­­­­­
Original
Message­­­­­
From:
Clemons.
Teresa@
epamail.
epa.
gov
[
mailto:
Clemons.
Teresa@
epamail.
epa.
gov]
On
Behalf
Of
Sally_
Shaver/
RTP/
USEPA/
US@
EPA
Sent:
Friday,
January
16,
2004
2:
19
PM
To:
Edmond_
Toy@
omb.
eop.
gov;
afraas@
omb.
eop.
gov
Cc:
Chamberlin.
Johnb@
epamail.
epa.
gov;
Throwe.
Scott@
epamail.
epa.
gov;
thrift.
mike@
epamail.
epa.
gov;
Durkee.
Stan@
epamail.
epa.
gov;
Mitchell.
Ken@
epamail.
epa.
gov;
Sorrels.
Larry@
epamail.
epa.
gov;
Hustvedt.
Ken@
epamail.
epa.
gov;
Kissell.
Mary@
epamail.
epa.
gov;
kphanks@
rti.
org;
rlnicholson@
rti.
org;
mason.
keith@
epamail.
epa.
gov;
Cristofaro.
Alexander@
epamail.
epa.
gov
Subject:
Plywood
and
Composite
Wood
Products
­
Advance
Copy
(
Non­
Risk
Portion)

Attached
is
an
advance
copy
of
the
PCWP
final
MACT
rule
and
preamble.
This
version
does
not
incorporate
risk
language
to
any
significant
extent.
Please
note
that
changes
to
the
text
may
occur
before
we
make
our
official
submittal
to
OMB
in
February.
Please
address
questions
and
comments
to
Mary
Tom
Kissell
at
919­
541­
4516.

(
See
attached
file:
Prom_
preamble7.
wpd)(
See
attached
file:
Prom_
rule2.
wpd)
Prom_
preamble7.
wpd
6560­
50­
P
ENVIRONMENTAL
PROTECTION
AGENCY
40
CFR
Parts
63
and
429
[
OAR­
2002­
0048,
FRL­
]

RIN
2060­
AG52
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products;
Effluent
Limitations
Guidelines
and
Standards
for
the
Timber
Products
Point
Source
Category;
List
of
Hazardous
Air
Pollutants,
Lesser
Quantity
Designations,
Source
Category
List
AGENCY:
Environmental
Protection
Agency
(
EPA).

ACTION:
Final
rules.

SUMMARY:
This
action
promulgates
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
the
plywood
and
composite
wood
products
(
PCWP)
source
category
under
the
Clean
Air
Act
(
CAA)
and
revisions
to
the
effluent
limitations,
guidelines
and
standards
for
the
timber
products
processing
source
category
under
the
Clean
Water
Act
(
CWA).

The
EPA
has
determined
that
the
PCWP
source
category
contains
major
sources
of
hazardous
air
pollutants
(
HAP),

including,
but
not
limited
to,
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
2
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
six
primary
HAP
emitted
have
been
classified
as
probable
or
possible
human
carcinogens.
This
action
will
implement
section
112(
d)
of
the
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).
The
rule
will
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
rule
will
reduce
emissions
of
volatile
organic
compounds
(
VOC)
by
25,000
Mg/
yr
(
27,000
tons/
yr).

The
EPA
is
also
amending
the
effluent
limitations,

guidelines
and
standards
for
the
timber
products
processing
point
source
category
codified
at
40
CFR
Part
429,
subpart
C
(
plywood
subcategory),
subpart
D
(
dry
process
hardboard
subcategory),
and
subpart
M
(
particleboard
manufacturing).

Today's
amendments
revise
the
definition
of
process
wastewater
found
at
§
429.11(
c)
to
exclude
certain
sources
of
wastewater
generated
by
air
pollution
control
devices
expected
to
be
installed
to
comply
with
today's
final
PCWP
NESHAP.

The
EPA
is
also
amending
the
list
of
categories
that
was
developed
pursuant
to
section
112(
c)(
1)
of
the
CAA.
The
3
EPA
is
delisting
a
low­
risk
subcategory
of
the
PCWP
source
category.
This
action
is
being
taken
in
part
to
respond
to
comments
submitted
by
the
American
Forest
&
Paper
Association
(
AF&
PA)
and
in
part
upon
the
Administrator's
own
motion,
pursuant
to
section
112(
c)(
9)
of
the
CAA.
This
action
is
based
on
EPA's
evaluation
of
the
available
information
concerning
the
potential
hazards
from
exposure
to
HAP
emitted
by
PCWP
facilities,
and
includes
a
detailed
rationale
for
removing
low­
risk
PCWP
facilities
from
the
source
category
list.

EFFECTIVE
DATE:
The
final
NESHAP
and
the
amendments
to
the
effluent
guidelines
are
effective
[
INSERT
DATE
60
DAYS
AFTER
DATE
OF
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
The
incorporation
by
reference
of
certain
publications
listed
in
the
final
NESHAP
is
approved
by
the
director
of
the
Office
of
the
Federal
Register
as
of
[
INSERT
DATE
60
DAYS
AFTER
DATE
OF
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].

ADDRESSES:
Docket
numbers
OAR­
2003­
0048
and
A­
98­
44,

containing
supporting
documentation
used
in
development
of
this
notice,
are
available
for
public
viewing
at
the
EPA
Docket
Center
(
Air
Docket),
EPA
West,
Room
B­
108,
1301
Constitution
Avenue,
NW,
Washington,
DC
20460.
These
dockets
also
contain
documentation
supporting
the
amendments
to
Part
429.
4
FOR
FURTHER
INFORMATION
CONTACT:
For
further
information
concerning
applicability
and
rule
determinations,
contact
the
appropriate
State
or
local
agency
representative.
If
no
State
or
local
representative
is
available,
contact
the
EPA
Regional
Office
staff
listed
in
40
CFR
63.13.
For
information
concerning
the
analyses
performed
in
developing
the
final
rule,
contact
Ms.
Mary
Tom
Kissell,
Waste
and
Chemical
Processes
Group,
Emission
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.
For
information
concerning
test
methods,
sampling,
and
monitoring
information,
contact
Mr.
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.
For
information
concerning
the
economic
impacts
and
benefit
analysis,
contact
Mr.
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,
email
address
sorrels.
larry@
epa.
gov.

For
information
concerning
the
effluent
guidelines,
contact
Mr.
Donald
Anderson,
Engineering
and
Analysis
Division
(
4303T),
U.
S.
EPA,
1200
Pennsylvania
Avenue,
N.
W.,
5
Washington,
DC
20460,
telephone
number
(
202)
566­
1021,

anderson.
donaldf@
epa.
gov.

SUPPLEMENTARY
INFORMATION:
Regulated
Entities.
Categories
and
entities
potentially
regulated
by
this
action
include:

Category
Rule
SIC
NAICS
Examples
of
regulated
entities
Industry
NESHAP
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)

Effluent
Guidelines
2436
321212
Softwood
plywood
and
veneer
plants
2493
321219
Reconstituted
wood
products
(
particleboard,
medium
density
fiberboard,
hardboard,
fiberboard,
and
oriented
strandboard
plants)

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
§
63.2231
of
the
final
rule.
If
you
have
any
questions
regarding
the
applicability
of
this
action
to
a
particular
entity,
consult
the
person
listed
in
6
the
preceding
FOR
FURTHER
INFORMATION
CONTACT
section.

Docket.
The
EPA
has
established
an
official
public
docket
for
this
action
including
both
Docket
ID
No.
OAR­
2003­
0048
and
Docket
ID
No.
A­
98­
44.
The
official
public
docket
consists
of
the
documents
specifically
referenced
in
this
action,
any
public
comments
received,
and
other
information
related
to
this
action.
All
items
may
not
be
listed
under
both
docket
numbers,
so
interested
parties
should
inspect
both
docket
numbers
to
ensure
that
they
have
received
all
materials
relevant
to
this
rule.
Although
a
part
of
the
official
docket,
the
public
docket
does
not
include
Confidential
Business
Information
or
other
information
whose
disclosure
is
restricted
by
statute.
The
official
public
docket
is
available
for
public
viewing
at
the
EPA
Docket
Center
(
Air
Docket),
EPA
West,
Room
B­
102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Public
Reading
Room
is
(
202)
566
 
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566
 
1742.

Electronic
Access.
You
may
access
this
Federal
Register
document
electronically
through
the
EPA
Internet
under
the
Federal
Register
listings
at
http://
www.
epa.
gov/
fedrgstr/.

You
may
also
access
a
copy
of
this
document
through
the
Technology
Transfer
Network
(
TTN)
at
7
http://
www.
epa.
gov/
ttn/
atw/
plypart/
plypart.
html.
An
electronic
version
of
the
public
docket
is
available
through
EPA's
electronic
public
docket
and
comment
system,
EPA
Dockets.
You
may
use
EPA
Dockets
at
http://
www.
epa.
gov.
edocket/
to
view
public
comments,
access
the
index
listing
of
the
contents
of
the
official
public
docket,
and
access
those
documents
in
the
public
docket
that
are
available
electronically.
Although
not
all
docket
materials
may
be
available
electronically,
you
may
still
access
any
of
the
publicly
available
docket
materials
through
the
docket
facility
identified
above.
Once
in
the
system,
select
"
search,"
then
key
in
the
appropriate
docket
identification
number.

Judicial
Review.
Under
section
307(
b)(
1)
of
the
CAA,

judicial
review
of
the
standards
and
limitations
of
the
final
rule
is
available
only
by
filing
a
petition
for
review
in
the
U.
S.
Court
of
Appeals
for
the
District
of
Columbia
Circuit
by
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
Under
section
307(
d)(
7)(
B)
of
the
CAA,
only
an
objection
to
the
final
rule
that
was
raised
with
reasonable
specificity
during
the
period
for
public
comment
can
be
raised
during
judicial
review.
Under
section
509(
b)(
1)
of
the
CWA,
judicial
review
of
today's
effluent
limitations
guidelines
and
standards
is
available
in
the
United
States
Court
of
Appeals
by
filing
a
8
petition
for
review
within
120
days
from
the
date
of
promulgation
of
those
guidelines
and
standards.
In
accordance
with
40
CFR
23.2,
the
water
portion
of
today's
rule
shall
be
considered
promulgated
for
the
purposes
of
judicial
review
at
1
pm
Eastern
time
on
[
INSERT
DATE
14
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
Moreover,
under
section
307(
b)(
2)
of
the
CAA
and
section
509(
b)(
2)
of
the
CWA,
the
requirements
established
by
the
final
rule
may
not
be
challenged
separately
in
any
civil
or
criminal
proceedings
brought
by
EPA
to
enforce
the
requirements.

Outline.
The
information
presented
in
this
preamble
is
organized
as
follows:

I.
Introduction
A.
What
Is
the
Source
of
Authority
for
Development
of
Today's
Regulations?
B.
What
Criteria
Are
Used
in
the
Development
of
NESHAP?
C.
How
Was
this
Final
Rule
Developed?
D.
What
Are
the
Health
Effects
of
the
Pollutants
Emitted
from
the
PCWP
Industry?
E.
Incorporation
by
Reference
of
NCASI
Test
Methods
F.
Incorporation
by
Reference
of
ASTM
Test
Method
II.
Summary
of
the
Final
Rule
A.
What
Process
Units
Are
Subject
to
this
Final
Rule?
B.
What
Pollutants
Are
Regulated
by
this
Final
Rule?
C.
What
Are
the
Compliance
Options?
D.
What
Operating
Requirements
Are
in
this
Final
Rule?
E.
What
Are
the
Work
Practice
Requirements?
F.
When
Must
I
Comply
With
this
Final
Rule?
G.
How
Do
I
Demonstrate
Initial
Compliance
With
this
Final
Rule?
H.
How
Do
I
Demonstrate
Continuous
Compliance
With
this
Final
Rule?
I.
How
Do
I
Demonstrate
that
My
Facility
Is
Part
of
the
Low­
risk
Subcategory?
III.
Summary
of
Environmental,
Energy,
and
Economic
Impacts
A.
How
Many
Facilities
Are
Impacted
by
this
Final
Rule?
9
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.
What
Are
the
Economic
Impacts?
H.
What
Are
the
Social
Costs
and
Benefits?
I.
How
Will
the
Risk­
based
Exemption
Affect
Impacts
IV.
Summary
of
Responses
to
Major
Comments
and
Changes
to
the
Plywood
and
Composite
Wood
Products
NESHAP
A.
Applicability
B.
Overlap
with
Other
Rules
C.
Amendments
to
the
Effluent
Guidelines
for
Timber
Products
Processing
D.
Existing
Source
MACT
E.
New
Source
MACT
F.
Definition
of
Control
Device
G.
Compliance
Options
H.
Testing
and
Monitoring
Requirements
I.
Routine
Control
Device
Maintenance
Exemption
(
RCDME)
J.
Startup,
Shutdown,
and
Malfunction
(
SSM)
K.
Risk­
based
Approaches
V.
Statutory
and
Executive
Order
Reviews
A.
Executive
Order
12866:
Regulatory
Planning
and
Review
B.
Paperwork
Reduction
Act
C.
Regulatory
Flexibility
Analysis
D.
Unfunded
Mandates
Reform
Act
E.
Executive
Order
13132:
Federalism
F.
Executive
Order
13175:
Consultation
and
Coordination
With
Indian
Tribal
Governments
G.
Executive
Order
13045:
Protection
of
Children
from
Environmental
Health
&
Safety
Risks
H.
Executive
Order
13211:
Actions
that
Significantly
Affect
Energy
Supply,
Distribution,
or
Use
I.
National
Technology
Transfer
and
Advancement
Act
J.
Congressional
Review
Act
I.
Introduction
A.
What
Is
the
Source
of
Authority
for
Development
of
Today's
Regulations?

Section
112(
c)
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
10
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.
In
addition,
when
we
proposed
the
PCWP
rule
on
January
9,
2003
(
68
FR
1276),
we
broadened
the
scope
of
the
source
category
to
include
lumber
kilns
located
at
stand­
alone
kiln­
dried
lumber
manufacturing
facilities
or
at
any
other
type
of
facility.
Major
sources
of
HAP
are
those
that
have
the
potential
to
emit
10
tons
per
year
or
more
of
any
one
HAP
or
25
tons
per
year
or
more
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
final
rule
make
up
the
emission
standards
and
work
practice
standards
for
the
PCWP
NESHAP.

We
are
promulgating
the
amendments
to
Part
429
under
the
authority
of
sections
301,
304,
306,
307,
308,
402,
and
501
11
of
the
CWA.

Section
112(
c)(
9)
of
the
CAA
allows
us
to
delete
categories
and
subcategories
from
the
list
of
HAP
sources
to
be
subject
to
MACT
standards
under
section
112(
d),
if
certain
substantive
criteria
are
met.
(
The
EPA
construes
this
authority
to
apply
to
listed
subcategories,
because
doing
so
is
logical
in
the
context
of
the
general
regulatory
scheme
established
by
the
statute,
and
is
reasonable
since
section
112(
c)(
9)(
B)(
ii)
expressly
refers
to
subcategories.)

To
delete
a
category
or
subcategory
the
Administrator
must
make
an
initial
demonstration
that
no
source
in
the
category
or
subcategory:
(
1)
emits
carcinogens
in
amounts
that
may
result
in
a
lifetime
cancer
risk
exceeding
on
in
a
million
to
the
individual
most
exposed;
(
2)
emits
non­
carcinogens
in
amounts
that
exceed
a
level
which
is
adequate
to
provide
an
ample
margin
of
safety
to
protect
public
health;
and
(
3)

emits
any
HAP
or
combination
of
HAP
in
amounts
that
will
result
in
an
adverse
environmental
effect,
as
defined
by
section
112(
a)(
7).

B.
What
Criteria
Are
Used
in
the
Development
of
NESHAP?

Section
112(
d)(
1)
of
the
CAA
requires
that
we
establish
NESHAP
for
the
control
of
HAP
from
both
new
and
existing
major
sources.
Section
112(
d)(
2)
of
the
CAA
requires
the
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
level
of
control
12
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
ensures
that
all
major
sources
achieve
a
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
under
section
112(
d)(
2)
of
the
CAA,

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
non­
air
quality
health
and
environmental
impacts,
and
energy
requirements.

C.
How
Was
this
Final
Rule
Developed?

We
proposed
standards
for
PCWP
on
January
9,
2003
(
68
FR
13
1276).
The
preamble
for
the
proposed
standards
described
the
rationale
for
the
proposed
standards.
Public
comments
were
solicited
at
the
time
of
proposal.
The
public
comment
period
lasted
from
January
9,
2003,
to
March
10,
2003.

Industry
representatives,
regulatory
agencies,
environmental
groups,
and
the
general
public
were
given
the
opportunity
to
comment
on
the
proposed
rule
and
to
provide
additional
information
during
the
public
comment
period.
We
also
offered
at
proposal
the
opportunity
for
a
public
hearing
concerning
the
proposed
rule,
but
no
hearing
was
requested.

We
met
with
stakeholders
on
several
occasions.

We
received
a
total
of
57
public
comment
letters
on
the
proposed
rule
during
the
comment
period.
Comments
were
submitted
by
industry
trade
associations,
PCWP
companies,

State
regulatory
agencies,
local
government
agencies,
and
environmental
groups.
Today's
final
rule
reflects
our
consideration
of
all
of
the
comments
received
during
the
comment
period.
Major
public
comments
on
the
proposed
rule,

along
with
our
responses
to
those
comments,
are
summarized
in
this
preamble.

D.
What
Are
the
Health
Effects
of
the
Pollutants
Emitted
from
the
PCWP
Industry?

This
final
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
from
PCWP
14
process
units
that
have
been
detected
in
one
or
more
emission
tests
include
acetaldehyde,
acetophenone,
acrolein,

benzene,
biphenyl,
bromomethane,
carbon
disulfide,
carbon
tetrachloride,
chloroform,
chloroethane,
chloromethane,

cresols,
cumene,
ethyl
benzene,
formaldehyde,
hydroquinone
methanol,
methylene
chloride,
MDI,
MEK,
MIBK,
n­
Hexane,

phenol,
propionaldehyde,
styrene,
toluene,
xylenes,

1,1,1­
trichloroethane,
bis­(
2­
ethylhexyl
phthalate),

4­
methyl­
2­
pentanone,
and
di­
n­
butyl
phthalate.
Many
of
these
HAP
are
rarely
detected
and
occur
infrequently.
The
predominant
HAP
emitted
(
i.
e.,
those
most
likely
to
be
emitted
in
detectable
quantities
and
with
high
mass
relative
to
other
HAP)
by
PCWP
facilities
include
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.
This
section
discusses
the
health
effects
associated
with
the
predominant
HAP
emitted
by
the
PCWP
industry.

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
15
populations
surrounding
these
facilities.
However,
to
the
extent
the
adverse
effects
do
occur,
today's
final
rule
would
reduce
emissions
by
sources
subject
to
the
standards
and
subsequent
exposures
to
such
emissions.

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
to
be
a
possible
human
16
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
17
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.

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),
18
reproductive,
developmental,
or
carcinogenic
effects
of
propionaldehyde
in
animals
or
humans.
We
have
not
classified
propionaldehyde
for
carcinogenicity.

E.
Incorporation
by
Reference
of
NCASI
Test
Methods
Today's
final
rule
amends
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)
NCASI
Method
IM/
CAN/
WP­
99.02,
Impinger/
Canister
Source
Sampling
Method
for
Selected
HAPs
and
Other
Compounds
at
Wood
Products
Facilities.
These
methods
are
available
from
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
OAR­
2003­
0048
and
Docket
Number
A­
98­
44).

These
documents
were
approved
for
incorporation
by
reference
by
the
Director
of
the
Federal
Register
in
accordance
with
5
U.
S.
C.
552(
a)
and
1
CFR
51.

F.
Incorporation
by
Reference
of
ASTM
Test
Method
Today's
final
rule
amends
40
CFR
63.14
by
revising
paragraph
(
b)
to
incorporate
by
reference
a
test
method
developed
by
the
American
Society
for
Testing
and
Materials
(
ASTM),
ASTM
D6348­
03,
"
Standard
Test
Method
for
19
Determination
of
Gaseous
Compounds
by
Extractive
Direct
Interface
Fourier
Transform
Infrared
(
FTIR)
Spectroscopy."

This
test
method
is
available
from
the
American
Society
for
Testing
and
Materials
(
ASTM),
100
Barr
Harbor
Drive,
Post
Office
Box
C700,
West
Conshohocken,
PA
19428­
2959;
or
ProQuest,
300
North
Zeeb
Road,
Ann
Arbor,
MI
48106.
This
document
has
been
approved
for
incorporation
by
reference
by
the
Director
of
the
Federal
Register
in
accordance
with
5
U.
S.
C.
552(
a)
and
1
CFR
51.

II.
Summary
of
the
Final
Rule
A.
What
Process
Units
Are
Subject
to
this
Final
Rule?

The
final
rule
regulates
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
20
the
process
units
at
PCWP
facilities
and
indicates
which
process
units
are
subject
to
the
control
requirements
in
today's
final
rule.
"
Process
unit"
means
equipment
classified
according
to
its
function
such
as
a
blender,

dryer,
press,
former,
or
board
cooler.

The
affected
source
for
this
final
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
at
a
major
source
facility.
One
of
the
implications
of
this
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
final
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
final
rule
contains
the
control
requirements
that
represent
the
MACT
level
of
control
only
for
lumber
kilns.
21
TABLE
1.
PROCESS
UNITS
THAT
ARE
SUBJECT
TO
THE
FINAL
CONTROL
REQUIREMENTS
For
the
following
process
units...
Does
today's
final
rule
include
control
requirements
for...

Existing
affected
sources?
New
affected
sources?

Softwood
veneer
dryersa;
primary
tube
dryers;
secondary
tube
dryers;
rotary
strand
dryers;
conveyor
strand
dryers;
green
rotary
dryers;
hardboard
ovens;
reconstituted
wood
product
presses;
and
pressurized
refiners
Yes
Yes
Press
predryers;
fiberboard
mat
dryers;
and
board
coolers
No
Yes
Dry
rotary
dryersa;
veneer
redryersa;
softwood
plywood
presses;
hardwood
plywood
presses;
engineered
wood
products
presses;
hardwood
veneer
dryersa;
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
(
including
group
1
miscellaneous
coating
operationsa);
and
standalone
digesters
No
No
aThese
process
units
have
work
practice
requirements
in
today's
final
rule
in
addition
to
or
instead
of
control
requirements.
Group
1
miscellaneous
coating
operations
include
application
of
edge
seals,
nail
lines,
logo
(
or
other
information)
paint,
shelving
edge
fillers,
trademark/
grade­
stamp
inks,
and
wood
putty
patches
to
plywood
and
composite
wood
products
(
except
kiln­
dried
lumber)
on
the
same
site
where
the
plywood
and
composite
wood
products
are
manufactured.
Group
1
miscellaneous
coating
operations
also
include
application
of
synthetic
patches
to
plywood
at
new
affected
sources.
22
B.
What
Pollutants
Are
Regulated
By
this
Final
Rule?

The
final
rule
regulates
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.
The
six
HAP
that
define
"
total
HAP"
make
up
96
percent
of
the
nationwide
HAP
emissions
from
PCWP
facilities
and
are
acetaldehyde,
acrolein,
formaldehyde,

methanol,
phenol,
and
propionaldehyde.
Other
HAP
are
sometimes
emitted
and
controlled
along
with
these
six
HAP,

but
in
lower
quantities.
Depending
upon
which
of
the
compliance
alternatives
you
choose,
you
could
be
required
to
measure
emissions
of
"
total
HAP,"
total
hydrocarbon
(
THC),

methanol,
or
formaldehyde
as
surrogates
for
measuring
all
HAP.
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.

C.
What
Are
the
Compliance
Options?

Today's
final
rule
includes
a
range
of
compliance
options,
which
are
summarized
in
the
following
subsections.

You
must
use
one
of
the
compliance
options
to
show
compliance
with
the
final
rule.
In
most
cases,
the
23
compliance
options
are
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
final
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
final
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

driedton
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.
There
is
no
production­
based
compliance
option
for
conveyor
strand
dryers.

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
24
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
25
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
wood
products
enclosure
as
defined
in
section
63.2292
in
today's
final
rule,
then
you
would
assign
the
enclosure
a
capture
efficiency
of
100
percent.
You
must
test
other
enclosures
to
determine
capture
efficiency
using
EPA
Test
Methods
204
and
204A
through
204F
(
as
appropriate)

found
in
40
CFR
Part
51,
Appendix
M,
or
the
alternative
tracer
gas
procedure
in
Appendix
A
to
today's
final
rule.

For
the
three
concentration
options
(
d
through
f),
you
must
have
an
enclosure
that
either
meets
the
criteria
for
a
wood
products
enclosure
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
are
required
to
meet
only
one
of
the
six
compliance
options
for
add­
on
control
systems.

However,
you
must
designate
in
your
permit
which
one
of
the
six
options
you
have
selected
for
the
affected
process
unit.

If
you
plan
to
operate
a
given
process
unit
under
different
conditions,
you
may
incorporate
multiple
compliance
options
for
the
add­
on
control
system
into
your
permit,
as
long
as
each
separate
operating
condition
is
identified
along
with
26
the
compliance
option
that
corresponds
to
that
operating
condition.

3.
Emissions
Averaging
Compliance
Option
Emissions
averaging
is
a
means
of
achieving
the
required
emissions
reductions
in
a
less
costly
way.
Therefore,
if
you
operate
an
existing
affected
source,
for
each
process
unit
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.
"

Debitgenerating
process
units"
are
the
PCWP
process
units
that
are
required
to
meet
the
control
requirements
but
that
you
choose
to
either
not
control
or
under­
control.
"

Creditgenerating
process
units"
are
the
PCWP
process
units
that
you
choose
to
control
that
are
not
required
to
be
controlled
under
the
standards.
When
determining
your
actual
mass
removal
(
AMR)
of
HAP,
you
may
include
partial
credits
generated
from
debit­
generating
process
units
that
are
under­
controlled
(
e.
g.,
you
may
receive
credit
for
25
percent
control
of
a
debit­
generating
process
unit).

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
27
debit­
generating
process
units
for
a
6­
month
compliance
period.
Total
HAP
is
defined
in
today's
final
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
debitgenerating
process
units
would
have
to
be
achieved
or
exceeded
by
the
AMR
of
total
HAP
achieved
by
creditgenerating
process
units.
The
AMR
is
determined
based
on
initial
performance
tests,
the
total
HAP
removal
efficiency
(
not
to
exceed
90
percent)
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
final
rule.
You
must
limit
emissions
averaging
to
the
process
units
located
within
your
affected
source.
Emissions
averaging
may
not
be
used
at
new
affected
sources.
You
may
not
include
in
an
emissions
average
those
process
units
that
are
not
operating
or
that
are
shut
down.
You
may
not
include
in
your
emissions
average
those
process
units
controlled
to
comply
with
a
State
or
Federal
rule
other
than
today's
final
rule.
Only
PCWP
process
units
using
add­
on
control
systems
may
be
used
28
to
generate
credits.

D.
What
Operating
Requirements
Are
in
this
Final
Rule?

The
operating
requirements
in
today's
final
rule
apply
to
add­
on
control
systems
used
to
comply
with
the
final
rule
and
to
process
units
meeting
the
final
production­
based
compliance
options
or
emissions
averaging
provisions
without
an
add­
on
control
device
(
e.
g.,
debit­
generating
process
units).
For
incineration­
based
control
devices
and
biofilters,
the
final
rule
specifies
that
you
must
either
monitor
operating
parameters
or
use
a
THC
continuous
emission
monitoring
system
(
CEMS)
to
demonstrate
continuous
compliance.
The
final
operating
requirements
are
summarized
below:

°
If
you
operate
a
thermal
oxidizer,
such
as
a
regenerative
thermal
oxidizer
(
RTO),
you
must
maintain
the
firebox
temperature
at
a
level
that
is
greater
than
or
equal
to
the
minimum
temperature
established
during
the
performance
test.
If
you
operate
a
combustion
unit
that
accepts
process
exhaust
into
the
flame
zone,
you
are
exempt
from
the
testing
and
monitoring
requirements
described
above
for
thermal
oxidizers.

°
If
you
operate
a
catalytic
oxidizer,
such
as
a
regenerative
catalytic
oxidizer
(
RCO)
or
thermal
catalytic
oxidizer
(
TCO),
you
must
maintain
the
average
catalytic
oxidizer
temperature
at
or
above
the
minimum
29
temperature
established
during
the
performance
test.

You
must
also
check
the
activity
level
of
a
representative
sample
of
the
catalyst
at
least
every
12
months.

°
If
you
operate
a
biofilter,
you
must
maintain
the
average
biofilter
bed
temperature
within
the
range
you
develop
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
must
certify
that
the
biofilter
and
associated
process
unit(
s)
have
not
been
modified
subsequent
to
the
date
of
the
performance
tests.

°
If
you
operate
an
add­
on
control
system
not
listed
in
today's
final
rule,
you
must
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.

°
If
you
operate
a
process
unit
that
meets
the
productionbased
compliance
options
or
a
process
unit
that
generates
debits
in
an
emissions
average
without
an
addon
control
device,
you
must
maintain
on
a
daily
basis
the
process
unit
controlling
operating
parameter(
s)

within
the
ranges
established
during
the
performance
30
test
corresponding
to
the
representative
operating
conditions
identified
during
the
performance
test.

°
As
an
alternative
to
monitoring
the
operating
parameters
specified
above
for
thermal
oxidizers,
catalytic
oxidizers,
biofilters,
other
control
devices,
and
process
units
that
meet
compliance
options
without
addon
control
systems,
you
may
monitor
THC
concentration
in
the
outlet
stack
with
a
THC
CEMS.
If
you
select
this
option,
you
must
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
final
rule
apply
to
softwood
veneer
dryers,
dry
rotary
dryers,
veneer
redryers,
hardwood
veneer
dryers,
and
group
1
miscellaneous
coating
operations.
For
softwood
veneer
dryers,
the
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).
For
group
1
miscellaneous
coating
operations,
the
work
practice
requirements
specify
that
you
must
use
a
non­
HAP
coating.
The
work
practice
requirements
31
also
specify
parameters
that
you
must
monitor
to
demonstrate
that
each
dry
rotary
dryer,
veneer
redryer,
and
hardwood
veneer
dryer
continuously
operates
in
a
manner
consistent
with
the
definitions
of
these
process
units
provided
in
today's
final
rule,
as
follows:

°
If
you
operate
a
dry
rotary
dryer,
you
must
maintain
the
inlet
dryer
temperature
at
or
below
600

F
and
maintain
the
moisture
content
of
the
wood
particles
entering
the
dryer
at
or
below
30
weight
percent,
on
a
dry
basis.

°
If
you
operate
a
veneer
redryer,
you
must
maintain
the
moisture
content
of
the
wood
veneer
entering
the
dryer
at
or
below
25
percent,
by
weight.

°
If
you
operate
a
hardwood
veneer
dryer,
you
must
process
less
than
30
percent,
by
volume,
softwood
species
each
year.

F.
When
Must
I
Comply
With
this
Final
Rule?

Existing
PCWP
facilities
must
comply
within
3
years
of
the
effective
date.
New
sources
that
commence
construction
after
January
9,
2003,
must
comply
immediately
upon
initial
startup
or
on
the
effective
date,
whichever
is
later.

Existing
sources
that
wish
to
be
included
in
the
delisted
low­
risk
subcategory
must
receive
EPA
approval
of
their
eligibility
demonstrations
no
later
than
3
years
after
the
effective
date,
or
be
in
compliance
with
the
final
rule.

New
sources
that
wish
to
be
included
in
the
delisted
low
32
risk
subcategory
must
receive
EPA
approval
of
their
applicability
demonstrations
no
later
than
initial
startup
or
on
the
effective
date,
which
ever
is
later,
or
be
in
compliance
with
the
final
rule.

G.
How
Do
I
Demonstrate
Initial
Compliance
With
this
Final
Rule?

The
initial
compliance
requirements
in
today's
final
rule
vary
with
the
different
compliance
options.

1.
Production­
Based
Compliance
Options
If
you
are
complying
with
the
production­
based
compliance
options
(
PBCO)
in
today's
final
rule,
you
must
conduct
an
initial
performance
test
using
specified
test
methods
to
demonstrate
initial
compliance.
You
must
test
the
efficiency
of
your
emissions
capture
device
during
the
initial
performance
test
if
the
process
unit
is
a
press
or
board
cooler.
The
actual
emission
rate
of
the
press
or
board
cooler
is
equivalent
to
the
measured
emissions
divided
by
the
capture
efficiency.
You
must
test
prior
to
any
wet
control
device
operated
on
the
process
unit.
During
the
performance
test,
you
must
identify
the
process
unit
controlling
parameter(
s)
that
affect
total
HAP
emissions;

these
parameters
must
coincide
with
the
representative
operating
conditions
you
describe
in
the
performance
test.

For
each
parameter,
you
must
specify
appropriate
monitoring
methods
and
monitoring
frequencies,
and
for
continuously
33
monitored
parameters,
you
must
specify
averaging
times
not
to
exceed
24
hours.
You
must
install
process
monitoring
equipment
or
establish
recordkeeping
procedures
to
be
used
to
demonstrate
compliance
with
the
operating
requirements
for
the
parameters
you
select.
During
the
initial
performance
test,
you
must
use
the
process
monitoring
equipment
or
recordkeeping
procedures
to
establish
the
parameter
value
(
e.
g.,
maximum,
minimum,
average,
or
range,

as
appropriate)
that
represents
your
operating
requirement
for
the
process
unit.
Alternatively,
you
may
install
a
THC
CEMS
and
monitor
the
process
unit
outlet
THC
concentration
and
establish
your
THC
operating
requirement
during
the
performance
test.

2.
Add­
On
Control
System
Compliance
Options
If
you
use
the
compliance
options
for
add­
on
control
systems,
you
must
conduct
an
initial
performance
test
using
specified
test
methods
to
demonstrate
initial
compliance.

With
the
exception
of
the
20
ppmvd
THC
concentration
option,

you
must
test
at
both
the
inlet
and
the
outlet
of
the
HAP
control
device.
For
HAP­
altering
controls
in
sequence,
such
as
a
wet
control
device
followed
by
a
thermal
oxidizer,
you
must
test
at
the
functional
inlet
of
the
control
sequence
(
e.
g.,
prior
to
the
wet
control
device)
and
at
the
outlet
of
the
control
sequence
(
e.
g.,
thermal
oxidizer
outlet).
If
you
use
a
wet
control
device
as
the
sole
means
of
reducing
34
HAP
emissions,
you
must
develop
and
implement
a
plan
to
address
how
organic
HAP
captured
in
the
wastewater
from
the
wet
control
device
is
contained
or
destroyed
to
minimize
rerelease
to
the
atmosphere
such
that
the
desired
emission
reduction
is
obtained.
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
wood
products
enclosure,

you
must
also
test
the
capture
efficiency
of
your
partial
wood
products
enclosure.
Prior
to
the
initial
performance
test,
you
must
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
final
rule.
During
the
initial
performance
test,

you
must
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
(
e.
g.,
baghouse
or
wet
electrostatic
precipitators
(
WESP)),
you
must
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
values
recorded
during
previous
performance
tests
for
the
biofilter
to
establish
your
operating
requirements
as
long
as
you
were
in
compliance
with
the
emission
limits
in
today's
final
rule
35
when
the
data
were
collected,
the
test
data
were
obtained
using
the
test
methods
in
today's
final
rule,
and
no
modifications
were
made
to
the
process
unit
or
biofilter
subsequent
to
the
date
of
the
performance
tests.

3.
Emissions
Averaging
Compliance
Option
If
you
elect
to
comply
with
the
emissions
averaging
compliance
option
in
today's
final
rule,
you
must
submit
an
Emissions
Averaging
Plan
(
EAP)
to
the
Administrator
for
approval.
The
EAP
must
describe
the
process
units
you
are
including
in
the
emissions
average.
The
plan
also
must
specify
which
process
units
will
be
credit­
generating
units
(
including
under­
controlled,
debit­
generating
process
units
that
also
generate
credits)
and
which
process
units
will
be
debit­
generating
units.
The
EAP
must
also
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.

Following
approval
of
your
EAP,
you
must
conduct
performance
tests
to
determine
the
total
HAP
emissions
from
all
process
units
included
in
the
EAP.
The
creditgenerating
process
units
must
be
equipped
with
add­
on
control
systems;
therefore,
for
those
process
units,
you
36
must
follow
the
procedures
for
demonstrating
initial
compliance
as
outlined
above
for
add­
on
control
systems.

For
debit­
generating
process
units
without
air
pollution
control
devices
(
APCD),
you
must
follow
the
same
procedure
for
establishing
your
operating
requirements
as
outlined
above
for
process
units
meeting
the
PBCO.
The
emissions
averaging
provisions
require
you
to
conduct
all
total
HAP
measurements
and
performance
test(
s)
when
the
process
units
are
operating
under
representative
operating
conditions.

Today's
final
rule
defines
"
representative
operating
conditions"
as
those
conditions
under
which
the
process
unit
will
typically
be
operating
following
the
compliance
date.

Representative
conditions
include
such
things
as
using
a
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
final
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
must
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,
37
particles,
or
strands
used
for
making
board)
entering
the
dryer.
You
must
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

F,
then
your
dryer
meets
the
definition
of
a
dry
rotary
dryer
in
today's
final
rule.
You
must
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
must
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
meets
the
definition
of
hardwood
veneer
dryer.
You
must
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.
38
To
demonstrate
initial
compliance
with
the
work
practice
requirements
for
softwood
veneer
dryers,
you
must
develop
a
plan
for
minimizing
fugitive
emissions
from
the
veneer
dryer
green
end
and
heated
zones.
You
must
submit
the
plan
with
your
notification
of
compliance
status
report.

To
demonstrate
initial
compliance
with
the
work
practice
requirements
for
veneer
redryers,
you
must
install
a
device
that
can
be
used
to
continuously
monitor
the
moisture
content
(
dry
basis)
of
veneer
entering
the
dryer.
You
must
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
meets
the
definition
of
a
veneer
redryer
in
today's
final
rule.
You
must
submit
the
monitoring
data
as
part
of
your
notification
of
compliance
status
report.

To
demonstrate
initial
compliance
with
the
work
practice
requirement
for
group
1
miscellaneous
coating
operations,

you
must
submit
a
signed
statement
with
your
notification
of
compliance
status
report
stating
that
you
are
using
non­
HAP
coatings.
You
must
also
have
a
record
(
e.
g.,
material
safety
data
sheets)
showing
that
you
are
using
non­
HAP
coatings
as
defined
in
the
final
PCWP
rule.
39
H.
How
Do
I
Demonstrate
Continuous
Compliance
With
this
Final
Rule?

The
continuous
compliance
requirements
in
today's
final
rule
vary
with
the
different
types
of
compliance
options.

1.
Production­
Based
Compliance
Options
If
you
comply
with
the
PBCO,
then
you
must
monitor
and/
or
record
the
controlling
operating
parameter(
s)

identified
as
affecting
total
HAP
emissions
from
the
process
unit(
s)
in
the
performance
test.
For
each
parameter,
you
must
use
the
monitoring
methods,
monitoring
frequencies,
and
averaging
times
(
for
continuously
monitored
parameters
not
to
exceed
24
hours)
specified
in
your
performance
test
and
Notification
of
Compliance
Status.
For
each
operating
parameter,
you
must
maintain
on
a
daily
basis
the
parameter
at
or
above
the
minimum,
at
or
below
the
maximum,
or
within
the
range
(
whichever
applies)
established
during
the
performance
test.

Instead
of
monitoring
process
operating
parameters,
you
may
operate
a
CEMS
for
monitoring
THC
concentration
to
demonstrate
compliance
with
the
operating
requirements
in
today's
final
rule.
If
you
choose
to
operate
a
THC
CEMS
in
lieu
of
a
continuous
parameter
monitoring
systems
(
CPMS),

you
must
demonstrate
continuous
compliance,
as
described
in
the
following
subsection.

2.
Add­
On
Control
System
Compliance
Options
40
For
add­
on
control
systems,
you
must
install
a
CPMS
to
monitor
the
temperature
or
install
a
CEMS
to
monitor
THC
concentration
to
demonstrate
compliance
with
the
operating
requirements
in
today's
final
rule.
If
you
operate
a
CPMS,

you
must
have
at
least
75
percent
of
the
required
recorded
readings
for
each
3­
hour
or
24­
hour
block
averaging
period
to
calculate
the
data
averages.
You
must
operate
the
CPMS
at
all
times
the
process
unit
is
operating.
You
must
also
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
must
calculate
and
record
the
average
values
of
each
operating
parameter
according
to
the
specified
averaging
times.

For
thermal
oxidizers,
you
must
continuously
maintain
the
3­
hour
block
average
firebox
temperature
at
or
above
the
minimum
temperature
established
during
the
performance
test.

For
catalytic
oxidizers,
you
must
continuously
maintain
the
3­
hour
block
average
catalytic
oxidizer
temperature
at
or
above
the
minimum
value
established
during
the
performance
test.
You
must
also
check
the
activity
level
of
a
representative
sample
of
the
catalyst
at
least
every
12
months
and
take
any
necessary
corrective
action
to
ensure
that
the
catalyst
is
performing
within
its
design
range.

For
biofilters,
you
must
continuously
maintain
the
24­

hour
block
average
biofilter
bed
temperature
within
the
41
operating
range
you
establish
during
the
performance
test.

You
must
also
conduct
a
repeat
performance
test
using
the
applicable
method(
s)
within
2
years
following
the
previous
performance
test
and
within
180
days
after
each
replacement
of
any
portion
of
the
biofilter
bed
with
a
different
media
or
each
replacement
of
more
than
50
percent
(
by
volume)
of
the
biofilter
bed
media
with
the
same
type
of
media.

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
must
also
comply
with
the
CEMS
data
quality
assurance
requirements
in
Procedure
1
of
Appendix
F
of
40
CFR
Part
60.

You
must
conduct
a
performance
evaluation
of
the
CEMS
according
to
40
CFR
63.8
and
Performance
Specification
8.

The
CEMS
must
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
must
calculate
and
record
the
3­
hour
block
average
THC
concentration
for
thermal
or
catalytic
oxidizers.
For
biofilters,
you
must
calculate
and
record
the
24­
hour
block
average
THC
concentration.
You
must
continuously
monitor
and
maintain
the
24­
hour
block
average
THC
concentration
at
or
below
the
maximum
established
during
the
performance
test.
You
may
use
a
CEMS
that
subtracts
42
methane
from
the
measured
THC
concentration
if
you
wish
to
do
so.

If
you
comply
with
today's
final
rule
using
an
add­
on
control
system,
you
may
request
a
routine
control
device
maintenance
exemption
from
the
Administrator.
Your
request
for
a
routine
control
device
maintenance
exemption
must
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
cannot
be
accomplished
during
process
shutdowns,
describe
how
you
plan
to
make
reasonable
efforts
to
minimize
emissions
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
must
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,
rotary
strand
dryer,
or
pressurized
refiner
controlled.
The
routine
control
device
maintenance
exemption
is
limited
to
0.5
percent
of
the
43
annual
operating
uptime
for
each
softwood
veneer
dryer,

reconstituted
wood
product
press,
reconstituted
wood
product
board
cooler,
hardboard
oven,
press
predryer,
conveyor
strand
dryer,
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
must
continuously
comply
with
the
applicable
operating
requirements
for
add­
on
control
systems
(
described
in
the
previous
subsection).
You
also
must
maintain
records
of
your
operating
hours
for
each
process
unit
included
in
the
EAP.
For
each
semiannual
compliance
period,
you
must
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
must
operate
all
dry
rotary
dryers
and
veneer
44
redryers
so
that
they
continuously
meet
the
definitions
of
these
process
units
in
today's
final
rule.
For
dry
rotary
dryers,
you
must
continuously
monitor
and
maintain
the
inlet
furnish
moisture
content
at
or
below
30
percent
and
the
inlet
dryer
operating
temperature
at
or
below
600

F.
You
must
also
calibrate
the
moisture
monitor
based
on
the
procedures
specified
by
the
moisture
monitor
manufacturer
at
least
once
per
semiannual
compliance
period
to
verify
the
readings
from
the
moisture
meter.
For
veneer
redryers,
you
must
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
must
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
must
continue
to
process
less
than
30
percent
softwood
veneer
by
volume
and
maintain
records
on
veneer
dryer
production.

To
demonstrate
continuous
compliance
with
the
work
practice
requirements
for
group
1
miscellaneous
coating
operations,
you
must
keep
records
showing
that
you
continue
to
use
non­
HAP
coatings
as
defined
in
the
final
rule.

I.
How
Do
I
Demonstrate
that
My
Facility
is
Part
of
the
45
Low­
risk
Subcategory?

III.
Summary
of
Environmental,
Energy,
and
Economic
Impacts
A.
How
many
facilities
are
impacted
by
this
final
rule?

Approximately
223
PCWP
facilities
nationwide
are
expected
to
meet
the
applicability
criteria
defined
in
today's
final
rule.
However,
only
212
of
these
facilities
have
equipment
that
is
subject
to
the
control
requirements
of
the
rule.
In
addition,
there
are
approximately
34
major
source
sawmill
facilities
that
produce
kiln­
dried
lumber;

although
these
major
source
sawmill
facilities
meet
the
applicability
criteria
in
the
final
rule,
there
are
no
control
requirements
for
any
of
the
equipment
located
at
the
sawmills.

The
number
of
impacted
facilities
was
determined
based
on
the
estimated
potential
to
emit
(
i.
e.,
uncontrolled
HAP
emissions)
from
each
facility,
whether
each
facility
has
any
process
units
subject
to
the
compliance
options,
and
whether
or
not
the
facility
already
operates
control
systems
necessary
to
meet
the
final
rule.
Facilities
with
estimated
potential
to
emit
25
tons
or
more
of
total
HAP
or
10
or
more
tons
of
an
individual
HAP
are
major
sources
of
HAP
and
are
subject
to
the
rule.
Of
the
estimated
212
facilities
with
equipment
subject
to
the
control
requirements
in
today's
final
rule,
an
estimated
166
are
expected
to
install
add­
on
46
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
166
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
environmental
and
cost
impacts
presented
in
this
preamble
represent
the
estimated
impacts
for
the
212
facilities.
The
impact
estimates
were
based
on
the
use
of
RTO
(
or
in
some
cases
a
combination
WESP
and
RTO)
because
RTO
are
the
most
prevalent
HAP
emissions
control
technology
used
in
the
PCWP
industry.
However,
technologies
other
than
RTO
could
be
used
to
comply
with
today's
final
rule.
For
a
facility
that
we
believe
already
achieves
the
emissions
reductions
required
by
today's
final
rule,
only
testing,

monitoring,
reporting
and
recordkeeping
cost
impacts
were
estimated.

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
today's
final
rule
will
reduce
total
HAP
emissions
from
the
PCWP
47
source
category
by
about
9,700
Mg/
yr
(
11,000
tons/
yr).
In
addition,
we
estimate
that
today's
rule
will
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,

today's
final
rule
will
also
reduce
emissions
of
criteria
pollutants,
such
as
carbon
monoxide
(
CO)
from
direct­
fired
emission
sources
and
particulate
matter
less
than
10
microns
in
diameter
(
PM10).
We
estimate
that
today's
final
rule
will
reduce
CO
emissions
by
about
10,000
Mg/
yr
(
11,000
tons/
yr).
We
estimate
that
the
rule
will
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
(
NOx).
We
estimate
that
the
nationwide
increase
in
NOx
emissions
due
to
the
use
of
RTOs
will
be
about
2,200
Mg/
yr
(
2,400
tons/
yr).
This
estimated
increase
in
NOx
emissions
may
be
an
overestimate
because
some
plants
may
select
control
technologies
other
than
RTO
to
comply
with
today's
final
rule.

Secondary
air
impacts
of
today's
final
rule
would
result
from
increased
electricity
usage
associated
with
operation
of
control
devices.
The
secondary
air
emissions
of
NOx,
CO,

PM10,
sulfur
dioxide
(
SO2)
depend
on
the
fuel
used
to
generate
electricity.
Therefore,
we
estimated
a
range
of
48
secondary
air
impacts
based
on
the
assumption
that
electricity
is
generated
by
natural
gas­
fired
and
coal­
fired
utility
plants.
Assuming
that
PCWP
plants
will
purchase
electricity
from
a
natural
gas­
fired
utility
plant,
we
estimate
that
the
final
rule
may
increase
secondary
emissions
of
criteria
pollutants
such
as
PM10,
sulfur
dioxide
(
SO2),
NOx,
and
CO
from
utility
plants
by
about
25
Mg/
yr
(
27
tons/
yr),
2.0
Mg/
yr
(
2.2
tons/
yr),
460
Mg/
yr
(
500
tons/
yr),
and
270
Mg/
yr
(
300
tons/
yr),
respectively.

Assuming
as
a
worst­
case
that
PCWP
plants
will
purchase
electricity
from
a
natural
gas­
fired
utility
plant,
we
estimate
that
the
final
rule
may
increase
secondary
emissions
of
PM10
by
100
Mg/
yr
(
110
tons/
yr),
SO2
by
4,000
Mg/
yr
(
4,500
tons/
yr),
NOx
by
2,000
Mg/
yr
(
2,200
tons/
yr),

and
CO
by
66
Mg/
yr
(
73
tons/
yr).

Our
estimates
regarding
reductions
in
HAP
and
criteria
pollutant
emissions,
and
increases
in
NOx
emissions
and
secondary
air
emissions,
will
necessarily
be
affected
by
the
extent
to
which
sources
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.

C.
What
are
the
water
quality
impacts?

Wastewater
is
produced
from
WESP
blowdown,
washing
out
of
RTO,
and
biofilters.
We
based
all
of
our
impact
estimates
on
the
use
of
RTO
(
with
or
without
a
WESP
upstream
depending
on
the
process
unit).
We
estimate
that
the
49
wastewater
generated
from
WESP
blowdown
and
RTO
washouts
will
increase
by
about
103
thousand
cubic
meters
per
year
(
m3/
yr)(
27
million
gallons
per
year
(
gal/
yr))
as
a
result
of
today's
final
rule,
in
advance
of
any
facility
demonstrating
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
According
to
the
data
in
our
MACT
survey,
this
nationwide
increase
in
wastewater
flow
is
within
the
range
of
water
flow
rates
handled
by
individual
facilities.

Facilities
would
likely
dispose
of
this
wastewater
by
sending
it
to
a
municipal
treatment
facility,
reusing
it
onsite
(
e.
g.,
in
log
vats
or
resin
mix),
or
hauling
it
offsite
for
spray
irrigation.
In
addition,
we
are
amending
the
effluent
limitations,
guidelines
for
the
timber
products
processing
point
source
category
to
allow
facilities
(
on
a
case­
by­
case
basis)
to
obtain
a
permit
to
discharge
wastewaters
from
APCD
installed
to
comply
with
the
final
PCWP
rule.

D.
What
are
the
solid
waste
impacts?

Solid
waste
is
produced
in
the
form
of
solids
from
WESP
and
by
RTO
or
RCO
media
replacement.
We
estimate
that
4,500
Mg/
yr
(
5,000
tons/
yr)
of
solid
waste
will
be
generated
as
a
result
of
today's
final
rule,
in
advance
of
any
facility
demonstrating
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
This
solid
material
may
be
disposed
of
in
a
landfill
or
used
for
other
purposes.
Some
PCWP
50
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
today's
final
rule,
in
advance
of
any
facility
demonstrating
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
The
estimated
increase
in
the
energy
demand
is
based
on
the
electricity
requirements
associated
with
RTO
and
WESP
and
the
fuel
requirements
associated
with
RTO.
Electricity
requirements
are
expected
to
increase
by
about
718
gigawatt
hours
per
year
(
Gwh/
yr)
under
today's
final
rule.
Natural
gas
requirements
are
expected
to
increase
by
about
45
million
m3/
yr
(
1.6
billion
cubic
feet
per
year
(
ft3/
yr))

under
the
final
rule.
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.

F.
What
are
the
cost
impacts?

The
cost
impacts
estimated
for
today's
final
rule
represent
a
high­
end
estimate
of
costs.
Although
the
use
of
51
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
PBCO
or
install
add­
on
control
devices
that
are
less
costly
to
operate,
such
as
RCO
and
biofilters.
Therefore,
our
cost
estimates
are
likely
to
be
overstated
as
we
anticipate
that
owners
and
operators
of
impacted
sources
will
take
advantage
of
available
cost
saving
opportunities.

The
high­
end
estimated
total
capital
costs
of
today's
final
rule
are
$
479
million.
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
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.
Wood
products
enclosure
costs
are
also
included
for
reconstituted
wood
products
presses.

The
high­
end
estimated
annualized
costs
of
the
final
standards
are
$
142
million.
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
52
included
in
the
delisted
low­
risk
subcategory.
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
the
emissions
averaging
provisions
in
today's
final
rule
are
not
accounted
for
in
either
the
capital
or
annualized
cost
estimates.

G.
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
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
today's
final
rule.
There
is
one
plant
closure
expected
out
of
the
223
facilities
affected
by
the
rule.
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
It
should
be
noted
that
the
baseline
economic
condition
of
the
facility
predicted
to
close
rather
than
incur
the
costs
of
compliance
with
the
rule
affects
the
closure
estimate
provided
by
the
economic
model,
and
that
the
facility
predicted
to
close
appears
to
have
low
profitability
levels
currently.
53
Therefore,
it
is
likely
that
there
is
no
adverse
impact
expected
to
occur
for
those
industries
that
produce
output
affected
by
the
rule,
such
as
hardboard,
softwood
plywood
and
veneer,
engineered
wood
products,
and
other
wood
composites.

H.
What
are
the
social
costs
and
benefits?

Our
assessment
of
costs
and
benefits
of
today's
final
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
and
Docket
number
OAR­
2003­
0048.

It
is
estimated
that
3
years
after
implementation
of
the
final
rule
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.
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
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
rule.
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
54
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
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
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
low­
risk
subcategory.
These
estimated
reductions
occur
from
existing
sources
in
operation
3
years
after
the
implementation
of
the
requirements
of
the
final
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
55
(
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
2
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
NOx
emissions
associated
with
today's
final
rule
as
a
result
of
increased
use
of
incineration­
based
controls.
These
NOx
emission
increases
by
themselves
could
cause
some
increase
in
ozone
and
PM
concentrations,
which
could
lead
to
impacts
on
human
health
56
and
welfare
as
listed
in
Table
2.
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
NOx
increases
at
affected
sources,

today's
final
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
NOx
from
electricity
generating
utilities.
As
such,
the
final
rule
may
result
in
additional
health
impacts
from
increased
ambient
PM
and
ozone
from
these
increased
utility
emissions.
We
did
not
quantify
or
monetize
these
health
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
CO.
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.
57
These
general
uncertainties
in
the
underlying
scientific
and
economics
literatures
are
discussed
in
detail
in
the
RIA
and
its
supporting
documents
and
references.

In
determining
the
overall
economic
consequences
of
this
rule,
it
is
essential
to
consider
not
only
the
costs
and
benefits
expressed
in
dollar
terms
but
also
those
benefits
and
costs
that
we
could
not
quantify.
A
full
listing
of
the
benefit
categories
that
could
not
be
quantified
or
monetized
in
our
analysis
is
provided
in
Table
2
of
this
preamble.
58
TABLE
2.
UNQUANTIFIED
BENEFIT
CATEGORIES
FROM
HAP,
OZONERELATED
AND
PM
EMISSIONS
REDUCTIONS
Unquantified
Effect
Categories
Associated
with
HAP
Unquantified
Effect
Categories
Associated
with
Ozone
Unquantified
Effect
Categories
Associated
with
PM
Health
Categories
Carcinogenicity
mortality
Genotoxicity
mortality
Noncancer
lethality
Pulmonary
function
decrement
Dermal
irritation
Eye
irritation
Neurotoxicity
Immunotoxicity
Pulmonary
function
decrement
Liver
damage
Gastrointestinal
toxicity
Kidney
damage
Cardiovascular
impairment
Hematopoietic
(
Blood
disorders)
Reproductive/
Develop
mental
toxicity
Airway
responsiveness
Pulmonary
inflammation
Increased
susceptibility
to
respiratory
infection
Acute
inflammation
and
respiratory
cell
damage
Chronic
respiratory
damage/
Premature
aging
of
lungs
Emergency
room
visits
for
asthma
Hospital
admissions
for
respiratory
diseases
Asthma
attacks
Minor
restricted
activity
days
Premature
mortality
Chronic
bronchitis
Hospital
admissions
for
chronic
obstructive
pulmonary
disease,
pneumonia,
cardiovascular
diseases,
and
asthma
Changes
in
pulmonary
function
Morphological
changes
Altered
host
defense
mechanisms
Cancer
Other
chronic
respiratory
disease
Emergency
room
visits
for
asthma
Lower
and
upper
respiratory
symptoms
Acute
bronchitis
Shortness
of
breath
Minor
restricted
activity
days
Asthma
attacks
Work
loss
days
Welfare
Categories
Corrosion/
Deteriorat
ion
Unpleasant
odors
Transportation
safety
concerns
Yield
reductions/
Foliar
injury
Biomass
decrease
Species
richness
decline
Species
diversity
decline
Community
size
decrease
Organism
lifespan
decrease
Trophic
web
shortening
Ecosystem
and
vegetation
effects
in
Class
I
areas
(
e.
g.,
national
parks)
Damage
to
urban
ornamentals
(
e.
g.,
grass,
flowers,
shrubs,
and
trees
in
urban
areas)
Commercial
field
crops
Fruit
and
vegetable
crops
Reduced
yields
of
tree
seedlings,
commercial
and
noncommercial
forests
Damage
to
ecosystems
Materials
damage
Reduced
worker
productivity
Materials
damage
Damage
to
ecosystems
(
e.
g.,
acid
sulfate
deposition)
Nitrates
in
drinking
water
59
I.
How
will
the
risk­
based
exemption
reduce
impacts?

Today's
final
rule
contains
criteria
defining
a
subcategory
of
low­
risk
PCWP
facilities.
Facilities
that
can
demonstrate
that
they
are
part
of
this
low­
risk
subcategory
are
not
required
to
comply
with
today's
final
rule.
Therefore,
the
impacts
of
today's
final
rule
will
be
reduced.
The
reduction
in
environmental,
energy,
and
economic
impacts
associated
with
inclusion
of
the
low­
risk
subcategory
option
in
the
final
PCWP
rule
are
summarized
in
this
section.

1.
Estimated
Baseline
Risks
and
Number
of
Low­
risk
Facilities
To
estimate
the
potential
baseline
risks
posed
by
the
PCWP
source
category
and
the
potential
impact
of
a
delisted
low­
risk
subcategory,
EPA
performed
a
preliminary
"
rough"

risk
assessment
for
189
of
the
223
facilities
in
the
PCWP
source
category.
All
HAP
were
included
in
the
assessment.

Of
the
189
facilities
assessed,
facilities
were
expected
to
pose
cancer
risks
equal
to
or
greater
than
one
in
one
million
to
their
surrounding
population.
facilities
were
predicted
to
pose
cancer
risks
of
one
in
100,000
or
greater,
and
PCWP
facilities
were
expected
to
pose
cancer
risks
equal
to
or
greater
than
one
in
10,000.

As
a
result
of
the
final
rule,
annual
cancer
incidence
would
be
reduced
from
about
0.09
cases/
year
to
about
0.02
60
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
hazard
index
(
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,

facilities
could
potentially
be
eligible
for
inclusion
in
the
delisted
low­
risk
subcategory
based
on
a
cancer
risk
level
of
10­
6
and
an
HI
limit
of
,
provided
these
assessments
are
confirmed
by
source­
specific
demonstrations.

The
difference
in
regulatory
impacts
due
to
inclusion
of
the
delisted
low­
risk
subcategory
in
the
final
PCWP
rule
are
summarized
in
the
following
paragraphs.

As
noted
in
section
III.
A,
of
the
223
PCWP
major
sources,
212
have
equipment
that
is
subject
to
control
requirements
in
the
final
rule,
and
166
of
these
facilities
would
have
been
expected
to
install
APCD
in
the
absence
of
any
delisted
low­
risk
subcategory.
We
expect
that
of
the
166
facilities
that
would
have
been
expected
to
install
controls
may
be
eligible
for
inclusion
in
the
delisted
low­
61
risk
subcategory.
The
remaining
facilities
possibly
eligible
for
the
delisted
low­
risk
subcategory
may
already
have
all
of
the
necessary
controls
or
may
not
have
any
equipment
that
would
have
been
subject
to
control
requirements.

2.
Air
quality
impacts
We
estimate
that
the
total
HAP
emissions
reductions
estimate
provided
in
section
III.
B
will
decrease
by
due
to
facilities
becoming
part
of
the
delisted
low­
risk
subcategory.
In
addition,
we
estimate
that
VOC
(
approximated
as
THC)
emissions
reductions
estimate
provided
in
section
III.
B
will
decrease
by
.
Therefore,
considering
the
impact
of
facilities
becoming
part
of
the
delisted
low
risk
subcategory,
we
estimate
that
today's
final
rule
will
result
in
a
total
reduction
in
HAP
emissions
of
and
a
total
reduction
in
VOC
emissions
of
.

Including
a
delisted
low­
risk
subcategory
will
affect
the
estimates
of
criteria
pollutant
reductions
as
well.
We
estimate
that
reduction
in
CO
emissions
from
direct­
fired
emission
sources
will
decrease
by
from
the
estimate
provided
in
section
III.
B.
As
a
result,
we
estimate
that
the
total
reduction
in
CO
emissions
will
be
approximately
.
We
62
also
estimate
that
the
PM10
emissions
reductions
reported
in
section
III.
B
will
decrease
by
.
Thus,
we
estimate
that
today's
final
rule
will
result
in
a
total
PM10
emissions
reduction
of
.
We
also
anticipate
that
emissions
of
NOx
from
combustion
of
exhaust
gases
in
an
RTO
will
decrease
due
to
facilities
becoming
a
part
of
the
delisted
low­
risk
subcategory.
We
estimate
that
NOx
emissions
increase
will
decrease
by
from
our
estimate
provided
in
section
III.
B,
resulting
in
a
total
increase
in
NOx
emissions
of
.

The
secondary
air
impacts
of
electricity
usage
generated
by
utility
plants
will
decrease
from
the
levels
estimated
in
section
III.
B.
We
estimate
that
the
worst­
case
secondary
emissions
increase
of
PM10,
SO2,
NOx,
and
CO
associated
with
coal­
fired
utility
plants
presented
in
section
III.
B
will
decrease
by
,
and
due
to
facilities
becoming
a
part
of
the
delisted
low­
risk
subcategory.
Thus,
we
estimate
that
today's
final
rule
will
increase
secondary
emissions
of
criteria
pollutants
by
no
more
than
PM10,

SO2,
NOx,
and
CO.
63
3.
Water
quality
impacts
We
estimate
that
the
wastewater
impacts
of
today's
final
rule
(
reported
in
section
III.
C)
will
be
reduced
by
about
due
to
facilities
becoming
part
of
the
delisted
low­
risk
subcategory.
Thus,
considering
the
reduction
in
impacts
associated
with
the
delisted
low­
risk
subcategory,
we
estimate
that
today's
final
rule
will
result
of
wastewater
generated
from
RTO
washouts
and
WESP
blowdown.

4.
Solid
waste
impacts
We
estimate
that
the
solid
waste
impacts
of
today's
final
rule
(
reported
in
section
III.
D)
will
be
reduced
by
about
due
to
facilities
becoming
part
of
the
delisted
low­
risk
subcategory.
Thus,
considering
the
reduction
in
impacts
associated
with
the
delisted
low­
risk
subcategory,
we
estimate
that
today's
final
rule
will
result
in
of
solid
waste
generated
from
WESPs
and
RTO
and
RCO
media
replacement.

5.
Energy
impacts
The
overall
electricity
and
natural
gas
energy
demand
reported
in
section
III.
E
is
expected
to
decrease
by
due
to
facilities
becoming
a
part
of
the
delisted
low­
risk
subcategory.
Therefore,
we
estimate
that
the
total
nationwide
increase
in
the
energy
demand
due
to
the
final
PCWP
rule
is
64
.
The
delisted
low­
risk
subcategory
is
expected
to
decrease
the
electricity
requirements
associated
with
RTO
and
WESP
by
_
resulting
in
a
total
nationwide
increase
of
.
We
also
estimate
that
the
reduction
in
impacts
associated
with
the
delisted
lowrisk
subcategory
will
result
in
a
decrease
in
the
fuel
requirements
for
RTOs
by
,
resulting
in
a
total
nationwide
fuel
increase
of
.

6.
Cost
impacts
Facilities
that
become
part
of
the
delisted
low­
risk
subcategory
will
not
need
to
install
APCD
to
comply
with
the
final
PCWP
rule.
Therefore,
the
high­
end
estimated
costs
of
today's
final
rule
will
be
less
than
the
estimates
presented
in
section
III.
F.
We
estimate
that
the
total
capital
costs
(
associated
with
procurement
of
RTO
equipment,
monitoring
equipment,
performance
tests,
and
wood
products
enclosures
for
existing
sources)
will
decrease
by
.
Therefore,

we
estimate
that
the
total
capital
costs
of
the
final
PCWP
rule
are
.
We
also
anticipate
a
decrease
of
in
the
high­
end
estimated
annualized
costs,
which
include
annualized
capital
costs
for
control
and
monitoring
equipment,
operation
and
maintenance
expenses,
and
recordkeeping
and
reporting
costs.
We
estimate
that
the
total
annualized
costs
of
the
final
PCWP
rule
are
65
Economic
impacts.

Social
costs
and
benefits.

IV.
Summary
of
Responses
to
Major
Comments
and
Changes
to
the
Plywood
and
Composite
Wood
Products
NESHAP
We
proposed
the
PCWP
NESHAP
on
January
9,
2003
(
68
FR
1276),
and
received
57
comment
letters
on
the
proposal
during
the
comment
period.
In
response
to
the
public
comments
received
on
the
proposed
rule,
we
made
several
changes
in
developing
today's
final
rule.
Table
3
provides
a
list
of
the
major
changes
that
we
made
to
the
final
rule.

The
major
comments
and
our
responses
are
summarized
in
the
following
sections.
A
complete
summary
of
the
comments
received
during
the
comment
period
and
responses
thereto
can
be
found
in
the
background
information
document
(
BID)
for
the
promulgated
rule,
which
is
available
from
several
sources
(
see
SUPPLEMENTARY
INFORMATION
section).
66
TABLE
3.
SUMMARY
OF
MAJOR
CHANGES
TO
SUBPART
DDDD
OF
PART
63
Proposed
Section
Final
Section
Change
from
Proposal
§
63.2232(
b
)
§
63.2232(
b
)
Description
of
affected
source
revised
to
be
consistent
with
revised
definition
§
63.2240
§
63.2240
Clarified
application
of
compliance
options
to
a
single
process
unit
§
63.2240(
a
)
§
63.2240(
a
)
Added
wet
control
device
to
the
list
of
devices
that
may
not
be
used
to
meet
the
PBCO
§
63.2240(
b
)
§
63.2240(
b
)
Changed
press
enclosure
reference
from
"
PTE"
to
"
wood
products
enclosure"

§
63.2240(
c
)(
1)
§
63.2240(
c
)(
1)
Revised
definition
of
AMR
and
OCEPi
in
emissions
averaging
calculations
to
clarify
that
sources
can
receive
partial
credits
from
debit­
generating
process
units
that
are
undercontrolled;
revised
definition
of
CDi
to
address
test
method
for
biological
treatment
units
that
do
not
meet
the
definition
of
biofilter
§
63.2240(
c
)(
2)(
iii)
§
63.2240(
c
)(
2)(
iii)
Revised
restriction
on
emissions
average
related
to
process
units
that
are
already
controlled.

 
§
63.2241(
c
)
Added
new
section
that
exempts
dry
rotary
dryers,
hardwood
veneer
dryers,
and
veneer
redryers
from
work
practice
requirements
if
they
comply
with
more
stringent
standards
in
§
63.2240
§
63.2250(
a
)
§
63.2250(
a
)
Revised
section
to
clarify
that
startup,
shutdown,
and
malfunction
refers
to
both
process
unit
and
control
unit
startup,
shutdown,
and
malfunction
§
63.2250(
d
)
§
63.2250(
a
)
Moved
and
revised
section
to
consolidate
explanation
of
startup,
shutdown,
and
malfunction
provisions
 
§
63.2250(
d
)
Added
specific
example
of
a
shutdown
for
direct­
fired
burners
and
a
specific
example
of
a
startup
for
direct­
fired
softwood
veneer
dryers
67
§
63.2250(
e
)
 
Removed
requirement
to
record
control
device
maintenance
schedule
§
63.2250(
f
)
 
Removed
requirement
to
maintain
and
operate
catalyst
according
to
manufacturer's
specifications
§
63.2251(
a
)
§
63.2251(
a
)
Added
partial
list
of
events
eligible
for
a
routine
control
device
exemption;
clarified
duty
to
minimize
emissions
§
63.2251(
b
)(
1)
§
63.2251(
b
)(
1)
Specified
type
of
strand
dryer
controlled
by
a
control
device
eligible
for
a
routine
control
device
maintenance
exemption
of
3
percent
of
annual
uptime
§
63.2251(
b
)(
2)
§
63.2251(
b
)(
2)
Added
conveyor
strand
dryer
to
list
of
process
units
controlled
by
a
control
device
eligible
for
a
routine
control
device
maintenance
exemption
of
0.5
percent
of
annual
uptime
§
63.2251(
e
)
§
63.2251(
e
)
Removed
requirement
to
schedule
control
device
maintenance
at
the
beginning
of
each
semi­
annual
period
§
63.2260(
a
)
§
63.2260(
a
)
Expanded
exemption
from
testing
and
monitoring
requirements
to
all
combustion
units
that
introduce
process
unit
exhaust
into
the
flame
zone.

§
63.2262(
d
)
§
63.2262(
d
)(
1)
§
63.2262(
d
)(
2)
Added
sampling
location
requirements
for
control
devices
in
sequence,
process
units
with
no
control
device,
and
process
units
with
a
wet
control
device
§
63.2262(
g
)
§
63.2262(
g
)(
1)
Reworded
and
renumbered
section
to
allow
for
one
case
in
which
nondetect
data
is
not
considered
to
be
one­
half
the
method
detection
limit
 
§
63.2262(
g
)(
2)
Added
exception
to
requirement
to
treat
non­
detect
data
as
one­
half
the
detection
limit
§
63.2262(
k
)(
1)
§
63.2262(
k
)(
1)
Clarified
requirements
for
establishing
the
minimum
firebox
temperature
for
thermal
oxidizers
68
§
63.2262(
k
)(
2)
§
63.2262(
k
)(
3)
 
 
Removed
sections
on
establishing
operating
parameter
limits
for
static
pressure
and
stack
gas
flow
for
thermal
oxidizers
§
63.2262(
k
)(
4)
§
63.2262(
k
)(
2)
Removed
references
to
static
pressure
and
gas
flow
rate
operating
parameters
§
63.2262(
k
)(
5)
§
63.2262(
k
)(
3)
Revised
eligibility
criteria
for
exemptions
from
performance
testing
and
operating
requirements
for
thermal
oxidizers
§
63.2262(
l
)(
1)
§
63.2262(
l
)(
1)
Clarified
requirements
for
establishing
the
minimum
catalytic
oxidizer
temperature
§
63.2262(
l
)(
2)
§
63.2262(
l
)(
3)
 
 
Removed
sections
on
establishing
operating
parameter
limits
for
static
pressure
and
stack
gas
flow
for
catalytic
oxidizers
§
63.2262(
l
)(
4)
§
63.2262(
l
)(
2)
Removed
references
to
static
pressure
and
gas
flow
rate
operating
parameters
§
63.2262(
m
)(
1)
§
63.2262(
m
)(
2)
§
63.2262(
m
)(
1)
§
63.2262(
m
)(
2)
Revised
requirements
for
establishing
biofilter
operating
limits
(
temperature
range)

§
63.2262(
n
)(
1)
§
63.2262(
n
)(
1)
Revised
monitoring
requirements
for
process
units
that
meet
compliance
options
without
the
use
of
an
add­
on
control
device
§
63.2267
§
63.2267
Added
initial
compliance
criteria
for
a
wood
products
enclosure
 
§
63.2268
Added
criteria
for
demonstration
of
initial
compliance
for
a
wet
control
device
§
63.2268(
a
)(
1)
§
63.2269(
a
)(
1)
Revised
continuous
parameter
monitoring
system
requirements
§
63.2268(
a
)(
3)
§
63.2268(
a
)(
4)
§
63.2270(
d
)
§
63.2270(
e
)
Revised
and
moved
sections
regarding
determination
of
block
averages
and
valid
data
to
section
on
continuous
compliance
requirements
§
63.2268(
b
)(
2)
§
63.2268(
b
)(
3)
§
63.2269(
b
)(
2)
§
63.2268(
b
)(
3)
Clarified
temperature
measurement
requirements
69
§
63.2268(
c
)
§
63.2268(
d
)
§
63.2268(
e
)
 
Removed
sections
regarding
pH,
pressure,
and
flow
monitoring
§
63.2268(
f
)(
1)
§
63.2268(
f
)(
2)
§
63.2269(
c
)(
1)
§
63.2269(
c
)(
2)
Revised
requirements
for
wood
moisture
monitoring
 
§
63.2269(
c
)(
5)
Added
equation
for
converting
moisture
measurements
from
wet
basis
to
dry
basis
§
63.2270(
c
)
§
63.2270(
c
)
Added
language
to
specify
that
data
recorded
during
periods
of
startup,
shutdown,
and
malfunction
may
not
be
used
in
data
averages
and
calculations
used
to
report
emission
or
operating
levels
 
§
63.2270(
f
)
Added
requirement
that
75
percent
of
readings
recorded
and
included
in
block
averages
must
be
based
on
valid
data
§
63.2280(
f
)(
6)
§
63.2280(
f
)(
6)
Revised
Emissions
Averaging
Plan
submission
requirements
to
include
information
on
debit­
generating
process
units
 
§
63.2282(
e
)
Added
requirement
to
keep
records
of
annual
catalyst
activity
checks
and
subsequent
corrective
actions
for
catalytic
oxidizers
 
§
63.2292
Added
definitions
of
"
agricultural
fiber,"
"
combustion
unit,"
"
conveyor
strand
dryer,"
"
conveyor
strand
dryer
zone,"
"
flame
zone,"
"
group
1
miscellaneous
coating
operations,"
"
non­
HAP
coating,"
"
one­
hour
period,"
"
partial
wood
products
enclosure,"
"
primary
tube
dryer,"
"
rotary
strand
dryer,"
"
secondary
tube
dryer,"
"
wet
control
device,"
and
"
wood
products
enclosure"

§
63.2292
 
Removed
definitions
of
"
permanent
total
enclosure,"
"
plant
site,"
and
"
strand
dryer"
70
§
63.2292
§
63.2292
Revised
definitions
of
"
affected
source,"
"
biofilter,"
"
fiber,"
fiberboard,"
"
hardboard,"
"
medium
density
fiberboard,"
"
miscellaneous
coating
operations,"
"
particle,"
"
particleboard,"
"
plywood
and
composite
wood
products
(
PCWP)
manufacturing
facility,"
"
softwood
veneer
dryer,"
and
"
thermal
oxidizer"

Table
1A
Table
1A
Changed
"
tube
dryers"
to
"
primary
tube
dryers"
and
added
"
secondary
tube
dryers";
added
PBCO
limit
for
secondary
tube
dryers;
revised
PBCO
limit
for
reconstituted
wood
product
board
coolers;
changed
"
strand
dryers"
to
"
rotary
strand
dryers"

Table
1B
Table
1B
Added
"
rotary
strand
dryers,"
"
conveyor
strand
dryer
zone
one
(
at
existing
affected
sources),"
and
"
conveyor
strand
dryer
zones
one
and
two
(
at
new
affected
sources)"
to
the
list
of
process
units
Table
2,
Line
1
Table
2,
Line
1
Reduced
thermal
oxidizer
operating
requirements
to
maintaining
the
average
firebox
temperature
above
the
minimum
temperature
Table
2,
Line
2
Table
2,
Line
2
Reduced
catalytic
oxidizer
operating
requirements
to
maintaining
the
temperature
above
a
minimum
temperature
and
checking
the
activity
level
of
a
representative
sample
of
the
catalyst
every
12
months
Table
2,
Line
3
Table
2,
Line
3
Reduced
biofilter
operating
requirements
to
maintaining
the
biofilter
bed
temperature
within
a
range
Table
2,
Line
5
Table
2,
Line
5
Revised
operating
requirements
for
process
units
without
control
devices
 
Table
3,
Line
5
Added
work
practice
requirements
for
group
1
miscellaneous
coating
operations
71
Table
4,
Line
9
Table
4,
Line
9
Revised
the
performance
test
criteria
for
reconstituted
wood
product
presses
and
reconstituted
wood
product
board
coolers
Table
4,
Line
11
Table
4,
Line
11
Revised
text
to
clarify
that
performance
test
requirements
apply
to
all
process
units
in
an
emissions
average
plan
Table
5,
Line
7
Table
5,
Line
7
Removed
minimum
heat
input
capacity
criterion
for
combustion
units
 
Table
5,
Line
8
Added
criteria
for
performance
testing
and
initial
compliance
demonstrations
for
wet
control
devices
 
Table
6,
Line
5
Added
initial
compliance
demonstration
for
Group
1
miscellaneous
coating
operations
Table
7,
Line
1
Table
7,
Line
1
Revised
"
at
or
above
the
maximum,
at
or
below
the
minimum"
to
read
"
at
or
above
the
minimum,
at
or
below
the
maximum"

 
Table
7,
Line
3
Added
continuous
compliance
requirements
(
periodic
testing)
for
biofilters
 
Table
7,
Line
4
Added
continuous
compliance
requirements
(
annual
catalyst
activity
check)
for
catalytic
oxidizers
 
Table
7,
Line
5
Added
continuous
compliance
requirements
for
process
units
achieving
compliance
without
an
addon
control
device
Table
8,
Line
1
Table
8,
Line
1
Specified
block
averages
of
24
hours
for
moisture
and
temperature
measurements
for
dry
rotary
dryers
Table
8,
Line
4
Table
8,
Line
4
Specified
block
average
of
24
hours
for
moisture
measurements
for
veneer
dryers
 
Table
8,
Line
5
Added
continuous
compliance
requirements
for
Group
1
miscellaneous
coating
operations
Table
10,
§
63.8(
g)
Table
10,
§
63.8(
g)
Added
"
rounding
of
data"
to
description
of
the
General
Provisions
section
72
Appendix
A
to
Subpart
DDDD
Appendix
A
to
Subpart
DDDD
Made
various
revisions
throughout
to
reflect
the
removal
of
a
permanent
total
enclosure
(
PTE)
as
a
requirement
for
reconstituted
wood
products
presses
and
board
coolers
73
A.
Applicability
1.
Definition
of
Affected
Source
Comment:
Several
commenters
requested
that
we
clarify
that
the
PCWP
affected
source
includes
refining
and
resin
preparation
activities
such
as
mixing,
formulating,

blending,
and
chemical
storage,
and
suggested
that
boilers
be
excluded.
The
commenters
wanted
to
ensure
that
onsite
resin
preparation
activities
are
specifically
mentioned
in
and
regulated
by
the
final
PCWP
rule
to
avoid
duplicate
regulation
of
those
activities
under
the
Miscellaneous
Organic
Chemical
Manufacturing
NESHAP
(
Subpart
FFFF)
or
the
Miscellaneous
Coating
Manufacturing
NESHAP
(
Subpart
HHHHH).

Commenters
also
recommended
changing
the
proposed
definition
of
affected
source
by
revising
the
definition
of
"
plant
site,"
which
was
used
in
the
affected
source
definition
at
proposal.
The
commenters
asked
that
we
make
the
definition
of
"
plant
site"
consistent
with
the
definition
of
"
major
source"
as
defined
for
Title
V
permitting
in
40
C.
F.
R.

§
70.2.
According
to
the
commenters,
the
proposed
definition
of
"
plant
site"
expanded
the
definition
of
a
source
beyond
that
used
for
Title
V
permitting
or
MACT
applicability
in
general.

Response:
We
agree
with
the
commenters
that
changes
should
be
made
to
the
definition
of
affected
source
and
revised
the
definition
in
the
final
rule.
We
added
resin
74
preparation
activities
to
the
definition
of
"
affected
source"
to
clarify
that
these
activities
are
part
of
the
PCWP
source
category
and
are
not
subject
to
Subparts
FFFF
or
HHHHH.
Resin
preparation
includes
any
mixing,
blending,
or
diluting
of
resins
used
in
the
manufacture
of
PCWP
products
which
occurs
at
the
PCWP
manufacturing
facility.
We
believe
this
change
is
appropriate
because
the
MACT
analysis
for
resin
preparation
activities
was
conducted
under
the
PCWP
rulemaking.
(
As
explained
in
the
proposal
BID
and
supporting
documentation,
we
determined
that
MACT
for
new
and
existing
blenders
and
resin
storage/
mixing
tanks
is
no
emissions
reduction.)
Subparts
FFFF
and
HHHHH
exclude
activities
included
as
part
of
the
affected
source
for
other
source
categories.
Thus,
onsite
resin
preparation
activities
at
a
PCWP
manufacturing
facility
are
not
subject
to
Subparts
FFFF
or
HHHHH.

We
added
refiners
to
the
definition
of
affected
source
to
clarify
that
these
sources
are
part
of
the
affected
source
and
were
part
of
the
MACT
analysis
for
the
PCWP
source
category.
(
For
new
and
existing
pressurized
refiners,
we
determined
that
MACT
is
based
on
the
use
of
incineration­
based
control
or
a
biofilter,
and
for
new
and
existing
atmospheric
refiners,
we
determined
that
MACT
is
no
emissions
reduction.)

We
deleted
all
references
to
"
plant
site"
from
the
final
75
rule
and
replaced
references
to
"
plant
site"
with
the
term
"
facility"
to
eliminate
confusion
regarding
which
emission
sources
constitute
the
affected
source
and
which
emission
sources
would
be
considered
when
making
a
major
source
determination.
The
term
"
plant
site"
was
used
only
in
the
proposed
definitions
of
"
affected
source"
and
"
plywood
and
composite
wood
products
manufacturing
facility."
Inclusion
of
the
term
"
plant
site"
in
the
proposed
definition
of
affected
source
unintentionally
broadened
the
definition
such
that
emission
sources
not
related
to
PCWP
manufacturing
could
be
construed
as
being
part
of
the
affected
source.

For
example,
under
the
proposed
definitions
of
"
affected
source"
and
"
plant
site,"
if
a
company
operated
both
a
PCWP
manufacturing
facility
and
a
wood
building
products
surface
coating
facility
at
the
same
site,
both
operations
might
be
considered
to
be
part
of
the
PCWP
affected
source
because
the
"
plant
site"
would
encompass
both
operations,
even
though
these
two
operations
are
regulated
under
separate
NESHAP.
We
deleted
the
term
"
plant
site"
in
the
final
rule
to
clarify
that
the
requirements
in
the
final
rule
would
only
apply
to
the
affected
source,
which
is
the
PCWP
manufacturing
facility.
However,
we
note
that
any
major
source
determination
would
be
based
on
total
emissions
from
both
operations
since
the
two
operations
are
colocated
and
under
common
control.
(
See
definition
of
major
source
in
the
General
Provisions
[
40
CFR,
Part
63,
Subpart
A].)
76
We
did
not
incorporate
the
commenters'
suggestion
to
specifically
exclude
boilers
from
the
definition
of
"
affected
source"
because
it
is
possible
for
a
boiler
to
be
subject
to
both
the
PCWP
NESHAP
and
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP
(
e.
g.,
if
a
portion
of
the
boiler
exhaust
is
used
to
direct
fire
dryers
while
the
remaining
portion
of
the
boiler
exhaust
is
vented
to
the
atmosphere).
However,

in
most
cases,
combustion
units
would
only
be
subject
to
one
MACT.
The
overlap
between
the
PCWP
NESHAP
and
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP
is
also
discussed
in
section
IV.
B
of
this
preamble.

2.
Process
Definitions
Comment:
Commenters
recommended
that
a
number
of
definitions
included
in
the
proposed
rule
be
revised
to
better
distinguish
between
particleboard,
MDF
and
hardboard
and/
or
to
be
consistent
with
definitions
developed
by
the
American
National
Standards
Institute
(
ANSI).

Response:
We
made
changes
to
several
of
the
proposed
process­
related
definitions
including
the
definitions
of
particle,
fiber,
hardboard,
MDF,
and
particleboard.
These
minor
changes
incorporate
some
of
the
wording
in
similar
definitions
used
by
ANSI
but
do
not
affect
the
scope
or
applicability
of
the
rule.
We
also
added
a
definition
of
agricultural
fiber
recommended
by
commenters
because
the
77
term
"
agricultural
fiber"
appears
in
the
definition
of
plywood
and
composite
wood
products
facility.

Comment:
Several
commenters
requested
that
the
proposed
definition
of
tube
dryer
be
changed
so
that
stages
in
multistage
tube
dryers
would
be
considered
as
separate
tube
dryers.
With
this
change,
different
control
options
could
be
applied
to
different
dryer
stages.

Response:
Under
the
proposed
definition
of
tube
dryer,
a
multistage
tube
dryer
with
more
than
one
control
device
and
emissions
point
would
be
considered
one
process
unit.
In
developing
the
proposed
rule,
we
noted
that
the
function
of
tube
dryers
is
the
same
regardless
of
single­
or
multistage
configuration
and
that
distinguishing
between
dryer
configurations
would
not
change
the
results
of
the
MACT
floor
analysis,
despite
the
fact
that
the
majority
of
the
HAP
emissions
exhaust
from
the
primary
stage.
Therefore,
we
made
no
distinction
between
single­
stage
and
multistage
tube
dryers
at
proposal.
However,
we
agree
with
the
commenters
that
defining
the
stages
of
multistage
tube
dryers
separately
would
allow
facilities
the
flexibility
of
choosing
different
compliance
options
for
each
stage
of
the
tube
dryer,
and
we
have
included
separate
definitions
of
primary
tube
dryer
and
secondary
tube
dryer
in
the
final
rule.
The
MACT
floor
for
both
primary
tube
dryers
and
secondary
tube
dryers
is
the
same
(
e.
g.,
90
percent
reduction
in
emissions),
but
facilities
may
choose
different
78
control
options
for
the
primary
and
secondary
tube
dryers.

For
example,
a
facility
with
a
multistage
tube
dryer
could
use
an
add­
on
control
device
to
reduce
emissions
from
the
primary
tube
dryer
only
and
then
use
emissions
averaging
to
offset
the
uncontrolled
emissions
from
the
secondary
tube
dryer.

3.
Lumber
Kilns
Comment:
We
received
comments
from
representatives
of
sawmills
and
wood
treating
facilities
disagreeing
with
the
inclusion
of
lumber
kilns
in
the
PCWP
source
category.
The
commenters
stated
that
owners
and
operators
of
kilns
that
are
not
located
at
a
PCWP
facility
may
be
subject
to
other
requirements
of
the
rule
that
do
not
truly
apply
to
them,

including
costly
monitoring,
recordkeeping,
and
reporting.

One
commenter
was
concerned
that
the
owners
and
operators
of
non­
colocated
lumber
kilns
could
find
themselves
in
violation
of
the
May
15,
2002,
case­
by­
case
"
MACT
Hammer"

deadline
even
though
they
did
not
anticipate
being
included
in
the
rule,
and
thus
did
not
apply
for
the
case­
by­
case
consideration.

Response:
At
proposal,
we
broadened
the
PCWP
source
category
to
include
non­
colocated
lumber
kilns
(
i.
e.,
lumber
kilns
located
at
stand­
alone
kiln­
dried
lumber
manufacturing
facilities
or
at
any
other
type
of
facility).
In
the
preamble
to
the
proposed
rule,
we
noted
that
if
noncolocated
lumber
kilns
were
not
included
in
the
PCWP
NESHAP,
79
then
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
potentially
becoming
separately
subject
to
the
provisions
of
section
112(
g)
of
the
CAA
as
well.
We
felt
it
was
reasonable
to
include
non­
colocated
lumber
kilns
in
the
PCWP
source
category
because
the
design
and
operation
of
lumber
kilns
are
essentially
the
same
regardless
of
whether
the
kilns
are
located
at
a
sawmill
or
are
colocated
with
PCWP
or
other
types
of
manufacturing
operations.
At
proposal
we
noted
that
there
are
no
currently
applicable
controls
at
any
lumber
kilns
and
that
it
would
be
both
more
efficient
and
expeditious
to
include
all
lumber
kilns
in
the
MACT
analysis
for
the
PCWP
rule
than
to
separately
address
them
in
a
rulemaking
that
likely
would
not
result
in
meaningful
emissions
reductions
from
lumber
kilns.
In
addition,
we
noted
that
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).

In
an
attempt
to
better
understand
the
concerns
of
the
commenters,
we
met
with
wood
products
industry
representatives
who
requested
that
lumber
kilns
be
included
in
the
PCWP
source
category
and
with
the
commenters
who
disagreed
that
non­
colocated
lumber
kilns
should
be
included
in
the
PCWP
source
category.
After
consideration
of
concerns
expressed
by
all
of
the
commenters
on
this
issue,
80
we
maintain
that
it
is
more
efficient
for
EPA,
State
regulators,
and
lumber
kiln
operators
for
EPA
to
include
all
lumber
kilns
in
the
PCWP
NESHAP.
Because
the
MACT
floor
determination
for
lumber
kilns
is
no
emissions
reduction
(
as
explained
in
the
proposal
preamble),
there
will
not
be
a
significant
monitoring,
recordkeeping,
and
reporting
burden
for
facilities
with
only
non­
co­
located
lumber
kilns.
Only
those
facilities
that
are
major
sources
of
HAP
emissions
are
subject
to
the
PCWP
NESHAP.
Facilities
with
non­
colocated
lumber
kilns
that
are
classified
as
major
sources
of
HAP
must
submit
an
initial
notification
form
required
by
the
PCWP
NESHAP
and
the
Part
1
"
MACT
Hammer"
application
required
by
§
112(
j)
of
the
CAA.
We
note
that
both
of
these
forms
simply
ask
the
facilities
to
identify
themselves
to
EPA.
We
acknowledge
that
operators
of
non­
co­
located
lumber
kilns
were
not
aware
that
they
were
included
in
the
PCWP
source
category
until
the
proposed
PCWP
NESHAP
was
printed
in
the
Federal
Register
on
January
9,
2003,
and
therefore,

would
not
have
known
to
submit
a
Part
1
application
by
May
15,
2002.

4.
Regulated
HAP
Comment:
One
commenter
objected
to
the
fact
that
the
proposed
rule
only
set
standards
for
six
HAP.
The
commenter
asserted
that,
according
to
the
CAA
and
National
Lime
Ass'n
v.
EPA,
233
F.
3d
625,
633­
634
(
D.
C.
Cir.
2000),
we
are
required
to
set
standards
for
every
HAP
listed
in
112(
b)(
1)
81
emitted
by
PCWP
operations,
not
just
the
ones
that
are
the
easiest
to
measure.
Other
commenters
disagreed
and
noted
that
a
requirement
that
EPA
impose
an
emissions
standard
for
every
listed
HAP,
without
regard
to
whether
or
not
there
are
applicable
methods
for
reducing
HAP
emissions
or
whether
the
MACT
floor
sources
actually
use
such
method,
contradicts
the
plain
language
of
the
statute.
These
commenters
contended
that
the
statute
specifically
frames
the
inquiry
in
terms
of
degrees
of
reduction.

Response:
Today's
final
PCWP
rule
contains
numerical
emission
limits
in
terms
of
methanol,
formaldehyde,
THC,
or
"
total
HAP"
(
which
is
defined
in
this
final
rule
as
the
sum
of
six
HAP
including
acrolein,
acetaldehyde,
formaldehyde,

methanol,
phenol,
and
propionaldehyde).
The
nationwide
PCWP
emissions
of
"
total
HAP"
are
18,190
tons/
yr
which
is
96
percent
of
the
nationwide
emissions
of
all
HAP
(
19,000
tons/
yr)
emitted
by
PCWP
facilities.
The
six
HAP
that
comprise
"
total
HAP"
are
found
in
emissions
from
all
PCWP
product
sectors
that
contain
major
sources
and
in
emissions
from
most
process
units.
At
proposal,
when
we
stated
that
other
HAP
are
emitted
"
in
low
quantities
that
may
be
difficult
to
measure,"
we
were
referring
to
HAP
that
are
often
emitted
at
levels
below
test
method
detection
limits
(
68
FR
1276
at
1280,
January
9,
2003).
Our
data
clearly
show
that
these
other
HAP
are
difficult
or
impossible
to
measure
because
they
are
either
emitted
in
very
low
82
quantities
or
are
not
present.
Such
low
quantities
are
not
detectable
by
the
applicable
emission
testing
procedures
(
which
are
sensitive
enough
to
detect
HAP
at
concentrations
below
1
ppm).
Many
of
these
other
HAP
were
detected
in
less
than
15
percent
of
test
runs,
or
for
only
one
type
of
process
unit.

Based
on
our
emissions
data,
we
determined
that
methanol,
formaldehyde,
THC,
or
"
total
HAP"
are
appropriate
surrogates
for
measuring
all
organic
HAP
measurably­
emitted
by
the
PCWP
source
category.
The
PBCO
and
emissions
averaging
compliance
options
in
today's
final
PCWP
rule
are
based
on
"
total
HAP."
Review
of
the
emission
factors
used
to
develop
the
emissions
estimates
for
the
PCWP
source
category
indicates
that
uncontrolled
emissions
of
HAP
(
other
than
the
six
HAP)
are
always
lower
than
emissions
of
the
six
HAP
for
every
process
unit
with
MACT
control
requirements.

Thus,
process
units
meeting
the
PBCO
based
on
total
HAP
also
would
have
low
emissions
of
other
organic
HAP.
The
emissions
averaging
provisions
and
add­
on
control
device
compliance
options
involve
use
of
add­
on
APCD.
The
available
data
show
that
a
reduction
in
one
predominant
HAP
(
or
THC)
correlates
with
a
reduction
in
other
HAP
if
the
other
HAP
is
present
in
detectable
quantities
and
at
sufficient
concentration.
The
data
also
show
that
the
mechanisms
in
RTO,
RCO,
and
biofilters
that
reduce
emissions
of
formaldehyde
and
methanol
reduce
emissions
of
the
83
remaining
HAP.
In
addition,
an
analysis
of
the
physical
properties
of
the
organic
HAP
emitted
from
PCWP
processes
indicates
that
nearly
all
of
the
HAP
would
be
combusted
at
normal
thermal
oxidizer
operating
temperatures.
Today's
standards
are
based
on
the
use
of
add­
on
control
devices
because
the
available
emissions
data
do
not
reveal
any
process
variables
that
could
be
manipulated
(
without
altering
the
product)
to
achieve
a
quantifiable
reduction
in
emissions.
Furthermore,
nothing
in
the
data
suggests
that
process
variables
could
be
manipulated
in
a
way
that
would
alter
the
relationship
between
formaldehyde
and
methanol
reduction
and
reduction
of
other
HAP.
We
determined
that
it
is
appropriate
for
the
final
PCWP
rule
to
contain
compliance
options
in
terms
of
"
total
HAP,"
THC,
formaldehyde,
or
methanol
because
the
same
measures
used
to
reduce
emissions
of
these
pollutants
also
reduce
emissions
of
other
organic
HAP.

B.
Overlap
with
Other
Rules
1.
Overlap
with
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP
Comment:
Commenters
expressed
support
for
our
proposal
to
regulate
emissions
from
combustion
units
used
to
direct
fire
dryers
and
to
exclude
these
emissions
from
the
requirements
of
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP.
However,
the
commenters
expressed
concern
about
potential
NESHAP
applicability
84
questions
that
could
arise
during
short
periods
when
the
exhaust
gases
from
these
combustion
units
are
not
exhausting
through
the
dryers
and
would
bypass
any
controls
applied
to
these
dryers.
The
commenters
noted
that
in
some
of
the
combustion
units
associated
with
direct­
fired
dryers,
a
small
percentage
of
combustion
gas
is
routed
to
indirect
heat
exchange
and
then
is
normally
and
predominantly
routed
to
direct­
fired
gas
flow.
According
to
the
commenters,
in
these
"
hybrid
units,"
typically
only
a
small
fraction
of
combustion
gas
(
e.
g.,
less
than
10
percent
of
total
capacity)
is
routed
to
indirect
heat
exchange
for
hot
oil/
steam
generation.
This
fraction
of
the
combustion
unit
exhaust
then
generally
exhausts
through
the
direct­
fired
dryers
and
the
emissions
are
treated
by
the
add­
on
control
device
at
the
dryers'
outlet.
However,
under
certain
circumstances
(
e.
g.,
during
startups,
shutdowns,

emergencies,
or
periods
when
dryers
are
down
for
maintenance
but
steam/
thermal
oil
is
still
needed
for
plant
and/
or
press
heat),
some
systems
may
exhaust
directly
to
the
atmosphere
without
passing
through
the
direct­
fired
dryers
and
the
associated
control
systems.
The
commenters
recommended
that
this
small
subset
of
combustion
units
be
assigned
a
"
primary
purpose"
(
based
on
the
predominant
allocation
of
British
thermal
units
per
hour
(
Btu/
hr)
capacity
and/
or
predominant
mode
of
operation)
and
regulated
accordingly.
In
the
above
example,
the
commenters
assumed
that
the
primary
purpose
is
85
as
a
direct­
fired
dryer,
such
that
the
equipment
would
be
subject
to
the
PCWP
MACT
and
not
to
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP.

Response:
In
considering
the
commenters'
request,
we
reviewed
available
information
on
direct­
fired
dryers
and
the
associated
combustion
units
at
PCWP
facilities.
The
available
information
indicates
that
there
are
many
configurations
of
combustion
units,
dryers,
and
thermal
oil
heaters
in
the
PCWP
industry.
While
some
systems
have
the
"
hybrid"
configurations
described
by
the
commenters
whereby
a
portion
of
the
combustion
gas
is
routed
to
indirect
heat
exchange,
other
systems
retain
all
of
the
combustion
gas
within
the
direct­
fired
system.
We
do
not
have
sufficient
information
(
and
no
such
information
was
provided
by
the
commenters)
to
fully
evaluate
the
need
for
a
"
primary
purpose"
designation
for
PCWP
combustion
units,
to
establish
the
percentage­
of­
operating­
time
or
Btu
limits
for
such
a
"
primary
purpose"
designation,
or
to
determine
MACT
for
combustion
units
that
would
meet
the
"
primary
purpose"

designation.
For
example,
we
do
not
know
how
many
combustion
units
are
configured
to
incorporate
both
indirect
and
direct
heat
exchange,
and
for
these
units
we
do
not
know
the
amount
of
time
or
the
percentage
of
Btu
allocation
that
is
devoted
to
indirect
heat
exchange
or
the
controls
used
to
reduce
emissions
during
indirect
heat
exchange.
We
expect
86
that
all
of
these
factors
vary
substantially
from
facility
to
facility
for
those
facilities
that
have
these
"
hybrid"

combustion
units.
We
also
lack
information
on
the
emissions
reduction
techniques
(
e.
g.,
control
devices)
applied
to
combustion
units
associated
with
direct­
fired
PCWP
dryers
that
may
bypass
the
dryers
for
some
unknown
percentage
of
time.
Therefore,
we
believe
it
would
be
inappropriate
for
us
to
establish
a
"
primary
purpose"
designation
which
could
inadvertently
allow
facilities
to
configure
their
systems
to
direct
a
portion
of
their
uncontrolled
emissions
to
the
atmosphere
without
these
emissions'
being
subject
to
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP.
Also,
we
wish
to
clarify
that
the
PCWP
rule
regulates
only
that
portion
of
emissions
from
a
combustion
unit
that
are
routed
through
the
direct­
fired
dryers.
Any
emissions
from
a
combustion
unit
that
are
not
routed
through
the
direct­
fired
dryers
would
be
subject
to
the
Industrial/
Commercial/
Institutional
Boilers
and
Process
Heaters
NESHAP.
Therefore,
if
the
emissions
from
a
combustion
unit
are
split
such
that
only
a
portion
of
the
emissions
are
routed
through
a
direct­
fired
dryer,
then
the
combustion
unit
would
be
subject
to
both
rules.

For
those
occasions
when
a
facility
must
shut
down
its
direct­
fired
dryers
but
still
wants
to
operate
the
combustion
unit
to
heat
oil
for
the
press,
the
facility
could
propose
in
its
startup,
shutdown,
and
malfunction
87
(
SSM)
plan
to
route
exhaust
through
the
thermal
oil
heater
(
and
then
to
the
atmosphere)
during
these
periods.
The
permitting
authority
would
then
decide
on
a
facilityspecific
basis
if
heating
of
the
thermal
oil
heater
(
and
the
associated
uncontrolled
emissions)
should
be
allowed
during
dryer
SSM
considering
the
amount
of
time
that
this
condition
occurs,
the
fraction
of
combustion
unit
Btu
used
to
heat
the
thermal
oil
heater,
and
the
type
of
control
used
to
reduce
combustion
unit
emissions.

2.
Overlap
with
Wood
Building
Products
(
WBP)
NESHAP
Comment:
Commenters
on
the
proposed
Wood
Building
Products
(
Surface
Coating)
rule
(
Subpart
QQQQ)
asserted
that
neither
asphalt­
coated
fiberboard
nor
ceiling
tiles
are
coated
with
HAP­
containing
materials
and
that
regulating
such
products
would
be
burdensome.
These
commenters
requested
that
we
include
asphalt
coating
of
fiberboard
and
ceiling
tiles
in
today's
final
PCWP
rule
by
including
these
coating
operations
under
the
definition
of
miscellaneous
coating
operations
(
for
which
the
proposed
MACT
was
no
emissions
reduction),
so
that
these
operations
would
be
subject
to
the
PCWP
rule
and
not
the
WBP
rule.

Response:
In
the
proposed
rule,
we
addressed
overlap
between
the
Wood
Building
Products
(
Surface
Coating)
rule
(
WBP,
Subpart
QQQQ)
and
the
PCWP
NESHAP
by
including
specific
surface
coating
activities
(
which
occur
onsite
at
a
PCWP
manufacturing
facility)
in
the
definition
of
88
"
miscellaneous
coating
operations."
Inclusion
of
these
activities
in
the
definition
of
miscellaneous
coating
operations
means
that
these
activities
are
subject
to
the
PCWP
rule
and
not
to
the
WBP
rule.
We
made
changes
to
the
definition
of
miscellaneous
coating
operations
in
today's
final
rule
in
response
to
the
public
comments
we
received
on
the
proposed
WBP
rule
relating
to
asphalt­
coated
fiberboard
and
ceiling
tiles.

We
evaluated
the
types
of
coatings
and
processes
used
to
make
asphalt­
coated
fiberboard
and
found
that
only
a
few
facilities
in
the
United
States
make
these
products,
with
varying
manufacturing
and
coating
processes.
An
asphalt
emulsion
can
be
added
during
the
fiberboard
forming
process,

or
asphalt
can
be
applied
to
the
fiberboard
substrate.

Information
we
collected
on
asphalt
coatings
suggests
that
they
contain
no
HAP.
Depending
on
the
company
and
the
process,
the
coating
can
be
applied
before
or
after
the
final
dryer
with
the
product
allowed
to
air
dry.
Ceiling
tiles
are
usually
coated
using
non­
HAP
slurries
of
titanium
dioxide
and
various
clays,
and
no
organic
solvents
are
used.

Most
of
the
coatings
associated
with
these
types
of
products
are
applied
during
the
substrate
forming
process
(
i.
e.,
to
the
wet
mat
being
formed)
or
prior
to
the
final
substrate
drying
operation,
fiberboard
coating
operations
(
including
those
used
in
the
manufacture
of
asphalt­
coated
fiberboard
and
ceiling
tiles).
Because
no
HAP
are
contained
in
the
89
above­
mentioned
coatings,
the
coatings
are
applied
as
part
of
the
manufacturing
process,
and
MACT
for
these
coating
processes
is
no
emissions
reduction,
we
changed
the
definition
of
miscellaneous
coating
operations
to
include
"
application
of
asphalt,
clay
slurry,
or
titanium
dioxide
coatings
to
fiberboard
at
the
same
site
of
fiberboard
manufacture."
These
products
are
not
subject
to
the
final
WBP
surface
coating
rule.

C.
Amendments
to
the
Effluent
Guidelines
for
Timber
Products
Processing
Comment:
Several
commenters
requested
that
we
address
potential
conflicts
between
the
PCWP
rule
and
the
effluent
guidelines
for
the
Timber
Products
Processing
Point
Source
Category.
These
commenters
noted
that
the
effluent
guidelines
state
that
"
there
shall
be
no
discharge
of
process
wastewater
pollutants
into
navigable
waters."

However,
according
to
the
commenters,
at
the
time
that
statement
was
written,
air
pollution
controls
were
not
common,
and
EPA
was
not
aware
of
the
large
volumes
of
water
that
can
be
produced
by
APCD.
The
commenters
recommended
that
we
address
this
issue
by
revising
the
effluent
guidelines
at
40
CFR
Part
429.
Specifically,
these
commenters
asked
us
to
amend
the
definition
of
process
wastewaters
at
§
429.11(
c)
so
that
the
discharge
prohibition
in
Part
429
would
not
apply
to
wastewaters
associated
with
APCD
operation
and
maintenance
when
installed
to
comply
with
90
the
PCWP
MACT
rule.
These
commenters
asserted
that
effluent
limitations
for
these
wastewaters
should
be
developed
by
permit
writers
on
a
case­
by­
case
basis
based
upon
best
professional
judgment.
These
commenters
noted
that
the
language
we
included
in
the
preamble
to
the
proposed
rule
would
generally
accomplish
this
purpose
with
some
minor
changes
(
see
68
FR
1276
at
1305).
The
commenters
also
provided
rationale
and
data
to
support
their
recommendation.

The
commenters
contended
that
we
(
1)
underestimated
the
volume
of
wastewater
that
would
be
generated
by
the
application
of
MACT
and
as
a
result,
underestimated
the
associated
costs
of
disposing
of
this
wastewater,
(
2)
failed
to
address
the
achievability/
feasibility
of
MACT
if
the
discharge
of
air
pollution
control
wastewaters
is
prohibited,
and
(
3)
did
not
consider
wastewater
from
air
pollution
control
devices
when
the
Timber
Products
"
zero
discharge"
effluent
guidelines
were
originally
developed.

The
commenters
submitted
several
case
studies
to
demonstrate
the
variability
in
the
volume
of
wastewater
generated
at
various
PCWP
facilities
and
to
show
how
each
facility
currently
recycles,
reuses,
and
disposes
of
wastewater
generated
from
the
operation
and
maintenance
of
RTO,
WESP
and
biofilters.
The
commenters
also
argued
that
the
available
data
do
not
support
a
conclusion
that
wastewaters
generated
from
MACT
control
devices
can,
with
Best
Available
Technology
(
BAT),
be
managed
in
a
way
that
does
not
involve
91
a
discharge.

Response:
At
the
time
we
proposed
the
PCWP
rule,
we
indicated
that
we
would
consider
amending
the
definition
of
process
wastewater
in
Part
429
to
exclude
those
wastewaters
generated
by
APCD
operation
and
maintenance
when
installed
to
comply
with
the
PCWP
NESHAP.
We
indicated
in
the
preamble
to
the
proposal
that
we
would
amend
the
definition
of
process
wastewaters
if
information
and
data
were
submitted
to
support
the
industry's
assertions
that
PCWP
facilities
in
certain
subcategories
would
not
be
able
consistently
to
achieve
the
effluent
limitations
guidelines
and
standards
applicable
to
them
if
they
were
to
comply
with
the
proposed
PCWP
NESHAP.
As
part
of
the
PCWP
proposal,
we
described
with
specificity
how
we
would
revise
Part
429
if
we
were
convinced
that
such
revisions
were
appropriate
and
solicited
data
and
information.

Based
on
the
data
and
information
submitted
by
the
commenters,
we
have
concluded
that
facilities
subject
to
40
CFR
Part
429,
Subpart
B
(
Veneer
subcategory),
Subpart
C
(
Plywood
subcategory),
Subpart
D
(
Dry
Process
Hardboard
subcategory),
and
Subpart
M
(
Particleboard
Manufacturing
subcategory)
are
unable
to
comply
consistently
with
the
existing
Part
429
effluent
limitations
guidelines
and
standards,
which
prohibit
the
discharge
of
process
wastewater
pollutants,
because
of
the
volume
of
wastewaters
generated
by
APCD
that
are
installed
to
comply
with
the
PCWP
92
NESHAP
and
because
the
technology
basis
for
those
effluent
limitations
guidelines
and
standards
is
insufficient,
in
light
of
that
wastewater
volume
and
the
pollutant
content,

to
achieve
the
prohibition
on
process
wastewater
discharges
for
these
NESHAP­
related
APCD
wastewaters.
Therefore,
we
are
excluding
from
the
definition
of
process
wastewaters
in
40
C.
F.
R.
§
429.11(
c)
the
following
wastewaters
associated
with
APCD
used
by
PCWP
facilities
covered
by
Subparts
B,
C,

D,
and
M
to
comply
with
40
CFR
§
63.22:
wastewater
from
washout
of
regenerative
thermal
oxidizers
and
regenerative
catalytic
oxidizers,
wastewater
from
biofilters,
and
wastewater
from
wet
electrostatic
precipitators
used
upstream
of
thermal
oxidizers
or
catalytic
oxidizers.

In
addition,
we
agree
with
comments
that
we
will
need
considerably
more
data
and
information
to
promulgate
new
effluent
limitations
guidelines
and
standards
for
the
process
wastewaters
at
issue
today.
In
particular,
we
will
need
information
to
adequately
characterize
the
quantity
and
quality
of
wastewater
that
would
be
generated
as
result
of
compliance
with
the
MACT
standards.
The
volume
and
pollutant
content
of
wastewater
generated
at
these
facilities
are
related
to
production
processes,
air
pollution
control
equipment
that
generate
wastewater,
the
extent
of
opportunities
for
internal
recycling
of
wastewater,
and
the
availability
of
other
process
uses
for
wastewater.
Until
we
promulgate
effluent
limitations
93
guidelines
and
standards
for
pollutants
in
these
process
wastewaters,
BPT
and
BAT
effluent
limitations
should
be
established
on
a
case­
by­
case
basis
under
40
C.
F.
R.
§
125.3.

Thus,
individual
facilities
seeking
a
discharge
permit
will
have
the
opportunity,
on
a
case­
by­
case
basis,
to
characterize
and
obtain
discharge
allowances
for
their
wastewaters
from
APCD
installed
to
comply
with
the
PCWP
NESHAP.
The
permit
writer
would
be
expected
to
determine,

based
upon
best
professional
judgment
(
BPJ),
the
appropriate
effluent
limitations
for
these
APCD
wastewaters.
See
40
CFR
§
125.3.
The
permit
writer
can
take
into
account
facilityspecific
information
on
wastewater
volumes
and
pollutants,

available
wastewater
control
and
treatment
technologies,

costs
and
effluent
reduction
benefits,
receiving
water
quality,
and
any
applicable
State
water
quality
standards.

At
a
later
date,
we
expect
to
consider
whether
to
amend
the
existing
effluent
limitations
guidelines
and
standards
for
the
Timber
Processing
Industry
to
cover
these
process
wastewaters.
Such
an
effort
would
involve
gathering
and
analyzing
the
information
and
data
necessary
to
establish
revised
categorical
effluent
limitations
affecting
Subparts
B,
C,
D,
and
M
for
these
APCD
wastewaters
generated
in
complying
with
the
PCWP
NESHAP.

Today's
amendment
to
the
final
rule
is
based
on
regulatory
language
included
in
the
preamble
accompanying
the
proposed
NESHAP
for
PCWP
facilities
(
68
FR
1276
at
1305,
94
January
9,
2003).
The
preamble
described
the
relationship
of
the
proposed
MACT
rule
to
the
amendment
to
Part
429
under
consideration.
The
preamble
explained
that
the
entities
affected
by
the
proposed
MACT
rule
would
also
be
affected
by
the
proposed
amendment
to
Part
429;
presented
both
the
terms
and
substance
of
the
amendment
under
consideration;
and
described
the
subjects
and
issues
involved.
In
addition,
we
solicited
comments
on
whether
to
amend
40
C.
F.
R.
§
429.11(
c)

and
information
relevant
to
that
decision.
While
at
that
time
we
indicated
that
we
were
considering
employing
a
direct
final
rule
to
promulgate
any
such
amendment,
we
have
concluded
with
support
from
commenters
that
that
procedure
was
unnecessary
and
instead
are
taking
final
action
on
this
amendment
today
without
further
process.

D.
Existing
Source
MACT
1.
OSB
Strand
Dryers
Comment:
One
commenter
requested
that
further
consideration
be
given
to
the
emission
standards
for
lowtemperature
OSB
conveyor
strand
dryers.
The
commenter
stated
that
because
these
conveyor
strand
dryers
emit
less
HAP
than
rotary
strand
dryers
and
have
been
recognized
as
best
available
control
technology
(
BACT)
in
Minnesota,
they
should
be
exempted
from
control
requirements
in
the
final
PCWP
rule.
The
commenter
noted
that
the
12
conveyor
strand
dryers
used
by
their
company
have
three
drying
zones,
each
with
its
own
heating
system
and
exhaust
vent(
s).
When
95
drying
hardwoods,
no
VOC
control
is
required;
however,
when
drying
pine
the
company
controls
emissions
from
zones
1
and
2.
Zone
3
serves
as
a
final
conditioning
zone
and
is
exhausted
to
the
atmosphere
without
need
for
VOC
control.

The
proposed
PCWP
rule
would
have
required
the
sum
of
the
emissions
from
all
three
zones
to
be
reduced
to
MACT
levels
(
e.
g.,
90
percent
reduction).

Response:
The
MACT
analysis
we
conducted
at
proposal
treated
conveyor
strand
dryers
as
a
separate
equipment
group
from
rotary
strand
dryers.
We
noted
that
rotary
strand
dryers
operate
at
much
higher
inlet
temperatures
(
e.
g.,

often

900oF)
than
conveyor
strand
dryers
(
e.
g.,
typically
<
400oF)
and
that
rotary
dryers
provide
greater
agitation
of
the
wood
strands
than
conveyor
strand
dryers.
As
a
result,

the
emissions
from
conveyor
strand
dryers
are
lower
than
the
emissions
from
rotary
strand
dryers.
The
emissions
test
data
we
have
for
conveyor
strand
dryers
(
only
formaldehyde
and
THC
data
are
available)
indicate
that
formaldehyde
emissions
from
conveyor
strand
dryers
are
1
to
2
orders
of
magnitude
lower
than
for
rotary
strand
dryers.
The
THC
emissions
are
also
lower
for
conveyor
strand
dryers
than
for
rotary
dryers.
Our
MACT
analysis
for
conveyor
strand
dryers
at
proposal
concluded
that
three
of
the
eight
conveyor
strand
dryers
used
in
the
U.
S.
operated
with
process
incineration.
Because
there
are
less
than
30
conveyor
strand
dryers,
the
MACT
floor
was
based
on
the
control
level
96
achieved
by
the
third
best­
controlled
dryer.
Thus,
at
proposal,
we
determined
that
the
MACT
floor
control
system
for
new
and
existing
conveyor
strand
dryers
was
the
emissions
reduction
achievable
with
incineration­
based
control.
We
included
one
definition
of
"
strand
dryers"
in
the
proposed
PCWP
rule
since
MACT
for
both
rotary
and
conveyor
strand
dryers
was
represented
by
incineration­
based
control.

As
pointed
out
by
the
commenter,
conveyor
strand
dryers
have
distinct
zones,
with
each
zone
having
its
own
heating
system
and
exhaust.
We
reviewed
our
MACT
survey
data
and
learned
that
all
of
the
conveyor
strand
dryers
in
the
U.
S.

have
three
zones.
Upon
further
scrutiny
of
the
MACT
analysis
at
proposal,
we
learned
that
the
three
conveyor
strand
dryers
that
formed
the
basis
for
the
MACT
floor
at
proposal
were
routing
the
emissions
from
zone
1
only
to
an
onsite
combustion
unit
for
incineration.
The
remaining
five
conveyor
strand
dryers
have
no
HAP
control.
Thus,
our
conclusions
regarding
the
MACT
floor
for
conveyor
strand
dryers
at
proposal
were
overstated.
The
third
bestcontrolled
conveyor
strand
dryer
has
incineration­
based
control
only
on
zone
1
as
opposed
to
controls
on
all
zones.

Therefore,
we
revised
our
analysis
to
reflect
that
the
MACT
floor
for
existing
conveyor
strand
dryers
is
the
emissions
reduction
achievable
with
incineration­
based
control
on
zone
1.
To
implement
this
change,
we
added
definitions
for
97
"
conveyor
strand
dryer"
and
"
conveyor
strand
dryer
zone"
to
the
final
rule.

The
commenter
mentioned
operating
12
conveyor
strand
dryers.
Six
of
these
conveyor
strand
dryers
are
located
at
new
plants
that
were
not
included
in
our
pre­
proposal
MACT
floor
analysis.
These
six
conveyor
strand
dryers
route
emissions
from
zones
1
and
2
to
a
closed­
loop
incineration
system
for
emissions
control.
Given
that
newer
facilities
are
incinerating
conveyor
strand
dryer
exhaust
from
zones
1
and
2,
we
determined
that
the
MACT
floor
for
conveyor
strand
dryers
at
new
sources
is
the
emissions
reduction
achievable
with
incineration­
based
control
for
exhausts
from
zones
1
and
2.

As
described
in
the
promulgation
BID
and
supporting
documentation,
we
determined
that
the
environmental
benefit
of
controlling
additional
conveyor
dryer
zones
would
not
justify
the
cost
for
existing
or
new
conveyor
strand
dryers.

2.
Wood
Products
Press
Enclosures
Comment:
Many
commenters
argued
that
Method
204
compliance
should
not
be
a
part
of
the
PCWP
MACT
floor
for
presses
because
most
of
the
press
enclosures
that
were
described
in
the
industry
survey
data
as
having
permanent
total
enclosures
(
PTE)
were
never
certified
by
Method
204
criteria.
The
commenters
noted
that
most
of
these
enclosures
were
designed
according
to
Method
204
design
criteria;
however,
the
permits
for
these
facilities
never
98
required
them
to
comply
fully
with
Method
204
certification.

The
commenters
contended
that,
of
the
26
presses
identified
as
having
PTE,
only
2
had
actually
undergone
Method
204
certification.

The
commenters
also
argued
that
Method
204
cannot
be
applied
practically
to
the
hot
presses
that
are
used
at
PCWP
facilities.
The
commenters
stated
that
Method
204
was
developed
for
applications
where
the
emissions
have
consistent
properties;
however,
the
temperature
and
density
of
emissions
from
a
typical
multiple­
opening
batch
wood
products
press
are
constantly
changing
as
the
press
opens
and
closes,
which
creates
layers
of
gases
with
different
physical
properties
within
the
enclosure.
According
to
the
commenters,
instead
of
mixing
and
exiting
the
enclosure,
the
layers
of
gases
can
accumulate.
The
layers
of
gas
in
the
upper
region
of
the
enclosure
have
a
higher
temperature
and
pressure
than
the
air
outside
the
press,
and
the
lower
layers
of
gas
have
a
lower
temperature
and
pressure
than
the
air
outside
the
press.
The
commenters
maintained
that
to
force
the
gases
outside
the
enclosure,
the
operator
would
have
to
increase
the
airflow
through
the
system
to
a
rate
that
is
three
to
four
times
higher
than
would
be
necessary
for
an
enclosure
operating
at
a
homogenous
temperature
and
pressure.
The
commenters
contended
that,
while
many
of
the
wood
products
presses
were
designed
to
follow
the
Method
204
design
criteria,
they
were
not
designed
to
overcome
this
99
phenomenon
and
may
not
be
able
to
certify
that
all
of
the
emissions
are
captured
and
contained.

The
commenters
recommended
that
we
address
the
press
capture
efficiency
issue
by
implementing
work
practice
requirements
for
enclosures.
The
commenters
suggested
that
we
replace
the
proposed
definition
of
PTE
with
a
definition
that
includes
four
of
the
five
design
criteria
found
in
EPA
Method
204,
and
replaces
the
requirement
that
"
all
VOC
emissions
must
be
captured
and
contained
for
discharge
through
a
control
device"
with
a
requirement
that
"
fugitive
emissions
shall
be
minimized
through
appropriate
operation
and
maintenance
procedures
applied
to
the
PTE
system."

Response:
At
proposal,
we
stated
that
the
MACT
floor
determination
for
reconstituted
wood
products
presses
was
based,
in
part,
on
the
assumption
that
a
sufficient
number
of
these
presses
had
enclosures
that
had
been
certified
as
PTE
according
to
EPA
Method
204.
Presses
equipped
with
Method
204
certified
PTE
would
be
allowed
to
claim
100
percent
capture
efficiency,
and
thus,
the
rule
requirements
(
e.
g.,
90
percent
emissions
reduction)
would
effectively
apply
only
to
the
captured
emissions.

Based
on
our
review
of
available
permit
information,
we
agree
with
the
commenters'
assessment
that
few
permits
have
required
full
Method
204
certification
for
reconstituted
wood
products
press
enclosures,
even
though
many
of
these
press
enclosures
were
constructed
based
on
the
Method
204
100
design
criteria.
We
also
agree
that
the
nature
of
the
batch
pressing
operations
in
the
PCWP
industry
can
make
Method
204
certification
difficult.
Unlike
in
the
printing
and
publishing
industry,
for
which
Method
204
was
originally
developed,
batch
PCWP
presses
are
heated,
cyclical
operations.
Because
of
the
internal
pressurization
within
PCWP
press
enclosures,
small
amounts
of
fugitive
emissions
may
appear
around
the
outside
of
these
enclosures.
The
percentage
of
press
emissions
that
may
be
escaping
from
some
of
these
enclosures
has
not
been
quantified
but
is
expected
to
be
small
based
on
available
information.
We
understand
the
commenters'
concern
that,
due
to
the
presence
of
these
small
amounts
of
fugitive
emissions,
facilities
cannot
certify
that
their
Method
204
designed
press
enclosure
can
achieve
all
the
Method
204
criteria,
in
particular
the
criteria
in
Method
204
section
6.2
which
states
that
"
All
VOC
emissions
must
be
captured
and
contained
for
discharge
through
a
control
device."
While
we
believe
that
PCWP
press
enclosures
should
be
designed
to
capture
emissions
under
normal
operating
conditions,
we
do
not
believe
it
is
necessary
for
PCWP
facilities
to
increase
the
flow
rate
from
their
press
enclosures
(
and
the
size
of
their
APCD)
three
to
four
times
to
overcome
the
pressurization
within
the
press
enclosure.
For
the
PCWP
industry,
we
believe
it
would
be
particularly
inappropriate
to
require
such
a
large
increase
in
exhaust
flow
to
the
APCD
because
the
exhaust
flows
from
101
PCWP
process
equipment,
including
presses,
are
already
high
volume,
low
concentration
emission
streams.
High
volume,

low
concentration
exhaust
streams
generally
are
more
costly
to
treat
than
low
volume,
high
concentration
emission
streams.
The
best­
performing
press
enclosures
that
defined
the
MACT
floor
surround
heated
presses
and
are
all
believed
to
have
pressurization
within
the
press
enclosure.
In
addition,
we
note
that
board
cooler
exhaust
is
sometimes
directed
into
press
enclosures
and
that
enclosures
around
board
coolers
have
not
been
certified
according
to
EPA
Method
204.

Therefore,
instead
of
requiring
EPA
Method
204
certification
of
PCWP
press
and
board
cooler
enclosures
as
proposed,
today's
final
rule
sets
forth
slightly
different
criteria
for
press
and
board
cooler
enclosures.
These
criteria
are
based
on
the
design
criteria
for
PTE
included
in
EPA
Method
204,
as
recommended
by
the
commenters;

however,
the
criterion
to
capture
and
contain
all
VOC
emissions
has
been
replaced
with
a
requirement
that
the
enclosure
be
"
designed
and
maintained
to
capture
all
emissions
for
discharge
through
a
control
device."
To
effect
this
change,
we
deleted
references
to
PTE
in
the
final
rule
and
replaced
the
proposed
definition
of
PTE
with
a
new
definition
of
"
wood
products
enclosure"
that
lists
the
design
criteria
that
must
be
met
to
comply
with
MACT.

Enclosures
that
meet
the
definition
of
wood
products
102
enclosure
do
not
have
to
test
to
determine
the
capture
efficiency
of
these
enclosures,
but
can
assume
100
percent
capture,
such
that
the
control
requirements
(
e.
g.,
90
percent
reduction)
apply
only
to
the
captured
emissions
(
i.
e.,
the
small
amount
of
fugitive
emissions
outside
the
enclosure
is
disregarded).

We
also
replaced
the
proposed
definition
of
"
partial
enclosure"
with
a
slightly
revised
definition
of
"
partial
wood
products
enclosure"
to
eliminate
any
references
to
PTE
in
the
final
rule.
Because
the
capture
efficiency
of
"
partial
wood
products
enclosures"
is
unknown,
today's
final
rule
requires
facilities
to
test
the
capture
efficiency
of
partial
wood
products
enclosures
using
EPA
Methods
204
and
204A­
F
(
as
appropriate),
or
using
the
alternative
tracer
gas
procedure
included
in
Appendix
A
to
Subpart
DDDD.
In
addition,
facilities
have
the
option
of
using
other
methods
for
determining
capture
efficiency
subject
to
the
approval
of
the
Administrator.
As
was
proposed
and
suggested
by
the
commenters,
today's
final
rule
requires
facilities
using
partial
wood
products
enclosures
to
demonstrate
a
combined
90
percent
capture
and
control
efficiency
for
those
facilities
showing
compliance
with
the
percent
reduction
requirements
for
APCD.
If
the
partial
wood
products
enclosure
does
not
achieve
high
capture
efficiency,
then
facilities
must
offset
the
needed
capture
efficiency
by
achieving
a
higher
destruction
efficiency
or
with
emissions
103
averaging
(
with
the
press
being
an
under­
controlled
process
unit).

Comment:
One
commenter
objected
to
the
proposed
MACT
floor
for
continuous
presses
and
questioned
the
applicability
of
EPA
Method
204
to
continuous
presses.
The
commenter
requested
that
we
divide
continuous
and
batch
presses
into
two
different
process
unit
groups
for
the
purpose
of
determining
the
MACT
floor.
The
commenter
provided
information
from
environmental
engineering
firms
and
press
manufacturers
regarding
the
fundamental
differences
between
the
two
types
of
presses.
The
commenter
noted
that
continuous
presses
are
much
longer
than
batch
presses,
reaching
lengths
of
200
feet,
which
makes
them
difficult
to
completely
enclose.
The
commenter
was
unaware
of
any
continuous
presses
that
have
Method
204
certified
PTE.
The
commenter
stated
that
enclosing
a
continuous
press
would
cause
operational
problems,
such
as
heat
build­
up
and
impaired
visibility,
which
can
lead
to
mechanical
failures
and
unscheduled
downtime.
The
commenter
also
cited
potential
safety
concerns,
such
as
increased
fire
risk
and
the
possibility
of
unhealthy
levels
of
HAP
trapped
inside
the
enclosure.
The
commenter
further
noted
that
the
capital
and
operating
costs
of
PTE
applied
to
continuous
presses
would
exceed
those
associated
with
batch
presses
due
to
the
large
size
of
the
enclosure
and
the
increased
maintenance
costs
resulting
from
heat
build­
up
within
the
enclosure.
In
104
addition,
the
commenter
provided
VOC
emissions
data
based
on
measurements
made
at
different
points
along
the
length
of
one
of
their
continuous
presses
to
demonstrate
that
emissions
from
the
front
stages
are
minimal
and
that
the
majority
of
emissions
are
from
the
last
40
percent
of
the
press
length,
referred
to
as
the
"
decompression
zone."
The
commenter
contended
that
gathering
the
emissions
from
all
stages
of
the
continuous
press
will
result
in
a
more
dilute
stream,
which
will
be
less
cost­
effective
to
treat,
and
that
the
large
volume
of
exhaust
to
be
treated
would
likely
preclude
the
use
of
biofilters,
which
are
more
practical
for
treating
smaller
volumes
of
air.

To
remedy
the
situation,
the
commenter
recommended
that
we
divide
batch
and
continuous
presses
into
two
different
process
unit
groups
for
the
purpose
of
determining
the
MACT
floor.
Because
there
are
fewer
than
30
continuous
presses,

the
MACT
floor
for
existing
continuous
presses
would
be
determined
based
on
the
average
emissions
limitation
achieved
by
the
five
best­
performing
continuous
presses.

The
commenter
provided
information
to
support
the
commenter's
contention
that
none
of
the
continuous
presses
achieved
100
percent
capture
and
suggested
that
the
MACT
floor
for
capture
efficiency
is
80
percent
capture
of
emissions
from
the
decompression
stages.

Response:
As
explained
in
the
proposal
preamble,
we
based
the
MACT
floor
determinations
for
PCWP
equipment
on
105
process
units
that
are
similar
with
respect
to
design,

operation,
and
emissions.
We
acknowledge
that
continuous
presses
have
a
different
design
than
multiopening
batch
presses.
However,
continuous
presses
have
emissions
that
are
within
the
same
range
as
those
from
batch
presses
on
a
pound
per
thousand
square
feet
(
MSF)
of
board
basis.

Therefore,
we
believe
it
is
reasonable
to
group
batch
and
continuous
presses
together
for
purposes
of
determining
the
MACT
floor.
The
MACT
floor
for
continuous
presses
would
be
the
same
as
the
MACT
floor
for
batch
presses
regardless
of
whether
batch
and
continuous
presses
were
placed
in
separate
equipment
groups.
As
explained
below,
we
disagree
that
the
MACT
floor
capture
efficiency
for
continuous
presses
is
80
percent,
as
suggested
by
the
commenter.

The
commenter
was
incorrect
in
suggesting
that
there
are
no
continuous
presses
with
Method
204
certified
PTE.
The
two
existing
press
enclosures
in
the
PCWP
industry
identified
as
being
Method
204
certified
surround
continuous
presses.
The
lengths
of
these
two
continuous
presses
are
41.5
feet
and
110
feet.
Due
to
the
presence
of
these
presses
plus
additional
continuous
presses
equipped
with
total
enclosures
not
certified
via
Method
204,
the
MACT
floor
for
new
and
existing
continuous
presses
is
still
a
total
enclosure
and
incineration­
based
control
or
biofilter,

regardless
of
whether
or
not
batch
and
continuous
presses
are
treated
as
separate
equipment
groups.
In
addition,
106
there
is
a
Method
204
certified
PTE
around
a
181­
foot
continuous
press
at
a
newer
PCWP
facility
(
which
was
not
included
in
original
data
collection
efforts
and
the
preproposal
MACT
floor
determination);
however,
this
press
has
had
some
operational
problems
associated
with
its
PTE.
It
is
not
clear
if
the
operational
problems
experienced
by
this
181­
ft­
long
press
are
the
result
of
poor
PTE
design
or
inherent
technical
difficulties
associated
with
enclosing
long
continuous
PCWP
presses.

Long
continuous
presses
are
generally
being
installed
at
new
PCWP
facilities,
as
opposed
to
being
retrofit
at
existing
facilities.
Given
that
there
is
at
least
one
long
continuous
press
(
110
feet)
with
a
Method
204
certified
PTE
that
has
not
experienced
operational
problems
with
its
press
enclosure,
we
believe
that
wood
products
enclosures
(
as
defined
in
today's
final
rule)
can
be
designed
around
long
continuous
presses.
We
recognize
that
higher
cost
may
be
associated
with
wood
products
enclosures
around
long
continuous
presses
than
for
batch
presses,
but
the
CAA
does
not
allow
us
to
consider
cost
at
the
MACT
floor
control
level.

We
note
that
enclosures
greater
then
200
feet
in
length
are
common
in
the
printing/
publishing
industry.
However,
we
do
recognize
there
are
differences
in
the
enclosures
used
in
the
printing/
publishing
industry
and
those
in
the
PCWP
industry.
Although
not
cyclical
in
operation
like
batch
107
presses,
continuous
presses
are
heated
operations
and
may
also
have
internal
pressurization
issues
similar
to
those
raised
by
the
commenters
for
batch
presses.
Therefore,
we
believe
it
is
appropriate
for
the
same
definition
of
"
wood
products
enclosure"
promulgated
for
batch
presses
to
apply
to
long
continuous
presses
as
well
(
as
opposed
to
Method
204
certification).

3.
MACT
Floor
Determinations
of
No
Emissions
Reduction
Comment:
Industry
commenters
stated
that
the
proposed
MACT
floor
determinations
of
no
emissions
reduction
for
some
process
units
are
correct
and
accurately
reflect
current
PCWP
facility
practices.
The
commenters
stated
that
the
method
used
to
determine
the
MACT
floors
was
proper
under
the
CAA
and
consistent
with
recent
decisions
made
by
the
D.
C.
Circuit
(
i.
e.,
Cement
Kiln
Recycling
Coalition
v.
EPA,

255
F.
3d
855
(
D.
C.
Circuit
2001)
and
National
Lime
Association
v.
EPA,
233
F.
3d
625
(
D.
C.
Cir.
2000)).

According
to
the
industry
commenters,
in
Cement
Kiln,
EPA
identified
the
median
of
the
best­
performing
12
percent
of
sources
and
set
the
MACT
floor
at
the
worst
emission
level
achieved
by
any
source
using
the
same
emission
control
technology
that
was
used
by
most
of
the
top
12
percent.
The
industry
commenters
noted
that
the
D.
C.
Circuit
ruled
that
this
MACT
floor
was
not
a
valid
estimate
of
the
performance
of
the
best­
performing
sources
in
practice
and
that
EPA
assumed
that
control
technology
was
the
only
way
to
reduce
108
HAP
emissions,
but
other
factors
were
influencing
the
reduction.
The
industry
commenters
noted
that
some
of
those
factors
could
have
been
inadequate
maintenance
or
inferior
operating
practices,
in
which
case
the
worst­
performing
sources
would
certainly
not
be
an
estimate
of
the
bestperforming
sources
under
the
most
adverse
conditions.

According
to
the
industry
commenters,
the
court
noted
that
if
EPA
could
demonstrate
that
MACT
technology
significantly
controlled
emissions,
or
that
factors
other
than
the
control
had
a
negligible
effect,
the
MACT
approach
could
be
a
reasonable
means
of
satisfying
the
statute's
requirements.

The
industry
commenters
noted
that,
in
developing
the
PCWP
rule,
EPA
again
followed
the
MACT
approach,
determining
that
the
average
of
the
best­
performing
12
percent
of
certain
existing
PCWP
process
units
did
not
reflect
the
use
of
any
control
technology.
The
industry
commenters
further
noted
that,
in
the
PCWP
rule,
EPA
determined
that
no
other
universally
applicable
variables
would
affect
HAP
emissions,

a
determination
it
did
not
make
in
Cement
Kiln.
According
to
the
industry
commenters,
for
the
PCWP
process
units
for
which
the
MACT
floor
is
90
percent,
EPA
again
determined
that
there
are
no
other
factors
that
significantly
impact
the
removal
efficiencies
of
the
add­
on
controls.
For
these
reasons,
the
industry
commenters
contended
that
EPA
corrected
the
mistakes
made
in
the
Cement
Kiln
situation
109
when
developing
the
PCWP
MACT.

The
industry
commenters
noted
that
in
National
Lime,
EPA
followed
a
similar
MACT
approach
to
Cement
Kiln,
but
it
had
insufficient
data
for
some
HAP.
According
to
the
commenters,
if
EPA
found
an
insufficient
number
of
plants
in
its
database
controlling
a
particular
HAP
with
pollution
control
technology,
it
determined
that
the
emission
floor
was
"
no
control."
The
industry
commenters
noted
that
the
D.
C.
Circuit
stated
that
if
EPA
did
not
consider
alternative
pollution­
reducing
measures,
it
could
not
decline
to
set
emissions
standards
on
the
grounds
that
the
best­
performing
sources
did
not
use
control
technology.
The
industry
commenters
stated
that
the
D.
C.
Circuit
ruling
in
National
Lime
does
not
prevent
EPA
from
setting
a
MACT
floor
of
no
emissions
reduction;
however,
it
does
require
EPA
to
examine
all
methods
of
removing
HAP
before
setting
a
floor.

According
to
the
industry
commenters,
in
developing
the
PCWP
rule,
EPA
did
look
at
pollution
prevention
measures
and
other
approaches
to
determining
the
MACT
floor
but
found
none
that
are
universally
applicable
to
reduce
HAP
emissions.
Therefore,
the
industry
commenters
contended
that
EPA
is
permitted
by
statute
to
set
the
MACT
floor
for
existing
sources
at
any
level
not
less
stringent
than
the
average
limitation
achieved
by
the
best­
performing
12
percent,
even
if
that
floor
level
reflects
no
reduction
in
110
emissions.

One
commenter
disagreed
with
the
industry
commenters
and
stated
that
not
establishing
emissions
reduction
limits
for
operations
like
miscellaneous
coating
and
wastewater
is
unlawful.
The
commenter
argued
that
EPA
should
not
make
its
MACT
floor
decisions
based
on
"
insufficient
information"
and
the
fact
that
there
is
no
current
control
in
place.
The
commenter
stated
that,
according
to
National
Lime
Ass'n
v.

EPA,
233
F.
3d
625,
633­
634
(
D.
C.
Cir.
2000),
EPA
cannot
set
a
MACT
floor
of
no
emissions
reduction
because
it
believes
that
a
pollutant
is
not
controlled
by
any
particular
technology.
The
commenter
also
stated
that
EPA
failed
to
explain
why
insufficient
data
are
available
and
what
additional
steps
could
be
taken
to
obtain
the
necessary
data.
For
these
reasons,
the
commenter
stated
that
EPA's
proposed
MACT
floor
levels
of
no
emissions
reduction
are
unlawful.

Response:
As
explained
in
the
proposal
preamble
and
supporting
documentation,
for
those
process
units
not
required
to
meet
the
control
requirements
in
the
PCWP
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.

We
based
our
MACT
floor
determinations
for
PCWP
emission
111
sources
on
the
presence
or
absence
of
an
add­
on
air
pollution
control
device
because
we
are
not
aware
of
any
demonstrated
pollution
prevention
techniques
that
can
be
universally
applied
across
the
industry,
and
we
have
no
information
on
the
degree
of
emissions
reduction
that
can
be
achieved
through
pollution
prevention
measures.
Therefore,

to
our
knowledge
the
use
of
add­
on
controls
is
the
only
way
in
which
PCWP
sources
can
currently
limit
HAP
emissions,
and
the
only
way
to
identify
the
MACT
floor
for
these
sources
is
to
identify
a
level
that
corresponds
to
that
achieved
by
the
use
of
add­
on
controls.
When
determining
the
MACT
floor,
we
ranked
the
process
units
by
control
device
rather
than
by
actual
unit­
specific
emissions
reductions
because
we
have
limited
inlet/
outlet
emissions
data.
Based
on
the
available
information,
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.
An
analysis
of
the
available
emissions
data
does
not
reveal
any
process
variables
that
can
be
manipulated
(
without
altering
the
product)
to
achieve
a
quantifiable
reduction
in
emissions.
Ranking
process
units
according
to
control
device,
we
determined
that
the
MACT
floor
is
no
emissions
reduction
for
several
process
unit
groups
including
press
predryers,
fiberboard
mat
112
dryers,
and
board
coolers
at
existing
affected
sources;
and
dry
rotary
dryers,
veneer
redryers,
softwood
plywood
presses,
hardwood
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
at
new
and
existing
affected
sources.
As
explained
in
the
promulgation
BID
and
supporting
documentation,
we
also
determined
that
beyondthe
floor
control
options
are
too
costly
for
these
process
unit
groups.

At
proposal,
we
requested
comment
on
whether
no
emissions
reduction
for
miscellaneous
coating
operations
and
for
wastewater
operations
is
appropriate
(
68
FR
1276
at
1287).
We
also
requested
that
commenters
on
this
issue
submit
any
information
they
might
have
on
HAP
or
VOC
emissions
from
miscellaneous
coating
operations
and
wastewater
operations.
However,
no
additional
information
on
these
operations
was
received
from
any
of
the
commenters
on
the
proposed
rule.
Following
proposal,
we
reviewed
our
MACT
analyses
for
miscellaneous
coating
and
wastewater
operations,
as
described
in
the
following
paragraphs
and
in
the
promulgation
BID
and
supporting
documentation.
For
miscellaneous
coating
operations,
we
gathered
some
113
additional
information
and
were
able
to
revise
our
conclusions
regarding
MACT
in
the
absence
of
specific
information
on
the
emissions
reduction
achieved.
However,

we
have
no
more
reason
to
believe
now
than
we
did
at
proposal
that
PCWP
wastewater
operations
are
in
fact
subject
to
any
emission
control
measures.

Based
on
the
available
information,
we
have
no
basis
to
conclude
that
the
MACT
floor
for
new
or
existing
sources
is
represented
by
any
emission
reduction
for
several
of
miscellaneous
coating
processes
(
i.
e.,
anti­
skid
coatings,

primers,
wood
patches
applied
to
plywood,
concrete
forming
oil,
veneer
composing,
and
fire
retardants
applied
during
forming),
and
we
determined
that
there
are
no
cost­
effective
beyond­
the­
floor
measures
to
reduce
HAP
from
these
coating
processes.
However,
some
facilities
reported
use
of
water­
based
(
non­
HAP)
coatings
in
their
MACT
survey
responses
for
other
types
of
coatings
(
including
edge
seals,

nail
lines,
logo
paint,
shelving
edge
fillers,
and
trademark/
gradestamp
inks).
Other
facilities
reported
use
of
"
solvent­
based"
coatings
for
these
processes.
In
some
instances,
a
few
respondents
provided
information
on
the
percent
HAP
content
of
a
solvent­
based
coating.

Solvent­
based
coatings
do
not
always
contain
HAP
(
e.
g.,
the
solvent
may
be
mineral
oil
which
does
not
contain
HAP),
and
water­
based
coatings
typically
do
not
contain
HAP.
Thus,

many
of
the
coatings
reported
in
the
MACT
survey
responses
114
are
"
non­
HAP"
coatings.
While
the
emission
reduction
achieved
as
a
result
of
coating
substitutions
cannot
be
determined,
it
is
clear
that
use
of
non­
HAP
coatings
represents
the
MACT
floor
because
of
the
large
number
of
facilities
reporting
use
of
non­
HAP
coatings.

Beyond­
the­
floor
options
were
not
considered
for
edge
seals,

nail
lines,
logo
paint,
shelving
edge
fillers,
and
trademark/
gradestamp
inks
because
no
further
emissions
reductions
can
be
achieved
than
through
use
of
non­
HAP
coatings.
Based
upon
our
revised
MACT
analysis,
the
final
PCWP
rule
requires
use
of
"
non­
HAP
coating"
for
processes
identified
as
"
group
1
miscellaneous
coating
processes."

The
definition
of
"
non­
HAP
coating"
included
in
the
final
rule
was
based
on
the
description
of
non­
HAP
coatings
in
the
final
Wood
Building
Products
NESHAP
(
subpart
QQQQ).

This
definition
allows
for
unavoidable
trace
amounts
of
HAP
that
may
be
contained
in
the
raw
materials
used
to
produce
certain
coatings.
Through
the
definition
of
"
group
1
miscellaneous
coatings"
in
the
final
rule,
kiln­
dried
lumber
is
excluded
from
the
requirement
to
use
non­
HAP
coatings
because
application
of
coatings
used
at
kiln­
dried
lumber
manufacturing
facilities
is
not
part
of
the
PCWP
source
category.
Although
trademarks/
gradestamps
are
applied
to
kiln­
dried
lumber,
lumber
kilns
are
the
only
processes
at
kiln­
dried
lumber
manufacturing
facilities
covered
under
the
PCWP
source
category.
115
For
wastewater
operations,
we
concluded
that
we
had
insufficient
information
to
conclude
that
the
MACT
floor
level
of
control
is
represented
by
any
emissions
reductions.

The
available
information
on
wastewater
operations
collected
as
part
of
the
MACT
survey
of
the
PCWP
industry
and
information
contained
in
State
permits
indicated
that
these
sources
of
emissions
were
not
the
subject
of
control
requirements
and
were
not
expected
to
be
significant
sources
of
HAP
or
VOC
emissions.
As
stated
above,
we
received
no
comments
containing
additional
information
on
emissions
reduction
measures
or
HAP/
VOC
emissions
from
wastewater
operations.
Thus,
we
have
no
more
reason
to
believe
now
than
we
did
at
proposal
that
PCWP
wastewater
operations
are
in
fact
subject
to
any
control
measures.
As
a
result,
since
no
information
shows
that
these
PCWP
operations
use
add­
on
controls,
there
is
no
identifiable
numerical
emissions
level
that
would
correspond
to
a
MACT
floor
level
reflecting
the
use
of
controls,
and
the
only
floor
level
demonstrable
based
on
current
data
is
no
emissions
reduction.
Furthermore,

given
that
our
best
data
show
that
the
emissions
from
wastewater
operations
are
less
than
1
ton
per
year,
we
concluded
that
application
of
the
control
measures
mentioned
above
would
not
be
cost
effective
beyond­
the­
floor
options.

In
response
to
the
commenter's
objection
to
the
incompleteness
of
the
data
set
for
these
PCWP
operations,
we
note
that
the
D.
C.
Circuit
does
not
require
EPA
to
obtain
116
complete
data
as
long
as
we
are
able
to
otherwise
estimate
the
MACT
floor
(
Sierra
Club
V.
EPA,
167
F.
3d
658,662
(
D.
C.

Cir.
1999)).
Unlike
dryers
and
presses
at
PCWP
plants,

wastewater
operations
have
not
been
subjected
by
permitting
authorities
to
controls
for
HAP
emissions.
We
expended
much
effort
in
the
early
stages
of
the
project
gathering
complete
and
accurate
information
on
the
PCWP
processes
with
the
most
potential
for
HAP
emissions
and
the
greatest
potential
for
emission
control
(
i.
e.,
the
processes
that
have
been
the
focus
of
permit
requirements
limiting
HAP/
VOC
emissions)
and
the
final
PCWP
rule
addresses
emissions
from
these
process
units.

Had
we
been
given
reason
to
believe
that
there
were
emissions
control
measures
associated
with
wastewater
operations,
we
would
have
gathered
more
information
for
these
processes
earlier
in
the
project.
Even
though
we
have
determined
that
the
current
MACT
floor
for
these
PCWP
operations
is
no
emission
reduction,
since
available
information
indicates
they
are
not
controlled,
the
HAP
emissions
from
wastewater
operations
(
and
other
PCWP
sources
with
MACT
determinations
reflecting
no
emissions
reduction)

will
be
considered
further
when
we
review
residual
risk
as
required
under
§
112(
f).

E.
New
Source
MACT
Comment:
One
commenter
objected
to
our
determination
that
MACT
is
the
same
degree
of
control
for
new
and
existing
117
sources
for
many
process
units
based
on
the
fact
that
the
best
technology
is
the
same
for
new
and
existing
sources
(
i.
e.,
incineration­
based
controls
or
biofilters).
The
commenter
pointed
out
that,
according
to
the
proposal
BID,

the
maximum
percent
control
efficiency
is
in
the
upper
90s
for
THC,
formaldehyde,
and
methanol.
The
commenter
noted
that
the
CAA
requires
the
MACT
floor
to
be
based
on
the
degree
of
emissions
reduction
achieved
in
practice
by
the
best­
controlled
similar
source.
Thus,
the
commenter
requested
that
we
revise
the
new
source
MACT
requirements
for
process
units
based
upon
the
greatest
reductions
recorded.

Response:
As
explained
in
the
preamble
to
the
proposed
rule
and
supporting
documentation,
the
MACT
floor
for
both
new
and
existing
sources
is
based
on
the
estimate
of
the
performance
achieved
through
application
of
RTO,
RCO,
or
biofilters.
We
acknowledge
that
some
incineration­
based
controls
and
biofilters
can
achieve
greater
than
90%

reduction
in
HAP
or
THC
during
a
single
performance
test
or
a
test
run
within
a
performance
test.
However,
we
also
recognize
that
the
percent
reduction
achieved
can
vary
according
to
pollutant
inlet
concentration,
a
factor
that
is
not
directly
controllable
from
a
process
or
control
device
standpoint.
Other
unknown
factors
may
also
cause
variability
in
control
system
performance.
For
example,
we
have
THC
percent
reduction
data
for
an
RTO
used
to
control
118
emissions
from
three
tube
dryers
and
a
press
at
an
MDF
plant
for
two
emission
tests
conducted
at
different
times.
In
1996,
the
RTO
achieved
92.7
percent
reduction
of
THC,
and
in
1998
the
same
RTO
achieved
98.9
percent
reduction
of
THC.

In
addition,
we
have
emissions
test
data
for
the
same
process
unit
and
control
system
for
multiple
years,
and
these
data
show
different
emission
factors,
indicating
that
variability
is
inherent
within
each
process
unit
and
control
system
combination.
Thus,
we
estimate
that
the
best
MACT
technology
achieves
90
percent
HAP
reductions
when
variations
in
operations
and
measurements
are
considered.

F.
Definition
of
Control
Device
Comment:
Several
commenters
requested
that
we
add
scrubbers
and
adsorbers
to
the
proposed
definition
of
"
control
device"
and
that
condensers
be
omitted
from
the
definition.
One
of
the
commenters
operates
a
particleboard
press
that
is
equipped
with
a
condenser
that
condenses
steam
from
the
press
exhaust
and
then
routes
the
condensate
to
an
onsite
wastewater
treatment
system.
The
remaining
noncondensed
gases
are
combusted
in
an
onsite
boiler
as
supplemental
fuel.
This
commenter
would
like
to
be
able
to
comply
with
the
PBCO
for
reconstituted
wood
products
presses
rather
than
demonstrate
compliance
with
one
of
the
add­
on
control
system
compliance
options
(
e.
g.,
90
percent
emissions
reduction)
or
emissions
averaging
provisions;

however,
the
commenter
noted
that
PBCO
only
apply
to
119
uncontrolled
emission
sources.
Therefore,
the
commenter
requested
that
the
definition
of
control
device
be
limited
only
to
those
add­
on
control
systems
that
were
designed
with
HAP
removal
as
the
primary
goal.

Response:
We
disagree
with
the
commenters
that
the
proposed
definition
of
"
control
device"
should
be
changed.

The
definition
in
the
final
rule
does
not
include
scrubbers
or
absorbers
but
does
include
condensers
and
combustion
units
that
incinerate
process
unit
exhausts.
For
purposes
of
MACT
standards
development,
the
reason
a
control
device
is
installed
is
immaterial.
All
control
devices
or
techniques
that
reduce
HAP
emissions
are
considered
when
setting
MACT
standards.
We
note
that
the
PBCO
were
developed
and
included
in
the
PCWP
rule
for
inherently
lowemitting
process
units
or
process
units
with
pollution
prevention
techniques
and
not
for
process
units
with
add­
on
control
systems.
Therefore,
the
particleboard
press
equipped
with
the
condenser
and
combustion
unit
described
by
the
commenter
cannot
comply
using
the
PBCO.

In
the
proposed
PCWP
rule
we
intentionally
omitted
absorbers
(
e.
g.,
wet
scrubbers)
from
the
list
of
potential
control
devices
because
these
technologies
generally
are
not
reliable
for
reducing
HAP
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,
120
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.
We
wished
to
limit
the
examples
included
in
the
definition
of
"
control
device"
to
those
devices
for
which
we
have
data
to
demonstrate
that
they
are
effective
in
reducing
HAP
emissions
from
PCWP
facilities.
However,
we
note
that
the
definition
includes
the
phrase
"
but
not
limited
to"
and
does
not
exclude
other
types
of
controls.

We
are
aware
that
new
technologies
(
some
of
which
may
be
adsorption­
based
or
absorption­
based)
may
be
developed
that
effectively
reduce
HAP
emissions
from
PCWP
sources.
The
definition
of
"
control
device"
does
not
prevent
their
development
or
use.

Facilities
using
wet
scrubbers
or
WESP
to
meet
the
addon
APCD
or
emissions
averaging
compliance
options
can
petition
the
Administrator
for
approval
of
site­
specific
operating
requirements
to
be
used
in
demonstrating
continuous
compliance.
Alternatively,
facilities
using
a
wet
scrubber
or
WESP
may
use
a
THC
CEMS
to
show
that
the
THC
concentration
in
the
APCD
exhaust
remains
below
the
minimum
concentration
established
during
the
performance
test.
In
addition,
facilities
using
wet
control
devices
(
e.
g.,
wet
scrubber
or
WESP)
as
the
sole
means
of
reducing
HAP
emissions
must
submit
with
their
Notification
of
Compliance
Status
a
plan
for
review
and
approval
to
address
how
organic
121
HAP
captured
in
the
wastewater
from
the
wet
control
device
are
contained
or
destroyed
to
minimize
re­
release
to
the
atmosphere
such
that
the
desired
emission
reduction
is
obtained.
Because
wet
scrubbers
or
WESP
are
add­
on
APCD
and
have
variable
effects
on
HAP
emissions,
today's
final
rule
specifies
that
sources
cannot
use
add­
on
control
systems
or
wet
control
devices
to
meet
PBCO.
As
part
of
this
change,

we
added
a
definition
of
"
wet
control
device"
to
today's
final
rule.
We
note
that
PCWP
facilities
demonstrating
compliance
with
the
PBCO
for
process
units
equipped
with
any
wet
control
device
that
effects
HAP
emissions
must
test
prior
to
the
wet
control
device.

G.
Compliance
Options
1.
Add­
on
Control
System
Compliance
Options
Comment:
We
received
a
number
of
comments
related
to
the
six
add­
on
control
systems
compliance
options
and
how
these
options
might
be
implemented
at
an
actual
PCWP
facility.
One
commenter
argued
that
the
use
of
multiple
compliance
options
for
add­
on
control
systems
will
make
it
difficult
for
State
agencies
to
determine
if
a
facility
is
actually
in
compliance.
The
commenter
pointed
out
that,
if
a
facility
tested
for
two
options
but
passed
only
one,
it
would
still
be
in
compliance.
However,
the
commenter
stated
that
the
rule
was
unclear
whether
a
facility
would
be
in
violation
if
the
facility
chose
to
test
for
one
option,

failed
that
test,
and
then
conducted
another
test
to
122
determine
compliance
with
a
different
option.
The
commenter
contended
that
this
would
constitute
a
violation
of
the
standard,
and
any
retesting
to
determine
compliance
with
a
different
option
would
not
reverse
the
initial
violation.

Therefore,
the
commenter
requested
that
we
clarify
that
the
option
to
use
the
"
most
beneficial"
results
of
two
or
more
test
methods
applies
only
when
these
tests
are
conducted
during
a
single
performance
test.
According
to
the
commenter,
any
facility
that
chose
to
use
only
one
test
method
during
the
compliance
test
would
have
to
accept
the
results
of
that
test.

Other
commenters
argued
that
a
facility
should
be
able
to
switch
among
the
six
add­
on
control
options
as
needed
to
maintain
compliance.
To
illustrate
the
necessity
of
the
ability
to
switch
from
one
add­
on
control
option
to
another,

the
commenters
provided
an
example
whereby
the
operator
of
a
veneer
dryer
might
want
to
demonstrate
compliance
with
the
90
percent
THC
reduction
option
(
option
1
in
Table
1B
of
the
final
rule)
under
certain
operating
conditions
and
with
the
20
ppmv
THC
option
(
option
2
in
Table
1B
of
the
final
rule)

under
other
operating
conditions.
One
of
the
commenters
also
noted
that
production
starts
and
stops
and
minor
malfunctions
are
common
at
PCWP
facilities,
and
most
of
them
do
not
affect
the
performance
of
the
air
pollution
control
device.
However,
frequent
startup,
shutdown
and
malfunction
(
SSM)
events
resulting
in
a
low
concentration
to
the
inlet
123
of
the
control
device
could
affect
a
facility's
ability
to
comply
with
the
percent
reduction
option.
In
this
case,
the
commenter
stated
that
the
freedom
to
switch
compliance
options
would
be
valuable.
For
these
reasons,
the
