million.

### A-6 At this time, we are unable to provide a comp rehensive quantification and monetization of the HAP-related benefits of the final ru le. Nevertheless, it is possible to derive rough estimates for one of the more important benefit categories, i.e., the potential number of cancer cases avoided and cancer risk reduced as a result of the imposition of the MACT leve l of control on this source category. Our analysis suggests that imposition of the MACT level of control would reduce cancer cases by less than one case per year, on average, starting some years after impl ementation of the standards. We present these results in the RIA. This risk reduction estimate is uncer tain and should be regarded as an extremely rough estimate and should be viewed in the context of the full spectrum of unquantified noncancer effects associated with the HAP reductions. The risk reduc tion estimate will be somewhat less depending on the number of facilities eventually demonstrating eligibility for the low-risk subcategory.
The control technologies used to reduce the le vel of HAP emitted from PCWP sources are also expected to reduce emissions of CO, PM 10 , and VOC. Human health effects associated with exposure to CO include cardiovascular system and CNS effects, wh ich are directly related to reduced oxygen content of blood and which can result in modification of visual perception, hearing, motor and sensorimotor performance, vigilance, and cognitive ability. Th e VOC emissions reductions may lead to some reduction in ozone concentrations in areas in whic h the affected sources are located. There are both human health and welfare effects that result from e xposure to ozone, and these effects are listed earlier in the RIA and in the preamble..
At the present time, we cannot provide a monetary estimate for the benefits associated with the reductions in CO. We also did not provide a mone tary estimate for the benefits associated with the changes in ozone concentrations that result from the VOC emissions reductions since we are unable to do the necessary air quality modeling to estimate the ozone concentration changes. For PM 10 , we did not provide a monetary estimate for the benefits associ ated with the reduction of the emissions, although these reductions are likely to have significant health benefits to populations living in the vicinity of affected sources.
There may be increases in NO X emissions associated with today’s final rule as a result of increased use of incineration-based controls. These NO X emission increases by themselves could cause some increase in ozone and particulate matter (PM) concentrations, which could lead to impacts on human health and welfare as listed in Table 3 of th is preamble. The potential impacts associated with increases in ambient PM and ozone due to these emissi on increases are discussed in the RIA. In addition to potential NO X increases at affected sources, today’s final ru le may also result in additional electricity use at affected sources due to application of cont rols. These potential increases in electricity use may increase emissions of SO 2 and NO X from electricity generating utilities. As such, the final rule may result in additional health impacts from increased ambient PM and ozone from these increased utility emissions. However, it is possible that the Acid Rain trading program will serve to keep SO 2 emissions from increasing, and the NOx SIP call may serve to mitigate increases of NO X . We did not quantify or monetize these health impacts. All of these impacts will be reduced
In determining the overall economic consequences of the final rule, it is essential to consider not only the costs and benefits expressed in dollar terms but also those benefits and costs that we could not quantify. A full listing of the benefit categories that could not be quantified or monetized in our analysis is provided in Chapter 6 of the RIA. All of these benefits and effects will be mitigated depending on the number of facilities eventually demonstrati ng eligibility for the low-risk subcategory.5 Ibid.

6 U.S. Department of Energy, Energy Information Administration. 1998 Manufacturing Energy Consumption Survey. Located on the Internet at http://www.eia.doe.gov/ emeu/mecs/mecs98/datatables/contents.html.



### A-7 Small Business Analysis
As discussed in earlier sections of this preamble, we present the impacts of the rule associated with allowing PCWP facilities to demonstrate elig ibility for the delisted low-risk subcategory and thereby avoid MACT altogether. The number of sm all businesses impacted is re duced to seven from the original 17, and the total number of businesses impact ed is reduced to 42, down from the original 52. Small businesses represent 17 percent of the companies within the source category, which is down from the 32 percent estimate for the final rule. These sma ll businesses are expected to incur 4 percent of the total industry compliance costs of $75 million (the co sts considering inclusion of the delisted low-risk subcategory). There are no small firms with compliance costs equal to or greater than 3 percent of their sales as compared to three for the final rule. In a ddition, there are four small firms with cost-to-sales ratios between 1 and 3 percent, which is down from seven for the final rule.

Energy Impact Analysis
The impacts from consideration of a low-risk s ubcategory are a reduction in all of the energy impacts listed above. For fuel production, the result of this indirect effect from reduced product output is a reduction of only about 0.6 barrel per day nationwide, or a 0.000007 percent reduction nationwide based on 1998 U.S. fuel production data. 5 This is a 0.4 barrel smaller reduction than that estimated for the final rule. For coal production, the resulting indirect effect from reduced product output is a reduction of only 950 tons per year nationwide, or only a 0.0000044 percent reduction nationwide based on 1998 U.S. coal production data. This is a sm aller reduction than that estimated for the final rule by 1,050 tons per year. For electricity production, the resulting indirect effect from reduced product output is a reduction of 20.7 million kWh/ yr, or only a 0.00006 percent reduction nationwide based on 1998 U.S. electricity production data. This is a smaller output reduction than that estimated for the final rule by 22.1 million kWh/yr. Given that the estimated price increase for product output from any of the affected industries is no more than 2.5 percent, there should be no price increase for any energy type by more than this amount. The cost of energy distribution should not be affected by the final rule at all since the rule does not affect energy distribution facilities. Finally, with changes in net exports being a minimal percentage of domestic out put (0.006 percent, or practically the same as that for the final rule) from the affected industries, ther e will be only a negligible change in international trade, and hence in dependence on foreign energy s upplies. No other adverse outcomes are expected to occur with regards to energy supplies. Thus, the net effect on energy production if facilities are eligible for the low-risk source category is an increase in electricity output of 0.008 percent compared to 1998 output data, and a negligible change in output of other energy types. This is a 0.004 percent smaller increase in electricity output compared to the impact of the final rule. All of the results presented above account for the passthrough of costs to consumers, as well as the cost impact to producers. These results also account for how energy use is rela ted to product output for the affected industries. 6

### A-8TECHNICAL REPORT DATA (Please read Instructions on reverse before completing)

1. REPORT NO. EPA-452/R-04-005 2. 3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE Regulatory Impact Analysis for the Plywood and Composite Wood Products NESHAP 5. REPORT DATE February 2004

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS 

### Air Quality Strategies and Standards Division Innovative Strategies and Economics Group 10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO.

12. SPONSORING AGENCY NAME AND ADDRESS 

### Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency Research Triangle Park, NC 27711 13. TYPE OF REPORT AND PERIOD COVERED

14. SPONSORING AGENCY CODE 

### EPA/200/04

15. SUPPLEMENTARY NOTES

16. ABSTRACT 

### This report contains costs, economic impacts, and benefits information for the final Plywood and Composite Wood Products NESHAP. This MACT standard has annualized social costs of $135 million. No significant small business impacts are expected.

17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group 

### Air Pollution control, Economic Impacts, Small Business Impacts, Benefits

18. DISTRIBUTION STATEMENT


### Release Unlimited 19. SECURITY CLASS (Report) 

### Unclassified 21. NO. OF PAGES 

### 180

20. SECURITY CLASS (Page) 

### Unclassified 22. PRICE

EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE