National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products

Note: EPA no longer updates this information, but it may be useful as a reference or resource.

[Federal Register: January 9, 2003 (Volume 68, Number 6)]
[Proposed Rules]
[Page 1275-1339]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr09ja03-19]

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Part III
Environmental Protection Agency
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40 CFR 63
National Emission Standards for Hazardous Air Pollutants: Plywood and
Composite Wood Products; Proposed Rule

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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 63
[FRL-7419-3]
RIN 2060-AG52

National Emission Standards for Hazardous Air Pollutants: Plywood
and Composite Wood Products

AGENCY: Environmental Protection Agency (EPA).
ACTION: Proposed rule.
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SUMMARY: This action proposes national emission standards for hazardous
air pollutants (NESHAP) for the plywood and composite wood products
(PCWP) source category. The EPA has determined that the PCWP source
category contains major sources of hazardous air pollutants (HAP),
including acetaldehyde, acrolein, formaldehyde, methanol, phenol, and
propionaldehyde. These HAP are associated with a variety of adverse
health effects. These adverse health effects include chronic health
disorders (e.g., damage to nasal membranes, reproductive disorders, and
problems with pregnancies) and acute health disorders (e.g., irritation
of eyes, throat, and mucous membranes, dizziness, headache, and
nausea). Three of the HAP have been classified as probable or possible
human carcinogens. These proposed standards would implement section
112(d) of the Clean Air Act (CAA) by requiring all major sources
subject to the rule to meet HAP emission standards reflecting the
application of the maximum achievable control technology (MACT).
Implementation of the proposed standards would reduce HAP emissions
from the PCWP source category by approximately 9,700 megagrams per year
(Mg/yr) (11,000 tons per year (tons/yr)). In addition, the proposed
standards would reduce emissions of volatile organic compounds (VOC) by
25,000 Mg/yr (27,000 tons/yr). This action also proposes to add a
method to the relevant General Provisions to measure methanol,
formaldehyde, and phenol and a method to measure total HAP at PCWP
facilities.
DATES: Comments. Submit comments on or before March 10, 2003.
Public Hearing. If anyone contacts the EPA requesting to speak at a
public hearing by January 29, 2003, a public hearing will be held on
February 10, 2003.
ADDRESSES: Comments. Written comments sent by U.S. mail should be
submitted (in duplicate if possible) to: Air and Radiation Docket and
Information Center (Mail Code 6102T), Attention Docket Number A-98-44,
Room B108, U.S. EPA, 1301 Constitution Avenue, NW., Washington, DC
20460. Written comments delivered in person or by courier (e.g., FedEx,
Airborne, and UPS) should be submitted (in duplicate if possible) to:
Air and Radiation Docket and Information Center (Mail Code 6102T),
Attention Docket Number A-98-44, Room B102, U.S. EPA, 1301 Consitution
Avenue, NW., Washington, DC 20460. The EPA requests a separate copy
also be sent to the contact person listed below (see FOR FURTHER
INFORMATION CONTACT).
Public Hearing. If a public hearing is held, it will be held at 10
a.m. at the EPA Office of Administration Auditorium, Research Triangle
Park, North Carolina.
Docket. Docket No. A-98-44 contains supporting information used in
developing the standards. The docket is located at the U.S. EPA, 1301
Constitution Avenue, NW., Washington, DC 20460 in room B108, and may be
inspected from 8:30 a.m. to 5:30 p.m., Monday through Friday, excluding
legal holidays.
FOR FURTHER INFORMATION CONTACT:
General and technical information. Mary Tom Kissell, Waste and
Chemical Processes Group, Emissions Standards Division (C439-03), U.S.
EPA, Research Triangle Park, North Carolina 27711, telephone number
(919) 541-4516, electronic mail (e-mail) address kissell.mary@epa.gov.
Methods, sampling, and monitoring information. Gary McAlister,
Source Measurement Analysis Group, Emission Monitoring and Analysis
Division (D243-02), U.S. EPA, Research Triangle Park, North Carolina
27711, telephone number (919) 541-1062, e-mail address
mcalister.gary@epa.gov.
Economic impacts and benefit analysis. Larry Sorrels, Innovative
Strategies and Economics Group, Air Quality Strategies and Standards
Division (C339-01), U.S. EPA, Research Triangle Park, North Carolina
27711, telephone number (919) 541-5041, e-mail address
sorrels.larry@epa.gov.
SUPPLEMENTARY INFORMATION: Comments. Comments and data may be submitted
by electronic mail (e-mail) to: a-and-r-docket@epa.gov. Electronic
comments must be submitted as an ASCII file to avoid the use of special
characters and encryption problems and will also be accepted on disks
in WordPerfect[reg]
version 5.1, 6.1 or Corel 8 file format. All
comments and data submitted in electronic form must note the docket
number: A-98-44. No confidential business information (CBI) should be
submitted by e-mail. Electronic comments may be filed online at many
Federal Depository Libraries.
Commenters wishing to submit proprietary information for
consideration must clearly distinguish such information from other
comments and clearly label it as CBI. Send submissions containing such
proprietary information directly to the following address, and not to
the public docket, to ensure that proprietary information is not
inadvertently placed in the docket: Attention: Mary Tom Kissell, c/o
OAQPS Document Control Officer (C404-02), U.S. EPA, Research Triangle
Park NC 27711. The EPA will disclose information identified as CBI only
the extent allowed by the procedures set forth in 40 CFR part 2. If no
claim of confidentiality accompanies a submission when it is received
by the EPA, the information may be made available to the public without
further notice to the commenter.
Public Hearing. Persons interested in presenting oral testimony or
inquiring as to whether a hearing is to be held should contact JoLynn
Collins, Waste and Chemical Processes Group, Emissions Standards
Division (C439-03), U.S. EPA, Research Triangle Park, NC 27711,
telephone (919) 541-5671 at least 2 days in advance of the public
hearing. Persons interested in attending the public hearing must also
call JoLynn Collins to verify the time, date, and location of the
hearing. The public hearing will provide interested parties the
opportunity to present data, views, or arguments concerning these
proposed emission standards.
Docket. The docket is an organized and complete file of all the
information considered by the EPA in the development of this
rulemaking. The docket is a dynamic file because material is added
throughout the rulemaking process. The docketing system is intended to
allow members of the public and industries involved to readily identify
and locate documents so that they can effectively participate in the
rulemaking process. Along with the proposed and promulgated standards
and their preambles, the contents of the docket, with certain
exceptions, will serve as the record in the case of judicial review.
(See section 307(d)(7)(A) of the CAA.) The regulatory text and other
materials related to this rulemaking are available for review in the
docket or copies may be mailed on request from the Air Docket by
calling (202) 566-1742. A reasonable fee may be charged for copying
docket materials.
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World Wide Web (WWW). In addition to being available in the docket,
an electronic copy of today's proposed rule is also available on the
WWW through the Technology Transfer Network (TTN). Following signature,
a copy of the rule will be posted on the TTN's policy and guidance page
for newly proposed or promulgated rules http://www.epa.gov/ttn/oarpg.
The TTN provides information and technology exchange in various areas
of air pollution control. If more information regarding the TTN is
needed, call the TTN HELP line at (919) 541-5384.
Regulated Entities. Categories and entities potentially regulated
by this action include:
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Category SIC NAICS Examples of regulated entities
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Industry...................................... 2421 321999 Sawmills with lumber kilns.
2435 321211 Hardwood plywood and veneer plants.
2436 321212 Softwood plywood and veneer plants.
2493 321219 Reconstituted wood products
(Particleboard, medium density
fiberboard, hardboard, fiberboard,
and oriented strandboard plants).
2439 321213 Structural Wood Members, Not Elsewhere
Classified (Engineered wood products
plants).
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This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be regulated by this
action. To determine whether your facility is regulated by this action,
you should examine the applicability criteria in Sec. 63.2231 of the
proposed rule. If you have any questions regarding the applicability of
this action to a particular entity, consult the person listed in the
preceding FOR FURTHER INFORMATION CONTACT section.
Outline. The information presented in this preamble is organized as
follows:
I. Introduction
A. What Is the Purpose of This Proposed Rule?
B. What Is the Source of Authority for Development of NESHAP?
C. What Criteria Are Used in the Development of NESHAP?
D. How Was This Proposed Rule Developed?
E. What are the Health effects of the Pollutants Emitted From
the PCWP Industry?
F. Incorporation by Reference of NCASI Test Methods
G. Alternative Procedure for Determining Press Enclosure Capture
Efficiency
H. Changes to the Scope of a Source Category
II. Summary of Proposed Rule
A. What Process Units Are Subject to This Proposed Rule?
B. What Pollutants Are Regulated by This Proposed Rule?
C. What are the Compliance Options?
D. What Operating Requirements Are in the Proposed Rule?
E. What Are the Work Practice Requirements?
F. When Must I Comply With This Proposed Rule?
G. How Do I demonstrate Initial Compliance With This Proposed
Rule?
H. How Do I Demonstrate Continuous Compliance With This Proposed
Rule?
III. Rationale for Proposed Rule
A. How Did We Select the Source Category and Any Subcategories?
B. How Did We Define the Affected Source?
C. How Did We Determine the MACT Floor For Existing Sources?
D. How Did We Determine the MACT Floor For New Sources?
E. What Control Options Beyond the MACT Floor Did We Consider?
F. How Did We Select the Format of the Proposed Rule?
G. How Did We Select the Test Methods for Determining Compliance
With This Proposed Rule?
H. How Did We Select the Monitoring and Recordkeeping
Requirements?
I. How Did We Select the Notification and Reporting
Requirements?
IV. Summary of Environmental, Energy and Economic Impacts
A. How Many Facilities Are Impacted by This Proposed Rule?
B. What Are the Air Quality Impacts?
C. What Are the Water Quality Impacts?
D. What Are the Solid Waste Impacts?
E. What Are the Energy Impacts?
F. What Are the Cost Impacts?
G. Can We Achieve the Goals of the Proposed Rule in a Less
Costly manner?
H. What Are the Economic Impacts?
I. What Are the Social Costs and Benefits?
V. Relationship to Other Standards and Programs Under the CAA and
Other Statutes
A. Wood Building Products Surface Coating NESHAP Proposal
B. Wood Furniture Manufacturing Operations NESHAP (40 CFR Part
63, Subpart JJ)
C. Combustion Related NESHAP
D. New Source Review/Prevention of Significant Deterioration
Applicability
E. Interrelationship between MACT Provisions and PSD
F. Effluent Guidelines
VI. Administrative Requirements
A. Executive Order 12866, Regulatory Planning and Review
B. Executive Order 13132, Federalism
C. Executive Order 13175, Consultation and Coordination with
Indian Tribal Governments
D. Executive Order 13045, Protection of Children from
Environmental Health Risks and Safety Risks
E. Unfunded Mandates Reform Act of 1995
F. Regulatory Flexibility Act (RFA), as amended by the Small
Business Regulatory Enforcement Fairness Act (SBREFA) of 1996, 5
U.S.C. 601 et seq.
G. Paperwork Reduction Act
H. National Technology Transfer and Advancement Act of 1995
I. Executive Order 13211, Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use
I. Introduction
A. What Is the Purpose of This Proposed Rule?
The purpose of the proposed rule is to protect the public health by
reducing emissions of HAP from PCWP facilities.
B. What Is the Source of Authority for Development of NESHAP?
Section 112 of the CAA requires us to list categories and
subcategories of major sources and area sources of HAP and to establish
NESHAP for the listed source categories and subcategories. The PCWP
source category was originally 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 category. Major sources
of HAP are those that have the potential to emit greater than 10 tons/
yr of any one HAP or 25 tons per year of any combination of HAP.
Section 112(d) of the CAA directs us to adopt emission standards
for categories and subcategories of HAP sources. In cases where
emission standards are not feasible, section 112(h) of the CAA allows
us to develop design, equipment, work practice and/or operational
standards. The collection of compliance options, operating
requirements, and work practice requirements in today's proposed rule
make up the emission standards and
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work practice standards for the PCWP NESHAP.
C. What Criteria Are Used in the Development of NESHAP?
Section 112 of the CAA requires that we establish NESHAP for the
control of HAP from both new and existing major sources. 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 MACT.
The MACT floor is the minimum control level 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 that all
major sources achieve the level of control at least as stringent as
that already achieved by 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
standards for existing sources can be less stringent than standards for
new sources, but they cannot be less stringent than the average
emission limitation achieved by the best-performing 12 percent of
existing sources in the category or subcategory (or the best-performing
5 sources for categories or subcategories with fewer than 30 sources).
In developing MACT, we must also consider any control options that
are more stringent than the floor. We may establish standards more
stringent than the floor based on the consideration of cost of
achieving the emissions reductions, any health and environmental
impacts, and energy requirements.
D. How Was This Proposed Rule Developed?
We used several resources to develop this proposed rule, including
questionnaire responses from industry, emissions test data, site visits
to PCWP facilities, telephone contacts, and operating permits. We
consulted representatives of the PCWP industry, State and Federal
representatives, and emission control device vendors in developing this
proposed rule. Industry representatives provided emissions test data,
arranged site visits, reviewed draft questionnaires, and identified
issues and provided information to help resolve issues in the
rulemaking process. State representatives provided emissions test data
and copies of permits.
We identified the MACT floor level of control with information
obtained from the questionnaire responses, emission test reports, site
visits, telephone contacts, and operating permits.
E. What Are the Health Effects of the Pollutants Emitted From the PCWP
Industry?
This proposed rule protects air quality and promotes the public
health by reducing emissions of some of the HAP listed in section
112(b)(1) of the CAA. The HAP emitted by PCWP facilities include, but
are not limited to, acetaldehyde, acrolein, formaldehyde, methanol,
phenol, and propionaldehyde. Exposure to these compounds has been
demonstrated to cause adverse health effects when present in
concentrations higher than those typically found in ambient air.
We do not have the necessary data on each PCWP facility and the
people living around each facility to determine the actual population
exposures to the HAP emitted from these facilities and the potential
health effects. Therefore, we do not know the extent to which the
adverse health effects described in the following subsections occur in
the populations surrounding these facilities. However, to the extent
the adverse effects do occur, today's proposed rule would reduce
emissions and subsequent exposures.
1. Acetaldehyde
Acetaldehyde is ubiquitous in the environment and may be formed in
the body from the breakdown of ethanol (ethyl alcohol). Acute (short-
term) exposure to acetaldehyde results in effects including irritation
of the eyes, skin, and respiratory tract. In humans, symptoms of
chronic (long-term) exposure to acetaldehyde resemble those of
alcoholism. Long-term inhalation exposure studies in animals reported
damage to the nasal epithelium and mucous membranes, growth
retardation, and increased kidney weight. We have classified
acetaldehyde as a probable human carcinogen (Group B2) based on animal
studies that have shown nasal tumors in rats and laryngeal tumors in
hamsters.
2. Acrolein
Acute (short-term) inhalation exposure to acrolein may result in
upper respiratory tract irritation and congestion. The major effects
from chronic (long-term) inhalation exposure to acrolein in humans
consist of general respiratory congestion and eye, nose, and throat
irritation. Acrolein is a strong dermal irritant, causing skin burns in
humans. We consider acrolein a possible human carcinogen (Group C)
based on limited animal cancer data suggesting an increased incidence
of tumors in rats exposed to acrolein in the drinking water.
3. Formaldehyde
Both acute (short-term) and chronic (long-term) exposure to
formaldehyde irritates the eyes, nose, and throat, and may cause
coughing, chest pains, and bronchitis. Reproductive effects, such as
menstrual disorders and pregnancy problems, have been reported in
female workers exposed to formaldehyde. Limited human studies have
reported an association between formaldehyde exposure and lung and
nasopharyngeal cancer. Animal inhalation studies have reported an
increased incidence of nasal squamous cell cancer. We consider
formaldehyde a probable human carcinogen (Group B2).
4. Methanol
Acute (short-term) or chronic (long-term) exposure of humans to
methanol by inhalation or ingestion may result in blurred vision,
headache, dizziness, and nausea. No information is available on the
reproductive, developmental, or carcinogenic effects of methanol in
humans. Birth defects have been observed in the offspring of rats and
mice exposed to methanol by inhalation. A methanol inhalation study
using rhesus monkeys reported a decrease in the length of pregnancy and
limited evidence of impaired learning ability in offspring. We have not
classified methanol with respect to carcinogenicity.
5. Phenol
Acute (short-term) inhalation and dermal exposure to phenol is
highly irritating to the skin, eyes, and mucous membranes in humans.
Oral exposure to small amounts of phenol may cause irregular breathing,
muscular weakness and tremors, coma, and respiratory arrest at lethal
concentrations. Anorexia, progressive weight loss, diarrhea, vertigo,
salivation, and a dark coloration of the urine have been reported in
chronically (long-term) exposed humans. Gastrointestinal irritation and
blood and liver effects have also been reported. No studies of
developmental or reproductive effects of phenol in humans are
available, but animal studies have reported reduced fetal body weights,
growth retardation, and abnormal development in the offspring of
animals exposed to phenol by the oral route. We have classified phenol
in Group D, not classifiable as to human carcinogenicity.
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6. Propionaldehyde
No information is available on the acute (short-term) effects of
propionaldehyde in humans. Animal studies have reported that inhalation
exposure to high levels of propionaldehyde results in anesthesia and
liver damage. No information is available on the chronic (long-term),
reproductive, developmental or carcinogenic effects of propionaldehyde
in animals or humans. We have not classified propionaldehyde for
carcinogenicity.
F. Incorporation by Reference of NCASI Test Methods
With today's action, we are proposing to amend 40 CFR 63.14 by
revising paragraph (f) to incorporate by reference two test methods
developed by the National Council of the Paper Industry for Air and
Stream Improvement (NCASI): (1) Method CI/WP-98.01, Chilled Impinger
Method for Use at Wood Products Mills to Measure Formaldehyde,
Methanol, and Phenol; and (2) pending review by EPA, Method IM/CAN/WP-
99.01, Impinger/Canister Source Sampling Method for Selected HAPs at
Wood Products Facilities. These methods are available from the NCASI,
Methods Manual, P.O. Box 133318, Research Triangle Park, NC 27709-3318
or at http://www.ncasi.org . They are also available from the docket for
this proposed rule (Docket Number A-98-44).
In today's proposed rule, NCASI Method CI/WP-98.01 would be allowed
as an alternative to:
[sbull]
EPA Method 320, Measurement of Vapor Phase Organic and
Inorganic Emission by Extractive FTIR, for measuring methanol or
formaldehyde;
[sbull]
EPA Method 0011, Sampling for Selected Aldehyde and Ketone
Emissions from Stationary Sources, for measuring formaldehyde;
[sbull]
EPA Method 316, Sampling and Analysis for Formaldehyde
Emissions from Stationary Sources in the Mineral Wool and Wool
Fiberglass Industries, for measuring formaldehyde;
[sbull]
EPA Method 308, Procedure for Determination of Methanol
Emission from Stationary Sources, for measuring methanol; and
[sbull]
NCASI Method IM/CAN/WP-99.01 for measuring formaldehyde or
methanol.
The NCASI Method CI/WP-98.01 has been validated using EPA Method
301, Field Validation of Pollutant Measurement Methods from Various
Waste Media, for measuring methanol, formaldehyde, and phenol emissions
from PCWP facilities. (EPA Method 0011 is available in ``Test Methods
for Evaluating Solid Waste, Physical/Chemical Methods,'' EPA
Publication No. SW-846. EPA Methods 301, 308, 316, and 320 are in 40
CFR part 63, appendix A.)
In today's proposed rule, NCASI Method IM/CAN/WP-99.01, which is a
self-validating method, would be allowed, pending our review, as an
alternative to:
[sbull]
EPA Method 320, for measuring methanol, formaldehyde, or
total HAP;
[sbull]
EPA Methods 0011 and 316, for measuring formaldehyde;
[sbull]
EPA Method 308, for measuring methanol; and
[sbull]
NCASI Method CI/WP-98.01, for measuring formaldehyde or
methanol.
G. Alternative Procedure for Determining Press Enclosure Capture
Efficiency
We are working with industry representatives to develop a procedure
that uses measurement of tracer gas to determine capture efficiency. We
are proposing this ``tracer gas procedure'' today in appendix A to the
proposed subpart DDDD.
H. Changes to the Scope of a Source Category
Today's action serves to broaden the PCWP source category to
include lumber kilns located at stand-alone kiln-dried lumber
manufacturing facilities or at any other type of facility. Wood
products industry representatives requested that all lumber kilns
(regardless of location) be considered in today's proposed rule so
there would be one MACT determination for all lumber kilns nationwide.
If lumber kilns at stand-alone kiln-dried lumber manufacturing
facilities and other types of facilities are not included in the PCWP
NESHAP, kiln-dried lumber manufacturing could be listed as a major
source category under section 112(c) of the CAA in the future,
requiring a separate section 112(d) rulemaking, and may become
separately subject to the provisions of section 112(g) of the CAA as
well. Because the design and operation of lumber kilns are essentially
the same regardless of whether the kilns are located at a sawmill or
are co-located with PCWP or other types of manufacturing operations, we
have included lumber kilns in the PCWP source category. Broadening the
scope of the PCWP source category to include lumber kilns located at
any type of facility is reasonable because based on our information,
there are no currently applicable controls at any lumber kilns and it
is both more efficient and expeditious to include them in the MACT
process now than to separately address them in a rulemaking that would
not likely result in meaningful emissions reductions from lumber kilns.
Moreover, including all lumber kilns in the PCWP MACT results in
placing them on a faster schedule for purposes of future residual risk
analysis under CAA section 112(f).
II. Summary of Proposed Rule
A. What Process Units Are Subject to This Proposed Rule?
The proposed rule would regulate HAP emissions from PCWP facilities
that are major sources. Plywood and composite wood products are
manufactured by bonding wood material (fibers, particles, strands,
etc.) or agricultural fiber, generally with resin under heat and
pressure, to form a structural panel or engineered wood product.
Plywood and composite wood products manufacturing facilities also
include facilities that manufacture dry veneer and lumber kilns located
at any facility. Plywood and composite wood products include (but are
not limited to) plywood, veneer, particleboard, oriented strandboard,
hardboard, fiberboard, medium density fiberboard, laminated strand
lumber, laminated veneer lumber, wood I-joists, kiln-dried lumber, and
glue-laminated beams. Table 1 of this preamble lists the process units
at PCWP facilities and indicates which process units are subject to the
control requirements in today's proposed rule. ``Process unit'' means
equipment classified according to its function such as a blender,
dryer, press, former, or board cooler.
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Table 1.--Process Units That Are Subject to the Proposed Control
Requirements
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Does today's proposed rule include
control requirements for . . .
For the following process -----------------------------------------
units . . . Existing affected New affected
sources? sources?
------------------------------------------------------------------------
Softwood veneer dryers; tube Yes................ Yes.
dryers; strand dryers; green
rotary dryers; hardboard
ovens; reconstituted wood
product presses; and
pressurized refiners.
Press predryers; fiberboard No................. Yes.
mat dryers; and board coolers.
Dry rotary dryers; veneer No................. No.
redryers; plywood presses;
engineered wood products
presses; hardwood veneer
dryers; humidifiers;
atmospheric refiners;
formers; blenders; rotary
agricultural fiber dryers;
agricultural fiber board
presses; sanders; saws; fiber
washers; chippers; log vats;
lumber kilns; storage tanks;
wastewater operations;
miscellaneous coating
operations; and stand-alone
digesters.
------------------------------------------------------------------------
The affected source for this proposed rule is the combination of
all PCWP manufacturing operations, including PCWP process units, onsite
storage of raw materials, onsite wastewater treatment operations
associated with PCWP manufacturing, and miscellaneous coating
operations located in a single facility covering a contiguous area
under common control that is also a major source. One of the
implications of the proposed definition of affected source is that the
control requirements or ``floor,'' as defined in section 112(d)(3), are
determined for the entire PCWP facility. Therefore, except for lumber
kilns not otherwise located at PCWP facilities, this proposed rule
contains the control requirements that represent the MACT level of
control for the entire facility. For lumber kilns not otherwise located
at PCWP facilities, this proposed rule contains the control
requirements that represent the MACT level of control only for lumber
kilns.
B. What Pollutants Are Regulated by This Proposed Rule?
The proposed rule would regulate HAP emissions from PCWP
facilities. For the purpose of compliance with 40 CFR part 63, subpart
DDDD, we defined ``total HAP'' to be the sum of the emissions of six
primary HAP emitted from PCWP manufacturing. For the purpose of
determining whether your facility is a major source, you would have to
include all HAP as prescribed by rules and guidance pertaining to
determination of major source.
The six HAP that define ``total HAP'' are: Acetaldehyde, acrolein,
formaldehyde, methanol, phenol, and propionaldehyde. Other HAP are
sometimes emitted and controlled along with these six HAP, but in low
quantities that may be difficult to measure. Depending upon which of
the compliance alternatives you choose, you could be required to
measure emissions of total hydrocarbon (THC), methanol, or formaldehyde
as surrogates for measuring total HAP.
C. What Are the Compliance Options?
Today's proposed rule includes a range of compliance options which
are summarized in the following subsections. You would have to use one
of the compliance options to show compliance with the proposed rule. In
most cases, the proposed compliance options would be the same for new
and existing sources. Dilution to achieve compliance is prohibited as
specified in 40 CFR 63.4.
1. Production-Based Compliance Options
Today's proposed rule includes production-based compliance options
which are based on total HAP and vary according to type of process
unit. Total HAP emissions are defined in today's proposed rule as the
total mass emissions of the following six HAP: Acetaldehyde, acrolein,
formaldehyde, methanol, phenol, and propionaldehyde. The production-
based compliance options are in units of mass of pollutant per unit of
production. Add-on control systems may not be used to meet the
production-based compliance options. For pressurized refiners and most
dryers, the production-based compliance options are expressed as pounds
per oven-dried-ton of wood (lb/ODT). For presses, hardboard ovens, and
some dryers, the production-based compliance options are expressed as
pounds per thousand square feet of board (lb/MSF), with a reference
board thickness.
2. Add-On Control System Compliance Options
If you operate a process unit equipped with an add-on control
system, you may use any one of the following six compliance options.
``Add-on control system'' or ``control system'' means the combination
of capture and control devices used to reduce HAP emissions to the
atmosphere.
a. Reduce THC emissions (as carbon, and minus methane if you wish
to subtract methane) by 90 percent.
b. Reduce methanol emissions by 90 percent.
c. Reduce formaldehyde emissions by 90 percent.
d. Limit the concentration of THC (as carbon, and minus methane if
you wish to subtract methane) in the outlet of the add-on control
system to 20 parts per million by volume, dry basis (ppmvd).
e. Limit the concentration of methanol in the exhaust from the add-
on control system to 1 ppmvd (can be used only if the concentration of
methanol entering the control device is greater than or equal to 10
ppmvd).
f. Limit the concentration of formaldehyde in the exhaust from the
add-on control system to 1 ppmvd (can be used only if the concentration
of formaldehyde entering the control device is greater than or equal to
10 ppmvd).
In the first three options (a through c), the 90 percent control
efficiency represents a total control efficiency. Total control
efficiency is defined as the product of the capture efficiency and the
control device efficiency. For process units such as rotary strand
dryers, capture efficiency is not an issue because the rotary strand
dryer has a single exhaust point which is easily captured by the
control device. However, for presses and board coolers, the HAP
emissions cannot be completely captured without installing an
enclosure. If the enclosure meets the criteria for a permanent total
enclosure (PTE) as described in EPA Test Method 204 (40 CFR part 51,
appendix M), then you could assign the enclosure a capture efficiency
of 100 percent. You would have to test other enclosures to determine
capture efficiency using EPA Test Methods 204 and 204A through 204F (as
appropriate) or the alternative
[[Page 1281]]
tracer gas procedure in today's proposed rule. For the three
concentration options (d through f), you would need to have an
enclosure that either meets the criteria for a PTE or achieves a
capture efficiency greater than or equal to 95 percent.
The six compliance options are equivalent ways to express the HAP
control levels that represent the MACT floor. Because the compliance
options are equivalent for controlling HAP emissions, you would be
required to meet only one compliance option for add-on control systems.
For example, if you elect to test your control system for THC and
formaldehyde and the test results demonstrate compliance with only the
THC or only the formaldehyde compliance option, you would still be in
compliance with today's proposed rule.
3. Emissions Averaging Compliance Option
The CAA does not limit how we set control requirements beyond
requiring that they be applicable to all sources in a category and be
at least as stringent as the MACT floor. Therefore, the relevant
statutory language does not prohibit us from allowing a source to meet
MACT through use of emissions averaging as long as averaging does not
cross source category boundaries, and the standard is set at a level at
least as stringent as the MACT floor. As explained in this preamble, we
believe we have met these criteria. In addition, it should be noted
that Congress explicitly provided that cost should be considered in
setting the standards. Emissions averaging is a means of achieving the
required emissions reductions in a cost effective way. Therefore, if
you operate an existing affected source, you could choose to comply
with the emissions averaging provisions instead of the production-based
compliance options or add-on control system compliance options.
Emissions averaging is a system of debits and credits in which the
credits must equal or exceed the debits. ``Debit-generating process
units'' are the PCWP process units required to meet the proposed
control requirements that you choose to either not control or under-
control. ``Credit-generating process units'' are the PCWP process units
that you choose to control. You may take credit for emissions from
debit-generating process units that are under-controlled. Control
devices used for credit-generating process units may not be assigned
more than 90 percent control efficiency.
Under the emissions averaging provisions, you would determine the
required mass removal (RMR) of total HAP from debit-generating process
units for a 6-month compliance period. Total HAP is defined in today's
proposed rule to include acetaldehyde, acrolein, formaldehyde,
methanol, phenol, and propionaldehyde. The RMR would be based on
initial total HAP measurements for each debit-generating process unit,
your process unit operating hours for a 6-month period, and the
required 90 percent control system efficiency. One hundred percent of
the RMR for debit-generating process units would have to be achieved or
exceeded by the actual mass removal (AMR) of total HAP achieved by
credit-generating process units. The AMR is determined based on initial
performance tests, the total HAP removal efficiency of the control
systems used to control the credit-generating process units, and your
process unit operating hours over the 6-month period.
There are some restrictions on use of the emissions averaging
provisions in today's proposed rule. You would have to limit emissions
averaging to the process units located within your affected source.
Emissions averaging could not be used at new affected sources. You
could not include in an emissions average those process units that are
not operating or that are shut down. You could not include in your
emissions average those process units controlled to comply with a State
or Federal rule other than today's proposed rule (unless the process
unit was included in an emissions average and the control system was
installed before the process unit was subject to the other State or
Federal rule). Only PCWP process units using add-on control systems may
be used to generate credits.
D. What Operating Requirements Are in the Proposed Rule?
The operating requirements in today's proposed rule would apply to
add-on control systems used to comply with the proposed rule and to
process units that can meet the proposed production-based compliance
options. For incineration-based control devices and biofilters, the
proposed rule specifies that you would either monitor operating
parameters or use a THC continuous emission monitoring system (CEMS) to
demonstrate continuous compliance. The proposed operating requirements
are summarized below:
[sbull]
If you operate a thermal oxidizer, such as a regenerative
thermal oxidizer (RTO) or a combustion unit that accepts process
exhaust into the flame zone, you would be required to maintain the
firebox temperature at a level that is greater than or equal to the
minimum temperature established during the performance test. You would
also be required to maintain the average static pressure at the inlet
of the thermal oxidizer within the operating range established during
the performance test. You may choose to monitor gas flow rate at the
thermal oxidizer stack as an alternative to monitoring static pressure.
If you monitor gas flow, you must maintain the gas flow rate below the
maximum flow rate established during the performance test. If you
operate a combustion unit that accepts process exhaust into the flame
zone and that combustion unit has a heat input capacity of greater than
or equal to 44 megawatts (MW), you would be exempt from the testing and
monitoring requirements described above for thermal oxidizers.
[sbull]
If you operate a catalytic oxidizer, such as a regenerative
catalytic oxidizer (RCO) or thermal catalytic oxidizer (TCO), you would
be required to maintain the temperature upstream of the catalyst bed at
or above the minimum temperature established during the performance
test. You would also be required to maintain the average static
pressure at the inlet of the catalytic oxidizer within the operating
range established during the performance test. You may choose to
monitor gas flow rate at the catalytic oxidizer stack as an alternative
to monitoring static pressure. If you monitor gas flow, you must
maintain the gas flow rate below the maximum flow rate established
during the performance test.
[sbull]
If you operate a biofilter, you would be required to
maintain the temperature of the air stream entering the biofilter, pH
of the biofilter effluent, and pressure drop across the biofilter bed
within the ranges you specify during the initial performance test or
during qualifying previous performance tests using the required test
methods. If you use values from previous performance tests to establish
the operating parameter ranges, you would have to certify that the
biofilter and associated process unit(s) have not been modified
subsequent to the date the previous data were collected.
[sbull]
If you operate an add-on control system not listed in
today's proposed rule, you would establish operating parameters to be
monitored and parameter values that represent your operating
requirements during the performance test, subject to prior written
approval by the Administrator.
[sbull]
If you operate a process unit that can meet the production-
based compliance options without an add-on
[[Page 1282]]
control device, you would be required to maintain the average process
unit inlet or operating temperature (depending on the specific process
unit) below the maximum temperature established during the performance
test.
[sbull]
As an alternative to monitoring the operating parameters
specified above for thermal oxidizers, catalytic oxidizers, biofilters,
other control devices, and process units that meet the compliance
options for process units without add-on control systems, you would be
allowed to monitor THC concentration in the outlet stack with a THC
CEMS. You would be required to maintain the outlet THC concentration
below the maximum concentration established during the performance
test. You may choose to subtract methane from the THC concentration
measured by the CEMS if you wish to do so.
E. What Are the Work Practice Requirements?
The work practice requirements in today's proposed rule apply to
veneer dryers, dry rotary dryers, veneer redryers, and hardwood veneer
dryers. For veneer dryers, the proposed work practice requirements
require you to minimize fugitive emissions from the veneer dryer doors
(by applying appropriate operation and maintenance procedures) and from
the green end of the dryers (through proper balancing of hot zone
exhausts). The proposed work practice requirements also specify
parameters that you would monitor to demonstrate that each dry rotary
dryer, redryer, and hardwood veneer dryer continuously operates in a
manner consistent with the definitions of these process units provided
in today's proposed rule, as follows:
[sbull]
If you operate a dry rotary dryer, you would be required to
maintain the inlet dryer temperature at or below 600 [deg]F and
maintain the moisture content of the wood particles entering the dryer
at or below 30 weight percent, on a dry basis.
[sbull]
If you operate a veneer redryer, you would be required to
maintain the moisture content of the wood veneer entering the dryer at
or below 25 percent, by weight.
[sbull]
If you operate a hardwood veneer dryer, you would be
required to process less than 30 percent, by volume, softwood species
each year.
F. When Must I Comply With This Proposed Rule?
Existing PCWP facilities must comply within 3 years of the date the
promulgated rule is published in the Federal Register. New sources that
commence construction after today's date must comply immediately upon
initial startup or on the effective date of the rule, whichever is
later.
G. How Do I Demonstrate Initial Compliance With This Proposed Rule?
The initial compliance requirements in today's proposed rule vary
with the different compliance options.
1. Production-Based Compliance Options
If you are complying with the production-based compliance options
in today's proposed rule, you would be required to conduct an initial
performance test using specified test methods to demonstrate initial
compliance. You would be required to test the efficiency of your
emissions capture device during the initial compliance test if the
process unit is a press or board cooler. The actual emission rate of
the press or board cooler would be equivalent to the measured emissions
divided by the capture efficiency. You would be required to install
process (temperature) monitoring equipment to be used to demonstrate
compliance with the operating requirements for process units without
add-on control systems or install a THC CEMS and monitor the outlet THC
concentration. During the initial compliance test, you would use the
process monitoring equipment to establish the parameter value that
represents your operating requirement for the process unit.
2. Add-On Control System Compliance Options
If you use the compliance options for add-on control systems, you
would be required to conduct an initial performance test using
specified test methods to demonstrate initial compliance. With the
exception of the 20 ppmvd THC concentration option, you would be
required to test at both the inlet and the outlet of the control
device. If you use any of the six compliance options for add-on control
systems, and the process unit is a press or a board cooler without a
PTE, you would also be required to test the capture efficiency of your
partial enclosure. Prior to the initial performance test, you would be
required to install control device parameter monitoring equipment or
THC CEMS to be used to demonstrate compliance with the operating
requirements for add-on control systems in today's proposed rule.
During the initial compliance test, you would use the control device
parameter monitoring equipment or THC CEMS to establish the parameter
values that represent your operating requirements for the control
systems. If your add-on control system is preceded by a particulate
control device, you would only be required to establish operating
parameter values for the HAP control system and not for the particulate
control device. If your control device is a biofilter, then you may use
historical operating records for the biofilter to establish your
operating requirements as long as you were in compliance with the
emission limits in today's proposed rule when the data were collected,
the test data were obtained using the test methods in today's proposed
rule, and no modifications were made to the process unit or biofilter
subsequent to the date the historical data were collected.
3. Emissions Averaging Compliance Option
If you elect to comply with the emissions averaging compliance
option in today's proposed rule, you would be required to submit an
Emissions Averaging Plan (EAP) to the Administrator for approval. The
EAP would describe the process units you are including in the emissions
average. The plan also would specify which process units will be
credit-generating units and which process units will be debit-
generating units. The EAP would also have to include descriptions of
the control systems used to generate emission credits, documentation of
the total HAP measurements made to determine the RMR, calculations and
supporting documentation to demonstrate that the AMR will be greater
than or equal to the RMR, and a summary of the operating parameters
that will be monitored for the credit-generating units.
Following approval of your EAP, you would be required to conduct
performance tests to determine the total HAP emissions from all process
units included in the EAP. The credit-generating process units would be
equipped with add-on control systems; therefore, for those process
units, you would follow the procedures for demonstrating initial
compliance as outlined above for add-on control systems. The emissions
averaging provisions would require you to conduct all total HAP
measurements and performance test(s) when the process units are
operating under representative operating conditions. Today's proposed
rule defines ``representative operating conditions'' as those
conditions under which the process unit will be typically operating
following the compliance date. Representative conditions would include
such things as using a
[[Page 1283]]
representative range of materials (e.g., wood material of a typical
species mix and moisture content, typical resin formulations) and
operating the process unit at typical operating temperature ranges.
4. Work Practice Requirements
The work practice requirements in today's proposed rule do not
require you to conduct any initial performance tests. To demonstrate
initial compliance with the work practice requirements for dry rotary
dryers, you would have to install parameter monitoring devices to
continuously monitor the dryer inlet operating temperature and the
moisture content (dry basis) of the wood furnish (i.e., wood fibers,
particles, or strands used for making board) entering the dryer. You
would then use the parameter monitoring devices to continuously monitor
and record the dryer temperature and wood furnish moisture content for
a minimum of 30 days. If the monitoring data indicate that during the
minimum 30-day demonstration period, your dry rotary dryer continuously
processed wood furnish with an inlet moisture content less than or
equal to 30 percent, and the dryer was continuously operated at an
inlet dryer temperature less than or equal to 600 [deg]F, then your
dryer would meet the definition of a dry rotary dryer in today's
proposed rule. You would submit the monitoring data as part of your
notification of compliance status report.
To demonstrate initial compliance with the work practice
requirements for hardwood veneer dryers, you would have to calculate
the annualized percentage of softwood veneer processed in the dryer by
volume, using veneer dryer production records for the 12-month period
prior to the compliance date. If the total annual percentage by volume
of softwood veneer is less than 30 percent, your veneer dryer would
meet the definition of hardwood veneer dryer. You would then submit a
summary of the production data for the 12-month period and a statement
verifying that the veneer dryer will continue to process less than 30
percent softwoods as part of your notification of compliance status
report.
To demonstrate initial compliance with the work practice
requirements for softwood veneer dryers, you would have to develop a
plan for minimizing fugitive emissions from the veneer dryer green end
and heated zones. You would submit the plan with your notification of
compliance status report.
To demonstrate initial compliance with the work practice
requirements for veneer redryers, you would have to install a device
that can be used to continuously monitor the moisture content (dry
basis) of veneer entering the dryer. You would then use the moisture
monitoring device to continuously monitor and record the inlet moisture
content of the veneer for a minimum of 30 days. If the monitoring data
indicate that your veneer dryer continuously processed veneer with a
moisture content less than or equal to 25 percent during the minimum
30-day demonstration period, then your veneer dryer would meet the
definition of a veneer redryer in today's proposed rule. You would
submit the monitoring data as part of your notification of compliance
status report.
H. How Do I Demonstrate Continuous Compliance With This Proposed Rule?
The continuous compliance requirements in today's proposed rule
vary with the different types of compliance options.
1. Production-Based Compliance Options
If you comply with the production-based compliance options, then
you would have to install a continuous parameter monitoring system
(CPMS) to monitor the process operating parameter(s) used to
demonstrate compliance with the operating requirements in today's
proposed rule. Your CPMS would have to collect data at least every 15
minutes, and you would need to have at least three data points per hour
to have a valid hour of data. You would have to operate the CPMS at all
times the process unit is operating. You also would have to conduct
proper maintenance of the CPMS and maintain an inventory of necessary
parts for routine repairs of the CPMS. Using the data collected with
the CPMS, you would calculate and record the 3-hour block average
values of each process operating parameter.
The process operating parameter you would monitor for green rotary
dryers, tube dryers, and strand dryers is dryer inlet temperature. The
process operating parameter you would monitor for hardboard ovens,
press predryers, reconstituted wood product presses, fiberboard mat
dryer hot zones, and softwood veneer dryer hot zones is operating
temperature. You would not be required to monitor process parameters
for reconstituted wood product board coolers or pressurized refiners.
For each temperature parameter, you would have to continuously maintain
the 3-hour block average temperature below the maximum temperature
established during the performance test.
Instead of operating a CPMS, you could choose to operate a CEMS for
monitoring THC concentration to demonstrate compliance with the
operating requirements in today's proposed rule. If you choose to
operate a THC CEMS in lieu of a CPMS, you would have to demonstrate
continuous compliance as described in the following subsection.
2. Add-On Control System Compliance Options
For add-on control systems, you would have to install a CPMS to
monitor the specified control device operating parameter(s) or install
a CEMS to monitor THC concentration to demonstrate compliance with the
operating requirements in today's proposed rule. If you operate a CPMS,
it would have to collect data at least every 15 minutes, and you would
need to have at least three data points per hour to have a valid hour
of data. You would have to operate the CPMS at all times the process
unit is operating. You also would have to conduct proper maintenance of
the CPMS and maintain an inventory of necessary parts for routine
repairs of the CPMS. Using the data collected with the CPMS, you would
calculate and record the average values of each operating parameter
according to the specified averaging times.
For thermal oxidizers, you would have to continuously maintain the
3-hour block average firebox temperature at or above the minimum
temperature established during the performance test. For catalytic
oxidizers, you would have to continuously maintain the 3-hour block
average temperature upstream of the catalyst bed at or above the
minimum value established during the performance test. For both thermal
and catalytic oxidizers, you would also have to continuously maintain
the 3-hour block average static pressure at the inlet of the thermal
oxidizer within the operating range established during the performance
test. As an alternative to monitoring static pressure, you may monitor
gas flow rate at the oxidizer stack. If you monitor gas flow, you must
maintain the 3-hour block average gas flow rate below the maximum flow
rate established during the performance test.
For biofilters, you would have to maintain the gas temperature
entering the biofilter, effluent pH, and pressure drop across the
biofilter bed within the operating ranges you establish. You would
establish your biofilter operating parameter limits, their monitoring
frequencies, and their averaging times
[[Page 1284]]
based on data collected during the initial performance test or during
qualifying previous performance tests using the required test methods.
If you use values from previous performance tests to establish the
operating parameter ranges, you would have to certify that the
biofilter and associated process unit(s) have not been modified
subsequent to the date the previous data were collected. If previous
performance test data are not available (as would be the case for a new
biofilter installation) you would be allowed up to 180 days after the
compliance date to gather the necessary information and establish your
biofilter operating parameter ranges.
If you choose to operate a CEMS for monitoring THC concentration
instead of operating a CPMS, you must install, operate, and maintain
the CEMS according to Performance Specification 8 in 40 CFR part 60,
appendix B. You would also be required to comply with the CEMS data
quality assurance requirements in Procedure 1 of appendix F of 40 CFR
part 60. You would be required to conduct a performance evaluation of
the CEMS according to 40 CFR 63.8 and Performance Specification 8. The
CEMS would have to complete a minimum of one cycle of operation
(sampling, analyzing, and data recording) for each successive 15-minute
period. Using the data collected with the CEMS, you would calculate and
record the 3-hour block average THC concentration. You would have to
continuously monitor and maintain the 3-hour block average THC
concentration at or below the maximum established during the
performance test. You may use a CEMS capable of subtracting methane
from the measured THC concentration if you wish to do so.
If you comply with today's proposed rule using an add-on control
system, you could request a routine control device maintenance
exemption from the Administrator. Your request for a routine control
device maintenance exemption would have to document the need for
routine maintenance on the control device and the time required to
accomplish the maintenance, describe the maintenance activities and the
frequency of these activities, explain why the maintenance could not be
accomplished during process shutdowns, describe how you plan to
minimize emissions to the greatest extent possible during these
maintenance activities, and provide any other documentation required by
the Administrator. If your request for the routine control device
maintenance exemption is approved by the Administrator, it would have
to be incorporated into your title V permit. The compliance options and
operating requirements would not apply during times when control device
maintenance covered under your approved routine control device
maintenance exemption is performed. The routine control device
maintenance exemption may not exceed 3 percent of annual operating
uptime for each green rotary dryer, tube dryer, strand dryer, or
pressurized refiner controlled. The routine control device maintenance
exemption is limited to 0.5 percent of the annual operating uptime for
each softwood veneer dryer, reconstituted wood product press,
reconstituted wood product board cooler, hardboard oven, press
predryer, or fiberboard mat dryer controlled. If your control device is
used to control a combination of equipment with different downtime
allowances (e.g., a tube dryer and a press), then the highest (i.e., 3
percent) downtime allowance applies.
3. Emissions Averaging Compliance Option
To demonstrate continuous compliance with the emissions averaging
provisions, you would have to continuously comply with the applicable
operating requirements for add-on control systems (described in the
previous subsection). You also would have to maintain records of your
operating hours for each process unit included in the EAP. For each
semiannual compliance period, you would have to demonstrate that the
AMR equals or exceeds the RMR using your initial (or most recent) total
HAP measurements for debit-generating units, initial (or most recent)
performance test results for credit-generating units, and the operating
hours recorded for the semiannual compliance period.
4. Work Practice Requirements
To demonstrate continuous compliance with the work practice
requirements for dry rotary dryers and veneer redryers, you would be
required to operate all dry rotary dryers and veneer redryers so that
they continuously meet the definitions of these process units in
today's proposed rule. For dry rotary dryers, you would have to
continuously monitor and maintain the inlet furnish moisture content at
or below 30 percent and the inlet dryer operating temperature at or
below 600 [deg]F. You would also have to manually measure the moisture
content of a representative sample of the inlet wood furnish once per
day to verify the readings from the moisture meter. For veneer
redryers, you would have to continuously monitor and maintain the inlet
veneer moisture content at or below 25 percent.
To demonstrate continuous compliance with the work practice
requirements for softwood veneer dryers, you would have to follow the
procedures in your operating plan for minimizing fugitive emissions
from the green end and heated zones of the veneer dryer and maintain
records documenting that you have followed your plan. For hardwood
veneer dryers, you would have to continue to process less than 30
percent softwood veneer by volume and maintain records on veneer dryer
production.
III. Rationale for Proposed Rule
A. How Did We Select the Source Category and Any Subcategories?
The PCWP source category includes the manufacture of many types of
wood products, including (but not limited to) plywood, veneer,
particleboard, oriented strandboard, hardboard, fiberboard, medium
density fiberboard, laminated strand lumber, laminated veneer lumber,
wood I-joists, kiln-dried lumber, and glue-laminated beams. During our
review of the available information on this source category, we found
that the processes used to produce the different types of wood products
were more similar than dissimilar with respect to the types of
equipment used and the HAP emitted. Published definitions of the
various wood products often group several types of products together or
overlap with definitions developed for other similar wood products. As
the wood products industry continues its relatively high rate of
growth, new and different wood products are coming into the
marketplace, some of which are hybrids of existing wood products or
modified versions of existing wood products. Because the differences
between many of the product lines are already somewhat blurred and the
equipment that is used to manufacture wood products cuts across
industry sectors, we determined that establishing subcategories based
on product type was unwarranted and could seriously hamper
applicability determinations. Therefore, today's proposed rule does not
establish any subcategories under the PCWP source category.
B. How Did We Define the Affected Source?
In today's proposed rule, the affected source is the collection of
process units associated with the manufacturing of PCWP at a plant
site. The affected
[[Page 1285]]
source includes, but is not limited to, those process units found in
green end operations, drying operations, blending and forming
operations, pressing and board cooling operations, and miscellaneous
finishing operations (such as sanding, sawing, patching, edge sealing,
and other finishing operations not subject to other NESHAP). The
affected source also includes onsite storage of raw materials used in
the manufacture of PCWP, such as resins, onsite wastewater treatment
operations specifically associated with PCWP manufacturing, and
miscellaneous coating operations. The affected source includes lumber
kilns at PCWP manufacturing facilities and at any other facility.
Miscellaneous coating operations are activities such as edge
coating of PCWP, labeling and printing on PCWP, application of anti-
skid coatings, putty/patching operations at plywood facilities, etc.
Only those onsite miscellaneous coating operations at PCWP
manufacturing facilities that are listed in Sec. 63.2292 of today's
proposed rule are covered by these proposed NESHAP. We specifically
excluded these miscellaneous coatings operations from the proposed Wood
Building Products Surface Coating NESHAP (40 CFR part 63, subpart
QQQQ). We included these sources in the definition of affected source
for PCWP because these miscellaneous coating operations are part of the
PCWP manufacturing process and are performed at the same location.
To provide compliance flexibility, we defined the affected source
as the combination of all of the process units at a PCWP manufacturing
facility. Many of the PCWP facilities that already control HAP
emissions to the levels that would be required in today's proposed rule
do so by first combining emissions from different process units and
then controlling the combined emissions in one or more emission control
devices. Much of the control device efficiency data used to set the
proposed compliance options for add-on control systems was based on
control equipment that was used to control emissions from multiple
types of process units. As a result, the required level of control
would be the same for most types of process units. For example, the
control level for new and existing reconstituted wood products presses
would be the same as the control level for new and existing tube
dryers. We believe that the proposed broad definition of affected
source is consistent with the way the industry applies add-on control
devices, and that it creates more meaningful opportunities for
emissions averaging. The affected source definition we selected is the
same for both new and existing sources.
The affected source includes lumber kilns co-located at PCWP
manufacturing facilities and lumber kilns at other facilities that do
not manufacture PCWP (i.e., stand-alone kiln-dried lumber manufacturing
facilities such as sawmills). Wood products industry representatives
requested that all lumber kilns (regardless of location) be considered
in today's proposed rule so there would be one MACT determination for
all lumber kilns nationwide.
If lumber kilns at stand-alone kiln-dried lumber manufacturing
facilities are not included in the PCWP NESHAP, those stand-alone
facilities could be listed as a major source category under section
112(c) of the CAA in the future and may be subject to the provisions of
section 112(g) of the CAA as well. We believe no additional emissions
reductions would be accomplished by listing lumber kilns as a separate
source category or by having them regulated by case-by-case MACT. We
believe this because: (1) The design and operation of lumber kilns are
essentially the same regardless of whether the kilns are located at a
sawmill or co-located with PCWP manufacturing operations, (2) we know
of no lumber kilns that are controlled for HAP, and (3) we know of no
cost effective HAP controls for lumber kilns. In addition, we know of
no additional recordkeeping or reporting that stand-alone facilities
would incur by being part of the PCWP source category since the PCWP
source category includes only major sources. Including stand-alone
kilns in the PCWP source category will save resources for regulatory
agencies and industry and does not forego HAP reductions; therefore, we
are proposing stand-alone kilns as part of the PCWP source category.
C. How Did We Determine the MACT Floor for Existing Sources?
Section 112(l)(3) of the CAA specifies that each MACT standard be
at least as stringent as the floor for the sources in the relevant
source category or subcategory. Today's proposed PCWP rule does not
have subcategories; therefore, the average emission limitation achieved
by the best-performing 12 percent of all major PCWP facilities
represents the MACT floor for the source category. In order to rank the
PCWP facilities based on performance, we would need facilitywide
uncontrolled emissions data and facilitywide controlled emissions data
for each facility to determine the percent reduction in HAP emissions
achieved by each facility. We do not have actual facilitywide emissions
data; however, we have accurate and complete information on the type
and number of individual process units at PCWP facilities. In addition,
emissions data are based on process unit data. Therefore, we decided to
apply the MACT floor methodology at the process-unit level. Our
information is especially accurate and complete for dryers and presses,
which are generally the highest-emitting process units and the ones
most likely to have add-on control systems that reduce HAP emissions
from PCWP facilities. With this approach, the sourcewide MACT floor is
represented by the MACT floor level of control established for each
process unit group. We believe that applying the MACT floor methodology
to process unit groups results in the closest possible approximation of
the true sourcewide MACT floor, since it better enables us to take into
account process unit-specific emissions data. We do not believe the
results from this approach are significantly different from what they
would be if facilitywide source-specific data had been available.
We determined the MACT floor control level for existing sources
using the following procedure:
[sbull]
We reviewed available data on pollution prevention
techniques and the performance of add-on control devices and identified
those add-on control systems that were best at reducing HAP emissions;
[sbull]
For each process unit group identified in Table 1 of this
preamble, we ranked the process units in that group from the best
performing to the worst performing based on the type of add-on control
system applied to each process unit;
[sbull]
For each process unit group, we then identified the add-on
control system that represented the MACT floor technology; and
[sbull]
Using available information on the performance of the add-
on control systems, we determined the performance level of the add-on
control systems.
This procedure is explained in more detail in the following
paragraphs. Additional information on how we determined the proposed
MACT floor for the PCWP industry is available in the docket for this
rule (Docket Number A-98-44).
1. Identifying the Best-Performing Add-On Control Systems
Although we believe that the potential for pollution prevention
exists for some
[[Page 1286]]
facilities in the PCWP industry, we are not aware of any demonstrated
pollution prevention techniques that can be universally applied across
the industry. Furthermore, we have no information on the degree of
emissions reduction that can be achieved through pollution prevention
measures. The PCWP facilities use add-on control devices because there
currently are no feasible pollution prevention measures. Therefore, we
focused our analysis on the performance of add-on control devices. We
reviewed the available data on control device performance to determine
which add-on control systems are best at reducing HAP emissions. We
focused our analysis on THC, formaldehyde, and methanol because these
three pollutants are the most prevalent pollutants emitted from the
PCWP industry and represent the majority of the available data on
control device performance. The design and operating factors that
affect a control system's ability to reduce emissions of formaldehyde,
methanol, or THC are generally the same. For example, an RTO designed
to reduce THC emissions will also reduce formaldehyde or methanol
emissions.
Based on a review of the available control device performance data
for the PCWP industry, we concluded that only two types of add-on air
pollution control devices (APCD) consistently and continuously reduced
HAP emissions: incineration-based controls (including RTOs, RCOs, and
incineration of pollutants in onsite process combustion equipment used
to control emissions from various PCWP process units) and biofilters
(used to control PCWP press emissions). The control device efficiency
data showed that APCD installed for particulate matter (PM) abatement
had no effect on gaseous HAP or THC emissions. These APCD include
cyclones, multiclones (or multicyclones), baghouses (or fabric
filters), and electrified filter beds (EFB). The performance data for
wet electrostatic precipitators (WESP) and wet scrubbers installed for
PM control also showed no effect on HAP and THC emissions. These wet
systems may achieve short-term reductions in THC or gaseous HAP
emissions, however, 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
formaldehyde) diminishes as the recirculating scrubbing liquid becomes
saturated with these compounds.
The performance data for the incineration-based controls and
biofilters showed methanol and formaldehyde emissions reductions equal
to or greater than 90 percent, except in those cases where the
pollutant loadings of the emission stream entering the control systems
were very low. The performance data for THC showed that incineration-
based control systems could achieve THC emissions reductions equal to
or greater than 90 percent. The THC emissions reductions achieved with
biofilters varied somewhat, with an average THC reduction of about 80
percent. Although biofilters are less effective in reducing some of the
less water-soluble VOC compounds, such as pinenes, that make up a
portion of the THC measurements, they can achieve HAP emissions
reductions equal to or greater than 90 percent. These emissions
reductions are reported only for biofilters treating emissions from
presses at PCWP facilities. No PCWP process units other than presses
are currently using biofilters to reduce air pollution. Both
incineration-based controls and biofilters can achieve identical
formaldehyde and methanol emissions reductions.
2. Ranking of Process Units
We ranked the process units within each process unit group
according to the HAP control devices that were applied. Information on
the number of process units nationwide and the types of add-on control
devices applied to process units was based primarily on responses to a
survey of the industry.
When we ranked the process units, we treated process units equipped
with any type of incineration-based control system or biofilters as
being equivalent with respect to their potential to reduce HAP
emissions. We ranked the process units by control device rather than
actual unit-specific emissions reductions because we have limited
inlet/outlet data on which to calculate control efficiency. Based on
available information (e.g., RTO operating temperatures), we are not
aware of any significant design or operational differences among each
type of control system evaluated that would affect the ranking of
process units. Furthermore, we are not aware of factors other than the
type of control system used that would significantly affect the ranking
of process units.
3. Identifying Control Technologies To Establish the MACT Floor
We established MACT floor control levels by applying the floor
procedures to similar process units. We believe that this approach
results in the closest approximation of the true sourcewide MACT floor.
With a few exceptions, there were at least 30 process units in each
process unit group. As discussed in section I.C, when there are at
least 30 sources in the source category, the MACT floor for existing
sources is equivalent to the average emission limitation achieved by
the best-performing 12 percent of existing sources in that group. Our
interpretation of the ``average emission limitation'' is that it is a
measure of central tendency, such as the median. If the median is used
when there are at least 30 process units in a process unit group, then
the emission level achievable by the process unit and its control
system that is at the bottom of the top 6 percent of the best-
performing process units (i.e., the 94th percentile) represents the
MACT floor control level for that component of the sourcewide floor.
For example, there are approximately 303 softwood veneer dryers
nationwide, and HAP emissions from approximately 64 of these dryers (21
percent nationwide) are controlled using incineration-based control
systems. The HAP emissions from the remainder of the softwood veneer
dryers are uncontrolled. In this example, the 94th percentile is
represented by the control system applied to the softwood plywood dryer
ranked at number 18 (18/303 = 6 percent). However, incineration-based
controls are also used by softwood veneer dryers ranked below the 94th
percentile. Assuming that there are no significant design or
operational differences between the different types of incineration-
based control systems that would affect their performance, we would
consider the incineration-based control technologies as being
equivalent for control of HAP emissions. Thus, all of the softwood
veneer dryers equipped with incineration-based control systems would be
representative of the MACT floor level of control for softwood veneer
dryers.
For those process unit groups where there were fewer than 30 but at
least five process units, such as hardboard ovens, the emission level
achievable by the process unit and its control system that is the
median of the best-performing five sources represents the MACT floor
level of control. For example, the MACT floor level of control for
fiberboard mat dryers is no emissions reductions because there are ten
fiberboard mat dryers nationwide, and emissions from only two of the
ten fiberboard mat dryers are controlled (both via incineration).
Therefore, the top five fiberboard mat dryers include the two that are
controlled, plus three that are uncontrolled. In this example, the
[[Page 1287]]
median source (the fiberboard mat dryer ranked ``number 3'') is
uncontrolled.
When a process unit group had fewer than five process units, we
determined the appropriate control technology based on the control
technology used by the majority of the process units in the process
unit group.
For those process units not required to meet the control
requirements in today's proposed rule, we determined that: (1) The MACT
floor level of control is no emissions reductions, and beyond the floor
control options are too costly to be feasible; or (2) insufficient
information is available to conclude that the MACT floor level of
control is represented by any emissions reductions (miscellaneous
coating operations and wastewater operations). We are requesting
comment on whether no emissions reductions for miscellaneous coating
operations and for wastewater operations is appropriate. Commenters
should submit any information they have on HAP or VOC emissions from
miscellaneous coatings and wastewater operations.
4. Determining the Performance Level of MACT Floor Technologies
Using the procedures described above, we determined that the
proposed MACT floor level of control for process units was either no
emissions reductions or equivalent to the emissions reductions achieved
by incineration-based control systems or biofilters. Although some
process units are equipped with add-on controls that perform at a level
somewhere between zero emissions reductions and the performance level
achievable with incineration-based controls and biofilters, none of
these control systems were identified as MACT floor control
technologies because they either do not reduce organic HAP emissions
(bag houses) or do so on an inconsistent and unreliable basis (wet
electrostatic precipitators). Therefore, we focused our analysis on
incineration-based controls and biofilters.
For the purpose of establishing the performance level of the MACT
floor control systems, we decided to group all of the available data on
incineration-based controls and biofilters together. We grouped all the
data together because the available data for incineration-based
controls is incomplete. Without complete data, we could not identify
which were the best performing incinerators; therefore, we could not
identify the top performing 12 percent. By considering all of the
performance data together, we maximized the amount of available data on
which we could base the MACT floor level of performance.
The reasons the available data are incomplete are: Multiple
emission points are treated, inlet/outlet data are limited, data among
pollutants vary, and pollutant loadings are variable. These are
discussed below.
Multiple emission points treated. Some of the control systems treat
HAP emissions from multiple types of process units, such as tube
dryers, reconstituted panel presses, and board coolers. In those cases,
separate determinations of the performance of the control system on
emissions from each type of process unit were not possible.
Limited inlet/outlet data. Limited or no inlet/outlet data were
available for the control systems applied to the process units in each
group.
Variability in data among pollutants. In some cases, it was not
possible to directly compare the performance of different control
systems because data were not available for the same pollutant. For
example, for one RTO, we might only have THC emissions data, and for
another RTO, we might only have formaldehyde data.
Variability in pollutant loadings. Our ability to compare the
performance of the different types of incineration-based control
systems with each other 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. For example, the available THC
concentration data for the inlet of the control systems ranged from as
low as 45 ppmvd to as high as 5,100 ppmvd. With the exception of some
control systems with lower pollutant inlet concentrations, the
available data for incineration-based controls and biofilters show that
these control systems can achieve THC, methanol or formaldehyde
emissions reductions greater than or equal to 90 percent.
We considered basing the control system performance level on just
one pollutant, such as THC as a surrogate for HAP. Many of the existing
PCWP facilities with MACT control systems are already required to meet
a specified VOC control efficiency, and these facilities generally
measure THC emissions as a surrogate for VOC emissions. Source VOC mass
emissions (as required in new source review or prevention of
significant deterioration reviews and emission limits for VOC by
definition) must be expressed on a mass basis. This requires an
adjustment for other compounds, such as formaldehyde, to the measured
THC emissions. However, THC emissions data sometimes include methane
which is neither a HAP nor a VOC. The THC emissions data also
frequently include other non-HAP compounds, such as terpenes, which are
associated with processing of softwoods. We also considered basing the
control system performance level on HAP, measured as total HAP, or
methanol as a surrogate for HAP, or formaldehyde as a surrogate for
HAP. Methanol and formaldehyde are the predominant HAP emitted from
PCWP process units, and they can be measured directly. However, not all
process units emit formaldehyde at detectable levels, and not all
process units emit methanol at detectable levels, so basing the
performance level only on methanol or only on formaldehyde was not
possible. For process units where both the methanol and formaldehyde
emissions are low, THC emissions may be the only viable option for
defining the control system performance. We rejected basing the control
system performance level on total HAP emissions because it seemed
overly burdensome to require testing of multiple pollutants at the
outlet of a control device when testing of one dominant pollutant would
be sufficient for determining control device performance. Furthermore,
the total HAP control efficiency could be negatively affected by those
measurements for HAP not detected at either the inlet or outlet of the
control device (e.g., the method detection limit used in the
calculation of total HAP control efficiency may be slightly higher at
the inlet than the outlet resulting in decreased total HAP control
efficiency).
Another consideration in determining the performance level that
represents the MACT floor level of control is the format of this
performance level (e.g., percent reduction, outlet concentration
level). In general, applying an incineration-based MACT control system
to a process unit that emits high concentrations of HAP and THC will
result in a greater percentage of emissions reductions than if that
same incineration-based MACT control system was applied to a process
unit that emits lower concentrations of HAP and THC. Therefore, a
performance level solely in the form of a percent reduction in
emissions could not adequately characterize the performance level of
the MACT floor control technology. In similar MACT rulemakings where
incineration-based control technologies represent the MACT floor, we
have defined the performance level of the incineration-based control
technologies as either a
[[Page 1288]]
percent reduction or an outlet concentration, whichever is less
stringent, with both forms being considered equivalent to the other. We
have recognized in these previous MACT rulemakings that there are
practical limits to the ability of incineration-based control systems
to treat more dilute emission streams. We consider the practical limit
of control of THC via incineration to be approximately 20 ppmvd in the
outlet of the control device.
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, we decided to base the
MACT floor performance level on all three of the pollutants we analyzed
and include maximum concentration levels in the outlet of the control
systems as an alternative to emissions reductions. The MACT floor
performance level is a 90 percent reduction in THC or methanol or
formaldehyde emissions. The maximum concentration 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. We chose 20 ppmvd as the
alternative maximum concentration for THC because 20 ppmvd represents
the practical limit of control for THC. We chose 1 ppmvd as the maximum
outlet concentration for both methanol and formaldehyde because this
concentration is achievable by MACT control systems and the method
detection limits for these compounds using the NCASI impinger/canister
method (NCASI Method IM/CAN/WP-99.01, proposed to be incorporated by
reference in today's proposed rule) are less than 1 ppmvd. Based on the
available data for MACT control systems, these six emission levels for
add-on control systems are considered equivalent options for defining
the performance level of a MACT control system.
D. How Did We Determine the MACT Floor for New Sources?
For new sources, the CAA requires the MACT floor to be based on the
degree of emissions reductions achieved in practice by the best-
controlled similar source. We believe for most process unit groups that
the existing source MACT floor control level also represents the level
of control appropriate for new sources because the same types of
emission control systems, such as thermal oxidizers and biofilters, are
used. In these cases, the existing source MACT floor technology
represents the greatest degree of emissions reductions that is
achievable under all circumstances within each particular operation
regulated by the proposed rule. For a few process units, the MACT floor
level of control for new units is more stringent than for existing
units. In those cases, we determined the MACT floor control level for
existing process units was no emissions reductions, and that the MACT
control level for new sources was represented by incineration-based
controls or biofilters.
E. What Control Options Beyond the MACT Floor Did We Consider?
The control devices that represent the MACT floor control level
achieve the greatest HAP emissions reductions of any available control
technologies. There are no controls that achieve greater emissions
reductions than the MACT floor control level for process unit groups
with MACT floor control levels represented by incineration-based
controls or biofilters; therefore, we only looked at beyond the floor
options for process unit groups at existing sources where the MACT
floor level of control was no emissions reductions. Process units that
were inherently lower-emitting, such as sanding and sawing operations,
were excluded from the beyond-the-floor analyses because emissions from
these process units would not be cost effective to control. Based on a
review of the HAP emissions data for process units where the MACT floor
level of control was determined to be no emissions reductions, we
selected blenders and stand-alone digesters for a beyond-the-floor
analysis because these process units emit higher levels of HAP
emissions relative to other process units. We also conducted beyond-
the-floor analyses for three process unit groups with no emissions
reductions at the MACT floor control level for existing sources but
requiring control for new sources. These process units included
fiberboard mat dryers, press predryers, and board coolers. We
determined that the environmental benefits of requiring controls for
these process units did not justify the cost. Moreover, many of the
existing control devices at well-controlled 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.
Therefore, we decided that the control level for blenders, stand-alone
digesters, fiberboard mat dryers, press predryers, and board coolers
should be no emissions reductions at existing sources.
F. How Did We Select the Format of the Proposed Rule?
We decided to offer several formats for complying with today's
proposed rule. The purpose of multiple formats is to provide you the
flexibility to comply in the most cost-effective and efficient manner.
We considered the following factors in selecting the format of the
proposed rule:
[sbull]
The format should allow for multiple compliance techniques
for the various types of facilities in the industry.
[sbull]
The format should simplify compliance and ensure that the
cost of compliance is not excessive.
[sbull]
The format must be enforceable.
The format of this proposed rule is based on a combination of
production-based compliance options, percent emissions reduction
compliance options, pollutant concentration compliance options, and
work practice requirements. We are also including emissions averaging
as an option for complying with the proposed rule. The following
subsections describe the selection of the formats for each compliance
option and work practice requirement included in the proposed rule.
1. Production-Based Compliance Options
The production-based total HAP compliance options apply to process
unit emissions prior to entering an add-on control system. This option
allows for future pollution prevention techniques and cost-effective
control of inherently lower-emitting process units. The production-
based compliance options were determined by applying a 90 percent
reduction to the highest total HAP test for each type of process unit
with a controlled MACT floor. A 90 percent reduction was selected
because it is equivalent to the emissions reductions achievable through
the use of MACT. The 90 percent reduction was applied to the highest
tests rather than the average emission factors because the production-
based options calculated using the highest tests more closely correlate
with actual emissions from process units with MACT control systems. If
the average emission factors were used in the calculation of the
production-based compliance options, some of the process units with
MACT control systems would not be capable of meeting those options. Use
of statistical methods for predicting the highest test value likely to
be observed for each process unit was also considered. However, the
available total HAP test data sets are too small to justify use of
[[Page 1289]]
such statistical methods, and the resulting compliance options, in many
cases, seemed unreasonably high compared to the actual emissions from
process units with MACT control systems. Therefore, statistical methods
were not used. We based the production-based compliance options on
total HAP emissions, as defined in today's proposed rule, because of
the variability in uncontrolled HAP emissions within and among the
different types of process units. Total HAP emissions varied less than
the emissions of individual HAP and the emissions of THC.
2. Add-On Control System Compliance Options
The six compliance options for add-on control systems in today's
proposed rule are based on the performance of incineration-based
control systems and biofilters. We included two formats in these
compliance options: Emissions reductions (percent) and maximum outlet
pollutant concentrations. Many of the well-controlled facilities are
already subject to permit limits that are in the form of a percent
reduction in emissions. Therefore, we expect that some of those
facilities may choose to comply with an emissions reduction option. We
are also including outlet concentration options so that sources that
have lower inlet pollutant concentrations (and thus, have lesser
ability to achieve higher emissions reductions) can demonstrate
compliance. We consider the emissions reduction options and the outlet
concentration options to be equivalent limits. We are not requiring an
oxygen correction to the outlet concentration options because most of
our outlet concentration data were measured at ambient oxygen levels
due to the relatively dilute emission streams being treated. Dilution
to achieve compliance with the proposed PCWP rule is prohibited by 40
CFR 63.4.
We are restricting the use of the formaldehyde and methanol
concentration-based options to only those sources with formaldehyde or
methanol emissions entering the control device that are greater than 10
ppmvd. We have included this restriction to prevent circumvention of
the proposed standards. For example, if a process unit emits primarily
formaldehyde and only a very small amount of methanol (slightly less
than 1 ppmvd), without the 10 ppmvd restriction, you could demonstrate
compliance with the 1 ppmvd methanol concentration option without using
a control system or using a control system that does not reduce HAP,
such as a baghouse. The 10 ppmvd restriction does not apply to the
percent reduction compliance options.
3. Emissions Averaging Compliance Option
Today's proposed rule includes an emissions averaging compliance
option because we believe that emissions averaging represents an
equivalent, more flexible, and less costly alternative to controlling
certain emission points to MACT floor levels. Prior to an industry-
sponsored emissions test program carried out by NCASI, the majority of
the available emissions test data for the PCWP industry was limited to
THC and formaldehyde emissions data for dryers and presses. The
industry-sponsored test program provided speciated HAP emissions data
for a variety of process units at 29 different PCWP plants. For some of
these previously untested process units, the NCASI data represent the
only available HAP emissions data for those sources. A few of these
process units, such as blenders, may emit quantities of HAP equal to or
greater than the quantities emitted from some types of dryers and
presses. In addition to emitting more HAP, these other types of process
units often have a lower volume of exhaust gas to be treated compared
to dryers and presses. The combination of higher pollutant
concentrations and lower exhaust gas flow rates may make these other
process units more cost effective to control. However, very few PCWP
facilities have installed emission control devices on process units
other than dryers and presses. Therefore, when determining the MACT
floors for existing process units, the process units most likely to
have controlled MACT floors have been dryers and presses, with some
exceptions. Most other types of process units are largely uncontrolled
throughout the industry and based on our MACT analysis, we did not
include existing source control requirements for these process units in
today's proposed rule. Therefore, emissions from these other types of
process units at existing sources would not be controlled under the
point-by-point compliance options in today's proposed rule. By allowing
emissions averaging across the affected source, which is broadly
defined in today's proposed rule, sources can achieve the same
environmental gains as point-by-point compliance, but at reduced cost.
The emissions averaging provisions in today's proposed rule are
based in part on the emissions averaging provisions in the Hazardous
Organic NESHAP (HON). The legal basis and rationale for the HON
emissions averaging provisions were provided in the preamble to the
final HON (59 FR 19425, April 22, 1994). The rationale for including
certain limitations and requirements as part of today's emissions
averaging provisions follows the HON and is summarized below.
Emission points allowed in emissions averaging. Only those emission
points (process units) that are part of the affected source (PCWP
manufacturing facility), as defined in today's proposed rule, can be
included in an emissions average. Therefore, a PCWP facility collocated
with a pulp and paper mill, for example, cannot include emission points
in the pulp and paper mill as part of the emissions average.
Today's proposed rule also excludes new affected sources from the
proposed emissions averaging provisions. Today's proposed rule defines
affected sources broadly, such that a new source is essentially a whole
new ``green field'' mill. Therefore, not allowing emissions averaging
at new sources does not affect existing sources' ability to use
emissions averaging. New sources have historically been held to a
stricter standard than existing sources because it is most cost
effective to integrate state-of-the-art controls into equipment design
and to install the technology during construction of new sources. One
reason we allow emissions averaging is to give existing sources
flexibility to achieve compliance at diverse points with varying
degrees of control already in place in the most cost-effective and
technically reasonable fashion. This concern does not apply to new
sources which can be designed and constructed with compliance in mind.
Today's proposed rule also excludes from emissions averaging any
process units equipped with emission control systems that were
installed to comply with a State or Federal rule or statute (other than
today's proposed rule). We are including this restriction because
credits for controls applied to comply with another rule increase your
ability to generate credits, but do not generate any new emissions
reductions, thus creating more emissions. However, if a process unit in
your approved EAP used to generate emission credits later becomes
subject to a State or Federal rule other than the proposed PCWP rule,
the process unit can continue to generate credits in the approved plan.
Work practice requirements are excluded from emissions averaging
because, by definition, the level of emissions reduction achieved by
compliance with those requirements is not sufficiently quantifiable.
Limits on credit for control efficiencies. The proposed emissions
averaging provisions limit the value of
[[Page 1290]]
the control system efficiency (CD_i) to 90 percent in the
equation for calculating the AMR of total HAP from all process units
generating credits. No credit above 90 percent is allowed.
Differences from the HON emissions averaging approach. Some aspects
of the HON emissions averaging approach have not been included in the
proposed PCWP rule. Specifically, today's proposed rule does not limit
the number of emission points allowed in an emissions average, does not
require a hazard or risk analysis, and does not include a discount
factor. The HON limited the number of emission points that could be
used in an emissions average because of significant enforcement
concerns. The HON sources have many emission points, are complex and
diverse, and as a result are subject to a more complex set of emissions
averaging provisions. The PCWP facilities have fewer emission points
within each facility. Therefore, the enforcement concerns arising due
to the large number of emission points in each HON facility are
minimized for PCWP facilities. As a result, we believe a simpler set of
emissions averaging provisions is appropriate for PCWP facilities, and
the limitation on the number of points available for averaging was not
included in the proposed rule.
The HON requires a hazard and risk study for emission points
included in an emissions average largely because of the many pollutants
and many emission points at the source. The PCWP facilities have fewer
pollutants of concern and are likely to have similar HAP emissions from
the emission points that would be used to generate debits and credits.
Thus, we believe that averages will achieve a comparable hazard/risk
benefit as point-by-point compliance. Although States would still have
the discretion to require a PCWP facility that requested approval of an
emissions average to conduct a hazard and risk study (or preclude the
facility from using emissions averaging altogether), the proposed rule
does not require a hazard or risk study.
The HON requires a discount factor of 10 percent in credit
calculations to share with the environment some portion of the cost
savings due to emissions averaging and to account for uncertainty in
emissions estimation. Due to differences between PCWP and HON sources
(discussed below), we do not believe it is necessary for the proposed
PCWP rule to include a discount factor.
The HON proposal preamble (57 FR 62652, December 31, 1992) and the
HON final preamble discuss how cost savings due to emissions averaging
should be shared between industry and the environment. For the HON, we
decided that it was appropriate that industry share any cost savings
realized from emissions averaging and included a discount factor
because the costs of controlling different emission points could vary
significantly. The HON proposal preamble also discussed the level of
uncertainty in estimating emissions reductions that may result from
facilities using emissions averaging. For the HON, the uncertainty
arose from differing accuracies available for estimating emissions from
the number of emission points at a HON facility, the number of HAP
emitted from HON facilities, and the different types of emission
points.
The PCWP industry differs in almost every relevant factor from the
HON. First, HON facilities can cover several square miles and some
emission points, such as storage vessels, could be some distance from
other emission points making them relatively costly to control. Second,
as discussed previously, the number of points that might be included in
an emissions average at a PWCP facility is fewer than could be included
in a HON average and, therefore, less of a concern. Third, the
magnitude of emissions from HON emission points is typically much
greater than the emissions from PCWP emission points. Fourth, there are
six HAP of primary concern emitted from PCWP facilities compared to
over 140 HAP emitted from HON facilities. Fifth, the kinds of emission
points found at PCWP facilities are much more similar than those
regulated by the HON and, therefore, unlikely to introduce additional
uncertainty.
We believe the inclusion of emissions averaging into rules and the
decision on how to design an emission averaging approach for a
particular source category must be evaluated for each source category.
Although the HON and the proposed PCWP rule share the same legal basis
for including emission averaging as a compliance option and the same
basic system of credits and debits, some of the restrictions reasonable
for the HON emissions averaging provisions are unnecessary for the
proposed PCWP rule.
4. Work Practice Requirements
Section 112(h) of the CAA states that ``* * * if it is not feasible
in the judgement of the Administrator to prescribe or enforce an
emission standard for control of a hazardous air pollutant or
pollutants, the Administrator may, in lieu thereof, promulgate a
design, equipment, work practice, or operational standard, or
combination thereof * * *'' Section 112(h)(2) further defines the
phrase ``not feasible to prescribe or enforce an emission standard'' as
any situation in which ``* * * a hazardous air pollutant or pollutants
cannot be emitted through a conveyance designed and constructed to emit
or capture such pollutant, * * * or the application of measurement
methodology to a particular class of sources is not practicable * * *''
Today's proposed rule includes work practice requirements for
softwood veneer dryers, dry rotary dryers, hardwood veneer dryers, and
veneer redryers. The proposed work practice requirements for softwood
veneer dryers include a requirement to minimize fugitive emissions from
the veneer dryer doors and the green end of the dryer. It is not
practical for sources to measure the fugitive emissions from the
softwood veneer dryers; therefore, in lieu of establishing an emission
limit for fugitive emissions, we are proposing that sources develop a
plan for minimizing these emissions and keep records to document they
are following their plan.
For dry rotary dryers, hardwood veneer dryers, and veneer redryers,
the proposed work practice requirements would establish limits on how
these process units are operated and the types of materials processed
in these units. The MACT floors for dry rotary dryers, hardwood veneer
dryers and veneer redryers are all equivalent to no emissions
reductions because none of these process units have add-on control
devices. The emissions from these three types of process units are
relatively low compared to the emissions from other PCWP process units
subject to today's proposed rule. However, if these three types of
process units were operated in a manner that was inconsistent with how
they are defined in today's proposed rule, the emissions from these
process units could increase.
For example, a green rotary dryer, which has proposed compliance
options in today's proposed rule, is essentially the same in terms of
equipment as a dry rotary dryer. However, a dry rotary dryer emits much
less HAP than a green rotary dryer because it dries wood particles that
have been previously dried to some extent; thus, much of the HAP
present in the wood has already been released. The dry rotary dryers
also operate at lower temperatures, which further reduces the amount of
HAP emitted. Therefore, the operation of the rotary dryer, and not the
equipment design, determines whether it is classified as a green or dry
rotary dryer. Because the dry rotary dryers, veneer redryers and
hardwood veneer dryers
[[Page 1291]]
are defined and classified based on how they are operated, and we made
MACT floor determinations based on those classifications, we believe
that proposing work practice requirements (such as continuously
monitoring dryer temperature and wood moisture content) that ensure
that these process units continuously operate as defined in today's
proposed rule is more appropriate than proposing compliance options for
these process units.
G. How Did We Select the Test Methods for Determining Compliance With
the Proposed Rule?
Today's proposed rule would require you to conduct performance
tests to demonstrate compliance with the production-based compliance
options, compliance options for add-on control devices, and the
emissions averaging alternative. Depending upon which compliance option
you use, you would be required to measure emissions of methanol,
formaldehyde, THC, or total HAP. When determining compliance with
compliance options for presses and board coolers, you also would be
required to determine the capture efficiency of the enclosures for
those presses and board coolers that have enclosures that do not
qualify as PTE. For presses and board coolers that have partial
enclosures or no enclosures, you must determine the capture efficiency
of the emissions capture device by installing a TTE as described in EPA
Method 204 or using the tracer gas method as described in Appendix A to
today's proposed rule. The test methods you would have to use to
measure these pollutants and capture efficiency are discussed below.
We are proposing the use of EPA Method 25A (Determination of Total
Gaseous Organic Matter Concentration Using a Flame Ionization Analyzer)
for measuring THC emissions because most of the PCWP facilities that
are already required to measure THC emissions use this method. Also,
most of the available emissions data that we used to establish THC
control efficiencies for the various control systems were measured
using Method 25A and reported on an ``as carbon'' basis. Method 25A is
better suited than EPA Method 25 (Measurement of Total Gaseous
Nonmethane Organic Emissions as Carbon (TGNMO)) for measuring emission
streams from PCWP process units which typically have lower THC
concentrations (e.g., less than 50 ppm) and relatively high moisture
contents. However, unlike Method 25, Method 25A does measure methane as
a THC. Because many of the well-controlled PCWP facilities are required
by permit to reduce VOC emissions, these facilities generally are
allowed to subtract methane emissions from the THC measurement when
reporting VOC emissions because methane is not a VOC, according to
EPA's definition of VOC. Therefore, we also would allow you to subtract
methane emissions from measured THC values using EPA Method 18
(Measurement of Gaseous Organic Compound Emissions by Gas
Chromotography). Method 18 is a self-validating method.
We are proposing the use of the NCASI Method (NCASI Method CI/WP-
98.01, Chilled Impinger Method for Use at Wood Products Mills to
Measure Formaldehyde, Methanol, and Phenol, 1998) for measuring
methanol or formaldehyde. We are also proposing the NCASI Chilled
Impinger Canister Method (NCASI Method IM/CAN/WP-99.01) for measuring
total HAP emissions. Total HAP emissions are defined, for purposes of
today's proposed rule, as the sum of the emissions of acetaldehyde,
acrolein, formaldehyde, methanol, phenol, and propionaldehyde. The
NCASI Chilled Impinger Method (NCASI Method CI/WP-98.01), which we are
proposing to incorporate by reference, has been validated (using EPA
Method 301 criteria) for measuring formaldehyde, methanol, and phenol
from dryers and press vents at PCWP facilities. The NCASI Method IM/
CAN/WP-99.01, which we are proposing to incorporate by reference
(pending EPA review of the method), is a self-validating method that
can be used to measure numerous HAP compounds.
As an alternative to the NCASI methods, we are proposing use of
other applicable EPA test methods in order to increase the flexibility
of the proposed rule. You could use EPA Method 320 (Measurement of
Vapor Phase Organic and Inorganic Emission by Extractive FTIR) to
measure emissions of methanol, formaldehyde and total HAP. Method 320
is a self-validating method that uses Fourier transform infrared (FTIR)
spectroscopy. You could also use EPA Method 308 (Procedure for
Determination of Methanol Emission from Stationary Sources) for
measuring emissions of methanol. Method 308 predates the NCASI Chilled
Impinger Method and the NCASI Impinger Canister Method and has been
used to test PCWP emission sources in the past. You could use EPA
Method 0011 (Sampling for Selected Aldehyde and Ketone Emissions from
Stationary Sources) or EPA Method 316 (Sampling and Analysis for
Formaldehyde Emissions from Stationary Sources in the Mineral Wool and
Wool Fiberglass Industries) to measure formaldehyde emissions. Although
EPA Method 0011 has not been validated for use in the PCWP industry, it
predates the NCASI methods and EPA Method 320 and is frequently used to
measure formaldehyde emissions from PCWP process units. A comparison of
formaldehyde measurements made using the NCASI methods and EPA Method
0011 showed no significant differences (see Docket number A-98-44);
therefore, we would allow you to use EPA Method 0011 as an alternative
to the NCASI Methods for measuring formaldehyde. Although EPA Method
316 has not been validated for testing of PCWP process units, it is a
relatively new method for measuring formaldehyde concentrations as low
as 11 parts per billion. Therefore, it is included as an alternative to
the other test methods for formaldehyde in today's proposed rule.
We are proposing the use of EPA Method 204 (Criteria for and
Verification of Permanent or Temporary Total Enclosure) and Methods
204A through 204F for determining the capture efficiency of enclosures.
Methods 204A through 204F include the following: Method 204A--Volatile
Organic Compounds Content In Liquids Input Stream; Method 204B--
Volatile Organic Compounds Emissions In Captured Stream; Method 204C--
Volatile Organic Compounds Emissions In Captured Stream (Dilution
Technique); Method 204D--Volatile Organic Compounds Emissions In
Uncaptured Stream From Temporary Total Enclosure; Method 204E--Volatile
Organic Compounds Emissions In Uncaptured Stream From Building
Enclosure; and Method 204F--Volatile Organic Compounds Content In
Liquid Input Stream (Distillation Approach). If the enclosure meets the
definition and criteria in EPA Method 204 for a PTE, then you may
assume that its capture efficiency is 100 percent. If the enclosure is
not a PTE, then you would have to build a total temporary enclosure
(TTE) around the process unit that meets the definition of a TTE in EPA
Method 204, and you would be required to determine the capture
efficiency of the TTE using Methods 204A through 204F (as appropriate).
You would then have to measure emissions from both the control device
(if applicable) and the TTE and use the combined emissions to determine
compliance. If the process unit is uncontrolled, you would have to use
the capture efficiency of the TTE in determining the uncontrolled
emissions from the process unit.
[[Page 1292]]
Industry representatives have expressed concern with using EPA
Methods 204 and 204A through F for determining capture efficiency of
press enclosures. The industry representatives have indicated that some
facilities may have difficulty retrofitting a PTE or TTE that meets the
EPA Method 204 criteria. Partial enclosures may be able to achieve high
capture. We recognize the need for flexibility in determining capture
efficiency for PCWP press enclosures and, therefore, as an alternative
to Methods 204 and 204A through F, we are working with PCWP industry
representatives to develop and propose a tracer gas procedure that may
be used to determine the capture efficiency of PCWP press partial
enclosures. This alternative tracer gas procedure is provided as
Appendix A to today's proposed rule. This procedure would be applicable
for determination of capture efficiency for press enclosures that are
not considered to be PTE as defined in EPA Method 204, and the
procedure is proposed as an alternative to the construction of TTE.
Sulfur hexafluoride (SF6) is used as a tracer gas. This gas is not
indigenous to the ambient atmosphere and is nonreactive. The
alternative tracer gas procedure provided as Appendix A to today's
proposed rule is a ``work in progress.'' Industry representatives are
testing the tracer gas procedure and are expected to provide data and
feedback that may be used in revising the procedure if necessary.
Discussions with industry representatives regarding development of the
proposed alternative tracer gas procedure are documented in Docket A-
98-44. We welcome your comments on the proposed alternative tracer gas
procedure. We also welcome your comments on additional approaches for
determining capture efficiency, such as the use of computational fluid
dynamics (CFD) models or other methods that would meet the data quality
objective (DQO) or lower confidence limit (LCL) statistical criteria
outlined in Appendix A to subpart KK of 40 CFR part 63 (National
Emission Standards for the Printing and Publishing Industry). Today's
proposed rule would allow facilities to petition the Administrator for
use of alternative test methods.
H. How Did We Select the Monitoring and Recordkeeping Requirements?
We are proposing monitoring and recordkeeping requirements based on
a combination of general monitoring and recordkeeping requirements in
the NESHAP General Provisions (40 CFR part 63, subpart A) and specific
monitoring methods already in use at PCWP plants. The proposed
monitoring requirements we selected pertain to the operating
requirements for control devices and the work practice requirements for
various dryers.
The proposed recordkeeping requirements include submitting a copy
of each notification and report, as well as documentation supporting
any Initial Notification or Notification of Compliance Status,
according to the requirements in Sec. 63.10(b)(2)(xiv). You would also
have to keep the records specified in Sec. 63.6(e)(3) related to
startup, shutdown, and malfunction (SSM), records of performance tests,
as required in Sec. 63.7(g)(1), and records for each continuous
monitoring system (CMS), including CPMS or CEMS. The records for the
CMS would include records of the applicable operating requirements and
monitoring data required in today's proposed rule. You also would have
to keep records to demonstrate compliance with any work practice
requirements that apply to you.
How we selected the specific proposed monitoring and recordkeeping
requirements is discussed in the following subsections.
1. Control Device Parameter Monitoring and Recordkeeping Requirements
According to today's proposed rule, you would have the option of
either monitoring control device operating parameters or operating a
THC CEMS at the control device outlet to demonstrate continuous
compliance with the operating requirements. The operating parameters
for thermal oxidizers, catalytic oxidizers, and biofilters were
selected based on information from the questionnaire responses and
information from other source categories regarding the parameters that
are currently used as reliable indicators of control device
performance.
For thermal oxidizers, we would require monitoring for the
temperature in the firebox or in the ductwork immediately downstream of
the firebox. A sufficiently high temperature in the firebox helps to
ensure complete combustion of pollutants. We also would require you to
monitor the static pressure at the inlet of the thermal oxidizer as an
indicator of capture efficiency and the process unit exhaust flow rate
entering the thermal oxidizer. You may monitor gas flow rate at the
thermal oxidizer stack as an alternative to monitoring static pressure.
Monitoring of gas flow or static pressure can alert the operator to
problems such as plugging of the thermal oxidizer. Parameter monitoring
would not be required for combustion units with greater than or equal
to 44 MW heat input capacity that accept process exhausts into the
flame zone.
For catalytic oxidizers, we would require monitoring of the
temperature at the inlet of the catalyst bed. The rate at which
pollutants in the exhaust stream are oxidized on the catalyst is
greatly affected by temperature, as well as other parameters (such as
residence time and turbulence) that are fixed by the design of the
catalytic oxidizer. Monitoring of the inlet temperature to the
catalytic oxidizer helps to ensure that the system is operating as
designed with a temperature high enough to oxidize the pollutants. As
for thermal oxidizers, we also would require you to monitor the static
pressure at the inlet of the catalytic oxidizer or stack gas flow rate.
If you operate a thermal oxidizer or catalytic oxidizer, you would
be required to calculate and record 3-hour block averages of the
operating parameter values. We selected the 3-hour averaging time
because the initial performance test provisions in today's proposed
rule require you to perform a minimum of three 1-hour test runs, and
the control device operating requirements would be based on the average
values obtained using all test data obtained during the performance
test. Each 3-hour average parameter value must remain within the level
established during the performance test in order for you to demonstrate
continuous compliance with the operating requirement.
The proposed operating parameters for biofilters are based on
information about parameters currently monitored for biofilters
operated in the PCWP industry and on information supplied by a
biofilter vendor. For biofilters, you would be required to monitor the
following parameters to demonstrate continuous compliance: (1)
Temperature of the air stream entering the biofilter, (2) pressure drop
across the media bed, and (3) pH of the effluent. Monitoring
temperature and pH help determine the health of the microorganism
population. Extremes in either temperature or pH can slow or halt
microbial activity. Monitoring the pressure drop across the biofilter
can alert the operator to problems such as plugging or drying of the
bed media. Because factors that affect the performance of biofilters
and biofilter monitoring methods can be site specific, you would be
allowed to establish your biofilter operating parameter requirements
and their corresponding monitoring methods, monitoring frequencies, and
averaging times based on historical biofilter operating records. We
allow the use of historical records in setting the biofilter parameter
limits
[[Page 1293]]
because establishing limits during a 3-hour performance test may not
adequately identify acceptable operating ranges for biofilter
parameters. Some facilities in the PCWP industry have been operating
biofilters for years, and these facilities have learned through
experience the most appropriate monitoring methods, monitoring
frequencies, and optimal operating ranges for their biofilters. Because
historical biofilter operating records may not be available for some
biofilters (such as new biofilter installations), today's proposed rule
would allow up to 180 days following the compliance date for the
necessary operating data to be gathered for use in setting parameter
requirements. To ensure compliance, all historical operating data used
to establish the operating parameter limits must be accompanied by
performance test data for the same time period that show that the
biofilter was meeting the emission limits in today's proposed rule, and
that the data were collected using the test methods in today's proposed
rule. In addition, you would have to certify that no modifications have
been made to the biofilter or associated process unit(s) subsequent to
the date the historical data were collected. Because there are only a
few biofilters operating in the PCWP industry and we have limited
information on how changes in biofilter operating parameters affect
biofilter performance, we welcome your comments on these proposed
monitoring requirements for biofilters.
If you operate a control device other than a thermal oxidizer,
catalytic oxidizer, or biofilter, you would be required to petition the
Administrator for site-specific operating parameters to indicate proper
operation and continued performance of the control device. You would
establish the operating parameter values during the performance test
and maintain the parameters within the range established during the
performance test. The Administrator would determine whether maximum
value, minimum value, or a range of operating parameters is
appropriate. The Administrator would also determine the appropriate
averaging time for each monitoring parameter for the control device.
If you comply with the production-based compliance options, then
you would be required to continuously monitor a process operating
parameter (temperature). You would monitor dryer inlet temperature for
green rotary dryers, tube dryers, or strand dryers. You would monitor
operating temperature for hardboard ovens, press predryers,
reconstituted wood product presses, fiberboard mat dryer hot zones, and
softwood veneer dryer hot zones. You would not be required to monitor
process parameters for reconstituted wood product board coolers or
pressurized refiners. We request comment on whether the temperature
parameters are appropriate for monitoring to show compliance with the
production-based compliance options. The production-based compliance
options were developed for inherently low-emitting process units or
process units using pollution prevention. We believe that process unit
HAP emissions are somewhat dependent on dryer or press temperature;
however, other factors such as resin HAP content and percent of furnish
that enters the plant already dried may also affect HAP emissions. It
is not clear what pollution prevention techniques will be used to
comply with the production-based compliance options (partly because
pollution prevention measures are expected to evolve in the future),
therefore, we request your feedback on how facilities that will use
pollution prevention could show continuous compliance with the
production-based compliance options.
Instead of monitoring process or control system operating
parameters for thermal oxidizers, catalytic oxidizers, biofilters, or
other control systems, you could choose to monitor THC concentration
with a CEMS at the control device outlet to show compliance with the
operating requirements. If you use a THC CEMS, you would be required to
maintain the average THC concentration at the control device outlet
below the maximum THC concentration established during the performance
test. The purpose of monitoring THC concentration is to show compliance
with the operating requirements (as opposed to the compliance options);
thus, you could use the THC CEMS instead of CPMS regardless of whether
you demonstrate compliance with the THC, formaldehyde, methanol, or
total HAP compliance options. For example, you could conduct a
performance test to show that you reduce formaldehyde by 90 percent
while simultaneously operating the THC CEMS to determine the maximum 3-
hour block outlet THC concentration that would become your parameter
value representing your operating requirement. Generally, the same
parameters that affect control device formaldehyde, methanol, or total
HAP reduction efficiency also impact the THC reduction efficiency;
thus, we believe that allowing use of a THC CEMS instead of a operating
CPMS to demonstrate continuous compliance with the operating
requirements is appropriate. If you choose to do so, you may subtract
methane from the THC concentration measured with your THC CEMS (e.g.,
by using a CEMS that measures TGNMO).
Control device maintenance requirements vary significantly from
facility to facility. Although we believe that most of the maintenance
activities can be accomplished during scheduled facilitywide or partial
shutdowns, we recognize that some facilities may need to perform more
maintenance on their control systems than other facilities due to site-
specific factors, such as the nature and quantity of particulate
entering an RTO or the ability of an RTO to perform online bakeouts (a
feature often incorporated into newer RTO designs).
The most widely used add-on control systems at PCWP facilities are
RTO, RCO, and biofilters. As with any control device in any industry,
these control devices require routine maintenance. Routine maintenance
includes activities such as cleaning or replacement of corroded parts,
media replacement, bakeouts (RTO and RCO), washouts (RTO and RCO), and
cleaning of ducts. Some PCWP drying processes release particulates and
salts that can plug and weaken RTO and RCO media beds. Frequent
bakeouts and washouts are necessary to combat the particulate and salt
buildup. Partial or total media replacement is done when bakeouts and
washouts are no longer effective.
Plywood and composite wood products industry representatives have
requested that today's proposed rule include a downtime allowance that
would allow process units to operate while the control device is
offline for routine maintenance. After considering the available data,
we included in today's proposed rule a routine control device
maintenance exemption. To obtain the exemption, you must explain to the
Administrator why you cannot perform routine control device maintenance
during process shutdowns and describe how you plan to minimize
emissions to the greatest extent possible during the maintenance. The
routine control device maintenance exemption may not exceed 3 percent
of annual operating uptime for each green rotary dryer, tube dryer,
strand dryer, or pressurized refiner controlled. The routine control
device maintenance exemption is limited to 0.5 percent of annual
operating uptime for each softwood veneer dryer, reconstituted wood
product press, reconstituted wood product board cooler, hardboard oven,
press predryer, or fiberboard mat dryer
[[Page 1294]]
controlled. If your control device is used to control a combination of
equipment with different downtime allowances (e.g., a tube dryer and a
press), then the highest (i.e., 3 percent) downtime allowance applies.
The maximum percentages of operating time allowed for the routine
control device maintenance exemption are based on our independent
analysis of data from an extensive control device downtime survey
conducted by the PCWP industry.
We are requesting comment on the appropriateness of including a
routine control device maintenance exemption in today's proposed rule
and whether or not the downtime allowance allotted is appropriate as
the maximum amount of time per year for such an exemption. Commenters
should submit information and data that support their comments such as
detailed maintenance records and descriptions of the add-on control
systems, sources controlled by the control system, and any particulate
removal devices that precede the control system.
2. Monitoring and Recordkeeping Requirements for Process Units Without
Add-On Control Devices
If you comply with the production-based compliance options in
today's proposed rule without using an add-on control system, then you
would be required to monitor and record process unit operating
parameters. For most process units, temperature would be the required
process monitoring parameter. Although HAP emissions vary within and
among process units and no one process parameter is responsible for
these variations, we selected temperature as the proposed required
process monitoring parameter for most process units. We chose operating
temperature because it affects HAP emissions and can be controlled and
monitored relatively easily.
As for the control device operating requirements, you could choose
to monitor THC concentration using a CEMS at the process unit outlet
instead of monitoring process unit temperature. If you use a THC CEMS,
you would be required to maintain the average THC concentration at the
process unit outlet below the maximum THC concentration established
during the performance test.
If you elect to use emissions averaging, you would not be required
to monitor process parameters for those uncontrolled process units that
are used to generate debits. However, when you determine the total HAP
emissions from these uncontrolled process units, you would have to
perform the emissions measurements under representative operating
conditions, and you would be required to keep records of the hours of
operation for these uncontrolled process units.
3. Monitoring and Recordkeeping Requirements for Dry Rotary Dryer Work
Practice Requirements
Rotary dryers that meet the definition of ``dry rotary dryers'' in
today's proposed rule would not be subject to the proposed control
requirements. Green rotary dryers and dry rotary dryers are essentially
the same in terms of equipment design. The differences between the two
types of dryers are operational. Green rotary dryers are used to dry
green furnish, and dry rotary dryers are used to dry furnish that has
been previously dried. Green rotary dryers are defined as dryers that
dry wood particles that have a moisture content greater than 30 percent
on a dry basis or operate at an inlet dryer temperature greater than
600[deg]
F. Conversely, dry rotary dryers dry wood particles that have
a moisture content less than or equal to 30 percent on a dry basis and
operate at an inlet dryer temperature less than or equal to 600[deg]
F.
The 30 percent moisture and 600[deg]
F values were selected for the
definitions of dry and green rotary dryers based on values reported in
literature, in the questionnaire responses, and in the emissions test
reports.
Because the differences in dry rotary dryers and green rotary
dryers are operational, we are including monitoring requirements for
dry rotary dryers in today's proposed rule that would ensure that these
dryers operate as dry rotary dryers on a continuous basis. If you own
or operate a dry rotary dryer, you would be required to continuously
monitor, calculate, and record the 24-hour average dryer inlet
temperature and the 24-hour average moisture content of the incoming
wood particles. In addition to monitoring dryer inlet temperature and
furnish moisture, you would be required to take representative grab
samples of wood particles at the dryer inlet once each day of dryer
operation and manually determine the moisture content of the sample on
a dry basis. We have included the grab sampling requirement as a means
of checking the accuracy of the correlation between the moisture
content measured by the continuous moisture sensor and the dry basis
moisture content manually determined using a grab sample. The
continuous moisture sensors measure moisture level as the ratio of the
weight of water to the volume of wood (in the sensing zone). Today's
proposed rule defines moisture content, on a dry basis, as the ratio of
the weight of water to the weight of dry wood, multiplied by 100.
The requirements for the continuous moisture sensor and the grab
sample requirement are specified in Sec. 63.2268(f). We plan to add
performance specifications for the continuous moisture sensor to
include such parameters as the amount of drift allowed. We request
comment on drift and any other performance specifications that should
be added to ensure moisture content is being measured accurately, to
ensure flexibility in the type of continuous moisture sensor that can
be used by a facility, and to ensure compliance and enforceability. We
also plan to add specifications to the grab sample requirements, such
as including the period of time a sample must maintain a constant
weight. We request comment on what this period of time should be and
any other specifications that should be added to ensure accurate and
precise results.
However, if you choose or are required by some other regulatory
action to install a control device designed to reduce VOC or HAP
emissions from a dry rotary dryer, you would be exempted from the
process monitoring requirements for dry rotary dryers in today's
proposed rule.
4. Monitoring and Recordkeeping Requirements for Veneer Redryer Work
Practice Requirements
Veneer dryers that meet the definition of ``veneer redryers'' in
today's proposed rule would not be subject to the proposed control
requirements. Like the differences between green and dry rotary
particle dryers, the differences between veneer dryers and veneer
redryers are operational. Veneer dryers are used to dry green veneer,
and veneer redryers are used to redry veneer that has been previously
dried but requires some additional moisture reduction. Thus, in today's
proposed rule, veneer redryers are defined as veneer dryers with an
inlet veneer moisture content of less than 25 percent (by weight, dry
basis). The 25 percent value was selected as the criterion for
distinguishing between veneer dryers and veneer redryers because 25
percent was the highest reported veneer dryer outlet moisture content
in responses to a survey. If you own or operate a veneer redryer, you
would be required to continuously monitor, calculate, and record the
24-hour average inlet veneer moisture content to show that you
continuously meet the definition of a veneer redryer.
For purposes of today's proposed rule, process units heated by
microwaves or
[[Page 1295]]
radio frequency that are used to remove moisture from veneer are not
considered to be veneer dryers or veneer redryers, although these
process units are typically used to redry veneer. Emissions test data
from the NCASI sampling program indicate that emissions from radio
frequency veneer redryers are minimal compared to the emissions from
veneer dryers heated by conventional means (such as direct firing or
steam heating). Thus, the monitoring requirements for veneer redryers
described above would not apply to process units that dry or redry
veneer using microwaves or radio frequency.
5. Monitoring and Recordkeeping Requirements for Hardwood Veneer Dryer
Work Practice Requirements
Veneer dryers that meet the definition of ``hardwood veneer dryer''
in today's proposed rule would not be subject to the proposed control
requirements. Hardwood veneer dryers are defined in the proposed rule
as veneer dryers that process less than 30 percent softwood species on
an annual volume basis. If you own or operate a hardwood veneer dryer,
you would be required to keep a record (such as a purchase or
production record) of the annual volume percentage of softwood species
processed in the dryer to show that your dryer continuously meets the
definition of a hardwood veneer dryer.
6. Monitoring and Recordkeeping Requirements for Softwood Veneer Dryer
Work Practice Requirements
The proposed work practice requirement for softwood veneer dryers
is to minimize fugitive emissions from the dryer doors and green end.
If you own or operate a softwood veneer dryer, you would be required to
develop a plan for minimizing fugitive emissions from the dryer, and
you would have to keep records to document that you are following your
plan to show continuous compliance with the work practice requirement.
7. Additional Recordkeeping Requirements for Sources Complying With
Emissions Averaging Alternative
If you comply with the emissions averaging provisions, you would be
required to keep records of all information necessary to calculate
debits and credits, including records of your process unit operating
hours, records of total HAP measurements for debit-generating process
units, and records of performance tests for credit-generating process
units. You would also have to keep monitoring records for add-on
control systems used to control credit-generating process units.
I. How Did We Select the Notification and Reporting Requirements?
We selected the proposed notification and reporting requirements
based on requirements in the NESHAP General Provisions (40 CFR part 63,
subpart A) and specific requirements for the PCWP source category.
The notification requirements that we are proposing include Initial
Notifications, notification of performance test, Notification of
Compliance Status, and notification dates. These notification
requirements are based on requirements in Sec. Sec. 63.7(b) and (c),
63.8(e) and (f), 63.9(b) through (h), and 63.10(d)(2).
In addition, we selected notification requirements for the
emissions averaging provisions. If you comply with the emissions
averaging provisions, you would have to submit an EAP to the
Administrator for approval at least 1 year prior to the compliance
date, or 1 year prior to the date you would begin using an emissions
average to comply with the proposed rule, whichever is later. The EAP
would have to be submitted prior to the date you would begin using an
emissions average so that the Administrator would have time to review
and approve or disapprove the plan, and so that you would have time to
ensure that the emissions credits would equal or exceed the emissions
debits.
The proposed reporting requirements that we selected include
semiannual compliance reports, required in Sec. 63.10(e)(3), and
immediate SSM reports, required in Sec. 63.10(d)(5)(ii). If there are
no deviations from the compliance options, operating requirements, or
work practice requirements during the reporting period, then you would
only be required to include a statement that there were no deviations
in your semiannual compliance report. If there are deviations from the
compliance options, operating requirements, or work practice
requirements during a reporting period, then you would be required to
submit the information required in today's proposed rule in your
semiannual compliance report. If you have a startup, shutdown or
malfunction during the reporting period, and you take actions
consistent with your SSM plan (SSMP), then your compliance report would
have to include the information in Sec. 63.10(d)(5)(i). The submittal
date for the compliance report is based on information in Sec.
63.10(e)(3)(v).
If there is a startup, shutdown, or malfunction during the
reporting period, and you take actions inconsistent with the SSMP, then
you would be required to submit an immediate SSM report. The report
would have to include the actions taken for the event and the
information provided in Sec. 63.10(d)(5)(ii). The submittal date for
the immediate SSM report is based on Sec. 63.10(d)(5)(ii). For
facilities complying with the emissions averaging provisions, the
semiannual compliance report would have to contain calculations showing
that the AMR equals or exceeds the RMR in addition to the requirements
outlined above for semiannual compliance reports.
We have included a routine control device maintenance exemption in
today's proposed rule to provide an allowance for control device
downtime associated with routine maintenance such as bakeouts,
washouts, and media replacement. We would like to clarify that there
will also be instances when a control device is offline for correction
of malfunctions such as electrical problems, mechanical problems,
utility supply problems, pre-filer upsets, production malfunctions
(e.g., dryer fires), and weather-related problems. Because these
malfunctions are sudden, infrequent, and not reasonably preventable,
they would be covered under the SSM provisions of today's proposed
rule. In addition, control device downtime due to process upsets that
require shutdown and restarting of equipment would be covered under the
SSM provisions.
IV. Summary of Environmental, Energy and Economic Impacts
A. How Many Facilities Are Impacted by This Proposed Rule?
This proposed rule is expected to affect an estimated 223 existing
major source facilities that manufacture PCWP. The impacted facilities
generally manufacture one or more of the following products: softwood
plywood, softwood veneer, medium density fiberboard (MDF), oriented
strandboard (OSB), particleboard, hardboard, laminated strand lumber,
and laminated veneer lumber. The number of impacted facilities was
determined based on the estimated potential to emit (i.e., uncontrolled
HAP emissions) from each facility and whether or not the facility
already operates control systems necessary to meet the proposed
standards. 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
[[Page 1296]]
subject to today's proposed rule. Of the estimated 223 facilities
affected by this proposed rule, an estimated 166 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 units subject to the compliance options, or are expected to
comply with work practice requirements only.
The environmental and cost impacts presented in this preamble
represent the estimated impacts for the 223 facilities. The impact
estimates were based on the use of RTOs (or in some cases a combination
WESP and RTO) because RTOs are the most prevalent HAP emissions control
technology used in the PCWP industry. However, technologies other than
RTOs could be used to comply with today's proposed standards. For a
facility that we believe already achieves the emissions reductions
required by today's proposed rule, only recordkeeping cost impacts were
estimated.
The number of affected facilities presented above (223) does not
include major source facilities with lumber kilns that are not
otherwise PCWP facilities. Some of these facilities may be major
sources of HAP emissions due to lumber drying operations. Because
today's proposed rule contains no control requirements for lumber
kilns, we expect there to be no cost, environmental, or energy impacts
associated with today's proposed rule for these facilities.
B. What Are the Air Quality Impacts?
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
control. We estimate that the proposed standards would reduce total HAP
emissions from the PCWP source category by about 9,700 Mg/yr (11,000
tons/yr). In addition, we estimate that the proposed standards would
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).
In addition to reducing emissions of HAP and VOC, the proposed
standards would 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 (PM₁₀). We estimate
that the proposed standards would reduce CO emissions by about 10,000
Mg/yr (11,000 tons/yr). We estimate that the proposed standards would
reduce PM₁₀ emissions by about 11,000 Mg/yr (13,000 tons/
yr).
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 RTOs would be
about 4,300 Mg/yr (4,800 tons/yr). This estimated increase in
NO_X emissions may be an overestimate because some plants may
select control technologies other than RTOs to comply with the proposed
standards.
Indirect air impacts of today's proposed rule would result from
increased electricity usage associated with operation of control
devices. Assuming that plants will purchase electricity from a power
plant, we estimate that the proposed standards may increase secondary
emissions of criteria pollutants such as PM₁₀, sulfur
dioxide (SO₂), NO_X, and CO from power plants by
about 6,200 Mg/yr (6,900 tons/yr).
C. What Are the Water Quality Impacts?
Wastewater is produced from WESP blowdown, washing out of RTOs, and
biofilters. We based all of our impact estimates on the use of RTOs
(with or without a WESP upstream depending on the process unit). We
estimate that the wastewater generated from WESP blowdown and RTO
washouts would increase by about 43 thousand cubic meters per year
(m3/yr)(11 million gal/yr) as a result of today's proposed
rule. Facilities would likely dispose of this wastewater by sending it
to a municipal treatment facility, evaporating it onsite, incinerating
it in an onsite boiler, reusing it onsite (e.g., in log vats or resin
mix), or hauling it offsite for spray irrigation.
D. What Are the Solid Waste Impacts?
Solid waste is produced in the form of solids from WESPs and by RTO
or RCO media replacement. We estimate that 4,500 Mg/yr (5,000 tons/yr)
of solid waste would be generated as a result of today's proposed rule.
This solid material may be disposed of in a landfill or used for other
purposes. 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 beneficial reuse for wet control device solids (such as
giving them away to local farmers for soil amendment).
E. What Are the Energy Impacts?
The overall energy demand (i.e., electricity and natural gas) is
expected to increase by about 4.3 million gigajoules per year (GJ/yr)
(4.1 trillion British thermal units per year (Btu/yr)) nationwide under
the proposed standards. The estimated increase in the energy demand is
based on the electricity requirements associated with RTOs and WESPs
and the fuel requirements associated with RTOs. Electricity
requirements are expected to increase by about 718 gigawatt hours per
year (Gwh/yr) under the proposed standards. Natural gas requirements
are expected to increase by about 45 million m3/yr (1.6
billion cubic feet per year (ft3/yr)) under the proposed
standards.
F. What Are the Cost Impacts?
The cost impacts estimated for today's proposed 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 estimates 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 accurately predict which facilities would use emissions
averaging or production-based emissions limits or install less
expensive add-on control devices, 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
advantage of available cost saving opportunities.
The high-end estimated total capital costs of today's proposed rule
are $479 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 performance tests. Permanent total
enclosure costs are also included for reconstituted wood products
presses.
The high-end estimated annualized costs of the proposed standards
are $142 million. The annualized costs 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 savings and increased recordkeeping and reporting
costs associated with today's proposed emissions averaging alternative
standard are not accounted for in either the capital or annualized cost
estimates.
G. Can We Achieve the Goals of the Proposed Rule in a Less Costly
Manner?
We have made every effort in developing this proposal to minimize
the cost to the regulated community and allow maximum flexibility in
compliance options consistent with our statutory obligations. We
recognize, however, that the proposal may still
[[Page 1297]]
require some facilities to take costly steps to further control
emissions even though those 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,
specifically soliciting comment on whether there are further ways to
structure the proposed 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.
Representatives of the plywood and composite wood products industry
provided EPA with descriptions of three mechanisms that they believed
could be used to implement more cost-effective reductions in risk. The
docket for today's proposed rule contains ``white papers'' prepared by
industry that outline their proposed approaches (see docket number A-
98-44, Item i II-D-525). These approaches could be effective in
focusing regulatory controls on facilities that pose significant risks
and avoiding the imposition of high costs on facilities that pose
little risk to public health or the environment, and we are seeking
public comment on the utility of each of these approaches with respect
to this proposed rule.
One of the approaches, an applicability cutoff for threshold
pollutants, would be implemented under the authority of CAA section
112(d)(4); the second approach, subcategorization and delisting, would
be implemented under the authority of CAA section 112(c)(1) and (c)(9);
and, the third approach, would involve the use of a concentration-based
applicability threshold. We are seeking comment on whether these
approaches are legally justified and, if so, we ask for information
that could be used to support such approaches.
The maximum achievable control technology, or MACT, program
outlined in CAA section 112(d) is intended to reduce emissions of HAP
through the application of MACT to major sources of toxic air
pollutants. Section 112(c)(9) is intended to allow EPA to avoid setting
MACT standards for categories or subcategories of sources that pose
less than a specified level of risk to public health and the
environment. The EPA requests comment on whether the approaches
described here appropriately rely on the provisions of CAA section 112.
While the approaches focus on assessing the inhalation exposures of HAP
emitted by a source, EPA specifically requests comment on the
appropriateness and necessity of extending these approaches to account
for non-inhalation exposures or to account for adverse environmental
impacts. In addition to the specific requests for comment noted in this
section, we are also interested in any information or comment
concerning technical limitations, environmental and cost impacts,
compliance assurance, legal rationale, and implementation relevant to
the identified approaches. We also request comment on appropriate
practicable and verifiable methods to ensure that sources' emissions
remain below levels that protect public health and the environment. We
will evaluate all comments before determining whether either of the
three approaches will be included in the final rule.
1. Industry Emissions and Potential Health Effects
For the PCWP source category, six HAP make up about 96 percent of
the total organic HAP (i.e., does not include metals that are HAP).
Those six HAP are methanol, formaldehyde, acetaldehyde, phenol,
acrolein, and propionaldehyde. All HAP are not emitted by all sources.
However, all of the 223 major sources emit all six of the predominant
HAP, with a few exceptions. Some engineered wood plants do not emit
phenol; these plants are major sources but would not be affected by the
proposed rule because they have no equipment subject to the proposed
rule. Also, several particleboard plants do not emit propionaldehyde;
these particleboard plants have dry rotary particle dryers (as opposed
to green particle dryers), which are not subject to control
requirements. (For more information, see section III.C.3).
In accordance with section 112(k), EPA developed a list of 33 HAP
which present the greatest threat to public health in the largest
number of urban areas. Some of the PCWP HAP are included on this list
for the EPA's Urban Air Toxics Program. These HAP include three of the
six most predominant PCWP HAP (acetaldehyde, acrolein, and
formaldehyde). Additional urban HAP that may be emitted by PCWP
facilities include benzene, carbon tetrachloride, chloroform, and
methylene chloride.
In November 1998, EPA published ``A Multimedia Strategy for
Priority Persistent, Bioaccumulative, and Toxic (PBT) Pollutants.'' The
organic HAP emitted by PCWP facilities do not appear on the published
list of PBT compounds referenced in the EPA strategy.
To estimate the potential baseline risks posed by the PCWP source
category and the potential impact of applicability cutoffs, EPA
performed a ``rough'' risk assessment for 185 of the 223 facilities in
the PCWP source category. The HAP included in the assessment were
acetaldehyde, acrolein, benzene, formaldehyde, manganese, methanol,
methylene chloride, and phenol. Of these HAP, four are presently not
considered to have thresholds for cancer effects: acetaldehyde,
benzene, formaldehyde, and methylene chloride.
Of the 185 facilities assessed, 148 facilities were found to pose
cancer risks equal to or greater than one in one million to their
surrounding population. Forty-six facilities were predicted to pose
cancer risks of one in 100,000 or greater, and two PCWP facilities were
found to pose cancer risks equal to or greater than one in 10,000.
2. Applicability Cutoffs for Threshold Pollutants Under Section
112(d)(4) of the CAA
The first approach is an ``applicability cutoff'' for threshold
pollutants that is based on EPA's authority under CAA section 112(d)(4)
to establish standards for HAP which are ``threshold pollutants.'' A
``threshold pollutant'' is one for which there is a concentration or
dose below which adverse effects are not expected to occur over a
lifetime of exposure. For such pollutants, section 112(d)(4) allows EPA
to consider the threshold level, with an ample margin of safety, when
establishing emission standards. Specifically, section 112(d)(4) allows
EPA to establish emission standards that are not based upon the MACT
specified under section 112(d)(2) for pollutants for which a health
threshold has been established. Such standards may be less stringent
than MACT. Historically, EPA has interpreted section 112(d)(4) to allow
categories of sources that emit only threshold pollutants to avoid
further regulation if those emissions result in ambient levels that do
not exceed the threshold, with an ample margin of safety.\1\
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\1\ See 63 FR 18754, 18765-66 (April 15, 1998) (Pulp and Paper
Combustion Sources Proposed NESHAP)
---------------------------------------------------------------------------
A different interpretation would allow us to exempt individual
facilities within a source category that meet the section 112(d)(4)
requirements. There are three potential scenarios under this
interpretation of the section 112(d)(4) provision. One scenario would
allow an exemption for individual facilities that emit only threshold
pollutants and can demonstrate that their emissions of
[[Page 1298]]
threshold pollutants would not result in air concentrations above the
threshold levels, with an ample margin of safety, even if the category
is otherwise subject to MACT. A second scenario would allow the section
112(d)(4) provision to be applied to both threshold and non-threshold
pollutants, using the one in a million cancer risk level for
decisionmaking for non-threshold pollutants. A third scenario would
allow a section 112(d)(4) exemption at a facility that emits both
threshold and non-threshold pollutants. For those emission points where
only threshold pollutants are emitted and where emissions of the
threshold pollutants would not result in air concentrations above the
threshold levels, with an ample margin of safety, those emission points
could be exempt from the MACT standard. The MACT standard would still
apply to non-threshold emissions from other emission points at the
source. For this third scenario, emission points that emit a
combination of threshold and non-threshold pollutants that are co-
controlled by MACT would still be subject to the MACT level of control.
However, any threshold HAP eligible for exemption under section
112(d)(4) that are controlled by control devices different from those
controlling non-threshold HAP would be able to use the exemption, and
the facility would still be subject to the provisions of the standard
that control non-threshold pollutants or that control both threshold
and non-threshold pollutants.
Estimation of hazard quotients and hazard indices. Under the
section 112(d)(4) approach, EPA would have to determine that emissions
of each of the threshold pollutants emitted by PCWP sources at the
facility do not result in exposures which exceed the threshold levels,
with an ample margin of safety. The common approach for evaluating the
potential hazard of a threshold air pollutant is to calculate a
``hazard quotient'' by dividing the pollutant's inhalation exposure
concentration (often assumed to be equivalent to its estimated
concentration in air at a location where people could be exposed) by
the pollutant's inhalation Reference Concentration (RfC). An RfC is
defined as an estimate (with uncertainty spanning perhaps an order of
magnitude) of a continuous inhalation exposure that, over a lifetime,
likely would not result in the occurrence of adverse health effects in
humans, including sensitive individuals. The EPA typically establishes
an RfC by applying uncertainty factors to the critical toxic effect
derived from the lowest- or no-observed-adverse-effect level of a
pollutant.\2\ A hazard quotient less than one means that the exposure
concentration of the pollutant is less than the RfC and, therefore,
presumed to be without appreciable risk of adverse health effects. A
hazard quotient greater than one means that the exposure concentration
of the pollutant is greater than the RfC. Further, EPA guidance for
assessing exposures to mixtures of threshold pollutants recommends
calculating a ``hazard index'' by summing the individual hazard
quotients for those pollutants in the mixture that affect the same
target organ or system by the same mechanism.\3\ Hazard index (HI)
values would be interpreted similarly to hazard quotients; values below
one would generally be considered to be without appreciable risk of
adverse health effects, and values above one would generally be cause
for concern.
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\2\ ``Methods for Derivation of Inhalation Reference
Concentrations and Applications of Inhalation Dosimetry.'' EPA-600/
8-90-066F, Office of Research and Development, USEPA, October 1994.
\3\ ``Supplementary Guidance for Conducting Health Risk
Assessment of Chemical Mixtures. Risk Assessment Forum Technical
Panel,'' EPA/630/R-00/002. USEPA, August 2000. http://www.epa.gov/
nceawww1/pdfs/chem_mix/chem_mix_08_2001.pdf.
---------------------------------------------------------------------------
For the determinations discussed herein, EPA would generally plan
to use RfC values contained in EPA's toxicology database, the
Integrated Risk Information System (IRIS). When a pollutant does not
have an approved RfC in IRIS, or when a pollutant is a carcinogen, EPA
would have to determine whether a threshold exists based upon the
availability of specific data on the pollutant's mode or mechanism of
action, potentially using a health threshold value from an alternative
source, such as the Agency for Toxic Substances and Disease Registry
(ATSDR) or the California Environmental Protection Agency (CalEPA).
Table 2 of this preamble provides RfC's, as well as unit risk
estimates, for the HAP emitted by facilities in the PCWP source
category. A unit risk estimate is defined as the upper-bound excess
lifetime cancer risk estimated to result from continuous exposure to an
agent at a concentration of 1 [mu]g/m\3\ in air.
Table 2.--Dose-Response Assessment Values for Some HAP Reported Emitted by the Plywood and Composite Wood
Products Source Category a, b
----------------------------------------------------------------------------------------------------------------
Reference concentration c (mg/ Unit risk estimate d (1/(ug/
Chemical name CAS No. m3) m3))
----------------------------------------------------------------------------------------------------------------
Acetaldehyde...................... 75-07-0 9.0E-03 2.2E-06
(IRIS) (IRIS)
Acrolein.......................... 107-02-8 2.0E-05
(IRIS)
Benzene........................... 71-43-2 6.0E-02 7.8E-06
(CAL) (IRIS)
Carbon tetrachloride e............ 56-23-5 4.0E-02 1.5E-05
(CAL) (IRIS)
Chloroform e...................... 67-66-3 9.8E-02
(ATSDR)
Formaldehyde...................... 50-00-0 9.8E-03 1.3E-05
(ATSDR) (IRIS)
Manganese compounds............... 7439-96-5 5.0E-05
(IRIS)
Methanol.......................... 67-56-1 4.0E+00
(CAL)
Methyl ethyl ketone............... 78-93-3 1.0E+00
(IRIS)
Methylene chloride................ 75-09-2 1.0E+00 4.7E-07
(ATSDR) (IRIS)
[[Page 1299]]

Phenol............................ 108-95-2 2.0E-01
(CAL)
----------------------------------------------------------------------------------------------------------------
a Propionaldehyde, a HAP emitted by the PCWP source category, is not included in Table 2 because there are no
dose-response values for it.
b The table includes many, but not all, of the HAP emitted by the PCWP source category. The following additional
HAP have been detected at more than one PCWP facility: cumene, methyl isobutyl ketone (MIBK), styrene,
toluene, m,p-xylene, o-xylene, methylene diphenyl diisocyanate (MDI), chloromethane, and ethyl benzene. In
addition, the following HAP have been detected at only one PCWP facility: acetophenone, biphenyl, bis-(2-
ethylhexyl phthalate), bromomethane, carbon disulfide, di-n-butyl phthalate, ethyl benzene, hydroquinone, n-
hexane, 1,1,1-trichloroethane, 4-methyl-2-pentanone, chloroethane, m,p-cresol, and o-cresol. Other HAP,
including metal compounds (in addition to manganese compounds) may be emitted by facilities in the PCWP source
category.
c Reference Concentration: An estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous
inhalation exposure to the human population (including sensitive subgroups which include children, asthmatics
and the elderly) that is likely to be without an appreciable risk of deleterious effects during a lifetime. It
can be derived from various types of human or animal data, with uncertainty factors generally applied to
reflect limitations of the data used.
d Unit Risk Estimate: The upper-bound excess lifetime cancer risk estimated to result from continuous exposure
to an agent at a concentration of 1 [mu]g/m\3\ in air. The interpretation of the Unit Risk Estimate would be
as follows: if the Unit Risk Estimate = 1.5 x 10-6 per [mu]g/m\3\, 1.5 excess tumors are expected to develop
per 1,000,000 people if exposed daily for a lifetime to 1 [mu]g of the chemical in 1 cubic meter of air. Unit
Risk Estimates are considered upper bound estimates, meaning they represent a plausible upper limit to the
true value. (Note that this is usually not a true statistical confidence limit.) The true risk is likely to be
less, but could be greater.
e This HAP was detected at only one PCWP facility.
Sources:
IRIS = EPA Integrated Risk Information System
(http://www.epa.gov/iris/subst/index.html).
ATSDR = U.S. Agency for Toxic Substances and Disease Registry
(http://www.atsdr.cdc.gov/mrls.html ).
CAL = California Office of Environmental Health Hazard Assessment
(http://www.oehha.ca.gov/air/hot_spots/index.html ).
HEAST = EPA Health Effects Assessment Summary Tables (iPB(=97-921199, July 1997).
To establish an applicability cutoff under section 112(d)(4), EPA
would need to define ambient air exposure concentration limits for any
threshold pollutants involved. There are several factors to consider
when establishing such concentrations. First, we would need to ensure
that the concentrations that would be established would protect public
health with an ample margin of safety. As discussed above, the approach
EPA commonly uses when evaluating the potential hazard of a threshold
air pollutant is to calculate the pollutant's hazard quotient, which is
the exposure concentration divided by the RfC.
The EPA's ``Supplementary Guidance for Conducting Health Risk
Assessment of Chemical Mixtures'' suggests that the noncancer health
effects associated with a mixture of pollutants ideally are assessed by
considering the pollutants' common mechanisms of toxicity.\4\ The
guidance also suggests, however, that when exposures to mixtures of
pollutants are being evaluated, the risk assessor may calculate an HI.
The recommended method is to calculate multiple hazard indices for each
exposure route of interest and for a single specific toxic effect or
toxicity to a single target organ. The default approach recommended by
the guidance is to sum the hazard quotients for those pollutants that
induce the same toxic effect or affect the same target organ. A mixture
is then assessed by several HI, each representing one toxic effect or
target organ. The guidance notes that the pollutants included in the HI
calculation are any pollutants that show the effect being assessed,
regardless of the critical effect upon which the RfC is based. The
guidance cautions that if the target organ or toxic effect for which
the HI is calculated is different from the RfC's critical effect, then
the RfC for that chemical can be an overestimate, that is, the
resultant HI potentially may be overprotective. Conversely, since the
calculation of an HI does not account for the fact that the potency of
a mixture of HAP can be more potent than the sum of the individual HAP
potencies, an HI may potentially be underprotective in some situations.
---------------------------------------------------------------------------
\4\ Ibid.
---------------------------------------------------------------------------
Options for establishing a hazard index limit. One consideration in
establishing a hazard index limit is whether the analysis considers the
total ambient air concentrations of all the emitted HAP to which the
public is exposed.\5\ There are at least several options for
establishing a hazard index limit for the section 112(d)(4) analysis
that reflect, to varying degrees, public exposure.
---------------------------------------------------------------------------
\5\ Senate Debate on Conference Report (October 27, 1990),
reprinted in ``A Legislative History of the Clean Air Act Amendments
of 1990,'' Comm. Print S. Prt. 103-38 (1993) (``Legis. Hist.'' at
868.
---------------------------------------------------------------------------
One option is to allow the hazard index posed by all threshold HAP
emitted from PCWP sources at the facility to be no greater than one.
This approach is protective if no additional threshold HAP exposures
would be anticipated from other sources in the vicinity of the facility
or through other routes of exposure (e.g., through ingestion).
A second option is to adopt a ``default percentage'' approach,
whereby the hazard index limit of the HAP emitted by the facility is
set at some percentage of one (e.g., 20 percent or 0.2). This approach
recognizes the fact that the facility in question is only one of many
sources of threshold HAP to which people are typically exposed every
day. Because noncancer risk assessment is predicated on total exposure
or dose, and because risk assessments focus only on an individual
source, establishing a hazard index limit of 0.2 would account for an
assumption that 20 percent of an individual's total exposure is from
that individual source. For the purposes of this discussion, we will
call all sources of HAP, other than the facility in question,
``background'' sources. If the facility is allowed to emit HAP such
that its own impacts could result in HI values of one, total exposures
to threshold HAP in the vicinity of the facility could be substantially
greater than one due to background sources, and this would not be
protective of public health since only HI values below one are
considered to be without appreciable risk of adverse health effects.
Thus, setting the hazard index limit for the facility at some default
percentage of one will provide a buffer which would help to ensure that
total exposures to threshold HAP near the facility (i.e., in
combination with exposures due to background sources) will generally
not exceed one and can
[[Page 1300]]
generally be considered to be without appreciable risk of adverse
health effects.
The EPA requests comment on using the ``default percentage''
approach and on setting the default hazard index limit at 0.2. The EPA
is also requesting comment on whether an alternative HI limit, in some
multiple of one, would be a more appropriate applicability cutoff.
A third option is to use available data (from scientific literature
or EPA studies, for example) to determine background concentrations of
HAP, possibly on a national or regional basis. These data would be used
to estimate the exposures to HAP from non-PCWP sources in the vicinity
of an individual facility. For example, the EPA's National-Scale Air
Toxics Assessment (NATA) \6\ and ATSDR's Toxicological Profiles \7\
contain information about background concentrations of some HAP in the
atmosphere and other media. The combined exposures from PCWP sources
and from other sources (as determined from the literature or studies)
would then not be allowed to exceed a hazard index limit of one. The
EPA requests comment on the appropriateness of setting the hazard index
limit at one for such an analysis.
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\6\ See http://www.epa.gov/ttn/atw/nata.
\7\ See http://www.atsdr.cdc.gov/toxpro2.html .
---------------------------------------------------------------------------
A fourth option is to allow facilities to estimate or measure their
own facility-specific background HAP concentrations for use in their
analysis. With regard to the third and fourth options, the EPA requests
comment on how these analyses could be structured. Specifically, EPA
requests comment on how the analyses should take into account
background exposure levels from air, water, food and soil encountered
by the individuals exposed to PCWP emissions. In addition, we request
comment on how such analyses should account for potential increases in
exposures due to the use of a new or the increased use of a previously
emitted HAP, or the effect of other nearby sources that release HAP.
The EPA requests comment on the feasibility and scientific validity
of each of these or other approaches. Finally, EPA requests comment on
how we should implement the section 112(d)(4) applicability cutoffs,
including appropriate mechanisms for applying cutoffs to individual
facilities. For example, would the title V permit process provide an
appropriate mechanism?
Tiered analytical approach for predicting exposure. Establishing
that a facility meets the cutoffs under section 112(d)(4) will
necessarily involve combining estimates of pollutant emissions with air
dispersion modeling to predict exposures. The EPA envisions that we
would 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 pollutant concentrations in air and
estimates of risk.
As a first tier of analysis, EPA could develop a series 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
easily determine whether the emissions from their sources might cause a
hazard index limit to be exceeded.
A facility that does not pass this initial conservative screening
analysis could implement increasingly more site-specific but more
resource-intensive tiers of analysis using EPA-approved modeling
procedures in an attempt to demonstrate that exposure to emissions from
the facility does not exceed the hazard index limit. The EPA's guidance
could provide the basis for conducting such a tiered analysis.\8\
---------------------------------------------------------------------------
\8\ ``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.
---------------------------------------------------------------------------
The EPA requests comment on methods for constructing and
implementing a tiered analytical approach for determining applicability
of the section 112(d)(4) criterion to specific PCWP sources. It is also
possible that ambient monitoring data could be used to supplement or
supplant the tiered modeling approach described above. It is envisioned
that the appropriate monitoring to support such a determination could
be extensive. The EPA requests comment on the appropriate use of
monitoring in the determinations described above.
Accounting for dose-response relationships. In the past, EPA
routinely treated carcinogens as non-threshold pollutants. The EPA
recognizes that advances in risk assessment science and policy may
affect the way EPA differentiates between threshold and non-threshold
HAP. The EPA's Draft Revised Guidelines for Carcinogen Risk Assessment
\9\ suggest that carcinogens be assigned non-linear dose-response
relationships where data warrant. Moreover, it is possible that dose-
response curves for some pollutants may reach zero risk at a dose
greater than zero, creating a threshold for carcinogenic effects. It is
possible that future evaluations of the carcinogens emitted by this
source category would determine that one or more of the carcinogens in
the category is a threshold carcinogen or is a carcinogen that exhibits
a non-linear dose-response relationship but does not have a threshold.
---------------------------------------------------------------------------
\9\ ``Draft Revised Guidelines for Carcinogen Risk Assessment.''
NCEA-F-0644. USEPA, Risk Assessment Forum, July 1999. pp 3-9ff.
http://www.epa.gov/ncea/raf/pdfs/cancer_gls.pdf
The dose-response assessments for formaldehyde and acetaldehyde are
currently undergoing revision by the EPA. As part of this revision
effort, EPA is evaluating formaldehyde and acetaldehyde as potential
non-linear carcinogens. The revised dose-response assessments will be
subject to review by the EPA Science Advisory Board, followed by full
consensus review, before adoption into the EPA IRIS. At this time, EPA
estimates that the consensus review will be completed by the end of
2003. The revision of the dose-response assessments could affect the
potency factors of these HAP, as well as their status as threshold or
non-threshold pollutants. At this time, the outcome is not known. In
addition to the current reassessment by EPA, there have been several
reassessments of the toxicity and carcinogenicity of formaldehyde in
recent years, including work by the World Health Organization and the
Canadian Ministry of Health.
The EPA requests comment on how we should consider the state of the
science as it relates to the treatment of threshold pollutants when
making determinations under section 112(d)(4). In addition, EPA
requests comment on whether there is a level of emissions of a non-
threshold carcinogenic HAP (e.g., benzene, methylene chloride) at which
it would be appropriate to allow a facility to use the approaches
discussed in this section.
Risk assessment results. The results of the human health risk
assessments described below are based on approaches for quantifying
exposure, risk, and cancer incidence that carry significant
assumptions, uncertainties, and limitations. For example, in conducting
these types of analyses, there are typically many uncertainties
regarding dose-response functions, levels of exposure, exposed
populations, air quality modeling applications, emission levels, and
control effectiveness. Because the estimates derived from the various
scoping approaches are necessarily rough, we are concerned that they
not convey a
[[Page 1301]]
false sense of precision. It is expected that any point estimate of
risk reduction or benefits generated by these approaches should be
considered as part of a range of potential estimates.
If the final rule is implemented as proposed at all PCWP
facilities, 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 one in a million would be reduced from
about 900,000 to 150,000. In addition, the number of people exposed to
HI values equal to or greater than one was estimated to be reduced from
about 270,000 to about 30,000, and the number of people 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.)
Based on the results of this rough assessment, if the section
112(d)(4) approach is applied only to threshold pollutants, EPA
estimates that few, if any, of the 223 facilities in the plywood source
category could obtain an exemption from the rule, since it appears that
all or nearly all facilities emit some amount of one or more non-
threshold pollutants. If the revised dose-response assessments for
formaldehyde and acetaldehyde determine that they are threshold
carcinogens, these estimates could increase. This application of the
section 112(d)(4) approach is estimated to produce minimal potential
cost savings.
The second scenario under the section 112(d)(4) provision would
apply to both threshold and non-threshold pollutants. If this
interpretation is selected, EPA estimates that, if a HI limit of one
and a cancer risk level of 10-6 were used, as many as 33 of
the 223 facilities in the source category may be exempt from the
proposed rule and that, if a HI limit of 0.2 and a cancer risk level of
10-6 were used, as many as 26 of the 223 facilities may be
exempt. The EPA estimates that the cost of the rule as proposed would
be approximately $142 million per year, resulting in an annual cost
savings of about $9 million per year (for a HI limit of one) or about
$7 million per year (for a HI limit of 0.2) (as compared to
establishing a MACT standard for all plants in the industry).
The EPA does not expect the third scenario, which would allow
emission point exemptions, to be applicable for the PCWP source
category because mixtures of threshold and non-threshold pollutants are
co-emitted, and the same emission controls would apply to both. The
risk estimates from this rough assessment are based on typical facility
configurations (i.e., model plants) and, as such, they are subject to
significant uncertainties, such that the actual risks at any one
facility could be significantly higher or lower. Therefore, while these
risk estimates assist in providing a broad picture of impacts across
the source category, they should not be the basis for an exemption from
the requirements of the proposed rule. Rather, facility-specific risks
would require site-specific data and a more refined analysis.
For either of the first two approaches described above, the actual
number of facilities that would qualify for an exemption would depend
upon site-specific risk assessments and the specified hazard index
limit. If the section 112(d)(4) approach were adopted, the rulemaking
would likely indicate that the requirements of the rule do not apply to
any source that demonstrates, based on a tiered approach that includes
EPA-approved modeling of the affected source's emissions, that the
anticipated HAP exposures do not exceed the specified hazard index
limit.
3. Subcategory Delisting Under Section 112(c)(9)(B) of the CAA
The EPA is authorized to establish categories and subcategories of
sources, as appropriate, pursuant to CAA section 112(c)(1), in order to
facilitate the development 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 cause 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 adverse noncancer health effects, that ``* * *
emissions from no source in the category or subcategory * * * exceed a
level which is adequate to protect public health with an ample margin
of safety''; and (3) in the case of pollutants 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), EPA
is considering whether it would be possible to establish a subcategory
of facilities within the larger PCWP category that would meet the risk-
based criteria for delisting. Such criteria would likely include the
same requirements as described previously for the second scenario under
the section 112(d)(4) approach, whereby a facility would be in the low-
risk subcategory if its emissions of threshold pollutants do not result
in exposures which exceed the HI limits and if its emissions of non-
threshold pollutants do not result in exposures which exceed a cancer
risk level of 10-6. The EPA requests comment on what an
appropriate HI limit would be for a determination that a facility be
included in the low-risk subcategory.
Since each facility in such a subcategory would be a low-risk
facility (i.e., if each met these criteria), the subcategory could be
delisted in accordance with section 112(c)(9), thereby limiting the
costs and impacts of the proposed MACT rule to only those facilities
that do not qualify for subcategorization and delisting. The EPA
estimates that the maximum potential effect of this approach would be
the same as that of applying the section 112(d)(4) approach that allows
exemption of facilities emitting threshold and non-threshold pollutants
if exemption criteria are met (i.e., as many as 33 of the 223
facilities may be exempt under this approach, if an HI limit of one and
a cancer risk level of 10-6 are used; or, as many as 26 of
the 223 may be exempt if an HI limit of 0.2 and a cancer risk level of
10-6 are used).
Facilities seeking to be included in the delisted subcategory would
be responsible for providing all data required 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. The EPA
solicits comment on implementing a risk-based approach for establishing
subcategories of PCWP facilities.
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 predict exposures.
The EPA envisions that we would employ the same tiered analytical
approach described earlier in the section 112(d)(4) discussion for
these determinations.
One concern that EPA has with respect to this section 112(c)(9)
approach is the effect that it could have on the MACT floors. If many
of the facilities in the low-risk subcategory are well-controlled, that
could make the
[[Page 1302]]
MACT floor less stringent for the remaining facilities. One approach
that has been suggested to mitigate this effect would be to establish
the MACT floor now, based on controls in place for the entire category,
and to allow facilities to become part of the low-risk subcategory in
the future, after the MACT standard is established. This would allow
low risk facilities to use the section 112(c)(9) exemption without
affecting the MACT floor calculation. The EPA requests comment on this
suggested approach.
Another approach under section 112(c)(9) would be to define a
subcategory of facilities within the PCWP source category based upon
technological differences, such as differences in production rate,
emission vent flow rates, overall facility size, emissions
characteristics, processes, or air pollution control device viability.
The EPA requests comment on how we might establish PCWP subcategories
based on these, or other, source characteristics. If it could then be
determined that each source in this technologically-defined subcategory
presents a low risk to the surrounding community, the subcategory could
then be delisted in accordance with section 112(c)(9). The EPA requests
comment on the concept of identifying technologically-based
subcategories that may include only low-risk facilities within the PCWP
source category.
If this section 112(c)(9) approach were adopted, the rulemaking
would likely indicate that the rule does not apply to any source that
demonstrates that it belongs in a subcategory which has been delisted
under section 112(c)(9).
Consideration of criteria pollutants. Finally, EPA projects that
adoption of the MACT floor level of controls would result in increases
in NO_X emissions. This pollutant is a precursor in the
formation of fine PM, which has been associated with a variety of
adverse health effects (including premature mortality, chronic
bronchitis, and increased frequency of asthma attacks). The EPA
requests comment on the extent to which consideration should be given
to the adverse effects of the possible increase in NO_X
emissions from applying MACT technology, in the context of implementing
our authority under section 112(c)(9) or other exemptions.
H. What Are the Economic Impacts?
The economic impact analysis shows that the expected price
increases for affected output would range from only 0.7 to 2.5 percent
as a result of the proposed NESHAP for PCWP manufacturers. The expected
change in production of affected output is a reduction of 0.1 to 0.7
percent for PCWP manufacturers as a result of the proposed rule. There
is only one plant closure expected out of the 223 facilities affected
by the proposed rule. It should be noted that the baseline economic
condition of the facility predicted to close rather than incur the
costs of compliance with the proposed rule affects the closure estimate
provided by the economic model, and that the facility predicted to
close appears to have low profitability levels currently. Therefore, it
is likely that there is no adverse impact expected to occur for those
industries that produce output affected by the proposed rule, such as
hardboard, softwood plywood and veneer, engineered wood products, and
other wood composites.
I. What Are the Social Costs and Benefits?
Our assessment of costs and benefits of the proposed rule is
detailed in the ``Regulatory Impact Analysis for the Proposed Plywood
and Composite Wood Products MACT.'' The Regulatory Impact Analysis
(RIA) is located in Docket number A-98-44.
It is estimated that 3 years after implementation of the proposed
requirements, HAP would be reduced by 9,700 Mg/yr (11,000 tons/yr) due
to reductions in formaldehyde, acetaldehyde, acrolein, methanol, phenol
and several other HAP from existing PCWP emission sources. The health
effects associated with these HAP are discussed earlier in this
preamble.
At this time, we are unable to provide a comprehensive
quantification and monetization of the HAP-related benefits of this
proposal. 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 level of control on this source category.
Our analysis suggests that imposition of the MACT level of control
would reduce cancer cases by zero to less than one case per year, on
average, starting some years after implementation of the standards. We
present these results in the RIA. This risk reduction estimate is
uncertain 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 control technologies used to reduce the level of HAP emitted
from PCWP sources are also expected to reduce emissions of CO,
PM₁₀, and VOC. It is estimated that CO emission reductions
total approximately 10,000 Mg/yr (11,000 tons/yr), PM₁₀
emission reductions total approximately 11,000 Mg/yr (13,000 tons/yr),
and VOC emission reductions (approximated as THC) total approximately
25,000 Mg/yr (27,000 tons/yr). These estimated reductions occur from
existing sources in operation 3 years after the implementation of the
requirements of the proposed rule and are expected to continue
throughout the life of the sources. Human health effects associated
with exposure to CO include cardiovascular system and central nervous
system (CNS) effects, which 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. The VOC emissions reductions may lead to some
reduction in ozone concentrations in areas in which the affected
sources are located. There are both human health and welfare effects
that result from exposure to ozone, and these effects are listed in
Table 3 of this 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 monetary estimate for the benefits associated with the changes in
ozone concentrations that result from the VOC emission reductions since
we are unable to do the necessary air quality modeling to estimate the
ozone concentration changes. For PM₁₀, we did not provide a
monetary estimate for the benefits associated 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
the proposed 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 PM concentrations, which could lead to
impacts on human health and welfare as listed in Table 3. The potential
impacts associated with increases in ambient PM and ozone due to these
emission increases are discussed in the RIA. In addition to potential
NO_X increases at affected sources, the proposed rule may
also result in additional electricity use at affected sources due to
application of controls. These potential increases in electricity use
may increase emissions of SO₂ and NO_X from
electricity generating utilities. As such, the proposed rule may result
in additional health impacts from increased ambient PM and ozone from
these increased
[[Page 1303]]
utility emissions. We did not quantify or monetize these impacts.
Every benefit-cost analysis examining the potential effects of a
change in environmental protection requirements is limited to some
extent by data gaps, limitations in model capabilities (such as
geographic coverage), and uncertainties in the underlying scientific
and economic studies used to configure the benefit and cost models.
Deficiencies in the scientific literature often result in the inability
to estimate changes in health and environmental effects, such as
potential increases in premature mortality associated with increased
exposure to carbon monoxide. Deficiencies in the economics literature
often result in the inability to assign economic values even to those
health and environmental outcomes which can be quantified. These
general uncertainties in the underlying scientific and economics
literatures are discussed in detail in the RIA and its supporting
documents and references.
A full listing of the benefit categories that could not be
quantified or monetized in our analysis are provided in Table 3 of this
preamble. A full appreciation of the overall economic consequences of
the proposed PCWP standards requires consideration of all benefits and
costs expected to result from today's proposed rule, not just those
benefits and costs which could be expressed here in dollar terms.
Table 3.--Unquantified Benefit Categories From HAP, Ozone-Related, and PM Emissions Reductions
----------------------------------------------------------------------------------------------------------------
Unquantified effect Unquantified effect Unquantified effect
categories associated categories associated categories associated
with HAP with ozone with PM
----------------------------------------------------------------------------------------------------------------
Health Categories.................... Carcinogenicity Airway responsiveness, Premature mortality,
mortality, Pulmonary Chronic bronchitis,
Genotoxicity inflammation, Hospital admissions
mortality, Noncancer Increased for chronic
lethality, Pulmonary susceptibility to obstructive pulmonary
function, decrement, respiratory infection, disease, pneumonia,
Dermal irritation, Eye Acute inflamation and cardiovascular
irritation, respiratory cell diseases, and asthma,
Neurotoxicity, damage, Chronic Changes in pulmonary
Immunotoxicity, respiratory damage/ function,
Pulmonary function Premature aging of Morphological changes,
decrement, Liver lungs, Emergency room Altered host defense
damage, visits for asthma, mechanisms, Cancer,
Gastrointestinal Hospital admissions Other chronic
toxicity, Kidney for respiratory respiratory disease,
damage, Cardiovascular diseases, Asthma Emergency room visits
impairment, attacks, Minor for asthma, Lower and
Hematopoietic (Blood restricted activity upper respiratory
disorders), days. symptoms, Acute
Reproductive/ bronchitis, Shortness
Developmental toxicity. of breath, Minor
restricted activity
days, Asthma attacks,
Work loss days.
Welfare Categories................... Corrosion/ Ecosystem and Materials damage,
Deterioration, vegetation effects in Damage to ecosystems
Unpleasant odors, Class I areas (e.g., (e.g., acid sulfate
Transportation safety national parks), deposition), Nitrates
concerns, Yield Damage to urban in drinking water.
reductions/Foliar ornamentals (e.g.,
injury, Biomass grass, flowers,
decrease, Species shrubs, and trees in
richness decline, urban areas),
Species diversity Commercial field
decline, Community crops, Fruit and
size decrease, vegetable crops,
Organism lifespan, Reduced yields of tree
decrease, Trophic web seedlings, commercial
shortening. and non-commercial
forests, Damage to
ecosystems, Materials
damage, Reduced worker
productivity.
----------------------------------------------------------------------------------------------------------------
V. Relationship to Other Standards and Programs Under the CAA and Other
Statutes
A. Wood Building Products Surface Coating NESHAP Proposal
The proposed PCWP rule includes some miscellaneous coating
operations that are performed where the substrate is manufactured. We
included these miscellaneous coating operations in the proposed PCWP
rule instead of the upcoming Wood Building Products Surface Coating
NESHAP (40 CFR part 63, subpart QQQQ) so that most facilities would be
subject to only one of the rules. The miscellaneous coating operations
proposed today include the application of any of the following to
plywood or composite wood products: edge seals, moisture sealants,
anti-skid coatings, company logos, trademark or grade stamps, nail
lines, synthetic patches, wood patches, wood putty, concrete forming
oils, glues for veneer composing, and shelving edge fillers. In
addition, miscellaneous coating operations also include the application
of primer to OSB siding that occurs at the same site as the OSB
manufacture.
B. Wood Furniture Manufacturing Operations NESHAP (40 CFR Part 63,
Subpart JJ)
The Wood Furniture Manufacturing Operations NESHAP apply to wood
furniture manufacturing facilities that are engaged, either in part or
in whole, in the manufacture of wood furniture or wood furniture
components that are located at a plant site that is a major source of
HAP emissions. In the preamble to the final rule (60 FR 62936, December
7, 1995), we stated that wood furniture manufacturing operations
involving urea-formaldehyde resins were excluded from the Wood
Furniture Manufacturing Operations NESHAP and would be covered by the
proposed PCWP rule. Today's proposed rule covers manufacturing
operations at wood furniture manufacturing facilities that use urea-
formaldehyde resins. These operations include, but are not limited to,
the manufacture of hardwood plywood, particleboard, and medium density
fiberboard, all of which are included in the definition of a PCWP
manufacturing facility. Although some wood furniture plants may be
subject to both the Wood Furniture Manufacturing Operations NESHAP and
today's proposed rule, there are no overlapping
[[Page 1304]]
requirements for individual process units.
C. Combustion Related NESHAP
Plywood and composite wood products facilities operate combustion
units such as boilers, fuel cells, and thermal oil heaters that supply
heat to process units such as dryers and presses that are used in the
manufacture of PCWP. When the combustion unit supplies heat by directly
exhausting the combustion gas through a dryer, the dryer is considered
a ``direct-fired dryer.'' Therefore, the HAP emissions from a direct-
fired dryer are actually a combination of the emissions from the
combustion unit exhausting into the dryer and the emissions that result
from drying the wood. Because today's proposed rule regulates emissions
from direct-fired dryers, those combustion units associated with
direct-fired dryers are excluded from the requirements of other
combustion-related NESHAP, such as the Industrial/Commercial/
Institutional Boilers NESHAP and the Process Heaters NESHAP. However,
those combustion units that supply heat or steam to indirect-fired
dryers or presses (i.e., combustion unit exhaust does not contact wood
particles or veneers), and those thermal oil heaters that supply hot
oil for presses but which don't exhaust through dryers are not covered
by today's proposed rule and would be subject to the requirements of
the applicable combustion related NESHAP.
D. New Source Review/Prevention of Significant Deterioration
Applicability
We expect that many of the PCWP facilities impacted by today's
proposed rule will install RTOs to comply with the proposed HAP control
requirements. However, RTOs can generate NO_X emissions
during normal operation. If NO_X emission increases are great
enough, they may trigger the need for preconstruction permits under the
nonattainment new source review (NSR) or prevention of significant
deterioration (PSD) program (referred to in the remainder of this
preamble as ``major NSR''). During the development of today's proposed
rule, representatives from the PCWP industry requested that we consider
the application of an RTO to reduce HAP emissions to be a pollution
control project (PCP), as defined within the context of PSD and NSR,
such that RTOs installed to meet today's proposed rule would qualify
for an exemption from NSR/PSD.
In 1992, the EPA adopted an explicit PCP exclusion for electric
utility steam generating units (57 FR 32314). In a July 1, 1994
guidance memorandum, we provided guidance to permitting authorities on
the approvability of PCP exclusions for source categories other than
electric utilities. In that guidance (available on the TTN; see
``Pollution Control Projects and New Source Review (NSR)
Applicability'' from John S. Seitz, Director, OAQPS, to EPA Regional
Air Division Directors), we indicated that add-on controls and fuel
switches to less polluting fuels may qualify for an exclusion from
major NSR as a PCP. To be eligible to be excluded from otherwise
applicable major NSR requirements, a PCP must, on balance, be
``environmentally beneficial,'' and the permitting authority must
ensure that the project will not cause or contribute to a violation of
the NAAQS or PSD increment, or adversely affect visibility or other air
quality related values (AQRV) in a Class I area, and that offsetting
reductions are secured in the case of a project which would result in a
significant increase of a nonattainment pollutant. The permitting
authority can make these determinations outside of the major NSR
process. The 1994 guidance did not supercede existing NSR requirements,
including approved State NSR programs, nor void or create an exclusion
from any applicable minor source preconstruction review requirements in
an approved SIP. Any minor NSR permitting requirements in a SIP would
continue to apply, regardless of any exclusion from major NSR that
might be approved for a source under the PCP exclusion policy.
In the July 1, 1994 guidance memorandum, we specifically identified
the RTO as an example of an add-on control that is an appropriate
candidate for a case-by-case exclusion from major NSR as a PCP. We
believe that the current guidance on the PCP exclusion adequately
provides for the possible exemption from major NSR for PCP resulting
from today's proposed rule. Permitting authorities should follow that
guidance to the extent allowed under the applicable SIP in order to
determine whether the installation of an RTO in a given circumstance
qualifies as a PCP. Projects that qualify for the exclusion would be
covered under minor source regulations in the applicable SIP, and
permitting authorities would be expected to provide adequate safeguards
against NAAQS and increment violations and adverse impacts on AQRV in
Federal Class I areas. Only in those areas where potential adverse
impacts cannot be resolved through the minor NSR programs or other
mechanisms would major NSR apply.
E. Interrelationship Between MACT Provisions and PSD
We have received comments from some in industry who would like to
use the provisions of the proposed PCWP rule to satisfy requirements
for PSD. While many of the proposed PCWP provisions for HAP may be used
to comply with PSD, the PCWP provisions are not universally applicable.
In cases where one rule is more stringent than the other, you must
comply with both rules.
We do not usually state this explicitly in rule preambles because
it is established as a matter of law and precedence. However, because
of some misunderstandings from some in industry and our on-going
enforcement review of PSD compliance in the PCWP industry, we believe
it is helpful to discuss areas where the proposed PCWP rule and PSD may
have different requirements.
First, the proposed PCWP rule is a rule that would regulate HAP.
Decisions on control levels and compliance demonstrations are based on
HAP reductions. If decisions had been based on control of VOC, the
control level may have been different. For example, this proposed rule
requires 90 percent reduction of HAP from affected process units.
Prevention of significant deterioration may require control
efficiencies in excess of 90 percent. Another example is which process
units require control. In the proposed PCWP rule, the level of control
that represents the MACT floor for dry rotary dryers and hardwood
veneer dryers is no emissions reductions. We determined that requiring
controls was not cost effective for HAP. However, these process units
emit more VOC than HAP; therefore, we may determine for PSD that dry
rotary dryers and hardwood veneer dryers should be controlled.
Second, we want to clarify that THC is not the same as VOC. Two of
the compliance options in the proposed PCWP rule are based on
measurement of THC, as carbon, either with or without methane, as a
surrogate for measuring HAP. While THC, as carbon, is a good way to
determine percent reduction of a control device for HAP of concern for
the PCWP industry, it may not be appropriate for VOC.
F. Effluent Guidelines
Effluent guidelines applicable to categories and subcategories of
industrial point sources are issued under authority of the Clean Water
Act (sections 301, 304, 306, 307, 308, 402, and 501). The current
effluent guidelines are applicable to many PCWP
[[Page 1305]]
facilities and are found at 40 CFR part 429. Effluent limitations for a
number of the subcategories covered in 40 CFR part 429 prohibit
discharge of process wastewater pollutants into navigable waters of the
United States. Industry has requested that we propose to amend the
effluent guidelines in 40 CFR part 429, specifically the definition of
process wastewaters at Sec. 429.11(c), which affects all subparts
requiring no discharge of process wastewater pollutants, to allow
discharge of certain wastewaters, specifically wastewaters associated
with APCD operation and maintenance, by excluding them from the
applicability of these subparts. Industry has asserted that effluent
limitations for these wastewaters could be developed by permit writers
on a case-by-case basis based upon best professional judgment. Industry
comments are in Docket number A-98-44.
At this time, we are not proposing to amend the effluent guidelines
because many PCWP facilities are disposing of these wastewaters in
compliance with the existing regulations, for example, by recycling
them in the process or discharging them to a publicly owned treatment
works. We lack comprehensive information to support the industry's
suggestion that simultaneous compliance with the proposed rule and the
existing effluent guidelines would not be possible.
In order to consider industry's request, we would need to obtain
additional and more-detailed information than currently available that:
(1) Quantifies the volumes and pollutants present in the wastewaters
generated by APCD used to comply with the proposed rule so that
comparisons can be made with wastewaters regulated by the existing
effluent guidelines, and (2) documents the industry's wastewater
treatment and disposal practices to support the assertions that any
additional APCD wastewaters that may not have been considered in the
original rulemaking for part 429 are not or could not be disposed of in
a manner compliant with the existing effluent guidelines. We are
requesting comment and additional detailed information and supporting
data from interested parties on whether 40 CFR part 429, subparts B, C,
D, F, K, L, M, and O, should be amended by revising the applicability
of any or all of these subparts requiring no discharge of process
wastewater pollutants (i.e., by changing the definition of process
wastewater at Sec. 429.11(c)), such that the effluent guidelines would
not apply to wastewater produced by operation or maintenance of APCD
that are used to comply with the proposed rule. Any new information and
data will be considered and, if appropriate, could serve as the basis
for amending the definition of process wastewater found at 40 CFR Sec.
429.11(c) at the time the final PCWP MACT rule is promulgated. (The EPA
would consider employing a direct final rule to promulgate any such
amendment if we receive convincing supporting information as described
above and do not receive significant adverse comment on this issue in
response to today's proposed rule. If we do receive adverse comments,
we would need to propose the amendment prior to promulgation.) If
appropriate and promulgated, this amendment, or a similar amendment
designed to achieve the same result, would allow for the discharge of
such APCD wastewater that may result from compliance with the PCWP MACT
rule. We are considering an amendment to 40 CFR Sec. 429.11(c), to
read as follows (amending language in italics): The term ``process
wastewater'' specifically excludes non-contact cooling water, material
storage yard runoff (either raw material or processed wood storage),
boiler blowdown, and wastewater from air pollution control devices
installed to comply with the proposed national emissions standards for
hazardous air pollutants (NESHAP) for plywood and composite wood
products (PCWP) facilities (40 CFR Sec. 63.22). For the dry process
hardboard, veneer, finishing, particleboard, and sawmills and planing
mills subcategories, fire control water is excluded from the
definition.
The actual discharge allowances would be determined initially on a
case-by-case basis by NPDES permitting authorities using their best
professional judgment (See 40 CFR Sec. 125.3). (In this regard, the
industry has suggested that discharge limitations could be expressed in
the form of allowances for the discharges attributable to the proposed
PCWP MACT rule.) If we promulgate an amendment to part 429 of the type
described above at the time we promulgate the final PCWP MACT rule, we
will consider, through the CWA section 304(m) planning process, whether
it is appropriate to revise part 429 at a later time in order to
establish category-or subcategory-specific effluent limitations and
standards for such APCD wastewater discharges.
VI. Administrative Requirements
A. Executive Order 12866, Regulatory Planning and Review
Under Executive Order 12866 (58 FR 51735, October 4, 1993), 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 Executive 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, competition, jobs, the environment, public
health or safety, or State, local, or tribal governments or
communities;
(2) Create a serious inconsistency or otherwise interfere with an
action taken 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; or
(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, it has been
determined that this proposed rule is a ``significant regulatory
action'' because the annual costs of complying with the rule as
proposed are expected to exceed $100 million. Consequently, this action
was submitted to OMB for review under Executive Order 12866. Any
written comments from OMB and written EPA responses are available in
the docket (see ADDRESSES section of this preamble).
We did not estimate health and welfare benefits associated with
changes in emissions of HAP, CO, VOC, PM, NO_X and SO2 for
this proposed rule.
B. Executive Order 13132, Federalism
Executive Order 13132, entitled ``Federalism'' (64 FR 43255, August
10, 1999), requires EPA to develop an accountable process to ensure
``meaningful and timely input by State and local officials in the
development of regulatory policies that have federalism implications.''
``Policies that have federalism implications'' is defined in the
Executive Order to include regulations that have ``substantial direct
effects on the States, on the relationship between the national
government and the States, or on the distribution of power and
responsibilities among the various levels of government.'' Under
Executive Order 13132, EPA may not issue a regulation that has
federalism implications, that imposes substantial direct compliance
costs, and that is not required by statute, unless the Federal
government provides the funds necessary to pay the direct compliance
costs incurred by State and local governments, or EPA consults with
[[Page 1306]]
State and local officials early in the process of developing the
proposed regulation. The EPA also may not issue a regulation that has
federalism implications and that preempts State law unless the Agency
consults with State and local officials early in the process of
developing the proposed regulation.
If EPA complies by consulting, Executive Order 13132 requires EPA
to provide to OMB, in a separately identified section of the preamble
to the rule, a federalism summary impact statement (FSIS). The FSIS
must include a description of the extent of EPA's prior consultation
with State and local officials, a summary of the nature of their
concerns and the agency's position supporting the need to issue the
regulation, and a statement of the extent to which the concerns of
State and local officials have been met. Also, when EPA transmits a
draft final rule with federalism implications to OMB for review
pursuant to Executive Order 12866, EPA must include a certification
from the Agency's Federalism Official stating that EPA has met the
requirements of Executive Order 13132 in a meaningful and timely
manner.
This proposed rule will not have substantial direct effects on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various levels of government, as specified in Executive Order 13132.
The proposed rule would not impose directly enforceable requirements on
States, nor would it preempt them from adopting their own more
stringent programs to control emissions from PCWP facilities. Moreover,
States are not required under the CAA to take delegation of Federal
NESHAP and bear their implementation costs, although States are
encouraged and often choose to do so. Thus, the requirements of section
6 of the Executive Order do not apply to this proposed rule. Although
section 6 of Executive Order 13132 does not apply to this proposed
rule, EPA is providing State and local officials an opportunity to
comment on this proposed rule. A summary of the concerns raised during
the notice and comment process and EPA's response to those concerns
will be provided in the final rulemaking notice.
C. Executive Order 13175, Consultation and Coordination With Indian
Tribal Governments
Executive Order 13175, entitled ``Consultation and Coordination
with Indian Tribal Governments'' (65 FR 67249, November 6, 2000),
requires EPA to develop an accountable process to ensure ``meaningful
and timely input by tribal officials in the development of regulatory
policies that have tribal implications.'' ``Policies that have tribal
implications'' is defined in the Executive Order to include regulations
that have ``substantial direct effects on one or more Indian tribes, on
the relationship between the Federal government and the Indian tribes,
or on the distribution of power and responsibilities between the
Federal government and Indian tribes.''
This proposed rule does not have tribal implications. It will not
have substantial direct effects on tribal governments, on the
relationship between the Federal government and Indian tribes, or on
the distribution of power and responsibilities between the Federal
government and Indian tribes, as specified in Executive Order 13175. No
affected plant sites are owned or operated by Indian tribal
governments. Thus, Executive Order 13175 does not apply to this rule.
In the spirit of Executive Order 13175, and consistent with EPA policy
to promote communications between EPA and tribal governments, EPA
specifically solicits additional comment on this proposed rule from
tribal officials.
D. Executive Order 13045, Protection of Children From Environmental
Health Risks and Safety Risks
Executive Order 13045 (62 FR 19885, April 23, 1997) applies to any
rule that: (1) Is determined to be ``economically significant,'' as
defined under Executive Order 12866, and (2) concerns an environmental
health or safety risk that EPA has reason to believe may have a
disproportionate effect on children. If the regulatory action meets
both criteria, the EPA must evaluate the environmental health or safety
effects of the planned rule on children and explain why the planned
regulation is preferable to other potentially effective and reasonably
feasible alternatives considered by the Agency.
The Agency does not have reason to believe the environmental health
or safety risks associated with the emissions addressed by this
proposed rule present a disproportionate risk to children. The public
is invited to submit or identify peer-reviewed studies and data, of
which the Agency may not be aware, that assess the results of early
life exposure to the pollutants addressed by this proposed rule and
suggest a disproportionate impact.
E. Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Pub.
L. 104-4, establishes requirements for Federal agencies to assess the
effects of their regulatory actions on State, local, and tribal
governments and the private sector. Under section 202 of the UMRA, the
EPA generally must prepare a written statement, including a cost-
benefit analysis, for proposed and final rules with ``Federal
mandates'' that may result in expenditures by State, local, and Tribal
governments, in aggregate, or by the private sector, of $100 million or
more in any 1 year. Before promulgating an EPA rule for which a written
statement is needed, section 205 of the UMRA generally requires the EPA
to identify and consider a reasonable number of regulatory alternatives
and adopt the least-costly, most cost-effective, or least-burdensome
alternative that achieves the objectives of the rule. The provisions of
section 205 do not apply when they are inconsistent with applicable
law. Moreover, section 205 allows the EPA to adopt an alternative other
than the least-costly, most cost-effective, or least-burdensome
alternative if the Administrator publishes with the final rule an
explanation why that alternative was not adopted. Before the EPA
establishes any regulatory requirements that may significantly or
uniquely affect small governments, including tribal governments, it
must have developed under section 203 of the UMRA a small government
agency plan. The plan must provide for notifying potentially affected
small governments, enabling officials of affected small governments to
have meaningful and timely input in the development of EPA regulatory
proposals with significant Federal intergovernmental mandates, and
informing, educating, and advising small governments on compliance with
the regulatory requirements.
Since this rule is estimated to impose costs to the private sector
in excess of $100 million per year, it is considered a significant
regulatory action. Therefore, we have prepared the following statement
with respect to sections 202 through 205 of the UMRA.
1. Statutory Authority
This proposed rule establishes control requirements for existing
and new PCWP sources pursuant to section 112 of the CAA. The CAA
requires NESHAP to reflect the maximum degree of reduction in emissions
of HAP that is achievable. This is commonly referred to as MACT.
Section 112(d)(3) further
[[Page 1307]]
defines a minimum level of control that can be considered for MACT
standards, commonly referred to as the MACT floor--which for new
sources, is the level of control achieved by the best controlled
similar source, and for existing sources is the level of control
achieved by the average of the best performing 12 percent of sources in
the category (or the best-performing five sources for categories with
fewer than 30 sources).
Control technologies and their performance are discussed in the
background information document for this proposal (Docket number A-98-
44). We considered emission reductions, costs, environmental impacts,
and energy impacts in selecting the proposed MACT standards. The
proposed standards achieve sizable reductions in HAP and other
pollutant emissions.
2. Social Costs and Benefits
The regulatory analyses prepared for this proposed rule, including
our assessment of costs and benefits, is detailed in the ``Regulatory
Impact Analysis for the Proposed Plywood and Composite Wood Products
NESHAP'' in Docket A-98-44. Based on estimated compliance costs
associated with this proposed rule and the predicted change in prices
and production in the affected industries, the estimated social costs
of this proposed rule are $134.2 million (1999 dollars). The social
costs of this proposed rule are the costs imposed upon society as a
result of efforts toward compliance, and include the effects upon
consumers of products made by the affected facilities.
It is estimated that 3 years after implementation of the
requirements as proposed, HAP would be reduced by 9,700 Mg/yr (11,000
tons/yr) due to reductions in formaldehyde, acetaldehyde, acrolein,
methanol and other HAP from PCWP sources. Formaldehyde and acetaldehyde
have been classified as ``probable human carcinogens.'' Acrolein,
methanol and the other HAP are not considered carcinogenic, but produce
several other toxic effects. If implemented, the requirements of this
proposed rule would also achieve reductions of 10,000 Mg/yr (11,000
tons/yr) of CO, approximately 11,000 Mg/yr (13,000 tons/yr) of
PM₁₀, and approximately 25,000 Mg/yr (27,000 tons/yr) of VOC
(approximated as THC). Exposure to CO can effect the cardiovascular
system and the central nervous system. The PM emissions can result in
fatalities and many respiratory problems (such as asthma or
bronchitis).
At the present time, we cannot provide a monetary estimate for the
benefits associated with the reductions in HAP and CO. For VOC, we are
not able to estimate the benefits associated with the reductions due to
a lack of available air quality modeling to estimate the change in
ozone concentrations that occur with VOC emissions reductions. We
estimated the benefits associated with health effects of
PM₁₀ but were unable to quantify all categories of benefits
(particularly those associated with ecosystem and environmental
effects). The estimated benefits include the effects of potential
additional NO_X emissions that result from additional
combustion controls. The estimates of the potential additional
NO_X emissions are presented in Section IV of this preamble.
Nitrogen oxides are transformed into PM₁₀ in the atmosphere,
and these emissions hence offset the benefits from the PM₁₀
reductions mentioned above. Total monetized benefits for the
PME₁₀ and NO_X emissions changes using our
preferred approach to value benefits is $8.5 million (1999 dollars),
and $5.3 million (1999 dollars) using an alternative age-adjusted
approach recommended by others. The two approaches to valuing benefits
is discussed in more detail in this preamble in the Executive Order
12866 section and in the Regulatory Impact Analysis. The monetized
benefits should be considered along with the many categories of
benefits that we are unable to place a dollar value on to consider the
total benefits of this proposed rule.
3. Regulatory Alternatives Considered
The proposed standards reflect the MACT floor, the least stringent
regulatory alternative we may propose. In addition, we are proposing
the least burdensome and most flexible monitoring, reporting, and
recordkeeping requirements that we believe will assure compliance with
the compliance options and requirements of this proposed rule.
Therefore, the proposed regulatory alternative reflects the least
costly, most cost-effective, and least burdensome regulatory option
that achieves the objectives of the proposed rule.
4. Effects on the National Economy
The economic impact analysis for this proposed rule estimates
effects upon employment and foreign trade for the industries affected
by this proposed 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 proposed rule. There is also minimal change in the foreign 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.
5. Consultation With Government Officials
Throughout the development of this proposed rule, we interacted
with representatives of affected State and local officials to inform
them of the progress of our rulemaking efforts. We also consulted with
representatives from other entities affected by the proposed rule, such
as the American Forest & Paper Association, National Council for Air
and Stream Improvement, APA--The Engineered Wood Association, Composite
Panel Association, American Hardboard Association, Hardwood Plywood and
Veneer Association, and representatives from affected companies. We
will continue to interact with government officials and other entities
during the public comment period for this proposed rule and throughout
development of the promulgated PCWP standards.
The number of small entities that are significantly affected by
today's proposed PCWP standards is not expected to be substantial. This
proposed rule contains no regulatory requirements that might
significantly affect small governments because no PCWP facilities are
owned by such governments. The full analysis of potential regulatory
impacts on small organizations, small governments, and small businesses
is included in the economic impact analysis in the docket and is listed
at the beginning of today's action under SUPPLEMENTARY INFORMATION.
Because the number of small entities that are likely to experience
significant economic impacts as a result of today's proposed standards
is not expected to be substantial, no plan to inform and advise small
governments is required under section 203 of the UMRA.
F. Regulatory Flexibility Act (RFA), as Amended by the Small Business
Regulatory Enforcement Fairness Act (SBREFA) of 1996, 5 U.S.C. 601 et
seq.
The 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
[[Page 1308]]
substantial number of small entities. Small entities include small
businesses, small organizations, and small governmental jurisdictions.
For purposes of assessing the impacts of today's proposed rule on
small entities, small entity is defined as: (1) A small business
ranging from 500 to 750 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 and is not dominant in its field.
After considering the economic impact of today's proposed rule on
small entities, we certify that this action will not have a significant
impact on a substantial number of small entities. In accordance with
the RFA, we conducted an assessment of the proposed standards on small
businesses in the industries affected by the proposed rule. Based on
SBA size definitions for the affected industries and reported sales and
employment data, the Agency identified 17 of the 52 companies, or 32
percent, owning affected facilities as small businesses. Although small
businesses represent 32 percent of the companies within the source
category, they are expected to incur only 8 percent of the total
industry compliance costs of $142 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 cost-to-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
proposed rule. The analysis shows that of the 32 facilities owned by
affected small firms, only one would be expected to shut down rather
than incur the cost of compliance with the proposed rule. Although any
facility closure 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 experiencing adverse economic conditions for reasons
unconnected to this proposed rule are more vulnerable to the impact of
any new costs than those that are not.
The analysis indicates that the proposed rule should not generate a
significant impact on a substantial number of small entities for the
PCWP manufacturing source category for the following reasons. First, of
the ten small firms that have compliance costs greater than 1 percent
of sales, only three have compliance costs of greater than 3 percent of
sales. Second, the results of the economic impact analysis show that
only one facility owned by a small firm out of the 32 facilities owned
by affected small firms may close due to the implementation of this
proposed rule. The facility that may close rather than incur the cost
of compliance appears to have low profitability levels currently. 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, the analysis supports today's certification under the RFA
because, while a few small firms may experience significant impacts,
there will not be a substantial number incurring such a burden.
Although this proposed rule will not have a significant economic
impact on a substantial number of small entities, we minimized the
impact of this proposed rule on small entities in several ways. First,
we considered subcategorization based on production and throughput
level to determine whether smaller process units would have a different
MACT floor than larger process units. Our data show that
subcategorization based on size would not result in a less stringent
level of control for the smaller process units. Second, we chose to set
the control requirements at the MACT floor control level and not at a
control level more stringent. Thus, the control level specified in the
proposed PCWP rule is the least stringent allowed by the CAA. Third,
the proposed rule contains multiple compliance options to provide
facilities with the flexibility to comply in the least costly manner
while maintaining a workable and enforceable rule. The compliance
options include emissions averaging and production-based compliance
options 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
proposed rule includes multiple test method options for measuring
methanol, formaldehyde, and total HAP. In addition, we worked with
various trade associations during the development of the proposed rule.
We continue to be interested in the potential impacts of the proposed
rule on small entities and welcome comments on issues related to such
impacts.
G. Paperwork Reduction Act
The information collection requirements in this proposed rule will
be submitted for approval to OMB under the Paperwork Reduction Act, 44
U.S.C. 3501 et seq. The EPA has prepared an Information Collection
Request (ICR) document (1984.01), and you may obtain a copy from Susan
Auby by mail at Office of Environmental Information, Collection
Strategies Division (2822T), U.S. EPA, 1200 Pennsylvania Avenue NW.,
Washington, DC 20460, by e-mail at auby.susan@epa.gov, or by calling
(202) 566-1672. You may also download a copy off the Internet at http://www.epa.gov/icr.
The information requirements are not effective until
OMB approves them.
The information requirements are based on notification,
recordkeeping, and reporting requirements in the NESHAP General
Provisions (40 CFR part 63, subpart A), which are mandatory for all
operators subject to national emission standards. These recordkeeping
and reporting requirements are specifically authorized by section 114
of the CAA (42 U.S.C. 7414). All information submitted to the EPA
pursuant to the recordkeeping and reporting requirements for which a
claim of confidentiality is made is safeguarded according to Agency
policies set forth in 40 CFR part 2, subpart B.
The proposed rule would require maintenance inspections of the
control devices but would not require any notifications or reports
beyond those required by the NESHAP General Provisions. The
recordkeeping requirements require only the specific information needed
to determine compliance.
The annual monitoring, reporting, and recordkeeping burden for this
collection (averaged over the first 3 years after the effective date of
the rule) is estimated to be 4,658 labor hours per year, at a total
annual cost of $207,322. This estimate includes notifications that
facilities are subject to the rule; notifications of performance tests;
notifications of compliance status, including the results of
performance tests and other initial compliance demonstrations that do
not include performance tests; startup, shutdown, and malfunction
reports; semiannual compliance reports; and recordkeeping. In addition
to the requirements of 40 CFR part 63, subpart A, facilities that wish
to implement emissions averaging provisions must submit an emissions
averaging plan. Facilities may also submit a request for a routine
control device maintenance exemption to justify the need for routine
[[Page 1309]]
maintenance on the control device and to show how the facilities plan
to minimize emissions to the greatest extent possible during the
maintenance. Total capital/startup costs associated with the testing,
monitoring, reporting, and recordkeeping requirements over the 3-year
period of the ICR are estimated to be $122,040, with operation and
maintenance costs of $3,957.
Burden means the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency. This includes the time
needed to: (1) Review instructions; (2) develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining
information, and disclosing and providing information; (3) adjust the
existing ways to comply with any previously applicable instructions and
requirements; (4) train personnel to be able to respond to a collection
of information; (5) search data sources; (6) complete and review the
collection of information; and (7) transmit or otherwise disclose the
information.
An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
Comments are requested on the Agency's need for this information,
the accuracy of the provided burden estimates, and any suggested
methods for minimizing respondent burden, including through the use of
automated collection techniques. Send comments on the ICR to the
Director, Collection Strategies Division; U.S. Environmental Protection
Agency (2822); 1200 Pennsylvania Ave., NW., Washington, DC 20460; and
to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th St., NW., Washington, DC 20503, marked
``Attention: Desk Officer for EPA.'' Include the ICR number in any
correspondence. Since OMB is required to make a decision concerning the
ICR between 30 and 60 days after January 9, 2003, a comment to OMB is
best assured of having its full effect if OMB receives it by February
10, 2003. The final rule will respond to any OMB or public comments on
the information collection requirements contained in this proposal.
H. National Technology Transfer and Advancement Act of 1995
Section 12(d) of the National Technology Transfer and Advancement
Act (NTTAA) of 1995 (Pub. L. 104-113) (15 U.S.C. 272 note) directs us
to use voluntary consensus standards in our regulatory and procurement
activities unless to do so would be inconsistent with applicable law or
otherwise impractical. Voluntary consensus standards are technical
standards (e.g., materials specifications, test methods, sampling
procedures, business practices) developed or adopted by one or more
voluntary consensus bodies. The NTTAA directs us to provide Congress,
through annual reports to the OMB, with explanations when we do not use
available and applicable voluntary consensus standards.
In this proposed rule, we are proposing requirements to use EPA
Methods 1, 1a, 2, 2a, 2c, 2d, 2f, 2g, 3, 3a, 3b, 4, 18, 25a, 204,
204(a-f), 308, 316, 320, and SW 846 0011, and the NCASI methods
previously discussed in this preamble. Consistent with the NTTAA, we
conducted searches to identify voluntary consensus standards that could
be used in addition to the EPA methods.
No voluntary consensus standards were identified as applicable to
this proposed rule. For EPA Methods 1a, 2a, 2d, 2f, 2g, 204, 204a-f,
308, 316, and SW 846 0011, no applicable voluntary consensus standards
were found. The search and review results are documented in Docket A-
98-44. For EPA Methods 1, 2, 2c, 3, 3a, 3b, 4, 18, and 25a, we
identified voluntary consensus standards that would not be practical
due to lack of equivalency, detail, and/or quality assurance/quality
control requirements. Specific reasons why the voluntary consensus
standards are not practical are detailed in Docket A-98-44. For EPA
Methods 2, 3a, 25a, and 320, we identified voluntary consensus
standards that are under development or under EPA review. These
voluntary consensus standards are listed in Docket A-98-44. Therefore,
we do not propose to use any voluntary consensus standards.
We are requesting comment on compliance demonstration requirements
in this proposed rule and specifically invite you to identify
potentially-applicable voluntary consensus standards. You should
explain why this regulation should adopt a particular voluntary
consensus standard in lieu of or in addition to EPA's methods and/or
the NCASI methods. Emission test methods and performance specifications
submitted for evaluation should be accompanied with a basis for the
recommendation, including method validation data and the procedure used
to validate the candidate method (if method other than Method 301, 40
CFR part 63, appendix A, was used).
Table 4 of proposed subpart DDDD lists the testing methods and
performance standards included in the proposed regulations. Several of
the methods have been used by States and industry for more than 10
years. Nevertheless, under Sec. 63.7(e)(2)(ii) and (f), the proposal
also allows any State or source to apply to EPA for permission to use
an alternative method in place of any of the EPA testing methods or
performance standards listed in Table 4 of proposed subpart DDDD.
I. Executive Order 13211, Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use
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 Information and Regulatory
Affairs, Office of Management and Budget, a Statement of Energy Effects
for certain actions identified as ``significant energy actions.''
Section 4(b) of Executive Order 13211 defines ``significant 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 designated by the Administrator of the
Office of Information and Regulatory Affairs as a significant energy
action.'' The proposed 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.
This proposed 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 production related to implementation of
this proposal. In fact, as previously mentioned in this preamble, there
will be an increase in energy consumption, and hence an increase in
energy
[[Page 1310]]
production, resulting from installation of RTO and WESP likely needed
for sources to meet the requirements of the proposed rule. This
increase in energy consumption is equal to 718 million kilowatt-hours/
year (kWh/yr) for electricity and 45 million cubic meters/year
(m3/yr) for natural gas. These increases are equivalent to
0.012 percent of 1998 U.S. electricity production and 0.000001 percent
of 1998 U.S. natural gas production.\10\ 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.
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\10\ U.S. Department of Energy, Energy Information
Administration. Annual Energy Review, End-Use Energy Consumption for
1998. Located on the Internet at http://www.eia.doe.gov/emeu/aer/enduse.html
.
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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.\11\ 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 kWh/yr, or only a 0.00013 percent
reduction nationwide based on 1998 U.S. electricity 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, there will be only
a negligible change in international trade, and hence in dependence on
foreign energy supplies. No other adverse outcomes are expected to
occur with regards to energy supplies.Thus, the net effect of this
proposed rule on energy production is an increase in electricity output
of 0.012 percent compared 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.\12\ For more
information on the estimated energy effects, please refer to the
background memo \13\ to these calculations and the economic impact
analysis for the proposed rule. The background memo and economic impact
analysis are available in the public docket.
---------------------------------------------------------------------------
\11\ Ibid.
\12\ 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
.
\13\ U.S. Environmental Protection Agency. ``Energy Impact
Analysis of the Proposed Plywood and Composite Wood Products
NESHAP.'' July 30, 2001.
---------------------------------------------------------------------------
Therefore, we conclude that the rule if implemented as proposed is
not likely to have a significant adverse effect on the supply,
distribution, or use of energy.
List of Subjects in 40 CFR Part 63
Environmental protection, Administrative practice and procedure,
Air pollution control, Hazardous substances, Intergovernmental
relations, Incorporation by reference, Reporting and recordkeeping
requirements.
Dated: November 26, 2002.
Christine Todd Whitman,
Administrator.
For the reasons stated in the preamble, title 40, chapter I, part
63 of the Code of Federal Regulations is proposed to be amended as
follows:
PART 63--[AMENDED]
1. The authority citation for part 63 continues to read as follows:
Authority: 42 U.S.C. 7401 et seq.
Subpart A--[Amended]
2. Section 63.14 is amended by revising paragraph (f) to read as
follows: Sec. 63.14 Incorporations by reference.
* * * * *
(f) The following material is available from the National Council
of the Paper Industry for Air and Stream Improvement, Inc. (NCASI),
Methods Manual, P.O. Box 133318, Research Triangle Park, NC 27709-3318,
(919) 558-1987, or at http://www.ncasi.org .
(1) NCASI Method DI/MEOH-94.02, Methanol in Process Liquids GC/FID
(Gas Chromatography/Flame Ionization Detection), August 1998, IBR
approved for Sec. 63.457(c)(3)(ii).
(2) NCASI Method CI/WP-98.01, Chilled Impinger Method For Use At
Wood Products Mills to Measure Formaldehyde, Methanol, and Phenol,
1998, IBR approved for proposed Sec. 63.2262.
(3) NCASI Method IM/CAN/WP-99.01, Impinger/Canister Source Sampling
Method For Speciated HAPs at Wood Products Facilities, 1999, IBR
approved for proposed Sec. 63.2262.
* * * * *
3. Part 63 is amended by adding subpart DDDD to read as follows:
Subpart DDDD--National Emission Standards for Hazardous Air Pollutants:
Plywood and Composite Wood Products
What This Subpart Covers
Sec.
63.2230 What is the purpose of this subpart?
63.2231 Does this subpart apply to me?
63.2232 What parts of my plant does this subpart cover?
63.2233 When do I have to comply with this subpart?
Compliance Options, Operating Requirements, and Work Practice
Requirements
63.2240 What are the compliance options and operating requirements
and how must I meet them?
63.2241 What are the work practice requirements and how must I meet
them?
General Compliance Requirements
63.2250 What are the requirements for periods of startup, shutdown,
and malfunction?
63.2251 What are the requirements for the routine control device
maintenance exemption
Initial Compliance Requirements
63.2260 How do I demonstrate initial compliance with the compliance
options, operating requirements, and work practice requirements?
63.2261 By what date must I conduct performance tests or other
initial compliance demonstrations?
63.2262 How do I conduct performance tests and establish operating
requirements?
63.2263 Initial compliance demonstration for a dry rotary dryer.
63.2264 Initial compliance demonstration for a hardwood veneer
dryer.
63.2265 Initial compliance demonstration for a softwood veneer
dryer.
63.2266 Initial compliance demonstration for a veneer redryer.
63.2267 Initial compliance demonstration for a reconstituted wood
product press or board cooler.
63.2268 What are my monitoring installation, operation, and
maintenance requirements?
Continuous Compliance Requirements
63.2270 How do I monitor and collect data to demonstrate continuous
compliance?
63.2271 How do I demonstrate continuous compliance with the
compliance options, operating requirements, and work practice
requirements?
[[Page 1311]]
Notifications, Reports, and Records
63.2280 What notifications must I submit and when?
63.2281 What reports must I submit and when?
63.2282 What records must I keep?
63.2283 In what form and how long must I keep my records?
Other Requirements and Information
63.2290 What parts of the General Provisions apply to me?
63.2291 Who implements and enforces this subpart?
63.2292 What definitions apply to this subpart?
Tables
Table 1A to Subpart DDDD--Production-Based Compliance Options
Table 1B to Subpart DDDD--Add-On Control Systems Compliance Options
Table 2 to Subpart DDDD--Operating Requirements
Table 3 to Subpart DDDD--Work Practice Requirements
Table 4 to Subpart DDDD--Requirements for Performance Tests
Table 5 to Subpart DDDD--Performance Testing and Initial Compliance
Demonstrations for the Compliance Options and Operating Requirements
Table 6 to Subpart DDDD--Initial Compliance Demonstrations for Work
Practice Requirements
Table 7 to Subpart DDDD--Continuous Compliance With the Compliance
Options and Operating Requirements
Table 8 to Subpart DDDD--Continuous Compliance With the Work
Practice Requirements
Table 9 to Subpart DDDD--Requirements for Reports
Table 10 to Subpart DDDD--Applicability of General Provisions to
Subpart DDDD
Appendix
Appendix A to Subpart DDDD--Alternative Procedure to Determine
Capture Efficiency From A Hot Press Enclosure in the Plywood and
Composite Wood Products Industry Using Sulfur Hexafluoride Tracer
Gas
What This Subpart Covers

Sec. 63.2230 What is the purpose of this subpart?
This subpart establishes national compliance options, operating
requirements, and work practice requirements for hazardous air
pollutants (HAP) emitted from plywood and composite wood products
manufacturing facilities. This subpart also establishes requirements to
demonstrate initial and continuous compliance with the compliance
options, operating requirements, and work practice requirements.

Sec. 63.2231 Does this subpart apply to me?
This subpart applies to you if you meet the criteria in paragraphs
(a) and (b) of this section.
(a) You own or operate a plywood and composite wood products (PCWP)
manufacturing facility. A PCWP manufacturing facility is a plant site
that manufactures plywood and/or composite wood products by bonding
wood material (fibers, particles, strands, veneers, etc.) or
agricultural fiber, generally with resin under heat and pressure, to
form a structural panel or engineered wood product. Plywood and
composite wood products manufacturing facilities also include
facilities that manufacture dry veneer and lumber kilns located at any
facility. Plywood and composite wood products include (but are not
limited to) plywood, veneer, particleboard, oriented strandboard,
hardboard, fiberboard, medium density fiberboard, laminated strand
lumber, laminated veneer lumber, wood I-joists, kiln-dried lumber, and
glue-laminated beams.
(b) The PCWP manufacturing facility is located at a major source of
HAP emissions. A major source of HAP emissions is any stationary source
or group of stationary sources within a contiguous area and under
common control that emits or has the potential to emit any single HAP
at a rate of 9.07 megagrams (10 tons) or more per year or any
combination of HAP at a rate of 22.68 megagrams (25 tons) or more per
year.

Sec. 63.2232 What parts of my plant does this subpart cover?
(a) This rule applies to each new, reconstructed, or existing
affected source at a PCWP manufacturing facility.
(b) The affected source is the collection of dryers, blenders,
formers, presses, board coolers, and other process units associated
with the manufacturing of plywood and composite wood products at a
plant site. The affected source includes, but is not limited to, green
end operations, drying operations, blending and forming operations,
pressing and board cooling operations, and miscellaneous finishing
operations (such as sanding, sawing, patching, edge sealing, and other
finishing operations not subject to other NESHAP). The affected source
also includes onsite storage of raw materials used in the manufacture
of plywood and/or composite wood products, such as resins; onsite
wastewater treatment operations specifically associated with plywood
and composite wood products manufacturing; and miscellaneous coating
operations (defined in Sec. 63.2292). The affected source includes
lumber kilns at PCWP manufacturing facilities and at any other kind of
facility.
(c) An affected source is a new affected source if you commenced
construction of the affected source after January 9, 2003 and you meet
the applicability criteria at the time you commenced construction.
(d) An affected source is reconstructed if you meet the criteria as
defined in Sec. 63.2.
(e) An affected source is existing if it is not new or
reconstructed.

Sec. 63.2233 When do I have to comply with this subpart?
(a) If you have a new or reconstructed affected source, you must
comply with this subpart according to paragraph (a)(1) or (2) of this
section, whichever is applicable.
(1) If the initial startup of your affected source is before the
effective date of the subpart, then you must comply with the compliance
options, operating requirements, and work practice requirements for new
and reconstructed sources in this subpart no later than the effective
date of the subpart.
(2) If the initial startup of your affected source is after the
effective date of the subpart, then you must comply with the compliance
options, operating requirements, and work practice requirements for new
and reconstructed sources in this subpart upon initial startup of your
affected source.
(b) If you have an existing affected source, you must comply with
the compliance options, operating requirements, and work practice
requirements for existing sources no later than the date 3 years after
the effective date of the subpart.
(c) If you have an area source that increases its emissions or its
potential to emit such that it becomes a major source of HAP, you must
be in compliance with this subpart by the date 3 years after the
effective date of the subpart or upon initial startup of your affected
source as a major source, whichever is later.
(d) You must meet the notification requirements according to the
schedule in Sec. 63.2280 and according to 40 CFR part 63, subpart A.
Some of the notifications must be submitted before you are required to
comply with the compliance options, operating requirements, and work
practice requirements in this subpart.
[[Page 1312]]
Compliance Options, Operating Requirements, and Work Practice
Requirements

Sec. 63.2240 What are the compliance options and operating
requirements and how must I meet them?
You must meet the compliance options and operating requirements
described in Tables 1A, 1B, and 2 of this subpart and in paragraph (c)
of this section by using one or more of the compliance options listed
in paragraphs (a), (b), and (c) of this section. The process units
subject to the compliance options are listed in Tables 1A and 1B (the
same process units are listed in both tables) and are defined in Sec.
63.2292. You need only to meet one of the compliance options outlined
in paragraphs (a) through (c) of this section for each process unit.
You cannot use multiple compliance options for a single process unit.
(For example, you cannot use a production-based compliance option for
one vent of a veneer dryer and an add-on control system compliance
option for another vent on the same veneer dryer. You must use either
the production-based compliance option or an add-on control system
compliance option for the entire dryer.)
(a) Production-based compliance options. Meet the production-based
total HAP compliance options in Table 1A of this subpart and the
applicable operating requirements in Table 2 of this subpart. You may
not use an add-on control system to meet the production-based
compliance options.
(b) Compliance options for add-on control systems. Use an emissions
control system and demonstrate that the resulting emissions meet the
compliance options and operating requirements in Tables 1B and 2 of
this subpart. If you own or operate a reconstituted wood product press
at a new or existing affected source or a reconstituted wood product
board cooler at a new affected source, and you choose to comply with
one of the concentration-based compliance options for a control system
outlet (presented as option numbers 2, 4, and 6 in Table 1B of this
subpart), you must have a capture device that either meets the EPA
Method 204 criteria for a permanent total enclosure (PTE) or achieves a
capture efficiency of greater than or equal to 95 percent.
(c) Emissions averaging compliance option (for existing sources
only). Using the procedures in paragraphs (c)(1) through (3) of this
section, demonstrate that emissions included in the emissions average
meet the compliance options and operating requirements. New sources may
not use emissions averaging to comply with this subpart.
(1) Calculation of required and actual mass removal. Limit
emissions of total HAP, as defined in Sec. 63.2292, to include
acetaldehyde, acrolein, formaldehyde, methanol, phenol, and
propionaldehyde from your affected source to the standard specified by
Equations 1, 2, and 3 of this section.
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.016
(Eq. 1)(Eq. 2) (Eq. 3)Where:
RMR = required mass removal of total HAP from all process units
generating debits (i.e., all process units that are subject to the
compliance options in Tables 1A and 1B of this subpart and that are
either uncontrolled or under-controlled), pounds per semiannual period
AMR = actual mass removal of total HAP from all process units
generating credits (i.e., all process units that are controlled as part
of the Emissions Averaging Plan), pounds per semiannual period
UCEP_i = mass of total HAP from an uncontrolled or under-
controlled process unit (i) that generates debits, pounds per hour
OH_i = number of hours a process unit (i) is operated during
the semiannual period, hours per 6 month period
CD_i = control system efficiency for the emission point (i)
for total HAP, expressed as a fraction, and not to exceed 90 percent,
unitless
OCEP_i = mass of total HAP from a process unit (i) that
generates credits, pounds per hour
0.90 = required control system efficiency of 90 percent multiplied,
unitless
(2) Requirements for debits and credits. You must calculate debits
and credits as specified in paragraphs (c)(2)(i) through (vi) of this
section.
(i) You must limit process units in the emissions average to those
process units located at the existing affected source, as defined in
Sec. 63.2292.
(ii) You cannot use nonoperating process units to generate
emissions averaging credits. You cannot use process units that are
shutdown to generate emissions averaging debits or credits.
(iii) You may not include in your emissions average process units
controlled to comply with a State, Tribal, or Federal rule other than
this subpart, except when the control system installation and process
unit inclusion in the emissions average both pre-date the effective
date of the State, Tribal, or Federal rule.
(iv) You must use actual measurements of total HAP emissions from
process units to calculate your required mass removal (RMR) and actual
mass removal (AMR). The total HAP measurements must be obtained
according to Sec. 63.2262(b) through (d), (g), and (h), using the
methods specified in Table 4 of this subpart.
(v) Your initial demonstration that the credit-generating process
units will be capable of generating enough credits to offset the debits
from the debit-generating process units must be made under
representative operating conditions. After the compliance date, you
must use actual operating data for all debit and credit calculations.
(vi) Do not include emissions from the following time periods in
your emissions averaging calculations:
(A) Emissions during periods of startup, shutdown, and malfunction
as
[[Page 1313]]
described in the startup, shutdown, and malfunction plan.
(B) Emissions during periods of monitoring malfunctions, associated
repairs, and required quality assurance or control activities or during
periods of control device maintenance covered in your routine control
device maintenance exemption. No credits may be assigned to credit-
generating process units, and maximum debits must be assigned to debit-
generating process units during these periods.
(3) Operating requirements. You must meet the operating
requirements in Table 2 of this subpart for each process unit or
control device used in calculation of emissions averaging credits.

Sec. 63.2241 What are the work practice requirements and how must I
meet them?
(a) You must meet each work practice requirement in Table 3 of this
subpart that applies to you.
(b) As provided in Sec. 63.6(g), we, the EPA, may choose to grant
you permission to use an alternative to the work practice requirements
in this section.
General Compliance Requirements

Sec. 63.2250 What are the requirements for periods of startup,
shutdown, and malfunction?
(a) You must be in compliance with the compliance options,
operating requirements, and the work practice requirements in this
subpart at all times, except during periods of startup, shutdown, and
malfunction; prior to initial startup; and during the routine control
device maintenance exemption specified in Sec. 63.2251.
(b) You must always operate and maintain your affected source,
including air pollution control and monitoring equipment, according to
the provisions in Sec. 63.6(e)(1)(i).
(c) You must develop and implement a written startup, shutdown, and
malfunction plan (SSMP) according to the provisions in Sec.
63.6(e)(3).
(d) The compliance options, operating requirements, and work
practice requirements do not apply during times when the process
unit(s) subject to the compliance options, operating requirements, and
work practice requirements are not operating, or during scheduled
startup and shutdown periods, and during malfunctions. These startup
and shutdown periods must not exceed the minimum amount of time
necessary for these events, and during these events, you must minimize
emissions to the greatest extent possible.
(e) You must, at the beginning of each semiannual compliance
period, record your control device maintenance schedule for that
period. To the extent practical, startup and shutdown of emission
control systems must be scheduled during times when process equipment
is also shutdown for routine maintenance.
(f) If you use a catalytic oxidizer, you must maintain and operate
the catalyst according to the manufacturer's specifications.

Sec. 63.2251 What are the requirements for the routine control device
maintenance exemption?
(a) You may request a routine control device maintenance exemption
from the Administrator. Your request must justify the need for the
routine maintenance on the control device and the time required to
accomplish the maintenance activities, describe the maintenance
activities and the frequency of the maintenance activities, explain why
the maintenance cannot be accomplished during process shutdowns,
describe how you plan to minimize emissions to the greatest extent
possible during the maintenance, and provide any other documentation
required by the Administrator.
(b) The routine control device maintenance exemption must not
exceed the percentages of process unit operating uptime in paragraphs
(b)(1) and (2) of this section.
(1) If the control device is used to control a green rotary dryer,
tube dryer, strand dryer, or pressurized refiner, then the routine
control device maintenance exemption must not exceed 3 percent of
annual operating uptime for each process unit controlled.
(2) If the control device is used to control a softwood veneer
dryer, reconstituted wood product press, reconstituted wood product
board cooler, hardboard oven, press predryer, or fiberboard mat dryer,
then the routine control device maintenance exemption must not exceed
0.5 percent of annual operating uptime for each process unit
controlled.
(3) If the control device is used to control a combination of
equipment listed in both paragraphs (b)(1) and (2) of this section,
such as a tube dryer and a reconstituted wood product press, then the
routine control device maintenance exemption must not exceed 3 percent
of annual operating uptime for each process unit controlled.
(c) The request for the routine control device maintenance
exemption, if approved by the Administrator, must be incorporated by
reference in and attached to the affected source's title V permit.
(d) The compliance options and operating requirements do not apply
during times when control device maintenance covered under your
approved routine control device maintenance exemption is performed. You
must minimize emissions to the greatest extent possible during these
routine control device maintenance periods.
(e) You must, at the beginning of each semiannual compliance
period, record your control device maintenance schedule for that
period. To the extent practical, startup and shutdown of emission
control systems must be scheduled during times when process equipment
is also shutdown.
Initial Compliance Requirements

Sec. 63.2260 How do I demonstrate initial compliance with the
compliance options, operating requirements, and work practice
requirements?
(a) To demonstrate initial compliance with the compliance options
and operating requirements, you must conduct performance tests and
establish each site-specific operating requirement in Table 2 of this
subpart according to the requirements in Sec. 63.2262 and Table 4 of
this subpart. Combustion units with heat input capacity of greater than
or equal to 44 megawatts that accept process exhausts into the flame
zone are exempt from the initial performance testing and operating
requirements for thermal oxidizers.
(b) You must demonstrate initial compliance with each compliance
option, operating requirement, and work practice requirement that
applies to you according to Tables 5 and 6 of this subpart and
according to Sec. Sec. 63.2260 through 63.2268 of this subpart.
(c) You must submit the Notification of Compliance Status
containing the results of the initial compliance demonstration
according to the requirements in Sec. 63.2280(d).

Sec. 63.2261 By what date must I conduct performance tests or other
initial compliance demonstrations?
(a) You must conduct performance tests upon initial startup or no
later than 180 calendar days after the compliance date that is
specified for your source in Sec. 63.2233 and according to Sec.
63.7(a)(2), whichever is later.
(b) You must conduct initial compliance demonstrations that do not
require performance tests upon initial startup or no later than 30
calendar days after the compliance date that is specified for your
source in Sec. 63.2233, whichever is later.
[[Page 1314]]
Sec. 63.2262 How do I conduct performance tests and establish
operating requirements?
(a) You must conduct each performance test according to the
requirements in Sec. 63.7(e)(1), the requirements in paragraphs (b)
through (o) of this section, and according to the methods specified in
Table 4 of this subpart.
(b) Periods when performance tests must be conducted.
(1) You must not conduct performance tests during periods of
startup, shutdown, or malfunction, as specified in Sec. 63.7(e)(1).
(2) You must test under representative operating conditions as
defined in Sec. 63.2292. You must describe representative operating
conditions in your performance test report for the process and control
systems and explain why they are representative.
(c) Number of test runs. You must conduct three separate test runs
for each performance test required in this section, as specified in
Sec. 63.7(e)(3). Each test run must last at least 1 hour except for:
testing of a temporary total enclosure (TTE) conducted using Methods
204A through 204F which require three separate test runs of at least 3
hours each; and testing of an enclosure conducted using the alternative
tracer gas method in appendix A to this subpart which requires a
minimum of three separate runs of at least 20 minutes each.
(d) Location of sampling sites. Sampling sites must be located at
the inlet (if emission reduction testing or documentation of inlet
methanol or formaldehyde concentration is required) and outlet of the
control device and prior to any releases to the atmosphere.
(e) Collection of monitoring data. You must collect operating
parameter monitoring system or continuous emissions monitoring system
(CEMS) data at least every 15 minutes during the entire initial
performance test and determine the parameter or concentration value for
the operating requirement during the performance test using the methods
specified in paragraphs (k) through (o) of this section.
(f) Collection of production data. To comply with any of the
production-based compliance options, you must measure and record the
process unit throughput during each test.
(g) Nondetect data. When determining total HAP, formaldehyde,
methanol, or THC emission rates, all nondetect data, as defined in
Sec. 63.2292, must be treated as one-half of the method detection
limit.
(h) Calculation of percent reduction across a control system. When
determining the control system efficiency for any control system
included in your emissions averaging plan (not to exceed 90 percent)
and when complying with any of the compliance options based on percent
reduction across a control system in Table 1B of this subpart, as part
of the performance test, you must calculate the percent reduction using
Equation 1 of this section:
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.008
Where:
PR = percent reduction, percent
CE = capture efficiency, percent (determined for reconstituted wood
product presses and board coolers as required in Table 4 of this
subpart)
ER_in = emission rate of total HAP (calculated as the sum of
the emission rates of acetaldehyde, acrolein, formaldehyde, methanol,
phenol, and propionaldehyde), THC, formaldehyde, or methanol in the
inlet vent stream of the control device, pounds per hour
ER_out = emission rate of total HAP (calculated as the sum of
the emission rates of acetaldehyde, acrolein, formaldehyde, methanol,
phenol, and propionaldehyde), THC, formaldehyde, or methanol in the
outlet vent stream of the control device, pounds per hour
(i) Calculation of mass per unit production. To comply with any of
the production-based compliance options in Table 1A of this subpart,
you must calculate your mass per unit production emissions for each
test run using Equation 2 of this section:
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.009
Where:
MP = mass per unit production, pounds per oven dried ton OR pounds per
thousand square feet on a specified thickness basis (see paragraph (j)
of this section if you need to convert from one thickness basis to
another)
ER_HAP = emission rate of total HAP (calculated as the sum of
the emission rates of acetaldehyde, acrolein, formaldehyde, methanol,
phenol, and propionaldehyde) in the stack, pounds per hour
P = process unit production rate (throughput), oven dried tons per hour
OR thousand square feet per hour on a specified thickness basis
CE = capture efficiency, percent (determined for reconstituted wood
product presses and board coolers as required in Table 4 of this
subpart)
?£(j) Thickness basis conversion. Use Equation 3 of this
section to convert from one thickness basis to another:
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.010
Where:
MSF_A = thousand square feet on an A-inch basis
MSF_B = thousand square feet on a B-inch basis
A = old thickness you are converting from, inches
B = new thickness you are converting to, inches
(k) Establishing thermal oxidizer operating requirements. If you
operate a thermal oxidizer, you must establish your thermal oxidizer
operating parameters according to paragraphs (k)(1) through (4) of this
section.
(1) During the initial performance test, you must continuously
monitor the firebox temperature during each of the required 1-hour test
runs. The minimum firebox temperature must then be established as the
average of the three minimum 15-minute firebox temperatures monitored
during the three test runs. Multiple 3-run performance tests may be
conducted to establish a range of parameter values under different
operating conditions.
(2) If you choose to monitor inlet static pressure during the
initial performance test, you must continuously monitor the static
pressure at the inlet of the thermal oxidizer during each of the
required 1-hour test runs. The static pressure operating range must
then be established as the maximum and minimum of the 15-minute static
pressures monitored during the entire 3-hour test. Multiple 3-run
performance tests may be conducted to establish a range of parameter
values under different operating conditions.
(3) If you choose to monitor stack gas flow during the initial
performance test, you must continuously monitor the gas flow rate at
the thermal oxidizer stack during each of the required 1-hour test
runs. The maximum flow rate must then be established as the average of
the three maximum 15-minute flow rates monitored during the three test
runs. Multiple 3-run performance tests may be conducted to establish a
range of parameter values under different operating conditions.
(4) You may establish a different minimum firebox temperature,
static
[[Page 1315]]
pressure operating range, or maximum stack gas flow rate for your
thermal oxidizer by submitting the notification specified in Sec.
63.2280(g) and conducting a repeat performance test as specified in
paragraphs (k)(1) and (3) of this section that demonstrates compliance
with the compliance options in Table 1B of this subpart.
(5) If your thermal oxidizer is a combustion unit with a heat input
capacity greater than or equal to 44 megawatts, then you are exempt
from the initial performance testing and monitoring requirements
specified in paragraphs (k)(1) through (4) of this section. To
demonstrate initial compliance, you must submit documentation with your
Notification of Compliance Status showing that your combustion unit has
a heat input capacity of greater than or equal to 44 megawatts and that
process exhausts controlled by the combustion unit enter into the flame
zone.
(l) Establishing catalytic oxidizer operating requirements. If you
operate a catalytic oxidizer, you must establish your catalytic
oxidizer operating parameters according to paragraphs (l)(1) through
(4) of this section.
(1) During the initial performance test, you must continuously
monitor the temperature upstream of the catalyst bed during the
required 1-hour test runs. The minimum upstream temperature must then
be established as the average of the three minimum 15-minute
temperatures upstream of the catalyst bed monitored during the three
test runs. Multiple 3-run performance tests may be conducted to
establish a range of parameter values under different operating
conditions.
(2) If you choose to monitor inlet static pressure during the
initial performance test, you must continuously monitor the static
pressure at the inlet of the catalytic oxidizer during each of the
required 1-hour test runs. The static pressure operating range must
then be established as the maximum and minimum of the 15-minute static
pressures monitored during the entire 3-hour test. Multiple 3-run
performance tests may be conducted to establish a range of parameter
values under different operating conditions.
(3) If you choose to monitor stack gas flow during the initial
performance test, you must continuously monitor the gas flow rate at
the catalytic oxidizer stack during each of the required 1-hour test
runs. The maximum flow rate must then be established as the average of
the three maximum 15-minute flow rates monitored during the three test
runs. Multiple 3-run performance tests may be conducted to establish a
range of parameter values under different operating conditions.
(4) You may establish a different minimum upstream temperature,
static pressure operating range, or maximum stack gas flow rate for
your catalytic oxidizer by submitting the notification specified in
Sec. 63.2280(g) and conducting a repeat performance test as specified
in paragraphs (l)(1) through (3) of this section that demonstrates
compliance with the compliance options in Table 1B of this subpart.
(m) Establishing biofilter operating requirements. If you operate a
biofilter, you must establish your average biofilter operating
requirements according to paragraphs (m)(1) through (3) of this
section.
(1) During the initial performance test, you must monitor the
temperature of the air stream entering the biofilter, pH of the
biofilter effluent, and pressure drop across the biofilter bed. You
must specify appropriate monitoring methods, monitoring frequencies,
and averaging times for the parameters. You also must specify
appropriate minimum limits, maximum limits, or operating ranges for the
parameters you will monitor. You may base operating ranges on values
recorded during previous performance tests provided that the data used
to establish the operating ranges have been obtained using the test
methods required in this subpart. If you use data from previous
performance tests, you must certify that the biofilter and associated
process unit(s) have not been modified subsequent to the date the
historical data were collected.
(2) If historical operating records are not readily available (as
would be the case for a new biofilter installation), you will be
allowed up to 180 days following the compliance date to gather data and
complete the requirements in paragraph (m)(1) of this section.
(3) You may establish different operating ranges for your biofilter
operating parameters by submitting the notification specified in Sec.
63.2280(g) and conducting a repeat performance test as specified in
paragraph (m)(1) of this section that demonstrates compliance with the
compliance options in Table 1B of this subpart.
(n) Establishing uncontrolled process unit operating requirements.
If you operate a process unit that meets a compliance option in Table
1A of this subpart without the use of a control device, you must
establish your process unit operating parameters according to
paragraphs (n)(1) through (2) of this section.
(1) During the initial performance test, you must continuously
monitor the process unit inlet temperature or operating temperature
(whichever applies, as specified for different process units in Table 2
of this subpart) during each of the required 1-hour test runs. The
maximum inlet temperature or maximum operating temperature must then be
established as the average of the three maximum 15-minute temperatures
monitored during the three test runs. Multiple 3-run performance tests
may be conducted to establish a range of parameter values under
different operating conditions.
(2) You may establish a different maximum temperature for your
process unit by submitting the notification specified in Sec.
63.2280(g) and conducting a repeat performance test as specified in
paragraph (n)(1) of this section that demonstrates compliance with the
compliance options in Table 1A of this subpart.
(o) Establishing operating requirements using total hydrocarbon
(THC) CEMS. If you choose to meet the operating requirements by
monitoring THC concentration instead of monitoring control device or
process operating parameters, you must establish your THC concentration
operating requirement according to paragraphs (o)(1) through (2) of
this section.
(1) During the initial performance test, you must continuously
monitor THC concentration using your CEMS during each of the required
1-hour test runs. The maximum THC concentration must then be
established as the average of the three maximum 15-minute THC
concentrations monitored during the three test runs. Multiple 3-run
performance tests may be conducted to establish a range of THC
concentration values under different operating conditions.
(2) You may establish a different maximum THC concentration by
submitting the notification specified in Sec. 63.2280(g) and
conducting a repeat performance test as specified in paragraph (o)(1)
of this section that demonstrates compliance with the compliance
options in Tables 1A and 1B of this subpart.

Sec. 63.2263 Initial compliance demonstration for a dry rotary dryer.
If you operate a dry rotary dryer, you must demonstrate that your
dryer processes furnish with an inlet moisture content of less than or
equal to 30 percent (by weight, dry basis) and operates with a dryer
inlet temperature of less than or equal to 600 [deg]F. You must
designate and clearly identify each dry rotary dryer. You must record
the inlet furnish moisture content (dry basis) and inlet dryer
[[Page 1316]]
operating temperature according to Sec. 63.2268(a), (b), and (f) for a
minimum of 30 calendar days. You must submit the highest recorded 24-
hour average inlet furnish moisture content and the highest recorded
24-hour average dryer inlet temperature with your Notification of
Compliance Status. In addition, submit with the Notification of
Compliance Status a signed statement by a responsible official that
certifies with truth, accuracy, and completeness that the dry rotary
dryer will dry furnish with a maximum inlet moisture content less than
or equal to 30 percent (by weight, dry basis) and will operate with a
maximum inlet temperature of less than or equal to 600[deg]F in the
future.

Sec. 63.2264 Initial compliance demonstration for a hardwood veneer
dryer.
If you operate a hardwood veneer dryer, you must record the annual
volume percentage of softwood veneer species processed in the dryer as
follows:
(a) Use Equation 1 of this section to calculate the annual volume
percentage of softwood species dried:
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.011
Where:
SW_[percnt] = annual volume percent softwood species dried
SW = softwood veneer dried during the previous 12 months, thousand
square feet (\3/8\-inch basis)
T = total softwood and hardwood veneer dried during the previous 12
months, thousand square feet (\3/8\-inch basis)
(b) You must designate and clearly identify each hardwood veneer
dryer. Submit with the Notification of Compliance Status the annual
volume percentage of softwood species dried in the dryer based on your
dryer production for the 12 months prior to the compliance date
specified for your source in Sec. 63.2233. If you did not dry any
softwood species in the dryer during the 12 months prior to the
compliance date, then you need only to submit a statement indicating
that no softwood species were dried. In addition, submit with the
Notification of Compliance Status a signed statement by a responsible
official that certifies with truth, accuracy, and completeness that the
veneer dryer will be used to process less than 30 volume percent
softwood species in the future.

Sec. 63.2265 Initial compliance demonstration for a softwood veneer
dryer.
If you operate a softwood veneer dryer, you must develop a plan for
review and approval for minimizing fugitive emissions from the veneer
dryer heated zones, and you must submit the plan with your Notification
of Compliance Status.

Sec. 63.2266 Initial compliance demonstration for a veneer redryer.
If you operate a veneer redryer, you must record the inlet moisture
content of the veneer processed in the redryer according to Sec.
63.2268(a) and (f) for a minimum of 30 calendar days. You must
designate and clearly identify each veneer redryer. You must submit the
highest recorded 24-hour average inlet veneer moisture content with
your Notification of Compliance Status to show that your veneer redryer
processes veneer with an inlet moisture content of less than or equal
to 25 percent (by weight, dry basis). In addition, submit with the
Notification of Compliance Status a signed statement by a responsible
official that certifies with truth, accuracy, and completeness that the
veneer redryer will dry veneer with a moisture content less than 25
percent (by weight, dry basis) in the future.

Sec. 63.2267 Initial compliance demonstration for a reconstituted
wood product press or board cooler.
If you operate a reconstituted wood product press at a new or
existing affected source or a reconstituted wood product board cooler
at a new affected source, then you must verify the capture efficiency
of the capture device for the press or board cooler using Methods 204
and 204A through 204F of 40 CFR part 51, appendix M (as appropriate) or
using the alternative tracer gas method contained in appendix A to this
subpart. You must submit the results of the capture efficiency
verification with your Notification of Compliance Status.

Sec. 63.2268 What are my monitoring installation, operation, and
maintenance requirements?
(a) General continuous parameter monitoring requirements. You must
install, operate, and maintain each continuous parameter monitoring
system (CPMS) according to paragraphs (a)(1) through (5) of this
section.
(1) The CPMS must complete a minimum of one cycle of operation for
each successive 15-minute period. To calculate a valid hourly value,
you must have at least three equally spaced data values for that hour
from a CPMS that is not out of control.
(2) At all times, you must maintain the monitoring equipment
including, but not limited to, maintaining necessary parts for routine
repairs of the monitoring equipment.
(3) Except as provided in paragraph (a)(4) of this section,
determine the 3-hour block average of all recorded readings, calculated
after every 3 hours of operation as the average of the previous 3
operating hours (not including startup, shutdown, and malfunction or
periods of control device maintenance covered by any approved routine
control device maintenance exemption).
(4) For dry rotary dryer and veneer redryer wood moisture
monitoring and for dry rotary dryer temperature monitoring, determine
the 24-hour block average of all recorded readings, calculated after
every 24 hours of operation as the average of the previous 24 operating
hours (not including startup, shutdown, and malfunction). To calculate
the average wood moisture or temperature for each 24-hour averaging
period, you must have at least 75 percent of the hourly averages for
that period using only hourly average values that are based on valid
data (i.e., not from periods when the monitor is out of control).
(5) Record the results of each inspection, calibration, and
validation check.
(b) Temperature monitoring. For each temperature monitoring device,
you must meet the requirements in paragraphs (a) and (b)(1) through (6)
of this section.
(1) Locate the temperature sensor in a position that provides a
representative temperature.
(2) Use a temperature sensor with a minimum tolerance of 4 [deg]F
or 0.75 percent of the temperature value, whichever is larger.
(3) If a chart recorder is used, it must have a sensitivity in the
minor division of at least 20 [deg]F.
(4) Perform an electronic calibration at least semiannually
according to the procedures in the manufacturer's owners manual.
Following the electronic calibration, you must conduct a temperature
sensor validation check in which a second or redundant temperature
sensor placed nearby the process temperature sensor must yield a
reading within 30 [deg]F of the process temperature sensor's reading.
(5) Conduct calibration and validation checks any time the sensor
exceeds the manufacturer's specified maximum operating temperature
range or install a new temperature sensor.
(6) At least quarterly, inspect all components for integrity and
all electrical connections for continuity, oxidation, and galvanic
corrosion.
(c) Pressure monitoring. For each pressure measurement device, you
must
[[Page 1317]]
meet the requirements in paragraphs (a) and (c)(1) through (7) of this
section.
(1) Locate the pressure sensor(s) in or as close to a position that
provides a representative measurement of the pressure.
(2) Minimize or eliminate pulsating pressure, vibration, and
internal and external corrosion.
(3) Use a gauge with a minimum tolerance of 0.5 inches of water
column or a transducer with a minimum tolerance of 1 percent of the
pressure range.
(4) Check pressure tap daily to ensure it is not plugged.
(5) Using a manometer, check gauge calibration quarterly and
transducer calibration monthly.
(6) Conduct calibration checks any time the sensor exceeds the
manufacturer's specified maximum operating pressure range or install a
new pressure sensor.
(7) At least quarterly, inspect all components for integrity, all
electrical connections for continuity, and all mechanical connections
for leakage.
(d) pH monitoring. For each pH measurement device, you must meet
the requirements in paragraphs (a) and (d)(1) through (4) of this
section.
(1) Locate the pH sensor in a position that provides a
representative measurement of pH.
(2) Ensure the sample is properly mixed and representative of the
fluid to be measured.
(3) Check the pH meter's calibration on at least two points every 8
hours of process operation.
(4) At least quarterly, inspect all components for integrity and
all electrical connections for continuity.
(e) Flow monitoring. For each flow measurement device, you must
meet the requirements in paragraphs (a) and (e)(1) through (5) of this
section.
(1) Locate the flow sensor and other necessary equipment such as
straightening vanes in a position that provides a representative flow.
(2) Use a flow sensor with a minimum tolerance of 2 percent of the
flow rate.
(3) Reduce swirling flow or abnormal velocity distributions due to
upstream and downstream disturbances.
(4) Conduct a flow sensor calibration check at least semiannually.
(5) At least quarterly, inspect all components for integrity, all
electrical connections for continuity, and all mechanical connections
for leakage.
(f) Wood moisture monitoring. For each furnish or veneer moisture
meter, you must meet the requirements in paragraphs (a)(1), (2), (4)
and (5) and paragraphs (f)(1) through (4) of this section.
(1) Use a moisture monitor with a minimum accuracy of 1 percent
moisture or better. Alternatively, you may use a moisture monitor with
a minimum accuracy of 5 percent moisture or better for dry rotary
dryers used to dry furnish with less than 25 percent moisture or for
veneer redryers used to redry veneer with less than 20 percent
moisture.
(2) Locate the moisture meter in a position that provides a
representative measure of furnish or veneer moisture.
(3) Check the moisture meter's calibration by manually determining
the moisture content of samples of furnish or veneer at least once each
day of process operation as follows:
(i) Collect a sample of furnish or veneer just as it passes by the
meter.
(ii) Record the moisture meter reading for the sample of furnish or
veneer collected.
(iii) Determine the moisture content of the furnish or veneer
sample by first weighing the wet sample and thoroughly drying the
sample until it reaches a constant weight in a bench-scale dryer. Use
Equation 1 of this section to calculate the furnish or veneer moisture
weight percent on a dry basis:
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.012
Where:
MC = moisture content of wood material (weight percent, dry basis)
W_wet = original weight of the wood, pounds
W_dry = weight of the dried wood, pounds
(4) At least quarterly, inspect all components of the moisture
meter for integrity and all electrical connections for continuity.
(g) Continuous emission monitoring system(s). Each CEMS must be
installed, operated, and maintained according to paragraphs (g)(1)
through (4) of this section.
(1) Each CEMS for monitoring THC concentration must be installed,
operated, and maintained according to Performance Specification 8 of 40
CFR part 60, appendix B. You must also comply with Procedure 1 of 40
CFR part 60, appendix F.
(2) You must conduct a performance evaluation of each CEMS
according to the requirements in 40 CFR 63.8 and according to
Performance Specification 8 of 40 CFR part 60, appendix B.
(3) As specified in Sec. 63.8(c)(4)(ii), each CEMS must complete a
minimum of one cycle of operation (sampling, analyzing, and data
recording) for each successive 15-minute period.
(4) The CEMS data must be reduced as specified in Sec. 63.8(g)(2)
and paragraph (a)(3) of this section.
Continuous Compliance Requirements

Sec. 63.2270 How do I monitor and collect data to demonstrate
continuous compliance?
(a) You must monitor and collect data according to this section.
(b) Except for, as appropriate, monitor malfunctions, associated
repairs, and required quality assurance or control activities
(including, as applicable, calibration checks and required zero and
span adjustments), you must conduct all monitoring in continuous
operation at all times that the process unit is operating. For purposes
of calculating data averages, you must not use data recorded during
monitoring malfunctions, associated repairs, out-of-control periods, or
required quality assurance or control activities. You must use all the
data collected during all other periods in assessing compliance. A
monitoring malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring to provide valid data. Monitoring
failures that are caused in part by poor maintenance or careless
operation are not malfunctions. Any period for which the monitoring
system is out-of-control and data are not available for required
calculations constitutes a deviation from the monitoring requirements.
(c) You may not use data recorded during monitoring malfunctions,
associated repairs, and required quality assurance or control
activities or data recorded during periods of control device downtime
covered in any approved routine control device maintenance exemption in
data averages and calculations used to report emission or operating
levels, nor may such data be used in fulfilling a minimum data
availability requirement, if applicable. You must use all the data
collected during all other periods in assessing the operation of the
control system.

Sec. 63.2271 How do I demonstrate continuous compliance with the
compliance options, operating requirements, and work practice
requirements?
(a) You must demonstrate continuous compliance with the compliance
options, operating requirements, and work practice requirements in
Sec. Sec. 63.2240 and 63.2241 that apply to you according to the
methods specified in Tables 7 and 8 of this subpart.
(b) You must report each instance in which you did not meet each
compliance option, operating requirement, and work practice
[[Page 1318]]
requirement in Tables 7 and 8 of this subpart that applies to you. This
includes periods of startup, shutdown, or malfunction and periods of
control device maintenance specified in paragraphs (b)(1) and (3) of
this section. These instances are deviations from the compliance
options, operating requirements, and work practice requirements in this
subpart. These deviations must be reported according to the
requirements in Sec. 63.2281.
(1) During periods of startup, shutdown, or malfunction, you must
operate in accordance with the SSMP.
(2) Consistent with Sec. 63.6(e) and 63.7(e)(1), deviations that
occur during a period of startup, shutdown, or malfunction are not
violations if you demonstrate to the Administrator's satisfaction that
you were operating in accordance with the SSMP. The Administrator will
determine whether deviations that occur during a period of startup,
shutdown, or malfunction are violations, according to the provisions in
Sec. 63.6(e).
(3) Deviations that occur during periods of control device
maintenance covered by any approved routine control device maintenance
exemption are not violations if you demonstrate to the Administrator's
satisfaction that you were operating in accordance with the approved
routine control device maintenance exemption.
Notifications, Reports, and Records

Sec. 63.2280 What notifications must I submit and when?
(a) You must submit all of the notifications in Sec. Sec. 63.7(b)
and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and
(h) by the dates specified.
(b) You must submit an Initial Notification no later than 120
calendar days after the effective date of the subpart or after initial
startup, whichever is later, as specified in Sec. 63.9(b)(2) and (3).
(c) If you are required to conduct a performance test, you must
submit a written notification of intent to conduct a performance test
at least 60 calendar days before the performance test is scheduled to
begin as specified in Sec. 63.7(b)(1).
(d) If you are required to conduct a performance test, design
evaluation, or other initial compliance demonstration as specified in
Tables 4, 5, and 6 of this subpart, you must submit a Notification of
Compliance Status as specified in Sec. 63.9(h)(2)(ii).
(1) For each initial compliance demonstration required in Table 5
or 6 of this subpart that does not include a performance test, you must
submit the Notification of Compliance Status before the close of
business on the 30th calendar day following the completion of the
initial compliance demonstration.
(2) For each initial compliance demonstration required in Tables 5
and 6 of this subpart that includes a performance test conducted
according to the requirements in Table 4 of this subpart, you must
submit the Notification of Compliance Status, including the performance
test results, before the close of business on the 60th calendar day
following the completion of the performance test according to Sec.
63.10(d)(2).
(e) If you request a routine control device maintenance exemption
according to Sec. 63.2251, you must submit your request for the
exemption no later than 30 days before the compliance date.
(f) If you use the emissions averaging compliance option in Sec.
63.2240(c), you must submit an Emissions Averaging Plan to the
Administrator for approval no later than 1 year before the compliance
date or no later than 1 year before the date you would begin using an
emissions average, whichever is later. The Emissions Averaging Plan
must include the information in paragraphs (f)(1) through (6) of this
section.
(1) Identification of all the process units to be included in the
emissions average indicating which process units will be used to
generate credits, and which process units that are subject to
compliance options in Tables 1A and 1B of this subpart will be
uncontrolled or under-controlled (used to generate debits).
(2) Description of the control system used to generate emission
credits for each process unit used to generate credits.
(3) Determination of the total HAP control efficiency for the
control system used to generate emission credits for each credit-
generating process unit.
(4) Calculation of the RMR and AMR, as calculated using Equations 1
through 3 of Sec. 63.2240(c)(1).
(5) Documentation of total HAP measurements made according to Sec.
63.2240(c)(2)(iv) and other relevant documentation to support
calculation of the RMR and AMR.
(6) A summary of the operating parameters you will monitor and
monitoring methods for each credit-generating process unit.
(g) You must notify the Administrator within 30 days before you
take any of the actions specified in paragraphs (g)(1) through (3) of
this section.
(1) You modify or replace the control system for any process unit
subject to the compliance options and operating requirements in this
subpart.
(2) You shutdown any process unit included in your Emissions
Averaging Plan.
(3) You change a continuous monitoring parameter or the value or
range of values of a continuous monitoring parameter for any process
unit or control device.

Sec. 63.2281 What reports must I submit and when?
(a) You must submit each report in Table 9 of this subpart that
applies to you.
(b) Unless the Administrator has approved a different schedule for
submission of reports under Sec. 63.10(a), you must submit each report
by the date in Table 9 of this subpart and as specified in paragraphs
(b)(1) through (5) of this section.
(1) The first compliance report must cover the period beginning on
the compliance date that is specified for your affected source in Sec.
63.2233 ending on June 30 or December 31, and lasting at least 6
months, but less than 12 months. For example, if your compliance date
is March 1, then the first semiannual reporting period would begin on
March 1 and end on December 31.
(2) The first compliance report must be postmarked or delivered no
later than July 31 or January 31 for compliance periods ending on June
30 and December 31, respectively.
(3) Each subsequent compliance report must cover the semiannual
reporting period from January 1 through June 30 or the semiannual
reporting period from July 1 through December 31.
(4) Each subsequent compliance report must be postmarked or
delivered no later than July 31 or January 31 for the semiannual
reporting period ending on June 30 and December 31, respectively.
(5) For each affected source that is subject to permitting
regulations pursuant to 40 CFR part 70 or 71, and if the permitting
authority has established dates for submitting semiannual reports
pursuant to Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), you
may submit the first and subsequent compliance reports according to the
dates the permitting authority has established instead of according to
the dates in paragraphs (b)(1) through (4) of this section.
(c) The compliance report must contain the information in
paragraphs (c)(1) through (8) of this section.
[[Page 1319]]
(1) Company name and address.
(2) Statement by a responsible official with that official's name,
title, and signature, certifying the truth, accuracy, and completeness
of the content of the report.
(3) Date of report and beginning and ending dates of the reporting
period.
(4) If you had a startup, shutdown, or malfunction during the
reporting period and you took actions consistent with your SSMP, the
compliance report must include the information specified in Sec.
63.10(d)(5)(i).
(5) A description of control device maintenance performed while the
control device was offline and one or more of the process units
controlled by the control device was operating, including the
information specified in paragraphs (c)(5)(i) through (iii) of this
section.
(i) The date and time when the control device was shutdown and
restarted.
(ii) Identification of the process units that were operating and
the number of hours that each process unit operated while the control
device was offline.
(iii) A statement of whether or not the control device maintenance
was included in your approved routine control device maintenance
exemption developed pursuant to Sec. 63.2251. If the control device
maintenance was included in your approved routine control device
maintenance exemption, then you must report the information in
paragraphs (c)(5)(iii)(A) through (C) of this section.
(A) The total amount of time that each process unit controlled by
the control device operated during the semiannual compliance period and
during the previous semiannual compliance period.
(B) The amount of time that each process unit controlled by the
control device operated while the control device was down for
maintenance covered under the routine control device maintenance
exemption during the semiannual compliance period and during the
previous semiannual compliance period.
(C) Based on the information recorded under paragraphs
(c)(5)(iii)(A) and (B) of this section for each process unit, compute
the annual percent of process unit operating uptime during which the
control device was offline for routine maintenance using Equation 1 of
this section.
[GRAPHIC]
[TIFF OMITTED]
TP09JA03.013
Where:
RM = Annual percentage of process unit uptime during which control
device is down for routine control device maintenance
PU_p = Process unit uptime for the previous semiannual
compliance period
PU_c = Process unit uptime for the current semiannual
compliance period
DT_p = Control device downtime claimed under the routine
control device maintenance exemption for the previous semiannual
compliance period
DT_c = Control device downtime claimed under the routine
control device maintenance exemption for the current semiannual
compliance period
(6) The results of any performance tests conducted during the
semiannual reporting period.
(7) If there are no deviations from any applicable compliance
option or operating requirement, and there are no deviations from the
requirements for work practice requirements in Table 8 of this subpart,
a statement that there were no deviations from the compliance options,
operating requirements, or work practice requirements during the
reporting period.
(8) If there were no periods during which the continuous monitoring
system(s) (CMS), including CEMS and CPMS, was out-of-control as
specified in Sec. 63.8(c)(7), a statement that there were no periods
during which the CMS was out-of-control during the reporting period.
(d) For each deviation from a compliance option or operating
requirement and for each deviation from the work practice requirements
in Table 8 of this subpart that occurs at an affected source where you
are not using a CMS to comply with the compliance options, operating
requirements, or work practice requirements in this subpart, the
compliance report must contain the information in paragraphs (c)(1)
through (6) of this section and the information in paragraphs (d)(1)
and (2) of this section. This includes periods of startup, shutdown,
and malfunction and routine control device maintenance.
(1) The total operating time of each affected source during the
reporting period.
(2) Information on the number, duration, and cause of deviations
(including unknown cause, if applicable), as applicable, and the
corrective action taken.
(e) For each deviation from a compliance option or operating
requirement occurring at an affected source where you are using a CMS
to comply with the compliance options and operating requirements in
this subpart, you must include the information in paragraphs (c)(1)
through (6) and the information in paragraphs (e)(1) through (11) of
this section. This includes periods of startup, shutdown, and
malfunction and routine control device maintenance.
(1) The date and time that each malfunction started and stopped.
(2) The date and time that each CMS was inoperative, except for
zero (low-level) and high-level checks.
(3) The date, time, and duration that each CMS was out-of-control,
including the information in Sec. 63.8(c)(8).
(4) The date and time that each deviation started and stopped, and
whether each deviation occurred during a period of startup, shutdown,
or malfunction; during a period of control device maintenance covered
in your approved routine control device maintenance exemption; or
during another period.
(5) A summary of the total duration of the deviation during the
reporting period and the total duration as a percent of the total
source operating time during that reporting period.
(6) A breakdown of the total duration of the deviations during the
reporting period into those that are due to startup, shutdown, control
system problems, control device maintenance, process problems, other
known causes, and other unknown causes.
(7) A summary of the total duration of CMS downtime during the
reporting period and the total duration of CMS downtime as a percent of
the total source operating time during that reporting period.
(8) A brief description of the process units.
(9) A brief description of the CMS.
(10) The date of the latest CMS certification or audit.
(11) A description of any changes in CMS, processes, or controls
since the last reporting period.
(f) If you comply with the emissions averaging compliance option in
Sec. 63.2240(c), you must include in your semiannual compliance report
calculations based on operating data from the semiannual reporting
period that demonstrate that actual mass removal equals or exceeds the
required mass removal.
(g) Each affected source that has obtained a title V operating
permit pursuant to 40 CFR part 70 or 71 must report all deviations as
defined in this subpart in the semiannual monitoring report required by
Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A). If an affected
source submits a compliance report pursuant to
[[Page 1320]]
Table 9 of this subpart along with, or as part of, the semiannual
monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec.
71.6(a)(3)(iii)(A), and the compliance report includes all required
information concerning deviations from any compliance option, operating
requirement, or work practice requirement in this subpart, submission
of the compliance report shall be deemed to satisfy any obligation to
report the same deviations in the semiannual monitoring report.
However, submission of a compliance report shall not otherwise affect
any obligation the affected source may have to report deviations from
permit requirements to the permitting authority.

Sec. 63.2282 What records must I keep?
(a) You must keep the records listed in paragraphs (a)(1) through
(4) of this section.
(1) A copy of each notification and report that you submitted to
comply with this subpart, including all documentation supporting any
Initial Notification or Notification of Compliance Status that you
submitted, according to the requirements in Sec. 63.10(b)(2)(xiv).
(2) The records in Sec. 63.6(e)(3)(iii) through (v) related
to startup, shutdown, and malfunction.
(3) The records in Sec. 63.2250(e) relating to control device
maintenance and documentation of your approved routine control device
maintenance exemption, if you request such an exemption under Sec.
63.2251.
(4) Records of performance tests and performance evaluations as
required in Sec. 63.10(b)(2)(viii).
(b) You must keep the records required in Tables 7 and 8 of this
subpart to show continuous compliance with each compliance option,
operating requirement, and work practice requirement that applies to
you.
(c) For each CEMS, you must keep the following records.
(1) Records described in Sec. 63.10(b)(2)(vi) through (xi).
(2) Previous (i.e., superseded) versions of the performance
evaluation plan as required in Sec. 63.8(d)(3).
(3) Request for alternatives to relative accuracy testing for CEMS
as required in Sec. 63.8(f)(6)(i).
(4) Records of the date and time that each deviation started and
stopped, and whether the deviation occurred during a period of startup,
shutdown, or malfunction or during another period.
(d) If you comply with the emissions averaging compliance option in
Sec. 63.2240(c), you must keep records of all information required to
calculate emission debits and credits.

Sec. 63.2283 In what form and how long must I keep my records?
(a) Your records must be in a form suitable and readily available
for expeditious review as specified in Sec. 63.10(b)(1).
(b) As specified in Sec. 63.10(b)(1), you must keep each record
for 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record.
(c) You must keep each record on site for at least 2 years after
the date of each occurrence, measurement, maintenance, corrective
action, report, or record according to Sec. 63.10(b)(1). You can keep
the records offsite for the remaining 3 years.
Other Requirements and Information

Sec. 63.2290 What parts of the General Provisions apply to me?
Table 10 of this subpart shows which parts of the General
Provisions in Sec. Sec. 63.1 through 63.13 apply to you.

Sec. 63.2291 Who implements and enforces this subpart?
(a) This subpart can be implemented and enforced by the U.S. EPA or
a delegated authority such as your State, local, or tribal agency. If
the EPA Administrator has delegated authority to your State, local, or
tribal agency, then that agency has the authority to implement and
enforce this subpart. You should contact your EPA Regional Office to
find out if this subpart is delegated to your State, local, or tribal
agency.
(b) In delegating implementation and enforcement authority of this
subpart to a State, local, or tribal agency under section 40 CFR part
63, subpart E, the authorities contained in paragraph (c) of this
section are retained by the EPA Administrator and are not transferred
to the State, local, or tribal agency.
(c) The authorities that will not be delegated to State, local, or
tribal agencies are listed in paragraphs (c)(1) through (4) of this
section.
(1) Approval of alternatives to the compliance options, operating
requirements, and work practice requirements in Sec. Sec. 63.2240 and
63.2241 as specified in Sec. 63.6(g). For the purposes of delegation
authority under 40 CFR part 63, subpart E, ``compliance options''
represent ``emission limits''; ``operating requirements'' represent
``operating limits''; and ``work practice requirements'' represent
``work practice standards.''
(2) Approval of major alternatives to test methods as specified in
Sec. 63.7(e)(2)(ii) and (f) and as defined in Sec. 63.90.
(3) Approval of major alternatives to monitoring as specified in
Sec. 63.8(f) and as defined in Sec. 63.90.
(4) Approval of major alternatives to recordkeeping and reporting
as specified in Sec. 63.10(f) and as defined in Sec. 63.90.

Sec. 63.2292 What definitions apply to this subpart?
Terms used in this subpart are defined in the Clean Air Act, in 40
CFR 63.2, the General Provisions, and in this section as follows:
Affected source means the collection of dryers, blenders, formers,
presses, board coolers, and other process units associated with the
manufacturing of plywood and composite wood products at a plant site.
The affected source includes, but is not limited to, green end
operations, drying operations, blending and forming operations,
pressing and board cooling operations, and miscellaneous finishing
operations (such as sanding, sawing, patching, edge sealing, and other
finishing operations not subject to other NESHAP). The affected source
also includes onsite storage of raw materials used in the manufacture
of plywood and/or composite wood products, such as resins; onsite
wastewater treatment operations specifically associated with plywood
and composite wood products manufacturing; and miscellaneous coating
operations (defined elsewhere in this section). The affected source
includes lumber kilns at PCWP manufacturing facilities and at any other
kind of facility.
Biofilter means an enclosed control system such as a tank or series
of tanks with a fixed roof that are filled with media (such as bark)
and use microbiological activity to transform organic pollutants in a
process exhaust stream to innocuous compounds such as carbon dioxide,
water, and inorganic salts. Wastewater treatment systems such as
aeration lagoons or activated sludge systems are not considered to be
biofilters.
Capture device means a hood, enclosure, or other means of
collecting emissions into a duct so that the emissions can be measured.
Capture efficiency means the fraction (expressed as a percentage)
of the pollutants from an emission source that are collected by a
capture device.
Catalytic oxidizer means a control system that combusts or
oxidizes, in the presence of a catalyst, exhaust gas from a process
unit. Catalytic oxidizers include regenerative catalytic oxidizers and
thermal catalytic oxidizers.
[[Page 1321]]
Control device means any equipment that reduces the quantity of a
hazardous air pollutant that is emitted to the air. The device may
destroy the hazardous air pollutant or secure the hazardous air
pollutant for subsequent recovery. Control devices include, but are not
limited to, thermal or catalytic oxidizers, combustion units that
incinerate process exhausts, biofilters, and condensers.
Control system or add-on control system means the combination of
capture and control devices used to reduce hazardous air pollutant
emissions to the atmosphere.
Deviation means any instance in which an affected source subject to
this subpart, or an owner or operator of such a source:
(1) Fails to meet any requirement or obligation established by this
subpart including, but not limited to, any compliance option, operating
requirement, or work practice requirement;
(2) Fails to meet any term or condition that is adopted to
implement an applicable requirement in this subpart, and that is
included in the operating permit for any affected source required to
obtain such a permit; or
(3) Fails to meet any compliance option, operating requirement, or
work practice requirement in this subpart during startup, shutdown, or
malfunction, regardless or whether or not such failure is permitted by
this subpart.
Dryer heated zones means the zones of a softwood veneer dryer or
fiberboard mat dryer that are equipped with heating and hot air
circulation units. The cooling zone(s) of the dryer through which
ambient air is blown are not part of the dryer heated zones.
Dry rotary dryer means a rotary dryer that dries wood particles or
fibers with a maximum inlet moisture content of less than or equal to
30 percent (by weight, dry basis) and operates with a maximum inlet
temperature of less than or equal to 600[deg]F. A dry rotary dryer is a
process unit.
Dry forming means the process of making a mat of resinated fiber to
be compressed into a reconstituted wood product such as particleboard,
oriented strandboard (OSB), medium density fiberboard (MDF), or
hardboard.
Fiber means the slender threadlike elements of wood or similar
cellulosic material, which are separated by chemical and/or mechanical
means, as in pulping, that can be formed into boards.
Fiberboard means a composite panel composed of cellulosic fibers
(usually wood or agricultural material) made by wet forming and
compacting a mat of fibers. Fiberboard density is less than 0.50 grams
per cubic centimeter (31.5 pounds per cubic foot).
Fiberboard mat dryer means a dryer used to reduce the moisture of
wet-formed wood fiber mats by operation at elevated temperature. A
fiberboard mat dryer is a process unit.
Furnish means the fibers, particles, or strands used for making
boards.
Glue-laminated beam means a structural wood beam made by bonding
lumber together along its faces with resin.
Green rotary dryer means a rotary dryer that dries wood particles
or fibers with an inlet moisture content of greater than 30 percent (by
weight, dry basis) at any dryer inlet temperature or operates with an
inlet temperature of greater than 600 [deg]F with any inlet moisture
content. A green rotary dryer is a process unit.
Hardboard means a composite panel composed of cellulosic fibers
made by dry or wet forming and pressing of a resinated fiber mat.
Hardboard has a density of 0.50 to 1.20 grams per cubic centimeter
(31.5 to 75 pounds per cubic foot).
Hardboard oven means an oven used to heat treat or temper hardboard
after hot pressing. Humidification chambers are not considered as part
of hardboard ovens. A hardboard oven is a process unit.
Hardwood means the wood of a broad-leafed tree, either deciduous or
evergreen. Examples of hardwoods include (but are not limited to)
aspen, birch, and oak.
Hardwood veneer dryer means a dryer that removes excess moisture
from veneer by conveying the veneer through a heated medium on rollers,
belts, cables, or wire mesh. Hardwood veneer dryers are used to dry
veneer with less than 30 percent softwood species on an annual volume
basis. Veneer kilns that operate as batch units, veneer dryers heated
by radio frequency or microwaves that are used to redry veneer, and
veneer redryers (defined elsewhere in this section) that are heated by
conventional means are not considered to be hardwood veneer dryers. A
hardwood veneer dryer is a process unit.
Kiln-dried lumber means solid wood lumber that has been dried in a
lumber kiln.
Laminated strand lumber (LSL) means a composite product formed into
a billet made of thin wood strands cut from whole logs, resinated, and
pressed together with the grain of each strand oriented parallel to the
length of the finished product.
Laminated veneer lumber (LVL) means a composite product formed into
a billet made from layers of resinated wood veneer sheets or pieces
pressed together with the grain of each veneer aligned primarily along
the length of the finished product. Laminated veneer lumber includes
parallel strand lumber (PSL).
Lumber kiln means an enclosed dryer operated at elevated
temperature to reduce the moisture content of lumber.
Medium density fiberboard (MDF) means a composite panel composed of
cellulosic fibers (usually wood) made by dry forming and pressing of a
resinated fiber mat.
Method detection limit means the minimum concentration of an
analyte that can be determined with 99 percent confidence that the true
value is greater than zero.
Miscellaneous coating operations means application of any of the
following to plywood or composite wood products: Edge seals, moisture
sealants, anti-skid coatings, company logos, trademark or grade stamps,
nail lines, synthetic patches, wood patches, wood putty, concrete
forming oils, glues for veneer composing, and shelving edge fillers.
Miscellaneous coating operations also include the application of primer
to OSB siding that occurs at the same site as OSB manufacture.
MSF means thousand square feet (92.9 square meters). Square footage
of panels is usually measured on a thickness basis, such as \3/8\-inch,
to define the total volume of panels. Equation 6 of Sec. 63.2262(j)
shows how to convert from one thickness basis to another.
Nondetect data means, for the purposes of this subpart, any value
that is below the method detection limit.
Oriented strandboard (OSB) means a composite panel produced from
thin wood strands cut from whole logs, formed into resinated layers
(with the grain of strands in one layer oriented perpendicular to the
strands in adjacent layers), and pressed.
Oven-dried ton(s) (ODT) means tons of wood dried until all of the
moisture in the wood is removed. One oven-dried ton equals 907 oven-
dried kilograms.
Particle means a distinct fraction of wood or other cellulosic
material produced mechanically and used as the aggregate for a
particleboard. Particles are larger in size than fibers.
Particleboard means a composite panel composed of cellulosic
materials (usually wood or agricultural fiber) in the form of discrete
pieces or particles, as distinguished from fibers, which are pressed
together with resin.
Permanent total enclosure (PTE) means a permanently installed
[[Page 1322]]
containment that meets the criteria of Method 204 (40 CFR part 51,
appendix M).
Plant site means all contiguous or adjoining property that is under
common control, including properties that are separated only by a road
or other public right-of-way. Common control includes properties that
are owned, leased, or operated by the same entity, parent entity,
subsidiary, or any combination thereof.
Plywood and composite wood products (PCWP) manufacturing facility
means a plant site that manufactures plywood and/or composite wood
products by bonding wood material (fibers, particles, strands, veneers,
etc.) or agricultural fiber, generally with resin under heat and
pressure, to form a structural panel or engineered wood product.
Plywood and composite wood products manufacturing facilities also
include facilities that manufacture dry veneer and lumber kilns located
at any facility. Plywood and composite wood products include (but are
not limited to) plywood, veneer, particleboard, oriented strandboard,
hardboard, fiberboard, medium density fiberboard, laminated strand
lumber, laminated veneer lumber, wood I-joists, kiln-dried lumber, and
glue-laminated beams.
Plywood means a panel product consisting of layers of wood veneers
hot pressed together with resin. Plywood includes panel products made
by hot pressing (with resin) veneers to a substrate such as
particleboard, MDF, or lumber.
Press predryer means a dryer used to reduce the moisture and
elevate the temperature of a wet-formed fiber mat before the mat enters
a hot press. A press predryer is a process unit.
Pressurized refiner means a piece of equipment operated under
pressure for preheating (usually by steaming) wood material and
refining (rubbing or grinding) the wood material into fibers.
Pressurized refiners are operated with continuous infeed and outfeed of
wood material and maintain elevated internal pressures (i.e., there is
no pressure release) throughout the preheating and refining process. A
pressurized refiner is a process unit.
Process unit means equipment classified according to its function
such as a blender, dryer, press, former, or board cooler.
Reconstituted wood product board cooler means a piece of equipment
designed to reduce the temperature of a board by means of forced air or
convection within a controlled time period after the board exits the
reconstituted wood product press unloader. Board coolers include wicket
and star type coolers commonly found at MDF and particleboard plants.
Board coolers do not include cooling sections of dryers (e.g., veneer
dryers or fiberboard mat dryers) or coolers integrated into or
following hardboard bake ovens or humidifiers. A reconstituted wood
product board cooler is a process unit.
Reconstituted wood product press means a press, including (if
applicable) the press unloader, that presses a resinated mat of wood
fibers, particles, or strands between hot platens or hot rollers to
compact and set the mat into a panel by simultaneous application of
heat and pressure. Reconstituted wood product presses are used in the
manufacture of hardboard, medium density fiberboard, particleboard, and
oriented strandboard. Extruders are not considered to be reconstituted
wood product presses. A reconstituted wood product press is a process
unit.
Representative operating conditions means operation of a process
unit during performance testing under the conditions that the process
unit will typically be operating in the future, including use of a
representative range of materials (e.g., wood material of a typical
species mix and moisture content or typical resin formulation) and
representative operating temperature range.
Resin means the synthetic adhesive (including glue) or natural
binder, including additives, used to bond wood or other cellulosic
materials together to produce plywood and composite wood products.
Responsible official means responsible official as defined in 40
CFR 70.2 and 71.2.
Softwood means the wood of a coniferous tree. Examples of softwoods
include (but are not limited to) Southern yellow pine, Douglas fir, and
White spruce.
Softwood veneer dryer means a dryer that removes excess moisture
from veneer by conveying the veneer through a heated medium on rollers,
belts, cables, or wire mesh. Softwood veneer dryers are used to dry
veneer with greater than or equal to 30 percent softwood species on an
annual volume basis. Veneer kilns that operate as batch units, veneer
dryers heated by radio frequency or microwaves that are used to redry
veneer, and veneer redryers (defined elsewhere in this section) that
are heated by conventional means are not considered to be softwood
veneer dryers. A softwood veneer dryer is a process unit.
Startup means bringing equipment online and starting the production
process.
Startup, initial means the first time equipment is put into
operation. Initial startup does not include operation solely for
testing equipment. Initial startup does not include subsequent startups
(as defined in this section) following malfunction or shutdowns or
following changes in product or between batch operations. Initial
startup does not include startup of equipment that occurred when the
source was an area source.
Startup, shutdown, and malfunction plan (SSMP) means a plan
developed according to the provisions of Sec. 63.6(e)(3).
Strand means a long (with respect to thickness and width), flat
wood piece specially cut from a log for use in oriented strandboard,
laminated strand lumber, or other wood strand-based product.
Strand dryer means a dryer operated at elevated temperature and
used to reduce the moisture of wood strands used in the manufacture of
OSB, LSL, or other wood strand-based products. A strand dryer is a
process unit.
Temporary total enclosure (TTE) means an enclosure constructed for
the purpose of measuring the capture efficiency of pollutants emitted
from a given source, as defined in Method 204 of 40 CFR part 51,
appendix M.
Thermal oxidizer means a control system that combusts or oxidizes
exhaust gas from a process unit. Thermal oxidizers include regenerative
thermal oxidizers and burners or combustion units that accept process
exhausts in the flame zone.
Total hazardous air pollutant (HAP) emissions means, for purposes
of this rulemaking, the sum of the emissions of the following six
compounds: acetaldehyde, acrolein, formaldehyde, methanol, phenol, and
propionaldehyde.
Tube dryer means a single-stage or multistage dryer operated at
elevated temperature and used to reduce the moisture of wood fibers or
particles as they are conveyed (usually pneumatically) through the
dryer. Resin may or may not be applied to the wood material before it
enters the tube dryer. A tube dryer is a process unit.
Veneer means thin sheets of wood peeled or sliced from logs for use
in the manufacture of wood products such as plywood, laminated veneer
lumber, or other products.
Veneer redryer means a dryer heated by conventional means, such as
direct wood-fired, direct-gas-fired, or steam heated, that is used to
redry veneer that has been previously dried. Because the veneer dried
in a veneer redryer has been previously dried, the inlet
[[Page 1323]]
moisture content of the veneer entering the redryer is less than 25
percent (by weight, dry basis). Batch units used to redry veneer (such
as redry cookers) are not considered to be veneer redryers. A veneer
redryer is a process unit.
Wet forming means the process of making a slurry of water, fiber,
and additives into a mat of fibers to be compressed into a fiberboard
or hardboard product.
Wood I-joists means a structural wood beam with an I-shaped cross
section formed by bonding (with resin) wood or laminated veneer lumber
flanges onto a web cut from a panel such as plywood or oriented
strandboard.
Work practice requirement means any design, equipment, work
practice, or operational standard, or combination thereof, that is
promulgated pursuant to section 112(h) of the Clean Air Act.
Table 1A to Subpart DDDD.--Production-Based Compliance Options
------------------------------------------------------------------------
You must meet the following
For the following process units . . production-based compliance option
. (total HAPa basis) . . .
------------------------------------------------------------------------
(1) Fiberboard mat dryer heated 0.022 lb/MSF \1/2\''
zones (at new affected sources
only).
(2) Green rotary dryers............. 0.058 lb/ODT
(3) Hardboard ovens................. 0.022 lb/MSF \1/8\''
(4) Press predryers (at new affected 0.037 lb/MSF \1/2\''
sources only).
(5) Pressurized refiners............ 0.039 lb/ODT
(6) Tube dryers..................... 0.26 lb/ODT
(7) Reconstituted wood product board 0.015 lb/MSF \3/4\''
coolers (at new affected sources
only).
(8) Reconstituted wood product 0.30 lb/MSF \3/4\''
presses.
(9) Softwood veneer dryer heated 0.022 lb/MSF \3/8\''
zones.
(10) Strand dryers.................. 0.18 lb/ODT
------------------------------------------------------------------------
\a\ Total HAP, as defined in Sec. 63.2292, includes acetaldehyde,
acrolein, formaldehyde, methanol, phenol, and propionaldehyde. lb/ODT
= pounds per oven dried ton; lb/MSF = pounds per thousand square feet
with a specified thickness basis (inches). Section 63.2262(j) shows
how to convert from one thickness basis to another.

Table 1B to Subpart DDDD.--Add-on Control Systems Compliance Options
------------------------------------------------------------------------
You must comply with one of the
For each of the following process units following six compliance
. . . options by using an emissions
control system . . .
------------------------------------------------------------------------
Fiberboard mat dryer heated zones (at (1) Reduce emissions of total
new affected sources only); Green HAP, measured as THC (as
rotary dryers; Hardboard ovens; Press carbon),\a\ by 90 percent; or
predryers (at new affected sources (2) Limit emissions of total
only); Pressurized refiners; Tube HAP, measured as THC (as
dryers; Reconstituted wood product carbon),\a\ to 20 parts per
board coolers (at new affected sources million by volume, dry
only); Reconstituted wood product (ppmvd); or
presses; Softwood veneer dryer heated (3) Reduce methanol emissions
zones; and Strand dryers. by 90 percent; or
(4) Limit methanol emissions to
less than or equal to 1 ppmvd
if uncontrolled methanol
emissions entering the control
device are greater than or
equal to 10 ppmvd; or
(5) Reduce formaldehyde
emissions by 90 percent; or
(6) Limit formaldehyde
emissions to less than or
equal to 1 ppmvd if
uncontrolled formaldehyde
emissions entering the control
device are greater than or
equal to 10 ppmvd.
------------------------------------------------------------------------
\a\ You may choose to subtract methane from THC as carbon measurements.

Table 2 to Subpart DDDD.--Operating Requirements
----------------------------------------------------------------------------------------------------------------
If you operate a(n) . . . You must . . . Or you must . . . Or you must . . .
----------------------------------------------------------------------------------------------------------------
(1) Thermal oxidizer................. Maintain the 3-hour Maintain the 3-hour Maintain the 3-hour
block average firebox block average firebox block average THC
temperature above the temperature above the concentration a in the
minimum temperature minimum temperature thermal oxidizer
established during the established during the exhaust below the
performance test; AND performance test; AND maximum concentration
maintain in 3-hour maintain the 3-hour established during
block average static block average gas flow performance test.
pressure at the inlet at the outlet of the
of the thermal thermal oxidizer below
oxidizer within the the maximum flow rate
operating range established during the
established during the performance test.
performance test.
--------------------------------------
[[Page 1324]]

(2) Catalytic oxidizer............... Maintain the 3-hour Maintain the 3-hour Maintain the 3-hour
block average block average block average THC
temperature upstream temperature upstrem of concentration a in the
of the catalyst bed the catalyst bed above catalytic oxidizer
above the minimum the minimum exhaust below the
temperature temperature maximum concentration
established during the established during the established during the
performance test; AND performance test; AND performance test.
maintain the 3-hour maintain the 3-hour
block average static block average gas flow
pressure at the inlet at the outlet of the
of the catalytic catalytic oxidizer
oxidizer within the below the maximum flow
operating range rate established
established during the during the performance
performance test. test.
--------------------------------------
(3) Biofilter........................ Maintain the Maintain the 3-hour
temperature of the air block average THC
stream entering the concentration a in the
biofilter, pH of the biofilter exhaust
biofilter effluent, below the maximum
and pressure drop concentration
across the biofilter established during the
bed within the ranges performance test.
established according
to Sec. 63.2262(m).
--------------------------------------
(4) Control device other than a Petition the Maintain the 3-hour
thermal oxidizer, catalytic Administrator for site- block average THC
oxidizer, or biofilter. specific operating concentration a in the
parameter(s) to be control device exhaust
established during the below the maximu
performance test and concentration
maintain the average established during the
operating parameter(s) performance test.
within the range(s)
established during the
performance test.
--------------------------------------
(5) Process unit that meets a Maintain the 3-hour Maintain the 3-hour
compliance option in Table 1A of block average inlet block average tHC
this subpart. temperature below the concentration a in the
maximum inlet process unit exhaust
temperature below the maximum
established during the concentration
performance test if established during the
the process unit is a performance test .
green rotary dryer,
tube dryer, or strand
dryer; OR maintain the
3-hour block average
process unit operating
temperature below the
maximum operating
temperature
established during the
performance test if
the process unit is a
hardboard oven, press
predryer, or
reconstituted wood
product press; OR
maintain the 3-hour
block average
operating temperature
in each of the hot
zones below the
maximum hot zone
temperatures
established during the
performance test if
the process unit is a
fiberboard mat dryer
or softwood veneer
dryer.
----------------------------------------------------------------------------------------------------------------
a You may choose to substract methane from THC measurements.

Table 3 to Subpart DDDD.--Work Practice Requirements
------------------------------------------------------------------------
For the following process units at
existing or new affected sources . You must . . .
. .
------------------------------------------------------------------------
(1) Dry rotary dryers............. Process furnish with a 24-hour block
average inlet moisture content of
less than or equal to 30 percent
(by weight, dry basis); AND operate
with a 24-hour block average inlet
dryer temperature of less than or
equal to 600[deg]F.
-----------------------------------
(2) Hardwood veneer dryers........ Process less than 30 volume percent
softwood species on an annual
basis.
-----------------------------------
(3) Softwood veneer dryers........ Minimize fugitive emissions from the
dryer doors through (proper
maintenance procedures) and the
green end of the dryers (though
proper balancing of the heated zone
exhausts).
-----------------------------------
[[Page 1325]]

(4) Veneer redryers............... Process veneer that has been
previously dried, such that the 24-
hour block average inlet moisture
content of the veneer is less than
or equal to 25 percent (by weight,
dry basis).
------------------------------------------------------------------------

Table 4 to Subpart DDDD.--Requirements for Performance Tests
------------------------------------------------------------------------
For . . . You must . . . Using . . .
------------------------------------------------------------------------
(1) Each process unit subject to Select sampling Method 1 or 1A of
a compliance option in Table 1A port's location 40 CFR part 60,
or 1B of this subpart or used and the number of appendix A (as
in calculation of an emissions traverse ports. appropriate).
average under Sec. 63.2240(c).
---------------------------------
(2) Each process unit subject to Determine velocity Method 2 in
a compliance option in Table 1A and volumetric addition to
or 1B of this subpart or used flow rate. Method 2A, 2C,
in calculation of an emissions 2D, 2F, or 2G in
average under Sec. 63.2240(c). appendix A to 40
CFR part 60 (as
appropriate).
---------------------------------
(3) Each process unit subject to Conduct gas Method 3, 3A, or
a compliance option in Table 1A molecular weight 3B in appendix A
or 1B of this subpart or used analysis. to 40 CFR part 60
in calculation of an emissions (as appropriate).
average under Sec. 63.2240(c).
---------------------------------
(4) Each process unit subject to Measure moisture Method 4 in
a compliance option in Table 1A content of the appendix A to 40
or 1B of this subpart or used stack gas. CFR part 60.
in calculation of an emissions
average under Sec. 63.2240(c).
---------------------------------
(5) Each process unit subject to Measure emissions Method 25A in
a compliance option in Table 1B of total HAP as appendix A to 40
of this subpart for which you THC. CFR part 60. You
choose to demonstrate may measure
compliance using a total HAP as emissions of
THC compliance option. methane using EPA
Method 18 in
appendix A to 40
CFR part 60 and
subtract the
methane emissions
from the
emissions of
total HAP as THC.
---------------------------------
(6) Each process unit subject to Measure emissions Method 320 in
a compliance option in Table of total HAP (as appendix A to 40
1A; OR for each process unit defined in Sec. CFR part 63; OR
used in calculation of an 63.2292). the NCASI Method
emissions average under Sec. IM/CAN/WP-99.01
63.2240(c). (incorporated by
reference, see
Sec. 63.14(f)).
---------------------------------
(7) Each process unit subject to Measure emissions Method 308 in
a compliance option in Table 1B of methanol. appendix A to 40
of this subpart for which you CFR part 63; OR
choose to demonstrate Method 320 in
compliance using a methanol appendix A to 40
compliance option. CFR part 63; OR
the NCASI Method
CI/WP-98.01
(incorporated by
reference, see
Sec. 63.14(f));
OR the NCASI
Method IM/CAN/WP-
99.01
(incorporated by
reference, see
Sec. 63.14(f)).
---------------------------------
(8) Each process unit subject to Measure emissions Method 316 in
a compliance option in Table 1B of formaldehyde. appendix A to 40
of this subpart for which you CFR part 63; OR
choose to demonstrate Method 320 in
compliance using a formaldehyde appendix A to 40
compliance option. CFR part 63; OR
Method 0011 in
``Test Methods
for Evaluating
Solid Waste,
Physical/Chemical
Methods'' (EPA
Publication No.
SW-846) for
formaldehyde; OR
the NCASI Method
CI/WP-98.01
(incorporated by
reference, see
Sec. 63.14(f));
OR the NCASI
Method IM/CAN/WP-
99.01
(incorporated by
reference, see
Sec. 63.14(f)).
---------------------------------
(9) Each reconstituted wood Determine the Methods 204 and
product press at a new or percent capture 204A through 204F
existing affected source or efficiency of the of 40 CFR part
reconstituted wood product enclosure 51, appendix M.
board cooler at a new affected directing Enclosures that
source subject to a compliance emissions to an meet the Method
option in Table 1B or used in add-on control 204 requirements
calculation of an emissions device. for a PTE are
average under Sec. 63.2240(c). assumed to have a
capture
efficiency of
100%. Enclosures
that do not meet
the PTE
requirements must
determine the
capture
efficiency by
constructing a
TTE according to
the requirements
of Method 204 and
applying Methods
204A through 204F
(as appropriate).
As an alternative
to Methods 204
and 204A through
204F, you may use
the tracer gas
method contained
in appendix A to
this subpart.
---------------------------------
[[Page 1326]]

(10) Each reconstituted wood Determine the A TTE and Methods
product press at a new or percent capture 204 and 204A
existing affected source or efficiency. through 204F (as
reconstituted wood product appropriate) of
board cooler at a new affected 40 CFR part 51,
source subject to a compliance appendix M. As an
option in Table 1A of this alternative to
subpart. installing a TTE
and using Methods
204 and 204A
through 204F, you
may use the
tracer gas method
contained in
appendix A to
this subpart.
---------------------------------
(11) Each process unit subject Establish the site- Data from the
to a compliance option in specific parameter
Tables 1A and 1B of this operating monitoring system
subpart or used in calculation requirements or THC CEMS and
of emissions averaging credits (including the the applicable
under Sec. 63.2240(c). parameter limits performance test
or THC method(s).
concentration
limits) in Table
2 of this subpart.
------------------------------------------------------------------------

Table 5 to Subpart DDDD.--Performance Testing and Initial Compliance
Demonstrations for the Compliance Options and Operating Requirements
------------------------------------------------------------------------
For the following
compliance
options and You have demonstrated
For each . . . operating initial compliance if
requirements . . . . .
.
------------------------------------------------------------------------
(1) Process unit listed in Meet the The average total HAP
Table 1A of this subpart. production-based emissions measured
compliance using the methods in
options listed Table 4 of this
in Table 1A of subpart over the 3-
this subpart. hour initial
performance test are
no greater than the
compliance option in
Table 1A of this
subpart; AND you
have a record of the
operating
requirement(s)
listed in Table 2 of
this subpart for the
process unit over
the performance test
during which
emissions did not
exceed the
compliance option
value.
-------------------------------
(2) Process unit listed in Reduce emissions Total HAP emissions,
Table 1B of this subpart. of total HAP, measured using the
measured as THC, methods in Table 4
by 90 percent. of this subpart over
the 3-hour
performance test,
are reduced by at
least 90 percent, as
calculated using the
procedures in Sec.
63.2262; AND you
have a record of the
operating
requirement(s)
listed in Table 2 of
this subpart for the
process unit over
the performance test
during which
emissions were
reduced by at least
90 percent.
-------------------------------
(3) Process unit listed in Limit emissions The average total HAP
Table 1B of this subpart. of total HAP, emissions, measured
measured as THC, using the methods in
to 20 ppmvd. Table 4 of this
subpart over the 3-
hour initial
performance test, do
not exceed 20 ppmvd;
AND you have a
record of the
operating
requirement(s)
listed in Table 2 of
this subpart for the
process unit over
the performance test
during which
emissions did not
exceed 20 ppmvd.
-------------------------------
(4) Process unit listed in Reduce methanol The methanol or
Table 1B of this subpart. or formaldehyde formaldehyde
emissions by 90 emissions measured
percent. using the methods in
Table 4 of this
subpart over the 3-
hour initial
performance test,
are reduced by at
least 90 percent, as
calculated using the
procedures in Sec.
63.2262; AND you
have a record of the
operating
requirement(s)
listed in Table 2 of
this subpart for the
process unit over
the performance test
during which
emissions were
reduced by at least
90 percent.
-------------------------------
(5) Process unit listed in Limit methanol or The average methanol
Table 1B of this subpart. formaldehyde or formaldehyde
emissions to emissions, measured
less than or using the methods in
equal to 1 ppmvd Table 4 of this
(if uncontrolled subpart over the 3-
emissions are hour initial
greater than or performance test, do
equal to 10 not exceed 1 ppmvd;
ppmvd). AND you have a
record of the
operating
requirement(s)
listed in Table 2 of
this subpart for the
process unit over
the performance test
during which
emissions did not
exceed 1 ppmvd. If
the process unit is
a reconstituted wood
product press or a
reconstituted wood
product board
cooler, your capture
device either meets
the EPA Method 204
criteria for a PTE
or achieves a
capture efficiency
of greater than or
equal to 95 percent.
-------------------------------
(6) Reconstituted wood product Compliance You submit the
press at a new or existing options in results of capture
affected source, or Tables 1A and 1B efficiency
reconstituted wood product of this subpart verification using
board cooler at a new or the emissions the methods in Table
affected source. averaging 4 of this subpart
compliance with your
option in Sec. Notification of
63.2240(c). Compliance Status.
-------------------------------
[[Page 1327]]

(7) Process unit listed in Compliance You submit with your
Table 1B of this subpart options in Table Notification of
controlled by routing exhaust 1B of this Compliance Status
to a combustion unit with subpart or the documentation
heat input capacity greater emissions showing that your
than or equal to 44 megawatts. averaging combustion unit has
compliance a heat input
option in Sec. capacity greater
63.2240(c). than or equal to 44
megawatts and that
the process exhausts
controlled enter
into the flame zone.
------------------------------------------------------------------------

Table 6 to Subpart DDDD.--Initial Compliance Demonstrations for Work
Practice Requirements
------------------------------------------------------------------------
You have
For the following demonstrated
For each. . . work practice initial compliance
requirements. . . if. . .
------------------------------------------------------------------------
(1) Dry rotary dryer............ Process furnish You meet the work
with an inlet practice
moisture content requirement AND
less than or you submit a
equal to 30 signed statement
percent (by with the
weight, dry Notification of
basis) AND Compliance Status
operate with an that the dryer
inlet dryer meets the
temperature of criteria of a
less than or ``dry rotary
equal to dryer'' AND you
600[deg]F. have a record of
the inlet
moisture content
and inlet dryer
temperature (as
required in Sec.
63.2263).
---------------------------------
(2) Hardwood veneer dryer....... Process less than You meet the work
30 volume percent practice
softwood species. requirement AND
you submit a
signed statement
with the
Notification of
Compliance Status
that the dryer
meets the
criteria of a
``hardwood veneer
dryer'' AND you
have a record of
the percentage of
softwoods
processed in the
dryer (as
required in Sec.
63.2264).
---------------------------------
(3) Softwood veneer dryer....... Minimize fugitive You meet the work
emissions from practice
the dryer doors requirement AND
and the green end. you submit with
the Notification
of Compliance
Status a copy of
your plan for
minimizing
fugitive
emissions from
the veneer dryer
heated zones (as
required in Sec.
63.2265).
---------------------------------
(4) Veneer redryers............. Process veneer You meet the work
with an inlet practice
moisture content requirement AND
of less than or you submit a
equal to 25 signed statement
percent (by with the
weight, dry Notification of
basis). Compliance Status
that the dryer
operates only as
a redryer AND you
have a record of
the veneer inlet
moisture content
of the veneer
processed in the
redryer (as
required in Sec.
63.2266).
------------------------------------------------------------------------

Table 7 to Subpart DDDD.--Continuous Compliance With the Compliance
Options and Operating Requirements
------------------------------------------------------------------------
You must
For the following demonstrate
For . . . compliance options continuous
and operating compliance by . .
requirements . . . .
------------------------------------------------------------------------
(1) Each process unit listed in Compliance options Collecting and
Tables 1A and 1B of this in Tables 1A and recording the
subpart or used in calculation 1B of this operating
of emissions averaging credits subpart or the parameter
under Sec. 63.2240(c). emissions monitoring system
averaging data listed in
compliance option Table 2 of this
in Sec. subpart for the
63.2240(c) and process unit
the operating according to Sec.
requirements in 63.2268(a)-(e);
Table 2 of this AND reducing the
subpart based on operating
monitoring of parameter
operating monitoring system
parameters. data to the
specified average
in units of the
applicable
requirement
according to
calculations in
Sec.
63.2268(a); AND
maintaining the
average operating
parameter at or
above the
maximum, at or
below the
minimum, or
within the range
(whichever
applies)
established
according to Sec.
63.2262.
---------------------------------
(2) Each process unit listed in Compliance options Collecting and
Tables 1A and 1B of this in Tables 1A and recording the THC
subpart or used in calculation 1B of this monitoring data
of emissions averaging credits subpart or the listed in Table 2
under Sec. 63.2240(c). emissions of this subpart
averaging for the process
compliance option unit according to
in Sec. Sec.
63.2240(c) and 63.2268(g); AND
the operating reducing the CEMS
requirements in data to 3-hour
Table 2 of this block averages
subpart based on according to
THC CEMS data. calculations in
Sec.
63.2268(g); AND
maintaining the 3-
hour block
average THC
concentration in
the exhaust gases
less than or
equal to the THC
concentration
established
according to Sec.
63.2262.
------------------------------------------------------------------------

[[Page 1328]]

Table 8 to Subpart DDDD.--Continuous Compliance With the Work Practice
Requirements
------------------------------------------------------------------------
You must
For the following demonstrate
For . . . work practice continuous
requirements . . . compliance by . .
.
------------------------------------------------------------------------
(1) Dry rotary dryer............ Process furnish Maintaining the
with an inlet inlet furnish
moisture content moisture content
less than or at less than or
equal to 30 equal to 30
percent (by percent (by
weight, dry weight, dry
basis) AND basis) AND
operate with an maintaining the
inlet dryer inlet dryer
temperature of temperature at
less than or less than or
equal to 600 equal to 600
[deg]F. [deg]F; AND
keeping records
of the inlet
furnish moisture
content and inlet
dryer
temperature.
---------------------------------
(2) Hardwood veneer dryer....... Process less than Maintaining the
30 volume percent volume percent
softwood species. softwood species
processed below
30 percent AND
keeping records
of the volume
percent softwood
species
processed.
---------------------------------
(3) Softwood veneer dryer....... Minimize fugitive Following (and
emissions from documenting that
the dryer doors you are
and the green end. following) your
plan for
minimizing
fugitive
emissions.
---------------------------------
(4) Veneer redryers............. Process veneer Maintaining the
with an inlet inlet moisture
moisture content content of the
of less than or veneer processed
equal to 25 at or below 25
percent (by percent AND
weight, dry keeping records
basis). of the inlet
moisture content
of the veneer
processed.
------------------------------------------------------------------------

Table 9 to Subpart DDDD.--Requirements for Reports
------------------------------------------------------------------------
The report must You must submit
You must submit a(n) . . . contain . . . the report . . .
------------------------------------------------------------------------
(1) Compliance report........... The information in Semiannually
Sec. 63.2281(c) according to the
through (g). requirements in
Sec.
63.2281(b).
---------------------------------
(2) Immediate startup, shutdown, (i) Actions taken By fax or
and malfunction report if you for the event. telephone within
had a startup, shutdown, or 2 working days
malfunction during the after starting
reporting period that is not actions
consistent with your SSMP. inconsistent with
the plan.
(ii) The By letter within 7
information in working days
Sec. after the end of
63.10(d)(5)(ii). the event unless
you have made
alternative
arrangements with
the permitting
authority.
------------------------------------------------------------------------

Table 10 to Subpart DDDD.--Applicability of General Provisions to Subpart DDDD
----------------------------------------------------------------------------------------------------------------
Citation Subject Brief description Applies to subpart DDDD
----------------------------------------------------------------------------------------------------------------
Sec. 63.1.......................... Applicability.......... Initial applicability Yes.
determination;
Applicability after
standard established;
Permit requirements;
Extensions,
notifications.
--------------------------------------
Sec. 63.2.......................... Definitions............ Definitions for part 63 Yes.
standards.
--------------------------------------
Sec. 63.3.......................... Units and Abbreviations Units and abbreviations Yes.
for part 63 standards.
--------------------------------------
Sec. 63.4.......................... Prohibited Activities.. Prohibited Activities; Yes.
Compliance date;
Circumvention,
severability.
--------------------------------------
Sec. 63.5.......................... Construction/ Applicability; Yes.
Reconstruction. applications;
approvals.
--------------------------------------
Sec. 63.6(a)....................... Applicability.......... GP apply unless Yes.
compliance extension;
GP apply to area
sources that become
major.
--------------------------------------
Sec. 63.6(b)(1)-(4)................ Compliance Dates for Standards apply at Yes.
New and Reconstructed effective date; 3
sources. years after effective
date; upon startup; 10
years after
construction or
reconstruction
commences for section
112(f).
--------------------------------------
Sec. 63.6(b)(5).................... Notification........... Must notify if Yes.
commenced construction
or reconstruction
after proposal.
--------------------------------------
Sec. 63.6(b)(6).................... [Reserved]............. ....................... .......................
--------------------------------------
[[Page 1329]]

Sec. 63.6(b)(7).................... Compliance Dates for Area sources that Yes.
New and Reconstructed become major must
Area Sources that comply with major
Become Major. source standards
immediately upon
becoming major,
regardless of whether
required to comply
when they were an area
source.
--------------------------------------
Sec. 63.6(c)(1)-(2)................ Compliance Dates for Comply according to Yes.
Existing Sources. date in subpart, which
must be no later than
3 years after
effective date; for
section 112(f)
standards, comply
within 90 days of
effective date unless
compliance extension.
--------------------------------------
Sec. 63.6(c)(3)-(4)................ [Reserved]............. ....................... .......................
--------------------------------------
Sec. 63.6(c)(5).................... Compliance Dates for Area sources that Yes.
Existing Area Sources become major must
that Become Major. comply with major
source standards by
date indicated in
subpart or by
equivalent time period
(e.g., 3 years).
--------------------------------------
Sec. 63.6(d)....................... [Reserved]............. ....................... .......................
--------------------------------------
Sec. 63.6(e)(1)-(2)................ Operation & Maintenance Operate to minimize Yes.
emissions at all
times; correct
malfunctions as soon
as practicable;
operation and
maintenance
requirements
independently
enforceable;
information
Administrator will use
to determine if
operation and
maintenance
requirements were met.
--------------------------------------
Sec. 63.6(e)(3).................... Startup, Shutdown, and Requirement for SSM and Yes.
Malfunction Plan SSMP; Content of SSMP.
(SSMP).
--------------------------------------
Sec. 63.6(f)(1).................... Compliance Except You must comply with Yes.
During SSM. emission standards at
all times except
during SSM.
--------------------------------------
Sec. 63.6(f)(2)-(3)................ Methods for Determining Compliance based on Yes.
Compliance. performance test,
operation and
maintenance plans,
records, inspection.
--------------------------------------
Sec. 63.6(g)(1)-(3)................ Alternative Standard... Procedures for getting Yes.
an alternative
standard.
--------------------------------------
Sec. 63.6(h)(1)-(9)................ Opacity/Visible Requirements for NA.
Emission (VE) opacity and visible
Standards. emission standards.
--------------------------------------
Sec. 63.6(i)(1)-(14)............... Compliance Extension... Procedures and criteria Yes.
for Administrator to
grant compliance
extension.
--------------------------------------
Sec. 63.6(j)....................... Presidential Compliance President may exempt Yes.
Exemption. source category from
requirement to comply
with rule.
--------------------------------------
Sec. 63.7(a)(1)-(2)................ Performance Test Dates. Dates for Conducting Yes.
Initial Performance
Testing and Other
Compliance
Demonstrations; Must
conduct 180 days after
first subject to rule.
--------------------------------------
Sec. 63.7(a)(3).................... Section 114 Authority.. Administrator may Yes.
require a performance
test under CAA section
114 at any time.
--------------------------------------
Sec. 63.7(b)(1).................... Notification of Must notify Yes.
Performance Test. Administrator 60 days
before the test.
--------------------------------------
Sec. 63.7(b)(2).................... Notification of If have to reschedule Yes.
Rescheduling. performance test, must
notify Administrator 5
days before scheduled
date of rescheduled
date.
--------------------------------------
Sec. 63.7(c)....................... Quality Assurance/Test Requirement to submit Yes.
Plan. site-specific test
plan 60 days before
the test or on date
Administrator agrees
with; test plan
approval procedures;
performance audit
requirements; internal
and external QA
procedures for testing.
--------------------------------------
Sec. 63.7(d)....................... Testing Facilities..... Requirements for Yes.
testing facilities.
--------------------------------------
Sec. 63.7(e)(1).................... Conditions for Performance tests must Yes.
Conducting Performance be conducted under
Tests. representative
conditions; cannot
conduct performance
tests during SSM; not
a violation to exceed
standard during SSM.
--------------------------------------
[[Page 1330]]

Sec. 63.7(e)(2).................... Conditions for Must conduct according Yes.
Conducting Performance to rule and EPA test
Tests. methods unless
Administrator approves
alternative.
--------------------------------------
Sec. 63.7(e)(3).................... Test Run Duration...... Must have three test Yes.
runs of at least one
hour each; compliance
is based on arithmetic
mean of three runs;
specifies conditions
when data from an
additional test run
can be used.
--------------------------------------
Sec. 63.7(f)....................... Alternative Test Method Procedures by which Yes.
Administrator can
grant approval to use
an alternative test
method.
--------------------------------------
Sec. 63.7(g)....................... Performance Test Data Must include raw data Yes.
Analysis. in performance test
report; must submit
performance test data
60 days after end of
test with the
notification of
compliance status;
keep data for 5 years.
--------------------------------------
Sec. 63.7(h)....................... Waiver of Tests........ Procedures for Yes.
Administrator to waive
performance test.
--------------------------------------
Sec. 63.8(a)(1).................... Applicability of Subject to all Yes.
Monitoring monitoring
Requirements. requirements in
standard.
--------------------------------------
Sec. 63.8(a)(2).................... Performance Performance Yes.
Specifications. Specifications in
Appendix B of Part 60
apply.
--------------------------------------
Sec. 63.8(a)(3).................... [Reserved]............. ....................... .......................
--------------------------------------
Sec. 63.8(a)(4).................... Monitoring with Flares. Requirements for flares NA
in Sec. 63.11 apply.
--------------------------------------
Sec. 63.8(b)(1).................... Monitoring............. Must conduct monitoring Yes.
according to standard
unless Administrator
approves alternative.
--------------------------------------
Sec. 63.8(b)(2)-(3)................ Multiple Effluents and Specific requirements Yes.
Multiple Monitoring for installing
Systems. monitoring systems;
must install on each
effluent before it is
combined and before it
is released to the
atmosphere unless
Administrator approves
otherwise; if more
than one monitoring
system on an emission
point, must report all
monitoring system
results, unless one
monitoring system is a
backup.
--------------------------------------
Sec. 63.8(c)(1).................... Monitoring System Maintain monitoring Yes.
Operation and system in a manner
Maintenance. consistent with good
air pollution control
practices.
--------------------------------------
Sec. 63.8(c)(1)(i)................. Routine and Predictable Follow the SSM plan for Yes.
SSM. routine repairs; keep
parts for routine
repairs readily
available; reporting
requirements for SSM
when action is
described in SSM plan.
--------------------------------------
Sec. 63.8(c)(1)(ii)................ SSM not in SSMP........ Reporting requirements Yes.
for SSM Yes when
action is not
described in SSM plan.
--------------------------------------
Sec. 63.8(c)(1)(iii)............... Compliance with How Administrator Yes.
Operation and determines if source
Maintenance complying with
Requirements. operation and
maintenance
requirements; review
of source O&M
procedures, records;
manufacturer's
instructions,
recommendations;
inspection.
--------------------------------------
Sec. 63.8(c)(2)-(3)................ Monitoring System Must install to get Yes.
Installation. representative
emission of parameter
measurements; must
verify operational
status before or at
performance test.
--------------------------------------
Sec. 63.8(c)(4).................... Continuous Monitoring CMS must be operating Yes.
System (CMS) except during
Requirements. breakdown, out-of-
control, repair,
maintenance, and high-
level calibration
drifts; COMS must have
a minimum of one cycle
of sampling and
analysis for each
successive 10-second
period and one cycle
of data recording for
each successive 6-
minute period; CEMS
must have a minimum of
one cycle of operation
for each successive 15-
minute period.
--------------------------------------
[[Page 1331]]

Sec. 63.8(c)(5).................... COMS Minimum Procedures COMS minimum procedures NA.
--------------------------------------
Sec. 63.8(c)(6)-(8)................ CMS Requirements....... Zero and high level Yes.
calibration check
requirements; out-of-
control periods.
--------------------------------------
Sec. 63.8(d)....................... CMS Quality Control.... Requirements for CMS Yes.
quality control,
including calibration,
etc.; must keep
quality control plan
on record for 5 years.
Keep old versions for
5 years after
revisions.
--------------------------------------
Sec. 63.8(e)....................... CMS Performance Notification, Yes.
Evaluation. performance evaluation
test plan, reports..
--------------------------------------
Sec. 63.8(f)(1)-(5)................ Alternative Monitoring Procedures for Yes.
Method. Administrator to
approve alternative
monitoring.
--------------------------------------
Sec. 63.8(f)(6).................... Alternative Relative Procedures for Yes.
Accuracy Test. Administrator to
approve alternative
relative accuracy
tests for CEMS.
--------------------------------------
Sec. 63.8(g)....................... Data Reduction......... COMS 6-minute averages Yes.
calculated over at
least 36 evenly spaced
data points; CEMS 1
hour averages computed
over at least 4
equally spaced data
points; data that
can't be used in
average.
--------------------------------------
Sec. 63.9(a)....................... Notification Applicability and State Yes.
Requirements. Delegation.
--------------------------------------
Sec. 63.9(b)(1)-(5)................ Initial Notifications.. Submit notification 120 Yes.
days after effective
date; notification of
intent to construct/
reconstruct;
notification of
commencement of
construct/reconstruct;
notification of
startup; contents of
each.
--------------------------------------
Sec. 63.9(c)....................... Request for Compliance Can request if cannot Yes
Extension. comply by date or if
installed BACT/LAER.
--------------------------------------
Sec. 63.9(d)....................... Notification of Special For sources that Yes
Compliance commence construction
Requirements for New between proposal and
Source. promulgation and want
to comply 3 years
after effective date.
--------------------------------------
Sec. 63.9(e)....................... Notification of Notify Administrator 60 Yes.
Performance Test. days prior.
--------------------------------------
Sec. 63.9(f)....................... Notification of VE/ Notify Administrator 30 No.
Opacity Test. days prior.
--------------------------------------
Sec. 63.9(g)....................... Additional Notification of Yes.
Notifications When performance
Using CMS. evaluation;
notification using
COMS data;
notification that
exceeded criterion for
relative accuracy.
--------------------------------------
Sec. 63.9(h)(1)-(6)................ Notification of Contents; due 60 days Yes.
Compliance Status. after end of
performance test or
other compliance
demonstration, except
for opacity/VE, which
are due 30 days after;
when to submit to
Federal vs. State
authority.
--------------------------------------
Sec. 63.9(i)....................... Adjustment of Submittal Procedures for Yes.
Deadlines. Administrator to
approve change in when
notifications must be
submitted.
--------------------------------------
Sec. 63.9(j)....................... Change in Previous Must submit within 15 Yes.
Information. days after the change.
--------------------------------------
Sec. 63.10(a)...................... Recordkeeping/Reporting Applies to all, unless Yes.
compliance extension;
when to submit to
Federal vs. State
authority; procedures
for owners of more
than 1 source.
--------------------------------------
Sec. 63.10(b)(1)................... Recordkeeping/Reporting General Requirements; Yes.
keep all records
readily available;
keep for 5 years.
--------------------------------------
Sec. 63.10(b)(2)(i)-(iv)........... Records related to Occurrence of each of Yes.
Startup, Shutdown, and operation (process
Malfunction. equipment); occurrence
of each malfunction of
air pollution
equipment; maintenance
on air pollution
control equipment;
actions during
startup, shutdown, and
malfunction.
--------------------------------------
Sec. 63.10(b)(2)(vi) and (x)-(xi).. CMS Records............ Malfunctions, Yes.
inoperative, out-of-
control.
--------------------------------------
[[Page 1332]]

Sec. 63.10(b)(2)(vii)-(ix)......... Records................ Measurements to Yes.
demonstrate compliance
with compliance
options and operating
requirements;
performance test,
performance
evaluation, and
visible emission
observation results;
measurements to
determine conditions
of performance tests
and performance
evaluations.
--------------------------------------
Sec. 63.10(b)(2)(xii).............. Records................ Records when under Yes.
waiver.
--------------------------------------
Sec. 63.10(b)(2)(xiii)............. Records................ Records when using Yes.
alternative to
relative accuracy test.
--------------------------------------
Sec. 63.10(b)(2)(xiv).............. Records................ All documentation Yes.
supporting initial
notification and
notification of
compliance status.
--------------------------------------
Sec. 63.10(b) (3).................. Records................ Applicability Yes.
Determinations.
--------------------------------------
Sec. 63.10(c)(1)-(6),(9)-(15)...... Records................ Additional Records for Yes.
CMS.
--------------------------------------
Sec. 63.10(c)(7)-(8)............... Records................ Records of excess No.
emissions and
parameter monitoring
exceedances for CMS.
--------------------------------------
Sec. 63.10(d)(1)................... General Reporting Requirement to report.. Yes.
Requirements.
--------------------------------------
Sec. 63.10(d)(2)................... Report of Performance When to submit to Yes.
Test Results. Federal or State
authority.
--------------------------------------
Sec. 63.10(d)(3)................... Reporting Opacity or VE What to report and when NA.
Observations.
--------------------------------------
Sec. 63.10(d)(4)................... Progress Reports....... Must submit progress Yes.
reports on schedule if
under compliance.
--------------------------------------
Sec. 63.10(d)(5)................... Startup, Shutdown, and Contents and submission Yes.
Malfunction Reports.
--------------------------------------
Sec. 63.10(e)(1)-(2)............... Additional CMS Reports. Must report results for Yes.
each CEM Reports on a
unit; written copy of
performance
evaluation; 3 copies
of COMS performance
evaluation.
--------------------------------------
Sec. 63.10(e)(3)................... Reports................ Excess Emission Reports No.
--------------------------------------
Sec. 63.10(e)(4)................... Reporting COMS data.... Must submit COMS data NA.
with performance test
data.
--------------------------------------
Sec. 63.10(f)...................... Waiver for Procedures for Yes.
Recordkeeping/ Administrator to waive.
Reporting.
--------------------------------------
Sec. 63.11......................... Flares................. Requirements for flares NA.
--------------------------------------
Sec. 63.12......................... Delegation............. State authority to Yes.
enforce standards.
--------------------------------------
Sec. 63.13......................... Addresses.............. Addresses where Yes.
reports,
notifications, and
requests are send.
--------------------------------------
Sec. 63.14......................... Incorporation by Test methods Yes.
Reference. incorporated by
reference.
--------------------------------------
Sec. 63.15......................... Availability of Public and confidential Yes.
Information. information.
----------------------------------------------------------------------------------------------------------------
Appendix A to Subpart DDDD--Alternative Procedure To Determine Capture
Efficiency From A Hot Press Enclosure in the Plywood and Composite Wood
Products Industry Using Sulfur Hexafluoride Tracer Gas
1.0 Scope and Application
This procedure has been developed specifically for the proposed
rule for the plywood and composite wood products industry and is
used to determine the capture efficiency of a partial hot press
enclosure in that industry. This procedure is applicable for the
determination of capture efficiency for press enclosures that are
not considered to be permanent total enclosures (PTEs) as defined in
EPA Method 204 and is proposed as an alternative to the construction
of temporary total enclosures (TTEs). Sulfur hexafluoride
(SF₆) is used as a tracer gas (other tracer gases may be
used if approved by the Administrator). This gas is not indigenous
to the ambient atmosphere and is nonreactive.
This procedure uses infrared spectrometry (IR) as the analytical
technique. When the infrared spectrometer used is a Fourier-
Transform Infrared spectrometer (FTIR), an alternate instrument
calibration procedure may be used; the alternate calibration
procedure is the calibration transfer standard (CTS) procedure of
EPA Method 320. Other analytical techniques which are capable of
[[Page 1333]]
equivalent Method Performance (Section 13.0) also may be used.
Specifically, gas chromatography with electron capture detection
(GC/ECD) is an applicable technique for analysis of SF₆.
2.0 Summary of Method
A constant mass flow rate of SF₆ tracer gas is
released through manifolds at multiple locations within the
enclosure to mimic the release of HAP during the press process. This
test method requires a minimum of three SF₆ injection
points (two at the press unloader and one at the press) and provides
details about considerations for locating the injection points. An
infrared spectrometer (or GC/ECD) is used to measure the
concentration of SF₆ at the inlet duct to the control
device (outlet duct from enclosure). Simultaneously, EPA Method 2 is
used to measure the flow rate at the inlet duct to the control
device. The concentration and flow rate measurements are used to
calculate the mass emission rate of SF₆ at the control
device inlet. Through calculation of the mass of SF₆
released through the manifolds and the mass of SF₆
measured at the inlet to the control device, the capture efficiency
of the enclosure is calculated.
In addition, optional samples of the ambient air may be taken at
locations around the perimeter of the enclosure to quantify the
ambient concentration of SF₆ and to identify those areas
of the enclosure that may be performing less efficiently; these
samples would be taken using disposable syringes and would be
analyzed using a GC/ECD.
Finally, in addition to the requirements specified in this
procedure, the data quality objectives (DQO) or lower confidence
limit (LCL) criteria specified in Appendix A to 40 CFR part 63,
subpart KK, Data Quality Objective and Lower Confidence Limit
Approaches for Alternative Capture Efficiency Protocols and Test
Methods, must also be satisfied. A minimum of three test runs are
required for this procedure; however, additional test runs may be
required based on the results of the DQO or LCL analysis.
3.0 Definitions
3.1 Capture efficiency (CE). The weight per unit time of
SF₆entering the control device divided by the weight per
unit time of SF₆ released through manifolds at multiple
locations within the enclosure.
3.2 Control device (CD). The equipment used to reduce, by
destruction or removal, press exhaust air pollutants prior to
discharge to the ambient air.
3.3 Control/destruction efficiency (DE). The VOC or HAP removal
efficiency of the control device.
3.4 Data Quality Objective (DQO) Approach. A statistical
procedure to determine the precision of the data from a test series
and to qualify the data in the determination of capture efficiency
for compliance purposes. If the results of the DQO analysis of the
initial three test runs do not satisfy the DQO criterion, the LCL
approach can be used or additional test runs must be conducted. If
additional test runs are conducted, then the DQO or LCL analysis is
conducted using the data from both the initial test runs and all
additional test runs.
3.5 Lower Confidence Limit (LCL) Approach. An alternative
statistical procedure that can be used to qualify data in the
determination of capture efficiency for compliance purposes. If the
results of the LCL approach produce a CE that is too low for
demonstrating compliance, then additional test runs must be
conducted until the LCL or DQO is met. As with the DQO, data from
all valid test runs must be used in the calculation.
3.6 Minimum Measurement Level (MML). The minimum tracer gas
concentration expected to be measured during the test series. This
value is selected by the tester based on the capabilities of the IR
spectrometer (or GC/ECD) and the other known or measured parameters
of the hot press enclosure to be tested. The selected MML must be
above the low-level calibration standard and preferably below the
mid-level calibration standard.
3.7 Method 204. The U.S. EPA Method 204, ``Criteria For and
Verification of a Permanent or Temporary Total Enclosure'' (40 CFR
part 51, Appendix M). If the permanent total enclosure (PTE)
criteria in Method 204 are satisfied, the PTE around a hot press is
assumed to be 100 percent capture efficient.
3.8 Method 205. The U.S. EPA Method 205, ``Verification of Gas
dilution Systems for Field Instrument Calibrations'' (40 CFR part
51, Appendix M).
3.9 Method 320. The U.S. EPA Method 320, ``Measurement of Vapor
Phase Organic and Inorganic Emissions by Extractive Fourier
Transform Infrared (FTIR) Spectroscopy'' (40 CFR part 63, Appendix
A).
3.10 Overall capture and control efficiency (CCE). The
collection and control/destruction efficiency of both the PPE and CD
combined. The CCE is calculated as the product of the CE and DE.
3.11 Partial press enclosure (PPE). The physical barrier that
``partially'' encloses the press equipment, captures a significant
amount of the associated emissions, and transports those emissions
to the CD.
3.12 Test series. A minimum of three test runs or, when more
than three runs are conducted, all of the test runs conducted.
4.0 Interferences
There are no known interferences.
5.0 Safety
Sulfur hexafluoride is a colorless, odorless, nonflammable
liquefied gas. It is stable and nonreactive and, because it is
noncorrosive, most structural materials are compatible with it. The
Occupational Safety and Health Administration PEL-TWA and TLV-TWA
concentrations are 1,000 parts per million. Sulfur hexafluoride is
an asphyxiant. Exposure to an oxygen deficient atmosphere (less than
19.5 percent oxygen) may cause dizziness, drowsiness, nausea,
vomiting, excess salivation, diminished mental alertness, loss of
consciousness and death. Exposure to atmospheres containing less
than 12 percent oxygen will bring about unconsciousness without
warning and so quickly that the individuals cannot help themselves.
Contact with liquid or cold vapor may cause frostbite. Avoid
breathing sulfur hexafluoride gas. Self contained breathing
apparatus may be required by rescue workers. Sulfur hexafluoride is
not listed as a carcinogen or a potential carcinogen.
6.0 Equipment and Supplies
This method requires equipment and supplies for: (a) The
injection of tracer gas into the enclosure, (b) the measurement of
the tracer gas concentration in the exhaust gas entering the control
device, and (c) the measurement of the volumetric flow rate of the
exhaust gas entering the control device. In addition, the requisite
equipment needed for EPA Methods 1--4 will be required. Equipment
and supplies for optional ambient air sampling are discussed in
Section 8.6.
6.1 Tracer Gas Injection.
6.1.1 Manifolds. This method requires the use of tracer gas
supply cylinder(s) along with the appropriate flow control elements.
Figure 1 shows a schematic drawing of the injection system showing
potential locations for the tracer gas manifolds. Figure 2 shows a
schematic drawing of the recommended configuration of the injection
manifold. Three tracer gas discharge manifolds are required at a
minimum.
6.1.2 Flow Control Meter. Flow control and measurement meter for
measuring the quantity of tracer gas injected. A mass flow,
volumetric flow, or critical orifice control meter can be used for
this method. The meter must be accurate to within +/- 5 percent at
the flow rate used. This means that the flow meter must be
calibrated against a primary standard for flow measurement at the
appropriate flow rate.
6.2 Measurement of Tracer Gas Concentration.
6.2.1 Sampling Probes. Use Pyrex or stainless steel sampling
probes of sufficient length to reach the traverse points calculated
according to EPA Method 1.
6.2.2 Sampling Line. Use a heated Teflon sampling line to
transport the sample to the analytical instrument.
6.2.3 Sampling Pump. Use a sampling pump capable of extracting
sufficient sample from the duct and transporting to the analytical
instrument.
6.2.4 Sample Conditioning System. Use a particulate filter
sufficient to protect the sampling pump and analytical instrument.
At the discretion of the tester and depending on the equipment used
and the moisture content of the exhaust gas, it may be necessary to
further condition the sample by removing moisture using a condenser.
6.2.5 Analytical Instrument. Use one of the following analytical
instruments.
6.2.1.1 Spectrometer. Use an infrared spectrometer designed to
measuring SF6 tracer gas and capable of meeting or exceeding the
specifications of this procedure. An FTIR meeting the specifications
of Method 320 may be used.
6.2.1.2 GC/ECD. Use a GC/ECD designed to measure SF6 tracer gas
and capable of meeting or exceeding the specifications of this
procedure.
6.2.6 Recorder. At a minimum, use a recorder with linear strip
chart. An automated data acquisition system (DAS) is recommended.
6.3 Exhaust Gas Flow Rate Measurement. Use equipment specified
for EPA Methods 2,
[[Page 1334]]
3, and 4 for measuring flow rate of exhaust gas at the inlet to the
control device.
7.0 Reagents and Standards
7.1 Tracer Gas. Use SF6 as the tracer gas. The manufacturer of
the SF6 tracer gas should provide a recommended shelf life for the
tracer gas cylinder over which the concentration does not change
more than +/- 2 percent from the certified value. A gas mixture of
SF6 diluted with nitrogen should be used; based on experience and
calculations, pure SF6 gas is not necessary to conduct tracer gas
testing. Select a concentration and flow rate that is appropriate
for the analytical instrument's detection limit, the minimum
measurement level (MML), and the exhaust gas flow rate from the
enclosure (see section 8.1.1). You may use a tracer gas other than
SF6 with the prior approval of the Administrator. If you use an
approved tracer gas other than SF6, all references to SF6 in this
protocol instead refer to the approved tracer gas.
7.2 Calibration Gases. The SF₆ calibration gases
required will be dependent on the selected MML and the appropriate
span selected for the test. Commercial cylinder gases certified by
the manufacturer to be accurate to within 1 percent of the certified
label value are preferable, although cylinder gases certified by the
manufacturer to 2 percent accuracy are allowed. Additionally, the
manufacturer of the SF6 calibration gases should provide a
recommended shelf life for each calibration gas cylinder over which
the concentration does not change more than +/- 2 percent from the
certified value. Another option allowed by this method is for the
tester to obtain high concentration certified cylinder gases and
then use a dilution system meeting the requirements of EPA Method
205, 40 CFR part 51, Appendix M, to make multi-level calibration gas
standards. Low-level, mid-level, and high-level calibration gases
will be required. The MML must be above the low-level standard, the
high-level standard must be no more than four times the low-level
standard, and the mid-level standard must be approximately halfway
between the high- and low-level standards. See section 12.1 for an
example calculation of this procedure.
Note: If using an FTIR as the analytical instrument, the tester
has the option of following the CTS procedures of Method 320; the
calibration standards (and procedures) specified in Method 320 may
be used in lieu of the calibration standards and procedures in this
protocol.
7.2.1 Zero Gas. High purity nitrogen.
7.2.2 Low-Level Calibration Gas. An SF6 calibration gas in
nitrogen with a concentration equivalent to 20 to 30 percent of the
applicable span value.
7.2.3 Mid-Level Calibration Gas. An SF6 calibration gas in
nitrogen with a concentration equivalent to 45 to 55 percent of the
applicable span value.
7.2.4 High-Level Calibration Gas. An SF6 calibration gas in
nitrogen with a concentration equivalent to 80 to 90 percent of the
applicable span value.
8.0 Sample Collection, Preservation, Storage, and Transport
8.1 Test Design
8.1.1 Determination of Minimum Tracer Gas Flow Rate.
8.1.1.1 Determine (via design calculations or measurements) the
approximate flow rate of the exhaust gas through the enclosure
(acfm).
8.1.1.2 Calculate the minimum tracer gas injection rate
necessary to assure a detectable SF6 concentration at the exhaust
gas measurement point (see section 12.1 for calculation).
8.1.1.3 Select a flow meter for the injection system with an
operating range appropriate for the injection rate selected.
8.1.2 Determination of the Approximate Time to Reach
Equilibrium.
8.1.2.1 Determine the volume of the enclosure.
8.1.2.2 Calculate the air changes per minute of the enclosure by
dividing the approximate exhaust flow rate (8.1.1.1 above) by the
enclosed volume (8.1.2.1 above).
8.1.2.3 Calculate the time at which the tracer concentration in
the enclosure will achieve approximate equilibrium. Divide 3 by the
air changes per minute (8.1.2.2 above) to establish this time. This
is the approximate length of time for the system to come to
equilibrium. Concentration equilibrium occurs when the tracer
concentration in the enclosure stops changing as a function of time
for a constant tracer release rate. Because the press is
continuously cycling, equilibrium may be exhibited by a repeating,
but stable, cyclic pattern rather than a single constant
concentration value. Assure sufficient tracer gas is available to
allow the system to come to equilibrium, and to sample for a minimum
of 20 minutes and repeat the procedure for a minimum of 3 test runs.
Additional test runs may be required based on the results of the DQO
and LCL analyses described in 40 CFR part 63, subpart KK, Appendix
A.
8.1.3 Location of Injection Points. This method requires a
minimum of three tracer gas injection points. The injection points
should be located within leak prone, VOC/HAP-producing areas around
the press, or horizontally within 12 inches of the defined
equipment. One potential configuration of the injection points is
depicted in Figure 1. The effect of wind, exfiltration through the
building envelope, and air flowing through open building doors
should be considered when locating tracer gas injection points
within the PPE. The injection points should also be located at a
vertical elevation equal to the VOC/HAP generating zones. The
injection points should not be located beneath obstructions that
would prevent a natural dispersion of the gas. Document the selected
injection points in a drawing(s).
8.1.4 Location of Flow Measurement and Tracer Sampling. Accurate
CD inlet gas flow rate measurements are critical to the success of
this procedure. Select a measurement location meeting the criteria
of EPA Method 1 (40 CFR part 60, Appendix A), Sampling and Velocity
Traverses for Stationary Sources. Also, when selecting the
measurement location, consider whether stratification of the tracer
gas is likely at the location (e.g., do not select a location
immediately after a point of air in-leakage to the duct).
8.2 Tracer Gas Release. Release the tracer gas at a calculated
flow rate (see section 12.1 for calculation) through a minimum of
three injection manifolds located as described above in 8.1.3. The
tracer gas delivery lines must be routed into the enclosure and
attached to the manifolds without violating the integrity of the
enclosure.
8.3 Pretest Measurements.
8.3.1 Location of Sampling Point(s). If stratification is not
suspected at the measurement location, select a single sample point
located at the centroid of the CD inlet duct or at a point no closer
to the CD inlet duct walls than 1 meter. If stratification is
suspected, establish a ``measurement line'' that passes through the
centroidal area and in the direction of any expected stratification.
Locate three traverse points at 16.7, 50.0 and 83.3 percent of the
measurement line and sample from each of these three points during
each run, or follow the procedure in section 8.3.2 to verify whether
stratification does or does not exist.
8.3.2 Stratification Verification. The presence or absence of
stratification can be verified by using the following procedure.
While the facility is operating normally, initiate tracer gas
release into the PPE. For rectangular ducts, locate at least nine
sample points in the cross section such that the sample points are
the centroids of similarly-shaped, equal area divisions of the cross
section. Measure the tracer gas concentration at each point.
Calculate the mean value for all sample points. For circular ducts,
conduct a 12-point traverse (i.e., six points on each of the two
perpendicular diameters) locating the sample points as described in
40 CFR part 60, Appendix A, Method 1. Perform the measurements and
calculations as described above. Determine if the mean pollutant
concentration is more than 10 percent different from any single
point. If so, the cross section is considered to be stratified, and
the tester may not use a single sample point location, but must use
the three traverse points at 16.7, 50.0, and 83.3 percent of the
entire measurement line. Other traverse points may be selected,
provided that they can be shown to the satisfaction of the
Administrator to provide a representative sample over the stack or
duct cross section.
8.4 CD Inlet Gas Flow Rate Measurements. The procedures of EPA
Methods 1-4 (40 CFR part 60, Appendix A) are used to determine the
CD inlet gas flow rate. Molecular weight (Method (3) and moisture
(Method (4) determinations are only required once for each test
series. However, if the test series is not completed within 24
hours, then the molecular weight and moisture measurements should be
repeated daily. As a minimum, velocity measurements are conducted
according to the procedures of Methods 1 and 2 before and after each
test run, as close to the start and end of the run as practicable. A
velocity measurement between two runs satisfies both the criterion
of ``after'' the run just completed and ``before'' the run to be
initiated. Accurate exhaust gas flow rate measurements are critical
to the success of this procedure. If significant temporal variations
of flow rate are anticipated during the test run under normal
process operating conditions, take
[[Page 1335]]
appropriate steps to accurately measure the flow rate during the
test. Examples of steps that might be taken include: (1) Conducting
additional velocity traverses during the test run; or (2)
continuously monitoring a single point of average velocity during
the run and using these data, in conjunction with the pre- and post-
test traverses, to calculate an average velocity for the test run.
8.5 Tracer Gas Measurement Procedure.
8.5.1 Calibration Error Test. Immediately prior to the emission
test (within 2 hours of the start of the test), introduce zero gas
and high-level calibration gas at the calibration valve assembly.
Zero and calibrate the analyzer according to the manufacturer's
procedures using, respectively, nitrogen and the calibration gases.
Calculate the predicted response for the low-level and mid-level
gases based on a linear response line between the zero and high-
level response. Then introduce the low-level and mid-level
calibration gases successively to the measurement system. Record the
analyzer responses for the low-level and mid-level calibration gases
and determine the differences between the measurement system
responses and the predicted responses using the equation in section
12.3. These differences must be less than 5 percent of the
respective calibration gas value. If not, the measurement system
must be replaced or repaired prior to testing. No adjustments to the
measurement system shall be conducted after the calibration and
before the drift determination (section 8.5.4). If adjustments are
necessary before the completion of the test series, perform the
drift checks prior to the required adjustments and repeat the
calibration following the adjustments. If multiple electronic ranges
are to be used, each additional range must be checked with a mid-
level calibration gas to verify the multiplication factor.
Note: If using an FTIR for the analytical instrument, you may
choose to follow the pretest preparation, evaluation, and
calibration procedures of Method 320 (section 8.0) (40 CFR part 63,
Appendix A) in lieu of the above procedure.
8.5.2 Response Time Test. Conduct this test once prior to each
test series. Introduce zero gas into the measurement system at the
calibration valve assembly. When the system output has stabilized,
switch quickly to the high-level calibration gas. Record the time
from the concentration change to the measurement system response
equivalent to 95 percent of the step change. Repeat the test three
times and average the results.
8.5.3 SF₆ Measurement. Sampling of the enclosure
exhaust gas at the inlet to the CD should begin at the onset of
tracer gas release. If necessary, adjust the tracer gas injection
rate such that the measured tracer gas concentration at the CD inlet
is within the spectrometer's calibration range (i.e., between the
MML and the span value). Once the tracer gas concentration reaches
equilibrium, the SF₆ concentration should be measured
using the infrared spectrometer continuously for at least 20 minutes
per run. Continuously record (i.e., record at least once per minute)
the concentration. Conduct at least three test runs. On the
recording chart, in the data acquisition system, or in a log book,
make a note of periods of process interruption or cyclic operation
such as the cycles of the hot press operation. Table 1 summarizes
the physical measurements required for the press enclosure testing.
Note: If a GC/ECD is used as the analytical instrument, a
continuous record (at least once per minute) likely will not be
possible; make a minimum of five injections during each test run.
Also, the minimum test run duration criterion of 20 minutes applies.
8.5.4 Drift Determination. Immediately following the completion
of the test run, reintroduce the zero and mid-level calibration
gases, one at a time, to the measurement system at the calibration
valve assembly. (Make no adjustments to the measurement system until
both the zero and calibration drift checks are made.) Record the
analyzer responses for the zero and mid-level calibration gases and
determine the difference between the instrument responses for each
gas prior to and after the emission test run using the equation in
section 12.4. If the drift values exceed the specified limits
(section 13), invalidate the test results preceding the check and
repeat the test following corrections to the measurement system.
Alternatively, recalibrate the test measurement system as in section
8.5.1 and report the results using both sets of calibration data
(i.e., data determined prior to the test period and data determined
following the test period).
Note: If using an FTIR for the analytical instrument, you may
choose to follow the post-test calibration procedures of Method 320
(section 8.11.2) in lieu of the above procedures.
8.6 Ambient Air Sampling (Optional). Sampling the ambient air
surrounding the enclosure is optional. However, taking these samples
during the capture efficiency testing will identify those areas of
the enclosure that may be performing less efficiently.
8.6.1 Location of Ambient Samples Outside the Enclosure
(Optional). In selecting the sampling locations for collecting
samples of the ambient air surrounding the enclosure, consider
potential leak points, the direction of the release, and laminar
flow characteristics in the area surrounding the enclosure. Samples
should be collected from all sides of the enclosure, downstream in
the prevailing room air flow, and in the operating personnel
occupancy areas.
8.6.2 Collection of Ambient Samples (Optional). During the
tracer gas release, collect ambient samples from the area
surrounding the enclosure perimeter at predetermined location using
disposable syringes or some other type of containers that are non-
absorbent, inert and that have low permeability (i.e., polyvinyl
fluoride film or polyester film sample bags or polyethylene,
polypropylene, nylon or glass bottles). The use of disposable
syringes allows samples to be injected directly into a gas
chromatograph. Concentration measurements taken around the perimeter
of the enclosure provide evidence of capture performance and will
assist in the identification of those areas of the enclosure that
are performing less efficiently.
8.6.3 Analysis and Storage of Ambient Samples (Optional).
Analyze the ambient samples using an analytical instrument
calibrated and operated according to the procedures of this appendix
or ASTM E 260 and ASTM E 697. Samples may be analyzed immediately
after a sample is taken, or they may be stored for future analysis.
Experience has shown no degradation of concentration in
polypropylene syringes when stored for several months as long as the
needle or syringe is plugged. Polypropylene syringes should be
discarded after one use to eliminate the possibility of cross
contamination of samples.
9.0 Quality Control
9.1 Sampling, System Leak Check. A sampling system leak check
should be conducted prior to and after each test run to ensure the
integrity of the sampling system.
9.2 Zero and Calibration Drift Tests
------------------------------------------------------------------------
Quality control
Section measure Effect
------------------------------------------------------------------------
8.5.4........................... Zero and Ensures that bias
calibration drift introduced by
tests. drift in the
measurement
system output
during the run is
no greater than 3
percent of span.
------------------------------------------------------------------------
10.0 Calibration and Standardization
10.1 Control Device Inlet Air Flow Rate Measurement Equipment.
Follow the equipment calibration requirements specified in Methods
2, 3, and 4 for measuring the velocity, molecular weight, and
moisture of the control device inlet air.
10.2 Tracer Gas Injection Rate. A dry gas volume flow meter,
mass flow meter, or orifice can be used to measure the tracer gas
injection flow rate. The selected flow measurement device must have
an accuracy of greater than +/- 5 percent at the field operating
range. Prior to the test, verify the calibration of the selected
flow measurement device using either a wet test meter, spirometer,
or liquid displacement meter as the calibration device. Select a
minimum of two flow rates to bracket the expected field
[[Page 1336]]
operating range of the flow meter. Conduct three calibration runs at
each of the two selected flow rates. For each run, note the exact
quantity of gas as determined by the calibration standard and the
gas volume indicated by the flow meter. For each flow rate,
calculate the average percent difference of the indicated flow
compared to the calibration standard.
10.3 Spectrometer. Follow the calibration requirements specified
by the equipment manufacturer for infrared spectrometer measurements
and conduct the pretest calibration error test specified in section
8.5.1. Note: if using an FTIR analytical instrument see Method 320,
section 10.
10.4 Gas Chromatograph. Follow the pre-test calibration
requirements specified in section 8.5.1.
10.4 Gas Chromatograph for Ambient Sampling (Optional). For the
optional ambient sampling, follow the calibration requirements
specified in section 8.5.1 or ASTM E 260 and E 697 and by the
equipment manufacturer for gas chromatograph measurements.
11.0 Analytical Procedures
The sample collection and analysis are concurrent for this
method (see section 8.0).
12.0 Calculations and Data Analysis
12.1 Estimate MML and Span. The MML is the minimum measurement
level. The selection of this level is at the discretion of the
tester. However, the MML must be higher than the low-level
calibration standard and the tester must be able to measure at this
level with a precision of <=10 percent. As an example, select the
MML as 10 times the instrument's published detection limit. The
detection limit of one instrument is 0.01 parts per million by
volume (ppm_v). Therefore, the MML would be 0.10
ppm_v. Select the low-level calibration standard as 0.08
ppm_v. The high-level standard would be four times the
low-level standard or 0.32 ppm_v. A reasonable mid-level
standard would then be 0.20 ppm_v (halfway between the
low-level standard and the high-level standard). Finally, the span
value would be approximately 0.40 ppm_v (the high-level
value is 80 percent of the span). In this example, the following
MML, calibration standards, and span values would apply:
MML = 0.10 ppm_v
Low-level standard = 0.08 ppm_v
Mid-level standard = 0.20 ppm_v
High-level standard = 0.32 ppm_v
Span value = 0.40 ppm_v
12.2 Estimate Tracer Gas Injection Rate for the Given Span. To
estimate the minimum and maximum tracer gas injection rate, assume a
worst case capture efficiency of 80 percent, and calculate the
tracer gas flow rate based on known or measured parameters. To
estimate the minimum tracer gas injection rate, assume that the MML
concentration (10 times the IR detection limit in this example) is
desired at the measurement location. The following equation can be
used to estimate the minimum tracer gas injection rate:
((Q_T-MIN x 0.8)/Q_E) x (C_T / 100) x
106 = MML
Q_T-MIN = 1.25 x MML x (Q_E /C_T) x
10-4
Where:
Q_T-MIN = minimum volumetric flow rate of tracer gas
injected, scfm
Q_E = volumetric flow rate of exhaust gas, scfm
C_T = Tracer gas (SF₆) concentration in gas
blend, percent by volume
MML = minimum measured level, ppm_v = 10 x IR_DL
(for this example)
IR_DL= IR detection limit, ppm_v
Standard conditions: 20 [deg]C, 760 mm Hg.
To estimate the maximum tracer gas injection rate, assume that
the span value is desired at the measurement location. The following
equation can be used to estimate the maximum tracer gas injection
rate:
((Q_T-MAX x 0.8)/Q_E) x (C_T / 100) x
106 = span value
Q_T-MAX = 1.25 x span value x (Q_E /
C_T) x 10-4
Where:
Q_T-MAX = maximum volumetric flow rate of tracer gas
injected, scfm
Span value = Instrument span value, ppm_v
The following example illustrates this calculation procedure:
Find the range of volumetric flow rate of tracer gas to be
injected when the following parameters are known:
Q_E = 60,000 scfm (typical exhaust gas flow rate from a
press enclosure)
C_T = 2 percent SF₆ in nitrogen
IR_DL= 0.01 ppm_v (per manufacturer's
specifications)
MML = 10 x IR_DL = 0.10 ppm_v
Span value = 0.40 ppm_v
Q_T = ?
Minimum tracer gas volumetric flow rate:
Q_T-MIN = 1.25 x MML x (Q_E /C_T) x
10-4
Q_T-MIN = 1.25 x 0.10 x (60,000/2) x 10-4 =
0.375 scfm
Maximum tracer gas volumetric flow rate:
Q_T-MAX = 1.25 x span value x (Q_E /
C_T) x 10-4
Q_T-MAX = 1.25 x 0.40 x (60,000/2) x 10-4 = 1.5
scfm
In this example, the estimated total volumetric flow rate of the
two percent SF₆ tracer gas injected through the manifolds
in the partial enclosure lies between 0.375 and 1.5 scfm.
12.3 Calibration Error. Calculate the calibration error for the
low-level and mid-level calibration gases using the following
equation:
Err = [bond]
C_std - C_meas [bond]
/
C_std x 100
Where:
Err = Calibration error, percent
C_std = Low-level or mid-level calibration gas value,
ppm_v
C_meas = Measured response to low-level or mid-level
concentration gas, ppm_v
12.4 Calibration Drift. Calculate the calibration drift for the
zero and low-level calibration gases using the following equation:
D = [bond]
C_initial - C_final [bond]
/
C_span x 100
Where:
D = Calibration drift, percent
C_initial = Low-level or mid-level calibration gas value
measured before test run, ppm_v
C_final = Low-level or mid-level calibration gas value
measured after test run, ppm_v
C_span = Span value, ppm_v
12.5 Calculate Capture Efficiency. The equation to calculate
press enclosure capture efficiency is provided below:
CE = (SF_6-CD / SF_6-INJ) x 100
Where:
CE = capture efficiency
SF_6-CD = mass of SF₆ measured at the inlet to
the CD
SF_6-INJ = mass of SF₆ injected from the tracer
source into the PPE
Calculate the CE for each of the initial three test runs. Then,
follow the procedures outlined in section 12.6 to calculate the
Overall Capture Efficiency.
12.6 Calculate Overall Capture Efficiency. After calculating the
capture efficiency for each of the initial three test runs, follow
the procedures in 40 CFR part 63, subpart KK, Appendix A to
determine if the results of the testing can be used in determining
compliance with the requirements of the proposed rule. There are two
methods that can be used: the DQO and LCL methods. The DQO method is
described in section 3 of 40 CFR part 63, subpart KK, Appendix A and
provides a measure of the precision of the capture efficiency
testing conducted. Section 3 of 40 CFR part 63, subpart KK, Appendix
A provides an example calculation using results from a facility. If
the DQO criteria are met using the first set of three test runs,
then the facility can use the average capture efficiency of these
test results to determine the capture efficiency of the partial hot
press enclosure. If the DQO criteria are not met then the facility
can conduct another set of three runs and run the DQO analysis again
using the results from the six runs OR the facility can elect to use
the LCL approach.
The LCL method is described in section 4 of 40 CFR part 63,
subpart KK, Appendix A and provides sources that may be performing
much better than their regulatory requirement a screening option by
which they can demonstrate compliance. The LCL approach compares the
80 percent lower confidence limit for the mean measured CE value to
the applicable regulatory requirement. If the LCL capture efficiency
is higher than the applicable limit, then the facility is in initial
compliance and would use the LCL capture efficiency as the capture
efficiency to determine compliance. If the LCL capture efficiency is
lower than the applicable limit, then the facility must perform
additional test runs and re-run the DQO or LCL analysis.
13.0 Method Performance
13.1 Measurement System Performance Specifications.
13.1.1 Zero Drift. Less than +/- 3 percent of the span value.
13.1.2 Calibration Drift. Less than +/- 3 percent of the span
value.
13.1.3 Calibration Error. Less than +/- 5 percent of the
calibration gas value.
13.2 Flow Measurement Specifications. The mass flow, volumetric
flow, or critical orifice control meter used should have an accuracy
of greater than +/- 5 percent at the flow rate used.
13.3 Calibration and Tracer Gas Specifications. The manufacturer
of the
[[Page 1337]]
calibration and tracer gases should provide a recommended shelf life
for each calibration gas cylinder over which the concentration does
not change more than +/- 2 percent from the certified value.
14.0 Pollution Prevention [Reserved]
15.0 Waste Management [Reserved]
16.0 References
1. 40 CFR part 60, Appendix A, EPA Method 1--Sample and velocity
traverses for stationary sources.
2. 40 CFR part 60, Appendix A, EPA Method 2--Determination of
stack gas velocity and volumetric flow rate.
3. 40 CFR part 60, Appendix A, EPA Method 3--Gas analysis for
the determination of dry molecular weight.
4. 40 CFR part 60, Appendix A, EPA Method 4--Determination of
moisture content in stack gases.
5. SEMI F15-93 Test Method for Enclosures Using Sulfur
Hexafluoride Tracer Gas and Gas Chromotography.
6. Memorandum from John S. Seitz, Director, Office of Air
Quality Planning and Standards, to EPA Regional Directors, Revised
Capture Efficiency Guidance for Control of Volatile Organic Compound
Emissions, February 7, 1995. (That memorandum contains an attached
technical document from Candace Sorrell, Emission Monitoring and
Analysis Division, ``Guidelines for Determining Capture
Efficiency,'' January 9, 1994).
7. Technical Systems Audit of Testing at Plant ``C,'' EPA-454/R-
00-26, May 2000.
8. Material Safety Data Sheet for SF₆. Air Products
and Chemicals, Inc. Website: www3.airproducts.com. October 2001.
17.0 Tables, Diagrams, Flowcharts, and Validation Data
Table 1.--Summary of Critical Physical Measurements for the Press Enclosure Testing
----------------------------------------------------------------------------------------------------------------
Measurement
Measurement instrumentation Measurement frequency Measurement site
----------------------------------------------------------------------------------------------------------------
Tracer gas injection rate............ Mass flow meter, Continuous............. Injection manifolds
volumetric flow meter (cylinder gas).
or critical orifice.
--------------------------------------
Tracer gas concentration at control Infrared Spectrometer Continuous (at least Inlet duct to the
device inlet. or GC/ECD. one reading per control device (outlet
minute) for a minimum duct of enclosure).
of 20 minutes.
--------------------------------------
Volumetric air flow rate............. EPA Methods 1, 2, 3, 4 Each test run for Inlet duct to the
(40 CFR part 60, velocity (minimum); control device (outlet
Appendix A). Daily for moisture and duct of enclosure).
[sbull]
Velocity sensor molecular weight.
(Manometer/Pito t
tube).
[sbull]
Thermocouple...
[sbull]
Midget Impinger
sampler.
[sbull]
Orsat or Fyrite
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[FR Doc. 03-84 Filed 1-8-03; 8:45 am]
BILLING CODE 6560-50-C

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