"
Hunt,
Tim"
<
Tim_
Hunt@
afandpa
To:
Mary
Kissell/
RTP/
USEPA/
US@
EPA
.
org>
cc:
Ken
Hustvedt/
RTP/
USEPA/
US@
EPA,
Sally
Shaver/
RTP/
USEPA/
US@
EPA
10/
27/
03
06:
17
PM
Subject:
Wood
MACT
Mary
Tom,

As
you
know,
we
have
been
examining
ways
to
increase
the
use
of
pollution
prevention
as
a
real
compliance
alternative
in
Wood
MACT.
The
PBELs
are
a
start
and
the
use
of
add­
on
controls
with
them
would
really
help
(
subject
of
10/
30
meeting).
Another
approach
is
to
give
facilities
more
time
to
comply
if
they
adopt
P2
given
the
complexities
to
ensure
sufficient
reductions.
This
approach
originated
from
discussions
with
OGC.

We
would
like
to
talk
about
this
idea
on
Thursday
during
our
meeting
along
with
the
more
traditional
one­
year
compliance
extension.

Let
me
know
if
you
have
any
questions
in
advance.

<<
Compliance
extension
for
P2
10­
27­
03.
doc>>

Timothy
Hunt
Senior
Director,
Air
Quality
Programs
American
Forest
and
Paper
Association
Suite
800
1111
19th
St.,
NW
Washington,
DC
20036
phone:
202­
463­
2588
fax:
202­
463­
2423
Tim_
Hunt@
afandpa.
org
(
See
attached
file:
Compliance
extension
for
P2
10­
27­
03.
doc)
Importance
of
a
Pollution
Prevention
Compliance
Extension
In
the
Plywood
and
Composite
Wood
Panel
MACT
The
proposed
Plywood
and
Composite
Wood
Panel
(
Wood)
MACT
rule
(
40
C.
F.
R.
§
63.2233),
requires
an
existing
source
to
come
into
compliance
three
years
after
its
promulgation.
AF&
PA
recommends
an
additional
4­
year
compliance
extension
for
process
units
that
intend
to
implement
pollution
prevention
as
their
primary
compliance
strategy.
The
concept
of
pollution
prevention
has
long
since
been
legitimized
as
the
best
way
to
utilize
limited
resources
and
protect
the
environment
from
unwanted
collateral
emissions
produced
by
the
use
of
add
on
controls.
The
life
cycle
inventory
(
LCI)
commissioned
by
AF&
PA
and
provided
as
part
of
AF&
PA's
comments
on
the
proposed
rule
shows
that
the
widespread
use
of
combustion
devices
such
as
RTOs
and
RCOs
will
have,
at
best,
a
questionable
net
benefit
to
the
environment.
Especially
significant
in
the
LCI
analysis
was
the
impact
of
emissions
related
to
the
off­
site
electrical
generation
needed
to
power
the
large
horsepower
fans
required
by
add­
on
controls.
AF&
PA
believes,
however,
that,
if
the
recommended
compliance
extension
cannot
be
accommodated,
industry
wide
implementation
of
innovative
pollution
prevention
options
may
be
precluded
due
to
the
significant
time
required
to
develop,
implement,
and
assess
the
success
of
innovative
approaches.

Pollution
prevention
projects
have
several
attributes
in
common
that
lead
to
their
being
more
complex,
time
consuming,
and
potentially
more
capital
intensive
than
simply
installing
add­
on
controls.
The
use
of
add­
on
controls
is
a
brute
force
approach
which
encourages
operations
to
run
hot,
hard,
and
dirty
in
order
to
justify
the
control
cost.
For
existing
facilities,
implementing
pollution
prevention
projects
may
involve
substantial
investment
and
modification
of
the
existing
processes
in
an
iterative
process
that
achieves
incremental
reductions,
identifies
roadblocks
to
further
progress,
addresses
those
roadblocks,
and
moves
on
to
the
next
issue.
The
time
commitment
to
pursue
this
strategy
can
be
substantial.

In
other
instances,
fundamental
changes
in
process
technology
may
be
needed.
For
example,
one
commonly
studied
approach
for
reducing
emissions
is
to
dry
the
wood
fiber
or
chips
at
a
substantially
lower
temperature
and/
or
to
a
higher
final
moisture
set­
point.
Maintaining
that
higher
moisture
set­
point
at
the
dryers
on
a
consistent
basis
without
excursions
on
the
high
side
which
threaten
product
quality
or
excursions
on
the
low
side
which
threaten
noncompliance
is
likely
to
require
process
refinements
in
wood
preparation,
wood
screening,
wood
flow
control
to
the
dryers,
dryer
temperature
control,
wood
moisture
measurement,
etc.
Accommodating
the
higher
moisture
content
in
the
board
manufacturing
process
is
likely
to
require
resin
reformulation,
blender
modifications,
forming
line
refinements,
and
other
measures
as
determined
during
the
process
of
feasibility
trials.
Implementing
such
an
approach
could
ultimately
involve
replacing
the
whole
dryer
system,
with
capital
costs
that
are
an
order
of
magnitude
greater
than
the
add­
on
control
systems,
but
with
substantially
lower
overall
operating
costs,
energy
use,
and
collateral
emissions.

It
would
seem
to
be
highly
appropriate
to
permit
additional
compliance
time
for
facilities
to
allow
sufficient
time
to
plan,
coordinate,
and
implement
the
best
1
combination
of
process
changes
to
facilitate
pollution
prevention
in
conjunction
with
a
rational
business
model.
Prior
MACT
standards
provide
precedent
for
such
an
approach.
Additional
justification
for
this
request
is
provided
below.

Widespread
implementation
of
pollution
prevention
options
would
be
precluded
Pollution
prevention
approaches
for
complying
with
the
Wood
MACT
rule
should
be
strongly
encouraged,
as
they
can
avoid
or
minimize
the
environmental
disbenefits
associated
with
using
add­
on,
incineration­
based
control
systems.
However,
because
many
of
the
envisioned
pollution
prevention
approaches
have
either
not
been
fully
researched
nor
field
tested,
an
additional
4­
year
window
is
necessary
to
foster,
develop
and
implement
these
approaches,
and
to
assure
continuous
compliance.
In
addition,
facility
managers
must
have
complete
confidence
that
pollution
prevention
approaches
will
meet
continuous
compliance
requirements.
Continuously
certifiable
compliance
can
be
threatened
by
process
variables
such
as
seasonality
of
raw
materials.
A
four­
year
compliance
extension
serves
to
provide
an
incentive
to
innovate
by
providing
additional
R&
D
time
that
will
serve
to
protect
against
noncompliance
action
during
the
crucial
new
technology
development
and
implementation
process.

Avoid
environmental
disbenefits
As
discussed
in
§
II
of
the
AF&
PA
comments
on
the
proposed
rule,
incineration­
based
add­
on
control
systems
have
significant
environmental
disbenefits.
These
include
large
increases
in
fossil
fuel
energy
use,
electric
power
consumption,
greenhouse
gas
emissions,
and
emissions
of
other
criteria
pollutants
including
SO2
and
NOx.
For
example,
at
many
wood
products
facilities,
the
burning
of
fossil
fuels
in
an
RTO/
RCO
may
be
the
only
significant
source
of
greenhouse
gas
emissions
(
CO2).
Moreover,
since
RTO/
RCOs
will
be
fired
exclusively
with
natural
gas
or
propane,
this
will
diminish
our
national
strategic
supply
used
for
home
heating,
electric
utilities,
and
vital
industrial
production,
for
little
or
no
environmental
benefit.
The
electrical
requirements
of
RTO/
RCO
technology
will
provide
additional
demands
on
scarce
electrical
generation/
transmission
resources
as
well
as
generation­
related
emissions.

Additional
time
is
needed
for
the
implementation
of
pollution
prevention
options
In
the
preamble
of
the
proposed
Wood
MACT
rule,
EPA
acknowledges
the
difficulties
in
implementing
pollution
prevention
options
with
the
following
quote:

Although
we
believe
that
the
potential
for
pollution
prevention
exists
for
some
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.
2
While
AF&
PA
believes
that
there
are
pollution
prevention
options
that
hold
significant
promise
for
successfully
reducing
emissions
to
the
ranges
required
by
the
proposed
rule,
the
industry
also
agrees
that
these
options
have
neither
been
widely
commercialized
nor
demonstrated.
This
is
not
for
lack
of
effort
or
research
on
the
part
of
the
PCWP
industry.
Industry­
wide
efforts
as
part
of
the
AF&
PA
Agenda
2020
and
company­
specific
projects
have
placed
a
high
priority
on
commercial
applications
for
these
technologies.
Companies
typically
consider
these
pollution
prevention
efforts
to
be
business
confidential
projects,
meaning
that
a
detailed
description
of
candidate
projects
is
not
appropriate.
However,
general
types
of
pollution
prevention
projects
being
developed
and
their
generic
attributes
are
described
in
the
following
paragraphs.
As
noted
above,
these
pollution
prevention
approaches
are
most
likely
to
be
implemented
in
conjunction
with
one
or
more
other
elements
leading
to
a
need
for
the
development
of
additional
levels
of
integration.
This
integration
can
only
be
accomplished
with
adequate
time.

1)
Low
Temperature/
High
Moisture
Drying
&
Pressing
It
is
widely
acknowledged
that
a
degree
of
HAP
reduction
can
be
accomplished
by
drying
fiber
at
a
lower
temperature.
However,
lowering
the
drying
temperature
also
has
the
unwanted
effect
of
reducing
the
rated
capacity
of
wood
drying/
pressing
equipment.
Additional
research
time
is
required
to
develop
methods
for
panel
construction
that
include
a
higher
moisture
specification
that
will
still
meet
consumer
quality
demands
and
maintain
the
production
viability
of
the
plant.
As
noted
above,
implementation
of
this
approach
at
an
existing
facility
is,
of
necessity,
an
iterative,
diagnostic
exercise
involving
virtually
all
aspects
of
the
manufacturing
process
and
is
likely
to
involve
elements
described
in
items
3,
4,
5,
and
6
below.
While
the
fundamental
feasibility
of
the
approach
has
been
studied
at
a
few
facilities,
each
plant
has
a
unique
combination
of
wood
species,
wood
refining
equipment
(
flakers,
chippers,
refiners,
etc.),
wood
screening
equipment,
dryers,
burners,
etc.
which
must
be
assessed.

Revamping
the
dryer
and
the
press
process
at
an
existing
plant
to
reduce
emissions
is
significantly
more
costly
and
time
consuming
than
merely
placing
an
end­
of­
pipe
air
pollution
control
system
on
the
process.
To
maintain
the
existing
capacity
of
the
plant,
the
revamping
project
would
typically
entail
the
replacement
of
the
dryers
and
significant
modifications
to
the
remainder
of
the
forming
line,
the
press
and
perhaps
the
other
combustions
systems.
And
even
with
such
a
project,
some
air
pollution
control
system
may
still
be
necessary.

The
revamping
project
is
estimated
to
have
a
capital
cost
of
two
to
four
times
the
cost
of
the
installation
of
an
end­
of­
pipe
air
pollution
control
systems.
The
project
development
and
installation
schedule
for
the
revamping
project
is
estimated
to
take
two
to
two­
and­
a­
half
times
as
long.
Note,
the
revamping
project
has
additional
costs
as
well,
including
a
significant
increase
in
lost
production.
The
tie­
in
and
startup
of
an
end­
of­
pipe
air
pollution
control
system
can
be
accomplished
with
little
or
no
disruption
to
production,
typically
from
two
days
to
a
week.
The
revamping
project
can
easily
lead
to
a
lost
production
equivalent
of
a
month,
which
could
amount
to
several
million
dollars
in
lost
revenue.
3
The
post­
installation
process
is
also
more
involved
in
the
revamping
project.
An
initial
baseline
is
required
including
determination
of
issues
such
as
seasonal/
wood
species­
related
variability.
This
process
can
easily
require
a
year
of
detailed
effort.
Then
follows
a
period
of
study
to
determine
what
moisture
levels
will
assure
consistent
compliance.
Next
is
a
variability
study
to
determine
refinements
needed
to
assure
consistent
maintenance
of
those
moisture
levels
across
a
reasonable
range
of
process
operations
including
seasonal
variations.
Next
is
a
process
study
to
determine
measures
needed
to
assure
adequate
production
quality,
quantity,
and
cost
at
the
new
moisture
levels.
A
period
of
implementation
of
process
refinements
would
then
be
necessary
followed
by
a
period
of
assessment
of
the
potential
for
maintenance
of
continuing
compliance
along
with
the
needed
production
attributes.
Given
the
number
of
variable
involved,
it
is
unlikely
that
all
issues
will
be
resolved
within
the
first
effort
requiring
additional
work
to
tie
up
loose
ends.
It
is
this
process
of
assess,
refine,
and
reassess
that
is
anticipated
to
require
the
requested
extension
of
time
for
demonstration
of
compliance.

2)
Conveyor
Drying
Conveyor
drying
is
a
relatively
new
concept
that
mechanically
conveys
the
wood
furnish
through
the
dryer
and
achieves
partial
control
by
routing
exhaust
gases
from
the
first
dryer
hot
zone
into
a
burner
section
or
a
boiler
and
recycling
the
latent
heat
back
into
the
dryer.
Since
airflow
is
not
relied
upon
to
move
the
furnish
through
the
dryer
(
as
is
the
case
with
most
rotary
dryers),
conveyor
dryers
can
carefully
regulate
temperatures
on
a
zoned
basis
and
provide
additional
emissions
reductions.
The
burner
or
boiler
provides
the
requisite
heat
for
the
drying
process
(
and
possibly
other
plant
heating
needs).
At
present,
there
are
few
commercial
applications,
and
even
fewer
vendors.
At
this
time,
conveyor
dryers
are
very
capital
intensive
and
have
a
significantly
higher
cost
than
implementing
the
control
technology.
Additional
compliance
time
is
warranted
so
that
companies
can
replace
existing
dryers
when
they
are
beyond
their
useful
life
(
average
10
to
15
years)
with
lower
HAP
emitting
conveyor
dryers.
While
a
four
year
compliance
extension
(
resulting
in
a
total
compliance
time
of
seven
years)
does
not
extend
to
the
full
useful
life
of
existing
dryers,
the
extension
would
allow
a
sufficient
portion
of
the
useful
life
of
existing
dryers
to
be
expended
such
that
it
would
be
economically
viable
for
companies
to
invest
the
significantly
higher
capital
that
is
required
to
replace
current
dryers
with
conveyor
dryers,
rather
than
simply
installing
incinerators.

3)
Species
Control/
Substitution
Some
facilities
may
have
the
ability
to
utilize
lower
HAP
emitting
raw
material
species
or
combinations
of
such.
Other
facilities
are
performing
research
on
agricultural
substitutes
that
may
have
lower
HAP
emissions.
This
process
of
substitution
of
raw
materials
gives
rise
to
all
the
process
considerations
described
for
the
low
temperature/
high
moisture
drying
and
pressing
described
above
plus
additional
material
handling
issues
based
on
the
nature
of
the
new
furnish
characteristics.
Additional
difficulties
can
be
encountered
locating
and
consolidating
a
new
supply
chain
for
new
lower
HAP
emitting
species.
The
requested
four­
year
4
extension
will
be
easily
consumed
in
working
through
these
issues
in
an
orderly
fashion.

4)
Resin
Reformulation
At
present
there
are
three
major
suppliers
of
resin
to
the
panel
industry.
All
the
major
suppliers
have
initiated
research
and
development
of
lower
HAP
resins.
Research
has
also
been
initiated
on
types
of
resins,
such
as
powdered
resins,
that
can
be
utilized
in
conjunction
with
lower
temperature
drying
to
provide
a
high
quality
product
with
a
higher
level
of
moisture
remaining
the
panel.
This
pollution
prevention
option
is
still
in
its
formative
stages.
While
some
preliminary
research
has
been
conducted,
another
3
to
5
years
is
likely
to
be
needed
before
lower
HAP
resins
become
commercially
viable.

5)
Reducing
Moisture
Variability/
Precision
Process
Control
By
using
precision
process
control
either
in
the
dryer
or
prior
to
the
dryer,
facilities
can
limit
high
moisture
variability
in
boards
and
flakes
that
contribute
to
overdrying
and
high
HAP
emissions.
By
reducing
this
variability,
target
moistures
can
be
increased
and
wood
fiber
temperatures
can
be
reduced
during
the
drying
process.
This
can
provide
substantial
reductions
in
HAP
formation
in
the
dryer.
While
some
aspects
of
this
approach
are
currently
available
and
demonstrated,
this
approach
alone
will
not
yield
sufficient
HAP
emission
reductions
by
itself
to
meet
the
requirements
of
the
rule.
Thus,
this
option
needs
to
be
used
in
conjunction
with
other
developed
and
un­
developed
pollution
prevention
options
described
in
this
paper.

6)
Green
Screening
HAP
release
is
directly
related
to
wood
tissue
temperature
during
drying.
Because
of
their
small
surface
areas,
fines
can
release
significant
quantity
of
HAPs
when
they
become
overheated/
overdryed.
When
these
small
particles
are
removed
prior
to
drying,
significant
HAP
reductions
can
be
accomplished.
Green
screening
is
a
substantial
capital
expense
potentially
affecting
all
downstream
processes.
Retrofit
of
this
equipment
at
an
existing
facility
requires
interruption
of
the
existing
line
of
process
flow
in
order
to
integrate
the
screening
process
ahead
of
the
furnish
dryers.
Costs
for
retrofit
application
can
easily
approach
$
1.0
million.

Since
green
fines
tend
to
stick
to
green
flakes,
their
separation
is
difficult
without
subjecting
the
flakes
to
excessive
agitation
which
produces
additional
fine
particles.
This
technology
has
not
widely
been
applied
in
the
Wood
Products
industry;
therefore,
research
needs
to
move
forward
on
optimum
screening
techniques
and
screen
sizes
in
relation
to
HAP
emissions.
Additionally,
alternative
uses
and
markets
for
the
material
rejected
by
the
screening
also
need
to
be
developed.

7)
Reduction
of
Temperature
Stratification
As
with
green
screening,
HAP
reduction
can
be
accomplished
by
reducing
the
temperature
stratification
within
flake
dryers
and
lowering
the
overall
dryer
operating
5
temperatures.
Accomplishing
these
reductions
will
require
an
iterative
process
of
equipment
modification
and
raw
material
flow
control
that
will
demand
time
for
development.
This
technology
option,
along
with
several
other
options
we
have
described
could
potentially
be
construed
as
physical
changes
or
changes
in
the
method
of
operation
requiring
NSR
permitting
delays
from
4
months
to
more
than
1
year.
Additionally,
this
technology
has
not
been
fully
developed
and,
in
all
likelihood
would
require
combinations
of
technologies
to
ensure
compliance.

8)
Oxidation
in
Existing
Combustion
Devices
The
industry
feels
strongly
that
the
use
of
an
existing
on­
site
combustion
device
such
as
process
boilers
or
thermal
oil
heaters
should
be
considered
as
an
environmentallypreferable
pollution
prevention
technique.
For
example,
part
of
the
emission
unit
exhaust
could
be
used
as
combustion
air
for
an
existing
boiler.
In
most
cases,
the
process
boiler
could
not
utilize
all
of
the
large
volume
of
air
from
multiple
dryer
stacks.
It
could,
however,
utilize
part
of
the
exhaust.
Using
this
approach
in
conjunction
with
one
or
several
of
the
other
pollution
prevention
techniques
that
are
not
yet
fully
developed,
a
facility
could
comply
with
a
production
based
emission
limit.
The
availability
of
this
option
would
preclude
the
need
for
RTO
technology
and
would
provide
a
net
benefit
to
the
environment
with
the
reduction
in
collateral
emissions.
The
success
of
this
option
is
at
least
partially
tied
to
further
research
on
airflow
reduction.
In
addition,
the
introduction
of
a
hot,
moist,
VOC­
laden
air
stream
into
an
existing
combustion
device
often
requires
extensive
re­
engineering
of
systems
originally
designed
for
ambient
combustion
air.
These
sorts
of
re­
engineering
and
retrofit
projects
require
far
more
time
and
effort
than
a
simple
installation
of
an
addon
control
but
can
accomplish
significant
HAPs
reductions
(
in
many
instances,
equal
to
that
of
an
RTO)
with
no
additional
combustion
of
fossil
fuels.
Accordingly,
all
possible
incentives
should
be
provided
to
maximize
the
implementation
of
this
option.

9)
Combination
of
Pollution
Prevention
Techniques
Plants
may
(
and
likely
will)
find
that
the
only
method
to
achieve
compliance
with
reliable
and
adequate
safety
margins
is
with
a
combination
of
the
techniques
cited
above
and
perhaps
others
not
yet
developed.
Necessarily,
that
would
create
complexities.
Extra
time
would
be
required
to
give
plant
managers
confidence
that
they
could
implement
these
pollution
prevention
strategies
into
their
plant
operating
procedures/
processes
and
still
meet
continuous
compliance
certification
constraints.

The
industry
is
committed
to
the
goals
of
the
MACT
rule,
and
believes
that
a
pollution
prevention
approach
ultimately
will
result
in
lower
overall
compliance
costs,
energy
use,
and
collateral
emissions
generation
while
still
providing
environmental
and
human
health
protection
consistent
with
the
goals
of
this
rule.
However,
there
are
unique
compliance
and
timing
issues
that
the
Wood
MACT
rule
may
create.
Specifically,
to
meet
the
3­
year
compliance
deadline,
only
the
add­
on
control
system
approach
is
viable
on
a
widespread
basis.
Its
environmental
disbenefits,
however,
6
warrant
allowing
additional
compliance
time
for
other
approaches
to
fully
realize
the
goals
of
this
rule.
Since
pollution
prevention
projects
take
longer
to
implement,
the
facilities
would
be
faced
with
installing
add­
on
control
systems
and
then
taking
them
out
or
substantially
modifying
them.
AF&
PA
believes
that
additional
compliance
time
would
ensure
that
the
maximum
degree
of
overall
pollution
reduction
is
achieved,
without
requiring
unnecessary
compliance
costs.
Further,
AF&
PA
believes
that
EPA
should
encourage
the
use
of
these
pollution
prevention
technologies,
but
recognizes
that
the
evaluation
and
implementation
of
these
technologies
would
add
time
and
capital
expense
to
the
compliance
activities
for
these
sources.

EPA
established
the
precedent
for
extending
compliance
deadlines
on
such
grounds
when
it
granted
an
eight­
year
compliance
deadline
for
kraft
mills
in
the
Pulp
&
Paper
Cluster
Rule.
63
Fed.
Reg.
18504
(
Apr.
15,
1998).
There,
EPA
declined
to
impose
a
three
year
compliance
window
on
grounds
that
it
would
prevent
the
achievements
of
greater
cost
savings
and
environmental
benefits
associated
with
the
combined
use
of
two
control
technologies:
brownstock
washers
and
oxygen
delignification
units
("
OD").
See
id.
at
18521­
22
(
adopting
rationale
stated
in
proposed
rule
for
five­
year
extension
of
compliance
term).
EPA
established
a
five­
year
global
extension
to
encourage
sources
to
install
ODs,
which
reduce
the
need
for
chlorinated
chemical
application
in
the
bleaching
process
resulting
in
reduced
loadings
of
chlorinated
pollutants
in
the
air
and
water.
61
Fed.
Reg.
9383,
9394
(
Mar.
8,
1996).
To
gain
the
maximum
benefit,
sources
would
have
had
to
upgrade
brownstock
washers
and
install
new
gas
collection
systems,
but
both
could
not
be
completed
within
three
years.
If
EPA
had
required
sources
to
spend
time
and
money
to
retrofit
their
washers
with
a
vent
gas
collection
system
to
meet
the
three­
year
deadline,
they
would
have
likely
postponed
or
foregone
installation
of
OD
later.
Explaining
why
a
five­
year
extension
was
warranted,
EPA
stated:

EPA
believes
the
additional
time
would
ensure
that
the
maximum
degree
of
overall
multi­
media
pollution
reduction
is
achieved,
without
requiring
unnecessary
compliance
costs.
.
.
.
EPA
encourages
the
implementation
of
these
pollution
prevention
technologies,
but
recognizes
the
evaluation
and
implementation
of
these
technologies
would
add
time
and
expense
to
the
compliance
activities
for
these
sources.

Id.
EPA
concluded
that
an
eight­
year
compliance
window
would
"
allow
sufficient
time
for
a
complete
evaluation
of
all
pollution
control
options."
See
id.
at
9395.
Notably,
EPA
questioned
seriously
"
whether
imposition
of
a
standard
that
result[
ed]
in
foregoing
substantial
cross­
media
environmental
benefits
could
be
MACT."
Id.

Similarly,
EPA
extended
the
compliance
deadline
for
imposition
of
MACT
on
storage
tanks
at
oil
refineries,
noting
that
a
three­
year
deadline
would
result
in
increased
HAP
emissions.
Specifically,
EPA
reasoned
that,
if
pollution
control
upgrades
were
mandated
for
tanks
at
unscheduled
times
relative
to
their
10­
year
cleaning
cycle,
the
amount
of
HAPs
released
in
the
process
would
exceed
the
amount
of
emissions
reduced
through
earlier
installation
of
controls.
EPA
stated:
7
The
EPA
determined
that
substantial
HAP
emissions
occur
when
storage
vessels
are
degassed
and
cleaned.
Typically,
storage
vessels
are
inspected
and
maintained
on
a
10­
year
schedule,
at
which
time
tanks
are
degassed
and
cleaned.
If
a
3­
year
compliance
schedule
were
required,
storage
vessels
would
be
degassed
and
cleaned
prematurely,
resulting
in
substantial
HAP
emissions
caused
by
the
rule.
These
HAP
emissions
could
not
be
balanced
in
less
than
5
years
for
floating
roof
tanks
by
the
emission
reduction
achieved
from
complying
with
the
rule.
By
changing
the
proposed
rule
to
allow
floating
roof
tanks
to
comply
with
the
storage
vessel
requirements
10
years
after
promulgation
of
the
rule
or
at
the
next
scheduled
inspection,
the
EPA
estimates
that
3,000
Mg/
yr
(
2,700
tpy)
of
HAP,
or
8,000
Mg
(
7,200
tpy)
of
HAP
over
3
years,
would
be
prevented
from
being
emitted.

60
Fed.
Reg.
43244,
43248
(
August
18,
1995).

A
similar
situation
exists
here.
As
discussed
above,
and
in
more
detail
in
AF&
PA's
comments
on
the
proposed
rule,
the
incineration
devices
that
otherwise
would
be
required
by
Wood
MACT
have
significant
corollary
environmental
disbenefits,
such
that
it
is
not
clear
whether
their
use
would
result
in
any
net
benefit
to
the
environment.
In
contrast,
several
promising
pollution
prevention
options
exist
for
the
wood
products
industry;
these
options
could
allow
many
sources
to
meet
the
HAP
reductions
mandated
by
the
rule
without
any
of
the
environmental
disbenefits
associated
with
these
RTOs
and
RCOs.
Yet
as
the
above
discussion
demonstrates,
if
sources
must
comply
within
three
years,
their
only
viable
option
will
be
installation
of
RTOs
or
RCOs.
Thus,
as
in
the
Pulp
&
Paper
Cluster
Rule
and
the
Petroleum
Refining
MACT,
allowing
an
extended
compliance
period
provides
an
opportunity
for
significantly
greater
environmental
benefits
than
could
otherwise
be
achieved.
Moreover,
as
EPA
correctly
noted
in
the
Pulp
&
Paper
Cluster
Rule,
here
it
is
arguable
"
whether
imposition
of
a
standard
that
result[
ed]
in
foregoing
substantial
cross­
media
environmental
benefits
could
be
MACT."
For
these
reasons,
a
four
year
pollution
prevention
compliance
extension
represents
sound
public
policy
and
is
supported
by
prior
precedent.

Recommended
Approach
In
order
to
address
the
challenges
with
implementing
pollution
prevention
options,
AF&
PA
suggests
adding
4
years
to
the
compliance
deadline,
for
a
total
of
seven
years.
The
facilities
that
implement
this
approach
would
be
required
to
provide
a
commitment
to
do
so
within
two
years
after
promulgation
of
the
rule,
and
also
provide
annual
progress
reports
to
identify
progress
towards
those
goals.
