News, Upcoming Events, and Regulatory Updates for the Forest Products Industry

Welcome to Issue No. 2 of our new quarterly forest products newsletter. I think the question at the top of everyone’s mind is What’s going to happen with the new administration? The National Association of Manufacturers (NAM) recently sent a letter to President-Elect Donald Trump that outlined a list of regulatory actions that would benefit manufacturing in the United States. They recommended actions such as a reconsideration of the lower PM2.5 National Ambient Air Quality Standards (NAAQS), maintaining the current ozone NAAQS, replacing the power plant greenhouse gas rules with more workable standards, and working more closely with manufacturers on various chemical regulations. The letter requested that the 2023 proposed revisions to the Air Emissions Reporting Requirements (AERR) rule and Project Emissions Accounting (PEA) not be finalized. Other issues important to the forest products industry would be a withdrawal of the 2023 “Good Neighbor Plan” and a different approach to the gap filling that U.S. Environmental Protection Agency (U.S. EPA) has been doing for National Emission Standards for Hazardous Air Pollutants (NESHAP), focusing on whether new standards are necessary based on risk, cost, feasibility of testing, and the overall value of setting additional standards. Both the pulp and paper and wood products sectors are facing potential expansions of NESHAP Subparts S, MM, and DDDD, the scope of which could be narrowed under a Trump administration. The new administration may also be more amenable to working on additional permitting and modeling guidance. As far as environmental justice, it is not likely to be a priority at the federal level under a Trump administration, but we expect environmental justice (EJ) policies and rules to continue to evolve at the state level. Read on for regulatory and technical tidbits of interest to the forest products industry and stay tuned for our 2025 Lookahead series of blogs in January.

Emerging Regulatory and Technical Topics

• U.S. EPA has released a new version of the TANKS software for estimating emissions from organic liquid storage tanks. TANKS version 5.1 is an online application now available for use. It doesn’t produce a report that looks as nice as the previous version, but it does use the most up-to-date methodology in AP-42 Section 7.1.
• Remember to check CEDRI to make sure you are using the most recent version of any required electronic report when you go to do your MACT reporting in January. For example, U.S. EPA recently updated the Boiler MACT consolidated semiannual report template. A log of updates is on the main CEDRI website.
• U.S. EPA has notified several pulp and paper facilities that they are subject to a Clean Air Act Section 114 Information Collection Request (ICR). The first phase of the ICR, a questionnaire related to 40 CFR Part 63, Subpart MM, has been issued and is due in 2025. U.S. EPA will issue a subsequent stack testing request for Subpart MM and a questionnaire and stack testing request for 40 CFR Part 63, Subpart S, to be completed in 2025 and 2026. These ICRs will inform U.S. EPA’s required periodic reviews of these subparts and 40 CFR Part 60, Subpart BBa. NCASI is compiling a list of questions and answers related to the ICR for members.
• U.S.?EPA recently issued a memo on correcting condensable PM stack test results due to ammonium sulfate formation.?Read our blog here.
• On November 22, 2024, U.S. EPA proposed the first of what is expected to be three new or revised rules related to the emissions of criteria pollutants, air toxics, and greenhouse gases (GHG) for stationary combustion turbines. The proposed update to the?New Source Performance Standards (NSPS) for Stationary Gas and Combustion Turbines?(40 CFR Part 60, Subparts GG and KKKK and the proposed new KKKKa) lowers the standards for the emissions of nitrogen oxides (NOX) for most new, modified, and reconstructed stationary combustion turbines, while keeping the current standards for sulfur dioxide (SO2) emissions the same. See our blog for the details.
• In October, U.S. EPA published final amendments to the NSPS for volatile organic liquid storage tanks, including revisions to Subpart Kb and a new Subpart Kc. Note that applicability of the new Subpart Kc is determined differently than facilities historically determined applicability of Subpart Kb. See our blog for the details.
• Years after the final revisions to the emission guidelines for commercial and industrial solid waste incineration (CISWI) units, U.S. EPA has finalized the Federal Plan that covers existing units in states where the guidelines were not adopted into the State Plan.
• U.S. EPA recently updated the Guideline on Air Quality Models (Appendix W to 40 CFR Part 51) and the AERMOD modeling system. The effective date for the changes to the Guideline is January 28, 2025, with a transition period that ends on November 29, 2025. The revisions to the Guideline are limited and are consistent with what was proposed in October 2023. U.S. EPA recently presented a webinar on the updates. Concurrent with these changes, U.S. EPA also finalized Guidance on Developing Background Concentrations for Use in Modeling Demonstrations. This guidance can be used to support the adjustment of monitor data in attainment areas to provide more representative background values for use in air dispersion modeling demonstrations, which will be critical in areas where the background is close to the recently lowered PM2.5 NAAQS.
• Clean Water Act (CWA) Hazardous Substances Facility Response Plan (FRP) Rule – After receiving many comments, the final rule was published in April of 2024 and is now codified at 40 CFR 118. The rule requires facilities within 0.5 mile of a navigable water with over 1,000 times the reportable quantity (RQ) of a CWA Hazardous Substance to determine whether they meet certain “substantial harm criteria.” Facilities that meet the substantial harm criteria are required to prepare, implement, and submit a FRP by June 1, 2027. Facilities that meet the initial applicability criteria but do not meet substantial harm criteria are required to certify that they do not meet the substantial harm criteria and provide supporting documentation. For more information on FRP, check out the recording of our webinar hosted on October 2.
• Lead and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI) - The deadline for submitting service line inventories as required by the LCRR passed on October 16, 2024. Days before, the Biden Administration finalized the LCRI. Both the LCRR and LCRI apply to community water systems (CWS) and non-transient, non-community water systems (NTNCWS). NTNCWS are public water systems that regularly supply water to at least 25 of the same people for at least six months per year (ex. Schools, factories, office buildings, and hospitals with their own water systems). LCRI requires additional inventorying of connector materials, validating accuracy of categorizing service lines as non-lead, replacement of certain service lines, and changes to action levels. All water systems must comply with the rule by November 1, 2027, with service line replacement completed within 10 years for most impacted systems. For more information, see our blog article.
• PFAS in Drinking Water – In April 2024, U.S. EPA finalized maximum contaminant levels (MCLs) for five individual PFAS and combined MCLs for mixtures of certain PFAS. U.S. EPA also finalized non-enforceable MCL goals (MCLGs). Drinking water systems have three years to complete initial monitoring with some time to take actions to reduce levels of PFAS. For more information, see our recent blog on PFAS.
• PFAS in Wastewater – Dischargers (including pulp and paper mills) in certain states are already starting to require data or statements regarding PFAS in NPDES renewal applications, and some NPDES permits renewed in the last couple of years now include PFAS monitoring requirements

Industry News

• AF&PA recently released a report on 2023 paper and cardboard recycling rates using an updated recycling rate methodology. In 2023, 46 million tons of paper was recycled. The?paper recycling rate?was?65-69%?and the?cardboard recycling rate?was?71-76%. About 80% of U.S. paper mills use some recycled paper to make new products.
• September 11, 2024? Summer 2024 brought numerous new, expanded facility announcements?Read more
• September 16, 2024? U.S. EPA says it has no obligation to regulate PFAS in biosolids in federal lawsuit?Read more
• September 23, 2024? Georgia-Pacific Holds Grand Opening for $550 Million Green Bay Tissue Mill?Read more
• October 1, 2024? Suzano Completes Acquisition of Pine Bluff Paper Mill and Waynesville Extrusion Facility?Read more
• October 2, 2024? Dart Container, Origin Materials announced workforce cuts in September?Read more
• October 11, 2024? International Paper, DS Smith shareholders vote to approve combination?Read more
• October 15, 2024? International Paper announces approximately 650 layoffs?Read more???
• October 16, 2024? National Forest Products Week?Read more
• October 21, 2024? International Paper to close facilities in 4 states, lay off hundreds?Read more
• October 22, 2024? Rayonier Advanced Materials Restarts Jesup Plant's A Line Ahead of Schedule?Read more
• October 24, 2024? Paper Excellence Group Rebrands All Legacy Businesses as Domtar?Read more
• October 28, 2024? Total U.S. Boxboard Production Increased Ten Percent in Q3 2024?Read more
• October 30, 2024? Smurfit Westrock cuts 800 positions, eyes footprint optimization and investments?Read more
• October 31, 2024? International Paper to Review of Strategic Options for Global Cellulose Fibers Business; Close Georgetown Pulp and Paper Mill?Read more
• October 31, 2024? DS Smith deal close pushed to 2025 as IP touts early results from its own turnaround plan?Read more
• November 4, 2024? Clearwater Paper Closes the Sale of Its Tissue Business to Sofidel for $1.06 Billion?Read more
• November 8, 2024? AF&PA Announces 2024 Award-Winning Sustainability Projects?Read more
• November 22, 2024? Irving Tissue Announces $600 Million Expansion Project at Macon, Georgia Tissue Mill?Read more
• December 6, 2024? Paper mills will host the launch of the demo for CO2 capture for chemical recovery boilers?Read more
• December 10, 2024? Novolex to Acquire Pactiv Evergreen for $6.7 Billion?Read more

Safety Corner

Combustible dust is a significant hazard in industries like forest products, where fine particles from processing wood or paper products can ignite and cause catastrophic explosions. Suspended dust in the air, combined with an ignition source, can trigger a rapid chain reaction. A small explosion can dislodge more dust, leading to a secondary, larger explosion that devastates facilities and endangers lives.

In January 2023, the Occupational Safety and Health Administration (OSHA) updated its Combustible Dust National Emphasis Program (NEP) to enhance the identification and reduction of combustible dust hazards across various industries, including forest products. This revision aims to focus enforcement efforts on industries with a higher incidence of combustible dust-related incidents, thereby improving workplace safety.

The forest products industry is particularly susceptible to combustible dust hazards due to processes that generate fine wood particles. The updated NEP emphasizes the importance of comprehensive hazard assessments, effective dust control measures, and adherence to housekeeping standards to mitigate the risk of dust explosions and fires. Employers are encouraged to familiarize themselves with OSHA’s guidelines and ensure compliance to protect workers from potential combustible dust hazards.?

By proactively implementing safety measures, the forest products industry can significantly reduce the likelihood of combustible dust incidents, safeguarding both employees and operations. For assistance, please reach out to your ALL4 project manager or Brian Godfrey at [email protected].

4 The Record: Behind the Scenes?is ALL4’s podcast, which we use to keep you informed on the latest changes in the world of environmental regulations and technology.

Hosted by Colin McCall, Chief Technical Officer.

Click here to view the library of current and archived recordings, including the latest podcast where Colin talks Air Quality Regulatory updates with Amy Marshall.

Events

Recent Relevant Webinars/Podcasts

• Air Regulatory Update podcast
• Water Regulatory Update podcast
• CWA Hazardous Substances Facility Response Plan webinar

Upcoming Events/Conferences

• Southwest Louisiana AWMA Spring Conference, February 27, 2025
• Louisiana Environmental Conference and Trade Fair, March 19-21, 2025
• North Carolina Manufacturers Association Air and Water Quality Workshops – February and March 2025

Training

ALL4 provides regular training programs and can customize a training program for your company or facility. For example, we recently presented a 4-hour training to a company’s environmental group focused on the basics of air construction permits, operating permits, and federal air rules specific to the types of equipment operated by the company. We can also provide custom Waste 101 training for your facility or company. The following training programs were updated recently and are a subset of those available on our website:

• Air Quality 101
• Water 101

Click here for a list of ALL4 conferences, webinars, trainings, and other events.

Upcoming Regulatory Deadlines:

The Risk Management Program (RMP) rule has a mandatory notification requirement due annually, but for the first time on December 19,?2024,?for coordination of emergency notifications under?40 CFR 68.96(a)?

• § 68.96 Emergency response exercises.?
• (a)?Notification exercises.?At least once each calendar year, the owner or operator of a stationary source with any Program 2 or Program 3 process shall conduct an exercise of the stationary source's emergency response notification mechanisms required under?§ 68.90(b)(3)?or?§ 68.95(a)(1)(i), as appropriate, before December 19, 2024, and annually thereafter. Owners or operators of responding stationary sources may perform the notification exercise as part of the tabletop and field exercises required in?paragraph (b)?of this section. The owner/operator shall maintain a written record of each notification exercise conducted over the last five years.?

Responding facilities (those with their own emergency response teams) must coordinate?with?the local, state, and federal agencies and ensure the community notification system functions per § 68.95(a)(1)(i). Non-responding facilities only have to make sure their system to contact the community emergency responders and communicate the emergency and response needed is functional per § (68.93(b)(3). We can help with either of these activities for your facility. If you have any questions, please reach out to your ALL4 project manager or Scott Kirkpatrick.?

Other upcoming regulatory deadlines:?

January?

• Quarterly compliance reports?
• Semi-annual Title V compliance reports??
• Semi-annual MACT and NSPS compliance reports?
• Semi-annual state-required reports?
• Annual air regulatory compliance reports?
• Annual wastewater reports (production report, biocides report, BMP incident report)?
• Monthly DMR reporting?

February?

• Tier II reports?
• Monthly DMR reporting?
• Waste minimization reports?

March?

• GHG reports?
• Monthly DMR reporting?

Tips & Tricks?

ALL4 has several staff who are experienced in onsite compliance assessments. Here are some reminders of common findings that are easily corrected before your next inspection or internal assessment:

• Improperly stored or labeled waste
• Waste stored onsite longer than allowed
• Inadequate aisle space in hazardous waste storage areas
• SPCC plan or inspection form does not account for all containers or tanks
• Failure to conduct stormwater sampling or monitoring
• Incomplete inventory of regulated refrigerant containing equipment, incomplete refrigerant records
• Failure to conduct or document required inspections and corrective actions under various plans or permits
• Failure to conduct required annual program reviews

Solutions Spotlight

Organizations often face significant challenges in assessing and communicating ESG and sustainability risks within their global value chains. With complex data sources, diverse stakeholders, and evolving regulatory demands, businesses need a secure, scalable, and intuitive solution to effectively visualize and manage risks.

ALL4 helps organizations address these challenges through our tailored Value Chain Risk Visualization Tools. Built on leading Business Intelligence platforms, our solutions integrate diverse data sources, provide actionable insights, and enable clear communication of material risks affecting the forest products industry.

• Customized Dashboards: Intuitive interfaces designed to deliver specific insights for diverse stakeholder needs.
• Dynamic Heat Maps: Pinpoint critical risk hotspots, such as:

1. Wildfire Risks: Map fire-prone areas to understand potential disruptions in raw material sourcing.
2. Water Scarcity: Assess regions where limited water availability affects forestry operations and processing facilities.
3. Geopolitical Instability: Identify regions where political risks or trade restrictions could impact the supply chain.
4. Climate Change Impacts: Visualize areas vulnerable to extreme weather or changing growing conditions.

• Comprehensive Data Integration: Seamlessly merge public, proprietary, and client-specific datasets for accurate and personalized risk assessment.
• Secure & Compliant: Built to adhere to the highest industry standards for security and compliance.
• Advanced Analytics: Assess logistics and supply chain risks, visualize transport layers, and aggregate multiple risk factors into a unified overview.
• Scalable & Flexible: Start with foundational features and expand to meet evolving requirements with ease.

ALL4’s extensive experience in the forest products industry, combined with our deep expertise in sustainability, enables us to develop tools and solutions tailored to the sector’s unique challenges. These tools help organizations effectively identify, monitor, and mitigate key risks, such as raw material vulnerabilities, environmental impacts, and regulatory compliance. Please contact Connie Prostko-Bell at [email protected] or 610-422-1110 for more information or to discuss how this tool could benefit your company.

I hope everyone has a great holiday season and I look forward to seeing you in 2025! Please reach out if you have any suggestions for our next quarterly newsletter.

Thanks,

Amy Marshall, Air Quality Practice Director

ALL4