125
commenters
requested
that
we
explicitly
state
in
the
PCWP
rule
that
"
a
facility
only
need
comply
with
any
one
of
the
6
options
at
any
one
time,
and
that
it
can
change
between
them
as
needed
to
fit
process
operating
conditions."

Response:
We
understand
the
commenters'
concerns
on
this
issue
and
have
made
some
wording
changes
in
the
final
rule
to
clarify
our
intentions
regarding
how
the
add­
on
control
system
compliance
options
should
be
implemented
at
PCWP
facilities.
The
proposed
rule
states
at
§
63.2240
that
"
You
cannot
use
multiple
compliance
options
for
a
single
process
unit."
We
included
this
provision
to
prevent
PCWP
sources
from
partitioning
emissions
from
a
single
process
unit
and
then
applying
different
control
options
to
each
portion
of
the
emissions
stream.
The
MACT
floor
determinations
and
compliance
options
were
all
based
on
the
full
flow
of
emissions
from
process
units,
and
therefore,

compliance
options
should
be
applied
to
the
same
mass
of
emissions
to
ensure
that
the
required
MACT
floor
emissions
reductions
are
achieved.
When
including
this
restriction,

we
did
not
necessarily
intend
to
limit
PCWP
facilities
to
only
one
of
the
six
options
for
add­
on
control
systems.
We
did
assume
that
each
source
would
likely
select
only
one
option,
and
that
at
any
point
in
time
for
purposes
of
assessing
compliance,
the
given
compliance
option
would
have
been
pre­
selected
and
reflected
as
applicable
in
the
source's
permit.
In
fact,
in
discussions
with
industry
126
representatives
prior
to
proposal,
they
expressed
concern
that
the
rule
be
written
to
make
it
clear
that
a
source
would
only
have
to
comply
with
one
option
and
not
all
six.

Based
on
available
data,
we
expect
that
most
facilities
will
be
able
to
demonstrate
compliance
with
more
than
one
of
the
compliance
options
for
add­
on
control
systems.
When
developing
the
six
compliance
options
for
add­
on
control
systems,
it
was
our
belief
that
PCWP
facilities
would
conduct
emissions
testing
(
e.
g.,
inlet
and
outlet
testing
for
THC,
methanol,
and
formaldehyde
over
a
range
of
APCD
operating
temperatures)
and
then,
based
on
the
results
of
testing,
select
the
option
that
provides
them
with
the
most
operating
flexibility
as
well
as
an
acceptable
"
compliance
margin"
(
i.
e.,
select
the
option
that
they
believe
will
be
easiest
for
them
to
meet
on
a
continuous
basis
under
varying
conditions).
The
operating
parameter
limit
to
be
reflected
in
the
source's
permit
(
e.
g.,
minimum
temperature)
would
be
based
on
the
measurements
made
during
the
compliant
test
runs.
For
example,
if
test
results
show
that
a
facility
can
achieve
90
percent
reduction
for
formaldehyde,
92
percent
reduction
for
methanol,
and
94
percent
reduction
for
THC,

then
the
facility
may
decide
to
reduce
THC
emissions
by
90
percent,
since
this
option
appears
to
provide
the
greatest
compliance
margin.
The
corresponding
operating
parameter
level
measured
during
the
testing
(
e.
g.,
minimum
15­
minute
RTO
temperature
during
a
3
run
test)
would
then
be
set
as
127
the
operating
limit
in
the
permit
for
that
source.
In
this
example,
if
the
RTO
operating
temperature
drops
below
the
operating
limit,
that
would
be
a
deviation,
and
any
subsequent
retesting
done
by
the
facility
would
presumably
be
done
based
on
the
chosen
compliance
option
(
e.
g.,
reduce
THC
emissions
by
90
percent).
Determining
compliance
in
this
case
is
relatively
straightforward.
However,
we
are
aware
that
State
agencies
may
simply
refer
to
a
NESHAP
as
part
of
a
permit
and
not
stipulate
which
compliance
option
the
facility
must
meet.
In
these
cases,
we
agree
with
the
commenter
who
was
concerned
that
compliance
can
be
complicated
when
the
referenced
NESHAP
contains
multiple
options,
and
that
such
a
broad
reference
would
not
be
adequate
to
identify
the
particular
option
(
and
parameter
operating
limits)
applicable
to
the
source.
We
also
agree
that,
if
a
facility
selects
multiple
options
under
the
compliance
options
for
add­
on
control
systems,
it
should
be
required
to
conduct
all
necessary
testing
associated
with
compliance
with
the
selected
options
concurrently.
In
addition
the
facility
should
obtain
permit
terms
reflecting
these
options
as
alternate
operating
scenarios
that
clearly
identify
at
what
points
and
under
what
conditions
the
different
options
apply,
such
that
compliance
can
be
determined
during
a
single
time
frame.
For
example,
if
the
source
wishes
to
include
options
1,
3,
and
5
in
their
permit,
then
it
must
perform
inlet
and
outlet
testing
for
128
THC,
methanol,
and
formaldehyde
any
time
the
State
agency
has
reason
to
require
a
repeat
performance
test
(
if
all
three
options
are
simultaneously
applicable)
or
test
for
the
single
applicable
option
that
corresponds
to
the
given
time
and
condition
(
if
the
options
apply
as
alternate
operating
scenarios
under
different
conditions).
With
this
approach,

we
would
avoid
situations
where
a
facility
retests
to
determine
compliance
with
a
compliance
option,
fails
to
demonstrate
compliance
with
that
option,
and
then
conducts
additional
testing
to
determine
compliance
with
other
options
that
are
not
pre­
established
as
applicable
at
a
later
date.

The
final
rule
clarifies
our
intentions
regarding
the
use
of
multiple
control
options
with
respect
to
add­
on
control
systems
versus
the
combining
of
control
options
for
a
single
process
unit.
The
language
in
§
63.2240
of
the
final
rule
has
been
modified
to
delete
the
proposed
text
stating
that
a
source
"
cannot
use
multiple
compliance
options
for
a
single
process
unit"
and
replace
it
with
a
statement
that
a
source
"
cannot
combine
compliance
options
in
paragraphs
(
a)[
PBCO],
(
b)[
add­
on
control
systems
compliance
options]
or
(
c)[
emissions
averaging
provisions]

for
a
single
process
unit."
We
believe
that
this
wording
change
clarifies
our
intention
to
prevent
sources
from
applying
different
control
options
to
different
portions
of
the
emissions
from
a
single
process
unit,
while
leaving
open
129
the
potential
for
PCWP
facilities
to
be
able
to
include
multiple
compliance
options
for
add­
on
control
systems
(
i.
e.,
one
option
per
defined
operating
condition)
in
a
State
permit.
Although
add­
on
controls
are
used
in
emissions
averaging
plans
to
achieve
full
or
partial
control
of
emissions
from
a
given
process
unit,
the
emissions
from
a
single
process
unit
cannot
be
parceled
such
that
a
portion
of
the
emissions
meets
one
of
the
add­
on
control
system
compliance
options
and
another
portion
is
used
as
part
of
an
emissions
averaging
plan.
The
final
rule
continues
to
state
that
sources
must
meet
at
least
one
of
the
six
options
for
add­
on
control
systems.

Comment:
Several
commenters
requested
that
PCWP
facilities
be
allowed
to
use
add­
on
control
methods
to
achieve
the
PBCO
limits.
The
commenters
argued
that
allowing
compliance
with
the
PBCO
using
APCD
is
consistent
with
other
MACT
rules
and
pollution
prevention
(
P2)

approaches.
According
to
the
commenters,
numerous
NESHAP
allow
emissions
limits
to
be
reached
using
add­
on
controls,

P2
techniques,
or
a
combination
of
both.
The
commenters
stated
that
there
was
no
legal
or
policy
basis
for
imposing
restrictions
on
the
use
of
PBCO
in
the
PCWP
MACT.
The
commenters
also
stated
that
using
add­
on
controls
to
comply
with
PBCO
will
benefit
facilities
that
have
process
units
that
emit
low
levels
of
HAP.
According
to
the
commenter,

some
companies
have
already
implemented
P2
strategies
that
130
have
been
established
as
BACT
in
a
prevention
of
significant
deterioration
(
PSD)
permit.
Because
these
P2
strategies
may
fall
short
of
the
PBCO,
companies
implementing
these
strategies
would
be
unable
to
achieve
compliance
with
the
proposed
rule
without
abandoning
the
P2
strategy
and
installing
full
control.
The
commenters
also
stated
that
incorporating
add­
on
controls
in
the
PBCO
would
provide
incentives
to
find
low­
energy
pollution
control
equipment.

The
commenters
gave
an
example
whereby
part
of
the
emission
unit
exhaust
could
be
used
as
combustion
air
for
an
onsite
boiler.
The
commenters
noted
that
in
most
cases,
the
boiler
could
only
handle
a
portion
of
the
exhaust
from
multiple
dryer
stacks.
The
commenters
stated
that
by
combining
this
type
of
partial
control
approach
with
low­
temperature
drying,
a
facility
may
be
able
to
meet
the
applicable
dryer
PBCO
limit.
According
to
the
commenters,
in
this
case,

allowing
for
partial
control
would
exclude
the
need
for
RTO
technology
and
would
provide
a
net
benefit
to
the
environment
with
a
reduction
of
collateral
oxidizer
emissions.
The
commenters
gave
another
example
in
which
a
facility
with
a
conveyor
strand
dryer
could
send
the
exhaust
from
the
first
dryer
section
to
a
burner
and
then
send
the
heat
back
to
the
dryer;
the
emissions
from
the
remaining
dryer
sections
would
be
uncontrolled
if
the
total
emissions
were
below
the
PBCO
limit.
In
a
third
example
provided
by
the
commenters,
a
facility
would
remove
enough
HAP
to
comply
131
with
the
PBCO
limit
using
a
scrubber,
which
would
require
less
energy
than
incineration.

Response:
Like
the
proposed
rule,
the
final
rule
does
not
allow
sources
to
comply
with
the
PBCO
through
the
use
of
add­
on
control
systems.
Our
intention
for
including
the
PBCO
was
to
provide
an
alternative
to
add­
on
controls
(
e.
g.,
allow
for
and
encourage
the
exploration
of
pollution
prevention,
which
currently
has
not
been
demonstrated
as
achieved
by
PCWP
sources)
and
not
to
create
another
compliance
option
for
sources
equipped
with
add­
on
control
systems
that
could
inadvertently
allow
add­
on
control
equipped
systems
to
not
perform
to
expected
control
efficiencies.
Sources
equipped
with
add­
on
control
systems
already
have
six
different
compliance
options
from
which
to
choose,
in
addition
to
the
emissions
averaging
compliance
option.
We
note
that
the
six
options
for
add­
on
control
systems
are
based
on
emissions
reductions
achievable
with
MACT
control
devices
and
thus
are
a
measure
of
the
performance
of
MACT
control
devices.
This
might
not
be
true
if
a
source
combined
PBCO
and
add­
on
controls,
as
explained
below.

At
proposal,
we
established
PBCO
limits
for
10
process
unit
groups.
Initially,
we
believed
that
we
needed
total
HAP
data
for
at
least
one
process
unit
in
each
process
unit
group
that
was
equipped
with
a
control
system
in
order
to
establish
the
PBCO
limits.
However,
we
had
to
discard
this
132
approach
because
controlled
total
HAP
data
are
not
available
for
half
(
5
of
10)
of
the
process
unit
groups.
We
developed
a
number
of
other
approaches
to
establishing
PBCO,
and
then
compared
the
results
of
these
approaches,
where
possible,

with
actual
emissions
in
the
outlet
of
MACT
control
devices.

The
approach
that
yielded
results
closest
to
actual
emissions
in
the
control
device
outlets
was
an
approach
based
on
a
90
percent
reduction
from
the
average
emissions
each
process
unit
group.
Thus,
this
approach
was
the
one
that
resulted
in
limits
that
would
most
closely
represent
an
alternative
to
the
six
compliance
options
for
add­
on
control
systems.
However,
our
intention
was
not
to
develop
an
alternative
limit
to
the
six
limits
already
established
for
add­
on
control
devices.
Our
intention
was
to
develop
an
alternative
for
P2
techniques.
We
decided
to
select
an
approach
that
allows
sources
that
develop
P2
techniques
(
or
are
otherwise
inherently
low­
emitting
sources)
to
comply
and
that
reduces
HAP
emissions
without
generating
the
NOx
emissions
associated
with
incineration­
based
controls.
As
a
result,
we
selected
a
90
percent
reduction
from
the
highest
data
point
within
each
process
unit
group,
because
the
results
appeared
to
be
at
levels
that
would
not
preclude
the
development
of
environmentally
beneficial
P2
options
as
MACT.

If
PBCO
were
allowed
as
another
option
for
measuring
the
performance
of
add­
on
control
devices,
operators
could
run
133
the
APCD
so
that
the
APCD
would
not
achieve
MACT
level
emissions
reductions,
but
would
meet
the
PBCO.
We
note
that
we
did
not
develop
the
methanol
and
formaldehyde
add­
on
control
options
(
options
4
and
6
in
Table
1B
of
the
final
rule)
based
on
typical
or
maximum
levels
of
methanol
and
formaldehyde
found
in
the
outlet
of
the
control
devices,
but
instead
looked
at
the
performance
of
the
MACT
control
devices
in
reducing
these
HAP,
set
the
levels
based
on
the
method
detection
limits
for
these
compounds,
and
included
a
minimum
inlet
concentration
requirement
for
the
use
of
the
outlet
concentration
options
to
ensure
that
HAP
emissions
reductions
are
achieved.
Allowing
the
use
of
APCD
to
comply
with
PBCO
could
allow
circumvention
of
such
optimization,

which
could
render
the
MACT
control
itself
to
be
less
effective
than
MACT.

Regarding
the
other
MACT
standards
referenced
by
the
commenters,
we
agree
that
these
other
rules
may
allow
facilities
more
flexibility
in
meeting
a
production­
based
option
(
e.
g.,
"
lb/
ton"
emission
limit);
however,
we
cannot
allow
add­
on
controls
to
be
used
to
meet
the
PBCO
in
the
PCWP
rule
because
doing
so
would
render
these
limits
not
equivalent
to
the
other
compliance
options.
For
example,

consider
a
typical
wood
products
press
with
an
annual
production
rate
of
100
million
square
feet
of
board
per
year
and
a
total
HAP
emission
rate
of
1.0
pound
per
thousand
square
feet
of
board
on
a
¾
­
inch
basis
(
lb/
MSF
¾
"
).
On
an
134
annual
basis,
the
example
press
emits
50
tons
of
HAP
per
year.
If
the
example
press
complies
with
the
90
percent
HAP
reduction
requirement,
then
the
HAP
emissions
reduction
achieved
will
be
at
least
45
tons
per
year.
However,
if
this
same
press
were
allowed
to
comply
with
the
applicable
PBCO
limit
(
0.30
lb/
MSF
¾
"
)
using
an
APCD
(
e.
g.,
RTO),
then
the
emissions
reduction
achieved
could
be
as
little
as
35
tons
per
year
if
the
APCD
is
only
applied
to
a
portion
of
the
press'
emissions
or
if
the
APCD
is
not
operated
at
MACTlevel
efficiency.
Not
only
would
a
significantly
lower
HAP
emissions
reduction
be
achieved
in
this
situation,
but
there
also
would
not
be
any
net
benefit
to
the
environment
to
justify
the
lower
HAP
reduction
(
i.
e.,
NOx
emissions
would
still
be
created).
Also,
we
wish
to
point
out
that
the
emissions
from
PCWP
process
units
are
not
insignificant,

even
when
these
units
operate
at
the
PBCO
thresholds.
For
example,
a
typical
wood
products
press
that
operates
at
the
applicable
PBCO
(
0.30
lb/
MSF
¾
"
)
still
emits
15
tons
of
HAP
per
year,
and
a
typical
rotary
strand
dryer
operating
at
the
applicable
PBCO
(
0.18
lb
per
oven­
dried
ton
(
ODT))
emits
6
tons
of
HAP
per
year.
Therefore,
we
believe
it
is
appropriate
and
in
keeping
with
the
MACT
floor
to
require
PCWP
process
units
with
uncontrolled
HAP
emissions
above
the
PBCO
thresholds
to
achieve
the
full
90
percent
reduction
in
emissions.
We
also
wish
to
clarify
that
a
PCWP
facility
may
use
any
number
of
compliance
options,
as
long
as
these
135
options
are
not
combined
for
an
individual
process
unit.

For
example,
a
facility
may
choose
to
meet
the
applicable
PBCO
limit
for
one
dryer,
control
emissions
from
a
blender
to
avoid
controlling
emissions
on
the
remaining
two
dryers
as
part
of
an
emissions
average,
and
comply
with
one
of
the
add­
on
control
systems
compliance
options
for
the
press.

Regarding
the
examples
cited
by
the
commenter
as
candidates
for
a
PBCO
if
add­
on
controls
were
allowed,
we
note
that
the
final
rule
includes
a
revised
MACT
floor
for
existing
conveyor
strand
dryers,
such
that
existing
conveyor
strand
dryers
that
send
the
emissions
from
the
first
dryer
section
back
to
the
combustion
unit
that
heats
the
dryer
should
be
able
to
meet
the
rule
requirements
without
additional
controls.
In
addition,
"
partial
control"
(
e.
g.,

routing
part
of
the
emission
stream
from
a
process
unit
to
an
onsite
combustion
unit
for
incineration)
is
allowed
as
part
of
an
emissions
averaging
plan
as
long
as
the
actual
emissions
reductions
achieved
are
greater
than
or
equal
to
the
required
emissions
reductions.
When
partial
control
is
used
as
part
of
an
emissions
averaging
plan,
the
overall
reductions
are
equivalent
to
what
would
be
achieved
if
a
source
elected
to
comply
using
the
add­
on
control
system
compliance
options;
however,
the
same
would
not
be
true
if
partial
control
were
used
to
comply
with
a
PBCO
limit.

Regarding
the
use
of
scrubbers
to
comply
with
a
PBCO,
as
stated
in
section
IV.
F
of
this
preamble,
the
PCWP
industry's
136
own
data
do
not
support
wet
scrubbers
as
a
reliable
control
technology
for
HAP,
and
sources
equipped
with
wet
control
devices
will
be
required
to
test
prior
to
the
wet
control
device
if
they
elect
to
comply
with
a
PBCO.

Comment:
Several
commenters
stated
that
PCWP
facilities
should
be
allowed
to
neglect
nondetect
HAP
measurements
for
PBCO
calculations.
The
commenters
argued
that
if
a
facility
is
forced
to
use
values
of
one­
half
the
detection
limit
for
nondetect
HAP,
that
facility
may
be
unable
to
use
PBCO
because
the
mass
of
emissions
attributed
to
undetected
compounds
may
consume
50
percent
or
more
of
the
PBCO
limit.

The
commenters
also
noted
that
the
detection
levels
measured
in
the
field
by
the
NCASI
test
method,
NCASI
IM/
CAN/
WP­

99.01,
generally
range
between
0.35
ppm
and
1
ppm,
and
the
detection
levels
of
the
FTIR
method
averages
about
1
ppm.

According
to
the
commenters,
even
at
these
low
concentrations,
using
one­
half
the
detection
limit
for
nondetect
compounds
can
put
the
PBCO
out
of
reach
for
a
high­
flow­
rate
PCWP
stream.
The
commenters
also
provided
a
sample
calculation
to
demonstrate
the
effect
that
the
detection
level
has
on
the
compliance
calculation.

Response:
In
responding
to
this
request,
we
reviewed
the
information
supplied
by
the
commenters
and
analyzed
the
potential
effects
of
making
the
requested
change
using
available
emissions
data.
After
reviewing
the
total
HAP
data
used
to
establish
the
PBCO
limits,
we
decided
that
137
sources
should
be
able
to
treat
nondetect
measurements
for
an
individual
HAP
as
"
zero"
for
the
sole
purpose
of
determining
compliance
with
the
PBCO,
if,
and
only
if,
the
following
two
conditions
are
met:
(
1)
the
detection
limit
for
that
pollutant
is
set
at
a
value
that
is
less
than
or
equal
to
1
ppmvd;
and
(
2)
emissions
of
that
pollutant
are
nondetect
for
all
three
test
runs.
We
included
the
first
condition
to
prevent
test
contractors
from
setting
the
detection
limits
too
high,
and
thus
generating
false
zeroes.

We
selected
1
ppmvd
as
the
maximum
detection
limit
value
because
it
matches
the
detection
limits
achievable
with
the
test
methods
included
in
the
PCWP
rule.
We
included
the
second
condition
to
ensure
that
the
source
is
truly
lowemitting
as
evidenced
by
three
nondetect
test
runs.
If
emissions
of
the
HAP
are
detected
during
any
one
test
run,

then
any
nondetect
runs
must
be
treated
as
being
equal
to
one­
half
the
detection
limit.
The
option
to
treat
nondetect
measurements
as
zero
does
not
apply
to
the
compliance
options
for
add­
on
control
systems
because
treating
the
outlet
emissions
from
a
control
device
as
zero
would
artificially
increase
the
calculated
control
efficiency
for
that
pollutant
to
100
percent.

To
ensure
that
the
PBCO
limits
were
developed
in
a
manner
consistent
with
how
they
would
be
applied,
the
PBCO
limits
were
recalculated
using
zero
for
nondetect
measurements
when
all
test
runs
were
nondetect.
As
a
138
result,
the
PBCO
limit
for
reconstituted
wood
product
board
coolers
changed
from
0.015
to
0.014
lb/
MSF
(
3/
4").
No
other
PBCO
limits
changed
as
a
result
of
using
zero
for
nondetects
when
calculating
the
PBCO
limits.

We
added
a
new
PBCO
limit
to
the
final
rule
for
secondary
tube
dryers.
This
new
limit
corresponds
to
our
decision
to
treat
primary
and
secondary
tube
dryers
as
separate
process
units,
as
discussed
previously
in
section
IV.
A
of
this
preamble.
The
final
rule
also
differentiates
between
rotary
strand
dryers
and
conveyor
strand
dryers,
as
discussed
in
section
IV.
D
of
this
preamble;
however,
no
new
PBCO
limits
have
been
added
for
these
two
process
units
groups.
The
final
PBCO
limit
for
rotary
strand
dryers
is
the
same
as
the
proposed
limit
for
"
strand
dryers"
because
the
data
used
to
establish
the
proposed
PBCO
limit
was
based
on
data
from
rotary
strand
dryers
exclusively.
We
do
not
have
the
necessary
data
to
establish
a
PBCO
for
conveyor
strand
dryers,
and
thus,
the
final
rule
does
not
include
a
PBCO
limit
for
that
process
unit
group.

3.
Emissions
Averaging
Provisions
Comment:
Industry
commenters
generally
expressed
support
for
the
inclusion
of
an
emissions
averaging
(
EA)

program
in
the
PCWP
rule,
but
requested
that
the
proposed
provisions
be
modified
to
allow
for
broader
use
of
emissions
averaging
at
PCWP
facilities.
Requested
modifications
include
allowing
sources
to
receive
credit
for
achieving
139
emissions
reductions
greater
than
90
percent;
basing
compliance
on
a
single
pollutant;
allowing
sources
to
combine
emissions
averaging
with
PBCO;
and
allowing
sources
to
receive
credit
for
P2
alternatives
as
part
of
an
EAP.

Each
of
these
requested
modifications
is
discussed
below.

Several
of
the
industry
commenters
contended
that
restricting
sources
to
a
maximum
control
efficiency
credit
of
90
percent
will
eliminate
an
important
incentive
for
sources
to
take
extra
steps
to
maximize
the
efficiency
of
add­
on
control
devices.
The
commenters
stated
that
allowing
credit
for
efficiencies
above
90
percent
would
encourage
those
operators
who
are
able
to
achieve
these
levels
to
run
controls
in
the
most
efficient
manner,
as
opposed
to
running
at
90
percent,
regardless
of
capability.
At
a
minimum,
the
commenters
requested
that
the
final
rule
allow
credit
for
control
efficiencies
greater
than
90
percent
for
those
process
units
with
no
MACT
control
requirements.
The
commenters
contended
that
because
these
emission
units
are
not
required
to
meet
any
specified
percent
reduction,
there
is
no
logical
reason
why
they
should
be
limited
to
receiving
credit
for
only
up
to
a
90
percent
reduction.

Several
commenters
suggested
that
we
allow
compliance
with
the
EA
provisions
to
be
based
on
a
single
pollutant,

specifically,
THC,
methanol,
or
formaldehyde.
With
this
modification,
sources
would
only
be
required
to
test
for
one
pollutant
instead
testing
for
all
six
HAP
that
comprise
140
"
total
HAP."

Several
commenters
requested
that
we
allow
sources
to
combine
emissions
averaging
with
the
PBCO.
Specifically,

the
commenters
requested
that
sources
be
allowed
to
apply
the
emissions
credit
generated
from
controlling
a
process
unit,
for
which
control
is
not
required,
to
another
process
unit
seeking
to
comply
with
a
PBCO
limit.
The
commenters
provided
an
example
where
a
facility
would
control
emissions
from
a
board
cooler
and
then
apply
the
resultant
emissions
reduction
to
a
press
that
had
emissions
above
the
applicable
PBCO
limit;
by
applying
the
emissions
credit
to
the
press,

the
press
emissions
would
be
reduced
below
the
PBCO
such
that
no
control
would
be
required
on
the
press
emissions.

The
commenters
stated
that
EPA
should
allow
combining
of
these
two
compliance
options
(
emissions
averaging
and
PBCO)

because
doing
so
would
make
the
rule
more
cost­
effective,

and
the
result
would
be
equally
beneficial
to
the
environment.

Industry
commenters
also
requested
that
we
modify
the
EA
provisions
to
allow
facilities
to
receive
emission
credits
for
P2
activities,
such
as
product
reformulation,
routing
process
unit
exhaust
to
existing
onsite
combustion
sources,

lowering
dryer
operating
temperatures,
partial
capture
and
control
of
process
unit
emissions,
increasing
use
of
hardwood
species,
production
curtailment,
and
scheduled
process
unit
downtime.
According
to
the
commenters,
not
141
allowing
P2
encourages
the
use
of
add­
on
controls
like
incineration,
rather
than
environmentally
beneficial
options
that
may
not
involve
add­
on
control
technology.
The
commenters
asserted
that
quantifying
emissions
from
pollution
prevention
projects
would
not
be
difficult
under
the
PCWP
emission
averaging
program.
According
to
the
commenters,
the
facility
would
calculate
the
"
total
allowable
emissions"
and
then
apply
a
90
percent
reduction
to
determine
the
equivalent
MACT
floor
level
of
control,
and
then
compare
the
total
emission
level
to
the
controlled
emission
level.

Response:
We
included
an
EA
compliance
option
in
the
proposed
rule
as
an
equivalent,
more
flexible,
and
less
costly
alternative
to
the
compliance
options
for
add­
on
control
systems.
As
explained
in
the
preamble
to
the
proposed
rule,
we
based
the
EA
provisions,
in
part,
on
the
EA
provisions
in
the
Hazardous
Organic
NESHAP
(
HON),
with
some
differences.
Unlike
the
HON,
the
proposed
(
and
final)

EA
provisions
in
the
PCWP
rule
do
not
include
(
1)
limits
on
the
number
of
sources
that
can
be
included
in
an
EA,
(
2)

requirements
for
a
hazard
or
risk
analysis,
or
(
3)

application
of
a
10
percent
discount
factor
to
emissions
credit
calculations.
In
addition,
the
EA
provisions
in
the
PCWP
rule
require
that
credits
for
emissions
reductions
be
achieved
using
APCD,
and
that
the
EAP
be
based
on
emissions
of
the
six
predominant
HAP
emitted
from
PCWP
process
units,
142
referred
to
as
"
total
HAP."
Also,
the
EA
provisions
do
not
allow
credit
for
reductions
beyond
90
percent.

We
disagree
with
the
commenters'
request
to
allow
credit
for
achieving
greater
than
90
percent
control
of
HAP
as
part
of
an
EAP.
We
note
that
the
90
percent
MACT
floor
level
(
upon
which
the
emissions
averaging
provisions
are
based)

reflects
the
inherent
variability
in
uncontrolled
emissions
from
PCWP
process
units
and
the
decline
in
performance
of
control
devices
applied
to
these
process
units.
The
data
set
used
to
establish
the
MACT
floor
is
composed
of
pointin
time
test
reports,
some
of
which
show
a
greater
than
90
percent
control
efficiency;
however,
we
selected
90
percent
as
the
MACT
floor
level
of
control
to
reflect
inherent
performance
variability.
Therefore,
it
would
be
inappropriate
to
allow
PCWP
facilities
to
receive
credit
for
similar
point­
in­
time
performance
tests
showing
greater
than
90
percent
control,
considering
that
the
same
types
of
control
technologies
would
be
used.

Regarding
the
commenters'
request
to
allow
credit
for
greater
than
90
percent
control
for
those
sources
with
no
MACT
control
requirements,
we
maintain
that
this
would
be
inappropriate
because
the
same
issues
of
emissions
variability
and
control
device
performance
apply
to
those
emission
sources,
and
they
likely
would
share
control
devices
with
PCWP
process
units
that
do
have
MACT
control
requirements.
143
We
have
rejected
the
commenters'
suggestion
to
base
the
EA
provisions
on
a
single
pollutant
(
e.
g.,
THC,
methanol
or
formaldehyde),
and
retained
the
requirement
in
the
final
rule
that
the
EAP
must
be
based
on
total
HAP.
The
predominant
HAP
emitted
from
a
given
process
unit
varies,

with
some
process
units
emitting
methanol
as
the
predominant
HAP
and
others
emitting
formaldehyde
or
acetaldehyde
as
the
predominant
HAP.
However,
the
predominant
HAP
will
always
be
one
of
the
six
we
have
identified
in
the
definition
of
total
HAP
in
the
PCWP
rule.
If
we
based
the
EAP
on
only
one
pollutant,
process
units
that
emit
the
target
HAP
in
small
quantities
will
not
be
correctly
accounted
for
in
the
EAP,

resulting
in
potentially
less
stringent
control
and
greater
potential
risk
than
would
result
with
other
control
options.

As
noted
above,
we
did
not
include
a
hazard/
risk
study
as
part
of
the
proposed
EAP
because
we
were
requiring
that
the
emissions
reductions
be
based
on
total
HAP,
and
PCWP
process
units
generally
emit
the
same
six
primary
HAP,
although
in
different
quantities
and
ratios.
Basing
the
EAP
on
a
single
pollutant
would
eliminate
our
rationale
for
not
requiring
a
risk
analysis.
We
also
note
that,
while
THC
emissions
are
an
acceptable
surrogate
for
monitoring
the
performance
of
an
add­
on
control
device
(
same
control
device
mechanisms
that
reduce
THC
emissions
reduce
HAP
emissions),
THC
emissions
are
not
an
accurate
surrogate
for
establishing
baseline
HAP
emissions
for
uncontrolled
process
units,
and
thus,
the
EAP
144
should
not
be
based
solely
on
THC
emissions.
Although
all
PCWP
process
units
emit
THC,
uncontrolled
THC
emissions
from
softwoods
are
substantially
higher
than
from
hardwoods
due
to
non­
HAP
compounds
(
e.
g.,
pinenes)
present
in
softwoods.

Therefore,
allowing
sources
without
add­
on
controls
to
focus
on
THC
reductions
achieved
by
increasing
hardwood
usage
might
reduce
THC
emissions
but
would
have
a
minimal
impact
on
HAP
emissions.
For
these
reasons,
we
believe
that,
for
the
purpose
of
this
rulemaking,
THC
should
only
be
used
as
a
surrogate
for
HAP
when
assessing
the
performance
of
an
add­
on
control
device,
and
should
not
be
used
as
a
surrogate
for
establishing
the
required
and
actual
mass
removal
of
HAP
as
part
of
an
EAP.

We
disagree
with
the
commenters
that
combining
the
EA
and
PBCO
options
will
result
in
equivalent
emissions
reductions.
As
we
stated
in
our
response
to
previous
comments
regarding
PBCO
(
see
section
IV.
G),
we
developed
the
PBCO
limits
to
provide
an
option
for
sources
that
develop
pollution
prevention
techniques.
The
PBCO
limits
represent
applicability
cutoffs
such
that
sources
with
emissions
below
the
applicable
PBCO
thresholds
are
not
required
to
further
reduce
those
emissions
below
MACT
levels.
By
combining
PBCO
limits
with
the
emissions
averaging
plans,
as
proposed
by
the
commenter,
we
would
be
allowing
higher­
emitting
sources
(
i.
e.,
those
that
cannot
meet
a
PBCO
and
which
should
be
controlled)
to
escape
controls
by
artificially
lowering
145
their
emissions
(
using
the
credits
from
the
EAP)
to
levels
that
would
qualify
as
"
low­
emitting"
(
below
PBCO
limits).

This
is
counter
to
the
intent
of
the
PBCO
and
would
result
in
lower
emissions
reductions
than
would
be
achieved
without
combining
these
two
compliance
options;
therefore,
this
does
not
represent
an
option
that
is
equivalent
to
the
MACT
floor
and
is
not
allowed
in
the
final
rule.

We
also
disagree
with
the
commenters'
suggestion
to
modify
the
EA
provisions
to
allow
sources
to
receive
credit
for
P2
projects
because:
(
1)
compliance
options
(
i.
e.,
PBCO)

already
exist
for
any
P2
projects
that
prove
feasible,
and
(
2)
inclusion
of
currently
undemonstrated
P2
projects
within
EAP
would
unnecessarily
complicate
these
plans
and
hamper
enforcement.
As
we
noted
previously
in
section
IV.
G.
2
of
this
preamble,
the
final
rule
allows
PCWP
facilities
to
use
both
pollution
prevention
(
PBCO)
and
emissions
averaging
at
the
same
facility;
sources
are
only
limited
in
that
they
cannot
apply
both
options
to
the
same
process
unit.
We
also
disagree
with
the
commenters'
assertion
that
quantifying
the
emissions
reductions
from
P2
projects
would
not
be
difficult.
Quantifying
the
emissions
reductions
associated
with
P2
projects
has
historically
been
a
contentious
issue,

especially
when
a
baseline
emission
level
must
be
established
from
which
to
calculate
the
emissions
reduction.

We
believe
that
the
same
issues
apply
for
PCWP
facilities,

especially
given
the
fact
that
P2
techniques
have
not
been
146
widely
used
or
documented
in
the
PCWP
industry.
In
contrast,
emission
reductions
achieved
through
the
use
of
add­
on
control
systems
are
easily
documented.
The
PBCO
were
established
to
address
the
future
development
and
implementation
of
pollution
prevention
techniques;
however,

the
resultant
PBCO
limits
do
not
require
that
emissions
reductions
be
determined.
Instead,
sources
simply
demonstrate
that
they
are
below
the
PBCO
limit
and
will
continue
to
operate
in
a
manner
that
ensures
they
will
remain
below
the
PBCO
limit.

Regarding
the
suggested
P2
option
of
increasing
a
facility's
use
of
hardwood
species,
in
addressing
other
issues,
commenters
stressed
the
difficulties
associated
with
maintaining
a
consistent
wood
material
flow
in
terms
of
species,
moisture
content,
etc.,
which
would
suggest
that
an
operating
condition
based
on
maintaining
a
set
level
of
wood
species
would
be
unworkable.
Furthermore,
for
veneer
dryers,
where
species
identification
(
hardwood
vs.

softwood),
and
thus
enforcement,
is
fairly
straightforward
from
the
standpoint
of
both
visual
inspection
and
endproduct
we
have
already
established
separate
MACT
floors
for
softwood
and
hardwood
veneer
dryers
(
and
require
no
further
emissions
reductions
from
hardwood
veneer
dryers).

When
the
end
product
is
particleboard
or
MDF,
and
the
raw
material
is
in
the
form
of
wood
chips,
planer
shavings,
or
sawdust,
determining
how
much
of
that
material
is
softwood
147
versus
hardwood
would
be
very
difficult,
and
likely
unenforceable.
Because
of
commenters'
concerns
that
an
operating
condition
based
on
wood
species
is
technically
unworkable
and
the
associated
enforcement
issues,
we
believe
this
option
is
not
viable.

Regarding
process
changes
such
as
reformulation,

lowering
dryer
temperature,
and
routing
process
unit
exhaust
to
existing
combustion
devices,
the
final
rule
already
includes
compliance
options
that
would
accommodate
all
of
these
strategies.
For
example,
product
reformulation
and
lowering
dryer
temperature
are
potential
P2
options,
and
the
PBCO
limits
would
apply
if
the
P2
efforts
sufficiently
lower
emissions.
The
PCWP
rule
distinguishes
between
green
(
high
temperature,
high
moisture)
rotary
dryers
and
dry
(
low
temperature,
low
moisture)
rotary
dryers
and
requires
no
further
emissions
reductions
from
dry
rotary
dryers.

Regarding
the
use
of
existing
combustion
units
as
control
devices,
the
final
rule
allows
sources
to
route
emissions
to
onsite
combustion
units
for
incineration.
The
final
rule
also
allows
sources
to
control
a
portion
of
a
process
unit's
emission
stream
as
part
of
an
emissions
average.
However,

we
disagree
that
incineration
of
emissions
in
onsite
process
units
is
a
pollution
prevention
measure.
Therefore,

compliance
with
the
PBCO
using
process
incineration
is
not
allowed
in
the
final
rule.
The
add­
on
control
system
and
emissions
averaging
compliance
options
are
available
for
148
process
units
controlled
by
routing
exhaust
to
an
onsite
combustion
unit.

The
final
PCWP
rule
does
not
allow
production
curtailment
to
be
counted
as
part
of
an
emissions
averaging
plan.
As
stated
in
the
preamble
to
the
proposed
rule
(
68
FR
1276
at
1285),
we
do
not
have
facility­
wide
uncontrolled
emissions
data
and
facility­
wide
controlled
emissions
data
for
each
PCWP
facility
to
determine
the
baseline
emissions
and
percent
reduction
in
HAP
achieved
by
each
facility.

Therefore,
the
MACT
floor
is
not
based
on
facility­
wide
emissions
and
emissions
reductions
achieved
during
year
"
x."

Instead,
the
MACT
floor
is
based
on
(
1)
the
presence
or
absence
of
certain
MACT
controls
(
in
place
as
of
April
2000)

on
certain
types
of
process
units
and
(
2)
test
data
showing
that
these
controls
reduce
emissions
by
greater
than
or
equal
to
90
percent.
We
applied
the
MACT
floor
methodology
at
the
process
unit
level
because
we
had
the
most
accurate
data
at
the
process­
unit
level,
making
this
approach
the
most
technically
and
legally
sound.
The
PCWP
industry
is
very
dynamic,
with
frequent
shutdowns
of
equipment
for
maintenance,
and
occasionally
longer
shutdowns
(
e.
g.,

monthlong
if
demand
drops.
The
PCWP
rule
requires
emissions
from
specified
process
units
at
impacted
PCWP
facilities
to
be
reduced
by
90
percent,
regardless
of
what
the
levels
of
emissions
are
for
those
facilities
in
a
particular
year.

Therefore,
implementation
of
the
final
PCWP
rule
at
149
individual
PCWP
facilities
will
result
in
greater
emissions
reductions
in
years
of
greater
production
and
lesser
emissions
reductions
during
years
of
lower
production.
As
mentioned
in
the
response
to
the
previous
comment,
the
emissions
averaging
provisions
must
achieve
emissions
reductions
that
are
greater
than
or
equal
to
those
that
would
be
achieved
using
the
add­
on
control
system
compliance
options,
which
specify
which
process
units
must
be
controlled.
If
we
allowed
"
credit"
for
production
curtailments,
the
overall
emissions
reduction
achieved
through
the
emissions
averaging
provisions
would
not
be
equivalent
to
what
would
be
achieved
through
the
use
of
the
add­
on
control
system
compliance
options,
and
therefore,
the
EAP
would
not
be
a
MACT­
equivalent
alternative.
For
example,
if
we
allowed
production
curtailments
to
count
toward
an
emissions
average,
then
a
facility
that
shuts
down
one
of
two
parallel
production
lines
(
each
of
which
includes
dryers
and
a
press,
plus
HAP­
emitting
equipment
that
does
not
have
associated
control
requirements)
may
not
be
required
to
control
the
emissions
from
any
of
the
dryers
or
press
on
the
remaining
production
line.
However,
if
the
same
facility
opted
to
comply
with
the
add­
on
control
system
compliance
options,
then
it
would
be
required
to
control
the
press
and
dryer
emissions
from
the
remaining
production
line
by
90
percent
regardless
of
whether
or
not
the
other
production
line
was
shut
down.
In
order
to
maintain
150
equivalency
between
the
EA
provisions
and
the
add­
on
control
system
compliance
options
and
to
preserve
the
required
HAP
emissions
reductions,
the
final
PCWP
rule
does
not
allow
production
curtailment
to
be
counted
as
part
of
an
emissions
averaging
plan.

Comment:
One
commenter
objected
to
the
inclusion
of
the
EA
option
in
the
rule
primarily
because
of
the
lack
of
a
requirement
to
conduct
a
hazard
or
risk
study.
This
commenter
asserted
that
removing
a
certain
mass
of
HAP
regardless
of
identity
is
not
equivalent
to
the
other
compliance
options,
and
when
the
dose­
response
and
exposure
data
are
examined,
it
should
be
obvious
that
trading
one
HAP
for
another
to
meet
a
required
mass
removal
(
RMR)
is
not
an
acceptable
option.
The
commenter
noted
that
there
are
currently
no
methods
for
weighting
the
toxicity
of
HAP
and
that
the
effects
of
simultaneous
exposure
to
several
HAP
also
are
unknown.
The
commenter
contended
that,
because
80
percent
of
the
PCWP
facilities
in
the
U.
S.
pose
cancer
risks
greater
than
1
in
1
million,
emissions
reductions
should
be
required
at
these
facilities
rather
than
allowing
potential
increases
in
toxic
emissions
from
certain
process
units.

Response:
We
disagree
with
commenter's
assertion
that
inclusion
of
the
EA
provisions
will
potentially
increase
toxic
emissions
at
certain
PCWP
process
units.
As
stated
in
the
preamble
to
the
proposed
rule
(
68
FR
1289­
1290,
January
9,
2003),
PCWP
facilities
have
fewer
pollutants
of
concern
151
(
as
compared
to
HON
facilities)
and
are
likely
to
have
similar
HAP
emissions
from
the
emission
points
(
process
units)
that
would
be
used
to
generate
debits
and
credits.

The
PCWP
facilities
emit
6
primary
HAP,
whereas
HON
facilities
may
emit
over
140
different
HAP.
The
PCWP
facilities
choosing
to
comply
through
emission
averaging
must
account
for
the
emissions
of
the
six
primary
HAP
("
total
HAP"),
which
represent
greater
than
96
percent
of
the
mass
of
HAP
emitted
from
PCWP
process
units.
Because
the
MACT
control
technologies
are
effective
in
reducing
the
emissions
of
all
six
of
these
HAP,
and
the
EA
provisions
require
the
use
of
add­
on
control
technologies
for
creditgenerating
sources
in
an
EAP,
we
believe
that
the
EA
provisions
will
achieve
a
hazard/
risk
benefit
comparable
to
what
would
be
achieved
through
point­
by­
point
compliance.

Although
the
final
rule
does
not
require
a
hazard/
risk
study,
States
will
still
have
the
discretion
to
require
a
PCWP
facility
that
requested
approval
of
an
EAP
to
conduct
a
hazard/
risk
study
(
or
could
preclude
the
facility
from
using
emissions
averaging
altogether).

Comment:
Several
commenters
requested
that
we
revise
the
definitions
of
some
of
the
variables
used
in
the
EA
equations
in
the
final
rule
to
clarify
that
sources
can
take
credit
for
emission
reductions
achieved
through
partial
control
of
debit­
generating
process
units.

Response:
We
agree
with
the
commenters'
request
and
152
revised
the
definitions
of
some
of
the
variables
used
in
the
EA
equations
in
today's
final
rule
to
clarify
that
partial
credits
generated
from
debit­
generating
process
units
that
are
undercontrolled
can
be
included
in
the
calculation
of
the
AMR.
For
example,
a
PCWP
facility
may
decide
to
control
30
percent
of
the
emissions
from
a
green
rotary
dryer
and
80
percent
of
the
emissions
from
a
blender
as
part
of
an
EAP
in
order
to
achieve
a
HAP
reduction
that
is
the
same
as
or
greater
than
what
the
facility
would
have
achieved
by
controlling
the
green
dryer
emissions
alone
by
90
percent.

In
this
example,
the
green
rotary
dryer
is
a
debitgenerating
unit
because
it
has
MACT
control
requirements;

however,
the
green
dryer
can
receive
credit
in
the
AMR
calculation
for
any
partial
emissions
reductions
that
are
achieved.

H.
Testing
and
Monitoring
Requirements
1.
Test
Methods
Comment:
Several
commenters
noted
that
one
of
the
NCASI
test
methods,
NCASI
IM/
CAN/
WP­
99.01,
has
been
updated,
and
requested
that
the
final
rule
refer
to
the
revised
version.

One
of
the
commenters
provided
a
revised
version
of
the
method,
identified
as
NCASI
IM/
CAN/
WP­
99.02.
This
commenter
noted
that
the
trained
NCASI
sampling
team
was
able
to
get
good
consistent
results
with
the
original
version
of
the
method
both
in
the
laboratory
and
in
the
field,
but
that
sampling
contractors
had
difficulty
obtaining
valid
results.
153
The
commenter
maintained
that
the
revised
version
is
easier
to
understand,
includes
more
details,
and
reflects
the
comments
of
the
contractors
that
have
experience
with
the
original
method.
The
commenter
also
stated
that
the
quality
assurance
requirements
were
strengthened
in
the
revised
version
to
ensure
good
results.
Several
commenters
also
noted
that
NCASI
is
currently
developing
a
new
method
for
measuring
the
six
HAP
("
total
HAP")
listed
in
the
PCWP
rule.

Therefore,
the
commenters
requested
that
we
include
language
in
the
final
rule
that
would
allow
PCWP
facilities
to
use
future
methods
once
they
have
been
reviewed
by
EPA
and
have
passed
Method
301
validation
at
a
PCWP
plant.

Response:
We
reviewed
the
revised
NCASI
method
IM/
CAN/
WP­
99.02
supplied
by
the
commenter
and
agree
that
the
revised
method
should
be
used;
therefore,
we
have
included
NCASI
IM/
CAN/
WP­
99.02
in
the
today's
final
rule.
Regarding
the
development
of
future
test
methods,
if
and
when
a
new
method
for
measuring
HAP
from
PCWP
sources
is
developed
and
validated
via
EPA
Method
301,
we
will
issue
an
amendment
to
the
final
rule
to
include
the
use
of
that
method
as
an
alternative
to
the
methods
included
in
the
final
rule
for
measuring
total
HAP
(
i.
e.,
NCASI
Method
IM/
CAN/
WP/
99.02
and
EPA
Method
320­­
Measurement
of
Vapor
Phase
Organic
and
Inorganic
Emission
by
Extractive
FTIR).
In
the
meantime,
if
the
new
method
is
validated
using
Method
301,
then
the
Method
301
results
can
be
used
to
request
approval
to
use
154
the
new
method
on
a
site­
specific
basis.

Comment:
Several
commenters
noted
that
the
tracer
gas
method
for
determining
capture
efficiency,
developed
by
a
PCWP
company
and
included
in
the
proposed
rule
(
68
FR
1276,

Appendix
A),
is
a
"
work
in
progress."
These
commenters
included
with
their
comments
a
copy
of
field
validation
tests
conducted
at
a
PCWP
facility.
The
commenters
noted
that
future
tests
are
planned
using
the
tracer
gas
method
and
that
the
results
of
these
tests
should
help
EPA
improve
the
use
and
application
of
the
proposed
tracer
gas
test.

Response:
We
have
reviewed
the
results
of
the
first
field
validation
test
of
the
tracer
gas
method
and
note
that
the
commenters
did
not
provide
any
specific
recommendations
for
modifying
the
tracer
gas
method
as
it
was
proposed.

Therefore,
other
than
a
few
minor
wording
changes,
we
did
not
make
any
substantive
changes
to
the
tracer
gas
method
in
the
final
rule.
If
the
results
of
subsequent
field
tests
demonstrate
a
need
to
(
further)
modify
the
tracer
gas
method,
we
will
issue
an
amendment
to
the
final
rule
to
incorporate
the
necessary
changes.

2.
Sampling
locations
Comment:
Several
commenters
recommended
that
the
rule
be
reworded
to
clearly
state
that
inlet
sampling
should
take
place
at
the
functional
inlet
of
a
control
device
sequence
or
at
the
primary
HAP
control
device
inlet.
For
example,

the
commenters
noted
that
the
final
rule
needs
to
clarify
155
that
sampling
should
take
place
at
the
inlet
of
a
WESP
that
precedes
an
RTO
instead
of
between
the
two
devices.
The
commenters
noted
that
many
WESP­
RTO
control
systems
are
too
closely
coupled
to
allow
for
a
sampling
location
in
between
that
meets
the
requirements
of
Method
1
or
1A,
40
CFR
60,

Appendix
A.

Response:
We
agree
with
the
commenters
and
have
revised
the
final
PCWP
rule
to
indicate
that,
for
HAP­
altering
controls
in
sequence,
such
as
a
wet
control
device
followed
by
a
thermal
oxidizer,
sampling
sites
must
be
located
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)
and
prior
to
any
releases
to
the
atmosphere.
In
addition,
as
discussed
in
section
IV.
F
of
this
preamble,
the
final
rule
also
clarifies
that
facilities
demonstrating
compliance
with
a
PBCO
limit
for
a
process
unit
equipped
with
a
wet
control
device
must
locate
the
sampling
site
prior
to
the
wet
control
device.

3.
Testing
Under
Representative
Operating
Conditions
Comment:
Several
commenters
objected
to
the
proposed
requirement
to
test
process
units
under
representative
operating
conditions.
The
commenters
argued
that,
because
the
initial
compliance
tests
determine
the
outer
limits
of
compliance,
those
tests
should
be
conducted
at
the
boundaries
of
expected
performance
for
the
process
and
control
units.
These
commenters
noted
that
testing
at
156
"
representative"
conditions
would
not
accurately
simulate
true
operating
conditions,
and
thus,
the
operating
parameter
limits
would
be
too
narrow.
Therefore,
the
commenters
contended
that
the
final
rule
should
specify
that
initial
compliance
tests
should
be
conducted
at
the
extremes
of
the
expected
operating
range
for
the
parameter
and
control
device
function.
In
addition,
one
of
the
commenters
noted
that
the
testing
provisions
should
also
address
potential
conflicts
with
traditional
State
requirements
to
test
at
maximum
or
design
conditions.

Response:
The
proposed
rule
defined
representative
operating
conditions
as
those
conditions
under
which
"
the
process
unit
will
typically
be
operating
in
the
future,

including
use
of
a
representative
range
of
materials[...]

and
representative
temperature
ranges."
We
disagree
that
the
proposed
requirement
to
test
under
representative
operating
conditions
will
conflict
with
State
requirements
and
result
in
operating
parameter
limits/
ranges
that
are
too
narrow.
We
wish
to
clarify
that
the
definition
of
"
representative
operating
conditions"
refers
to
the
full
range
of
conditions
at
which
the
process
unit
will
be
operating
in
the
future.
We
expect
that
facilities
will
test
under
a
variety
of
conditions,
including
upper
and/
or
lower
bounds,
to
better
define
the
minimum
or
maximum
operating
parameter
limit
or
broaden
their
operating
limit
ranges
(
where
applicable).
For
example,
if
a
facility
157
generally
operates
a
process
unit
(
equipped
with
an
RTO)

under
conditions
that
require
the
RTO
to
be
operated
at
a
minimum
temperature
of
1450

F
to
ensure
compliance
with
the
standards,
but
at
other
times
operates
that
process
unit
under
conditions
such
that
the
minimum
RTO
operating
temperature
must
be
1525

F
to
ensure
compliance,
then
the
facility
has
two
options.
One
option
is
for
the
facility
to
incorporate
both
of
these
operating
conditions
into
their
permit
such
that
they
are
subject
to
two
different
operating
parameter
limits
(
minimum
temperatures),
one
for
each
(
defined)
operating
condition.
As
an
alternative,
the
facility
could
decide
to
comply
with
the
parameter
limit
associated
with
the
"
worst­
case"
operating
conditions
(
most
challenging
conditions
for
the
RTO),
which
in
this
example
would
correspond
to
maintaining
a
minimum
RTO
operating
temperature
of
1525

F,
and
thus,
they
could
demonstrate
continuous
compliance
regardless
of
the
operating
condition
as
long
as
they
maintained
the
RTO
temperature
at
or
above
1525

F.
Also,
as
discussed
in
more
detail
in
section
IV.
H
of
this
preamble,
we
have
revised
the
monitoring
requirements
for
process
units
without
control
devices
to
allow
these
sources
to
establish
a
range
of
compliant
parameter
values.
In
addition,
those
PCWP
facilities
operating
biofilters
must
maintain
their
biofilter
bed
temperature
within
the
range
established
during
the
initial
performance
test
and,
if
available,
previous
performance
158
tests.
If
the
final
PCWP
rule
required
testing
at
maximum
operating
conditions,
there
would
be
no
way
for
facilities
to
identify
their
operating
parameter
ranges.
For
these
reasons,
we
maintain
that
the
requirement
to
test
at
representative
operating
conditions
is
appropriate
for
the
PCWP
rule.

4.
Process
Incineration
Monitoring
Requirements
Comment:
Several
commenters
expressed
approval
for
the
proposed
exemption
from
testing
and
monitoring
requirements
for
those
process
units
with
emissions
introduced
into
the
flame
zone
of
an
onsite
combustion
unit
with
a
capacity
greater
than
or
equal
to
44
megawatts
(
MW)(
150
million
Btu/
hr).
In
addition,
several
of
these
commenters
requested
that
we
expand
upon
this
exemption
in
the
final
rule.

First,
the
commenters
requested
that
we
extend
the
exemption
to
include
situations
where
the
process
unit
exhaust
is
introduced
into
the
combustion
unit
with
the
combustion
air.

The
commenters
noted
that
we
had
included
such
exemptions
in
the
HON
(
40
CFR,
Part
63,
Subpart
G)
and
in
the
Pulp
and
Paper
Cluster
Rule
(
40
CFR,
Part
63,
Subpart
S)
in
recognition
of
the
fact
that
boilers
greater
than
44
MW
typically
had
greater
than
¾
­
second
residence
time,
ran
hotter
than
1,500

F,
and
usually
had
destruction
efficiencies
greater
than
98
percent
(
see
65
FR
3909,

January
25,
2000,
and
65
FR
80762,
December
22,
2000,
at
§
63.443(
d)(
4)(
ii)).
The
commenters
stated
that
the
design
159
and
construction
of
PCWP
boilers
follow
the
same
principles
that
would
allow
for
these
operating
conditions.
Second,

the
commenters
requested
that
we
also
exempt
smaller
combustion
units
(
less
than
44
MW,
or
150
million
Btu/
hr)

from
the
testing
and
monitoring
requirements
if
the
process
unit
exhaust
is
introduced
into
the
flame
zone
of
the
combustion
unit.
The
commenters
noted
that
most
of
the
combustion
units
associated
at
PCWP
facilities
are
smaller
units
and
that
testing
of
these
units
can
be
complicated
by
their
configuration
and
integration
with
other
process
units.

Response:
After
reviewing
available
information
on
process
incineration
at
PCWP
facilities,
we
decided
to
include
smaller
combustion
units
in
the
exemption
from
testing
and
monitoring
requirements
if
the
process
exhaust
enters
into
the
flame
zone.
As
part
of
this
change,
we
have
included
definitions
of
"
flame
zone"
and
"
combustion
unit"

in
the
final
rule.
However,
we
decided
not
to
include
an
exemption
for
PCWP
combustion
units
that
introduce
the
process
exhaust
with
the
combustion
air.
As
noted
by
the
commenters,
the
HON
and
the
final
pulp
and
paper
MACT
I
rule
exempt
from
testing
and
monitoring
requirements
combustion
devices
with
heat
input
capacity
greater
than
or
equal
to
44
MW.
The
HON
also
exempts
from
testing
and
monitoring
combustion
devices
with
capacity
less
than
44
MW
if
the
exhaust
gas
to
be
controlled
enters
with
the
primary
fuel.
160
If
the
exhaust
gas
to
be
controlled
does
not
enter
with
the
primary
fuel,
then
testing
and
continuous
monitoring
of
firebox
temperature
is
required
by
the
HON.
Similarly,
the
final
pulp
and
paper
MACT
I
rule
exempts
from
testing
and
monitoring
requirements
combustion
devices
(
including
recovery
furnaces,
lime
kilns,
boilers,
or
process
heaters)

with
capacity
less
than
44
MW
if
the
exhaust
stream
to
be
controlled
enters
into
the
flame
zone
or
with
the
primary
fuel.
Similar
to
the
HON
and
pulp
and
paper
MACT
I
rules,

the
final
PCWP
rule
extends
the
exemption
from
testing
and
monitoring
requirements
to
combustion
units
with
heat
input
capacity
less
than
44
MW,
provided
that
the
exhaust
gas
to
be
treated
enters
into
the
combustion
unit
flame
zone.
If
the
exhaust
gas
enters
into
the
combustion
unit
flame
zone,

the
required
90
percent
control
efficiency
may
be
assumed.

If
the
exhaust
gas
does
not
enter
into
the
flame
zone,
then
the
testing
and
monitoring
requirements
for
thermal
oxidizers
will
apply.

As
noted
by
the
commenter,
the
HON
and
the
final
pulp
and
paper
MACT
I
rule
exempted
boilers
(
and
recovery
furnaces
at
pulp
and
paper
mills)
with
heat
input
capacity
greater
than
44
MW
from
testing
and
monitoring
requirements
because
performance
data
showed
that
these
large
boilers
achieve
at
least
98
percent
combustion
of
HAP
when
the
emission
streams
are
introduced
with
the
primary
fuel,
into
the
flame
zone,
or
with
the
combustion
air.
Lime
kilns
at
161
pulp
and
paper
mills
were
excluded
from
this
provision
because
we
did
not
have
any
data
to
show
that
lime
kilns
can
achieve
the
required
destruction
efficiency
when
the
HAP
emission
stream
is
introduced
with
the
combustion
air.

Therefore,
lime
kilns
at
pulp
and
paper
mills
that
accept
HAP
emission
streams
must
introduce
the
stream
into
the
flame
zone
or
with
the
primary
fuel.
We
do
not
have
the
data
to
show
that
the
design
and
construction
of
large
(>
44
MW)
combustion
units
at
PCWP
plants
would
be
similar
to
boilers
found
at
pulp
and
paper
mills.
Furthermore,

combustion
units
at
PCWP
plants
with
heat
input
capacity
of
greater
than
44
MW
are
less
prevalent
than
smaller
(
i.
e.,

less
than
44
MW)
PCWP
combustion
units,
and
many
of
these
smaller
combustion
units
are
not
boilers.
As
stated
above,

the
final
rule
exempts
these
smaller
combustion
units
from
the
testing
and
monitoring
requirements
provided
that
the
HAP
emission
stream
is
introduced
into
the
flame
zone.
For
these
reasons,
the
final
PCWP
rule
does
not
extend
the
exemption
from
testing
and
monitoring
to
those
boilers
greater
than
44
MW
that
introduce
the
HAP
emission
stream
with
the
combustion
air.

5.
Selection
of
Operating
Parameter
Limits
for
Add­
on
Control
Systems
Comment.
Several
commenters
stated
that
the
inlet
static
pressure
to
a
thermal
or
catalytic
oxidizer
is
not
a
reliable
indicator
of
the
flow
through
the
oxidizer,
the
162
destruction
efficiency,
or
the
capture
efficiency.
The
commenters
also
noted
that
the
preamble
to
the
PCWP
rule
stated
that
monitoring
the
static
pressure
can
indicate
to
the
operator
when
there
is
a
problem
such
as
plugging.

However,
the
commenters
stated
that
static
pressure
is
usually
the
last
indicator
of
these
types
of
control
device
problems.
As
discussed
in
the
promulgation
BID,
the
commenters
agreed
that
measuring
those
parameters
helps
to
assess
the
overall
condition
of
the
oxidizer
but
provided
reasons
why
setting
limits
on
these
parameters
is
inappropriate.
The
commenters
further
noted
that
monitoring
the
static
pressure
helps
to
control
the
speed
of
the
fan
or
the
oxidizer
dampers
so
that
all
the
air
flows
are
balanced.

According
to
the
commenters,
static
pressure
is
adjusted
to
avoid
vacuum
conditions
in
the
ductwork
of
multiple­
dryer
systems
treated
by
one
control
device
when
one
dryer
is
shut
down,
to
improve
emission
collection
efficiency
and
prevent
fugitive
emissions,
and
to
adjust
the
pressure
drop
across
a
bag
filter
as
it
fills
with
particulates,
among
other
reasons.
However,
the
commenters
stated
that,
if
operators
are
required
to
keep
the
static
pressure
within
an
operating
range,
it
will
limit
their
ability
to
maintain
capture
efficiency.
The
commenters
expressed
similar
concerns
regarding
air
flow
rate
monitoring
and
noted
that
numerous
factors
affect
the
air
flow
through
the
control
device,

including
the
rate
of
water
removal
in
dryers,
leakage
of
163
tramp
air
into
the
process,
the
number
of
processes
operating
for
control
units
that
receive
emissions
from
multiple
production
units,
and
the
overall
production
speed
due
to
process
adjustments.
The
commenters
noted
that,
in
those
cases
where
air
flow
to
the
oxidizer
is
not
constant,

monitoring
the
air
flow
through
the
oxidizer
will
not
be
an
accurate
measure
of
capture
efficiency.

Response:
After
reviewing
the
information
provided
by
the
commenters,
we
agree
that,
while
monitoring
the
static
pressure
or
air
flow
rate
helps
to
assess
the
overall
condition
of
the
oxidizer
and
provides
an
indication
that
emissions
are
being
captured,
setting
operating
limits
on
these
parameters
is
not
appropriate
for
the
reasons
given
by
the
commenters.
Therefore,
today's
final
rule
deletes
the
proposed
requirement
to
monitor
the
static
pressure
or
air
flow
rate
for
thermal
and
catalytic
oxidizers.

Comment:
Several
commenters
requested
that
we
modify
the
procedures
for
determining
the
minimum
operating
temperature
(
operating
limit)
for
thermal
and
catalytic
oxidizers.
The
commenters
stated
that,
due
to
the
normal
variation
in
combustion
temperatures,
a
facility
will
have
to
perform
the
initial
compliance
test
at
lower­
than­
normal
temperature
conditions
to
ensure
that
the
minimum
combustion
temperature
will
be
set
at
a
level
that
they
can
continuously
meet.
The
commenters
requested
that
we
allow
facilities
to
operate
the
thermal
oxidizers
up
to
50
°
F
lower
than
the
average
obtained
164
by
the
performance
test
and
allow
facilities
to
operate
RCO
at
a
level
that
is
100
°
F
above
the
minimum
operating
temperature
of
the
catalyst.
The
commenters
also
noted
that,
when
the
THC
concentration
in
the
inlet
is
high,
the
RCO
will
not
need
any
additional
heat
and
it
can
operate
at
temperatures
higher
than
the
set
point.
Therefore,
if
the
initial
compliance
tests
are
conducted
under
these
conditions,
the
operating
temperature
limit
will
be
too
high
for
production
rates
at
less
than
full
capacity.

Commenters
also
stated
that,
for
RCO,
the
thermocouple
should
be
placed
in
a
location
to
measure
the
temperature
of
the
gas
in
the
combustion
chamber
between
the
catalyst
beds
instead
of
in
a
location
to
measure
the
gas
stream
before
it
reaches
the
catalyst
bed.
The
commenters
noted
that,

because
the
gas
flow
reverses
direction
in
RCO,
the
"
inlet"

temperature
monitor
will
not
consistently
measure
the
gas
at
the
same
point
in
the
process
such
that
sometimes
the
gas
temperature
will
be
recorded
after
the
catalyst
beds
instead
of
before.
The
commenters
further
noted
that
placement
of
the
monitor
inside
the
combustion
chamber
would
eliminate
the
need
for
multiple
monitors
and
avoid
problems
such
as
overheating
and
burnout
of
the
catalyst
media
caused
by
the
temperature
delay
between
the
burner
and
the
RCO
inlet.

Response:
We
disagree
with
the
commenters'
request
to
include
a
50

F
margin
around
the
minimum
operating
temperature
established
during
the
thermal
oxidizer
165
compliance
test.
In
general,
selection
of
the
representative
operating
conditions
for
both
the
process
and
the
control
device
for
conducting
the
performance
test
is
an
important,
and
sometimes
complex,
task.
We
maintain
that
establishing
the
add­
on
control
device
operating
limit
at
the
level
demonstrated
during
the
performance
test
is
appropriate.
We
note
that
the
PCWP
rule
allows
a
facility
to
select
the
temperature
operating
limits
based
on
sitespecific
operating
conditions,
and
the
facility
is
able
to
consider
the
need
for
temperature
fluctuations
in
this
selection.
The
PCWP
rule
requires
that
the
operating
limit
be
based
on
the
average
of
the
three
minimum
temperatures
measured
during
a
3­
hour
performance
test
(
rather
than
on
the
average
temperature
over
the
3­
hour
period,
for
example)

to
accommodate
normal
variation
during
operation
and
ensure
that
the
minimum
temperature
established
represents
the
lowest
of
the
temperatures
measured
during
the
compliant
test.
For
example,
during
a
3­
hour,
3­
run
performance
test,

the
operating
limit
would
be
determined
by
averaging
together
the
lowest
15­
minute
average
temperature
measured
during
each
of
the
3
runs.
However,
continuous
compliance
with
the
operating
limit
is
based
on
a
3­
hr
block
average.

For
a
typical
3­
hour
set
of
data,
this
means
that
the
3­
hr
block
average
will
be
higher
than
the
average
of
the
3
lowest
15­
minute
averages,
so
the
temperature
monitoring
provisions
already
have
a
built­
in
compliance
margin.
In
166
addition,
the
final
rule
allows
PCWP
facilities
to
conduct
multiple
performance
tests
to
set
the
minimum
operating
temperature
for
RCO
and
RTO,
so
PCWP
sources
would
have
the
option
to
conduct
their
own
studies
(
under
a
variety
of
representative
operating
conditions)
in
order
to
establish
the
minimum
operating
temperature
at
a
level
that
they
could
maintain
and
that
would
provide
them
with
an
acceptable
compliance
margin.
We
believe
these
provisions
allow
sufficient
flexibility,
and
an
additional
tolerance
for
a
50oF
temperature
variation
is
not
necessary.
Therefore,
the
final
rule
does
not
allow
facilities
to
operate
thermal
oxidizers
50
°
F
lower
than
the
average
temperature
during
testing.

With
regard
to
RCO,
we
agree
with
the
commenters
that
when
the
THC
concentration
in
the
inlet
is
high,
the
RCO
will
not
need
any
additional
heat
and
it
can
operate
at
temperatures
higher
than
the
set
point.
Therefore,
if
the
initial
compliance
tests
are
conducted
under
these
conditions,
the
operating
temperature
limit
will
be
too
high
for
production
rates
at
less
than
full
capacity.
However,

the
final
rule
requires
emissions
testing
under
representative
operating
conditions
and
not
maximum
operating
conditions.
In
addition,
we
do
not
agree
with
the
commenter's
solution
to
set
the
operating
limit
at
100
°
F
above
the
minimum
operating
[
design]
temperature
of
the
catalyst.
As
with
RTO,
we
believe
it
is
incumbent
upon
the
167
facility
to
demonstrate
performance
and
establish
the
operating
limits
during
the
compliance
demonstration
test.

Therefore,
the
final
rule
requires
the
facility
to
establish
the
minimum
catalytic
oxidizer
operating
temperature
during
the
compliance
test.
However,
as
noted
below,
we
have
provided
more
flexibility
to
the
facility
regarding
temperature
monitoring
for
RTO
and
RCO.

We
recognize
that
in
a
typical
RTO
and
RCO
the
combustion
chamber
contains
multiple
burners,
and
that
each
of
these
burners
may
have
multiple
thermocouples
for
measuring
the
temperature
associated
with
that
burner.
The
final
rule
requires
establishing
and
monitoring
a
minimum
firebox
temperature
for
RTO.
In
an
RTO,
the
minimum
firebox
temperature
is
actually
represented
by
multiple
temperature
measurements
for
multiple
burners
within
the
combustion
chamber.
Thus,
the
final
rule
clarifies
that
facilities
operating
RTO
may
monitor
the
temperature
in
multiple
locations
within
the
combustion
chamber
and
calculate
the
average
of
the
temperature
measurements
to
use
in
establishing
the
minimum
firebox
temperature
operating
limit.

Regarding
RCO,
we
agree
with
the
commenters
that,

because
the
gas
flow
reverses
direction
in
RCO,
the
"
inlet"

temperature
monitor
will
not
consistently
measure
the
gas
at
the
same
point
in
the
process,
such
that
sometimes
the
gas
temperature
will
be
recorded
after
the
catalyst
beds
instead
168
of
at
the
inlet
to
the
beds.
We
did
not
intend
to
require
the
separate
measurement
of
each
"
inlet"
temperature
by
switching
the
data
recording
back
and
forth
to
coincide
with
the
flow
direction
into
the
bed.
The
intention
is
to
monitor
the
minimum
temperature
of
the
gas
entering
the
catalyst
to
ensure
that
the
minimum
temperature
is
maintained
at
the
operating
level
during
which
compliance
was
demonstrated.
This
can
be
accomplished
by
measuring
the
temperature
in
the
regenerative
canisters
at
one
or
more
locations.
Measuring
the
inlet
temperatures
of
each
catalyst
bed
and
then
determining
the
average
temperature
for
all
catalyst
beds
is
one
approach.
Even
though
some
of
the
beds
are
cooling
and
others
are
heating,
the
average
across
all
of
the
catalyst
beds
should
not
vary
significantly.
Another
acceptable
alternative
is
monitoring
the
combustion
chamber
temperature,
as
suggested
by
the
commenters.
The
monitoring
location(
s)
selected
by
the
facility
may
depend
on
the
operating
conditions
(
i.
e.,
THC
loading
to
the
unit)
during
the
performance
test
and
how
the
unit
is
expected
to
be
operated
in
the
future.
The
objective
is
to
establish
monitoring
and
operating
limits
that
are
representative
of
the
conditions
during
the
compliance
demonstration
test(
s)
and
representative
of
the
temperature
to
which
the
catalyst
is
exposed.
We
recognize
the
need
for
flexibility
in
selecting
the
temperature(
s)
to
be
monitored
as
operating
limits
for
RCO.
Therefore,
the
169
final
rule
provides
flexibility
by
allowing
facilities
with
RCO
to
choose
between
basing
their
minimum
RCO
temperature
limit
on
the
average
of
the
inlet
temperatures
for
all
catalyst
beds
or
the
average
temperature
within
the
combustion
chamber.
If
there
are
multiple
thermocouples
at
the
inlet
to
each
catalyst
bed,
then
we
would
expect
facilities
to
average
the
measurements
from
each
thermocouple
to
provide
a
representative
catalyst
bed
inlet
temperature
for
each
individual
catalyst
bed.

Finally,
the
final
rule
also
includes
an
option
(
in
lieu
of
monitoring
oxidizer
temperature)
for
monitoring
and
maintaining
the
oxidizer
outlet
THC
concentration
at
or
below
the
operating
limit
established
during
the
performance
test.
Use
of
the
THC
monitoring
option
would
eliminate
the
concerns
regarding
establishing
and
monitoring
oxidizer
operating
temperatures
(
in
effect,
it
provides
facilities
complete
flexibility
in
operation
of
the
control
device,
as
long
as
the
THC
outlet
concentration
remains
below
the
operating
limit).

Comment:
One
commenter
recommended
that
we
require
sampling
and
testing
of
the
catalyst
activity
level
for
RCO.

The
commenter
stated
that
the
proposed
requirement
to
monitor
inlet
pressure
may
not
be
sufficient
to
detect
catalyst
problems
such
as
poisoning,
blinding,
or
degradation.

Response:
We
agree
with
the
commenter
that
a
catalyst
170
activity
level
check
is
needed
because
catalyst
beds
can
become
poisoned
and
rendered
ineffective.
An
activity
level
check
can
consist
of
passing
an
organic
compound
of
known
concentration
through
a
sample
of
the
catalyst,
measuring
the
percentage
reduction
of
the
compound
across
the
catalyst
sample,
and
comparing
that
percentage
reduction
to
the
percentage
reduction
for
a
fresh
sample
of
the
same
type
of
catalyst.
Generally,
the
PCWP
facility
would
remove
a
representative
sample
of
the
catalyst
from
the
catalytic
oxidizer
bed
and
then
ship
the
sample
to
a
testing
company
for
analysis
of
its
ability
to
oxidize
organic
compounds
(
e.
g.,
by
a
flame
ionization
detector).

In
response
to
this
comment,
we
added
to
the
final
rule
a
requirement
for
facilities
with
catalytic
oxidizers
to
perform
an
annual
catalyst
activity
check
on
a
representative
sample
of
the
catalyst
and
to
take
any
necessary
corrective
action
to
ensure
that
the
catalyst
is
performing
within
its
design
range.
Corrective
actions
may
include
washing
or
baking
out
the
catalytic
media,

conducting
an
emissions
test
to
ensure
the
catalytic
media
is
resulting
in
the
desired
emissions
reductions,
or
partial
or
full
media
replacement.
Catalysts
are
designed
to
have
an
activity
range
over
which
they
will
reduce
emissions
to
the
desired
levels.
Therefore,
the
final
rule
specifies
that
corrective
action
is
needed
only
when
the
catalyst
activity
is
outside
of
this
range.
It
is
not
our
intention
171
for
facilities
to
replace
catalyst
if
the
catalytic
media
is
not
performing
at
the
maximum
level
it
achieved
when
the
catalyst
was
new.
Also,
the
final
rule
specifies
that
the
catalyst
activity
check
must
be
done
on
"
a
representative
sample
of
the
catalyst"
to
ensure
that
facilities
that
may
have
recently
conducted
a
partial
media
replacement
do
not
sample
only
the
fresh
catalytic
media
for
the
catalyst
activity
check.

Comment.
Several
commenters
stated
that
the
proposed
operating
requirements
for
pressure
drop
across
the
biofilter
bed
should
be
removed
from
the
final
PCWP
rule.

The
commenters
contended
that
pressure
drop
is
a
good
parameter
to
monitor
voluntarily
because
it
indicates
the
permeability
and
age
of
the
biofilter
bed,
helping
to
determine
maintenance
and
replacement
needs;
however,
it
is
not
an
indicator
of
destruction
efficiency.
The
commenters
noted
that,
because
of
normal
wear
and
tear,
the
pressure
drop
gradually
increases
over
the
2­
to
5­
year
life
span
of
the
biofilter,
so
it
would
not
be
possible
to
maintain
a
constant
operating
pressure.
The
commenters
further
noted
that
the
supporting
materials
in
the
project
docket
did
not
provide
any
information
or
data
that
would
support
the
idea
that
pressure
drop
is
an
indication
of
HAP
destruction
efficiency,
but
only
indicated
that
pressure
drop
was
an
indication
of
the
age
of
the
biofilter.
For
these
reasons,

the
commenters
argued
that
setting
an
absolute
limit
on
172
pressure
drop
was
inappropriate.

The
commenters
also
requested
that
the
proposed
requirements
to
monitor
the
pH
of
the
biofilter
bed
effluent
be
removed
from
the
final
PCWP
rule.
The
commenters
noted
that
pH
is
a
good
parameter
to
monitor
voluntarily
because
it
indicates
the
environmental
conditions
inside
the
biofilter
bed
and
can
indicate
the
presence
of
organic
acids
and
THC
decomposition
products,
but
it
is
not
a
reliable
indicator
of
destruction
efficiency.
According
to
the
commenters,
small
fluctuations
of
pH
are
expected
and
have
little
effect
on
the
biofilter
performance;
therefore,
the
narrow
range
of
pH
values
that
would
be
established
as
an
operating
range
by
the
initial
compliance
tests
should
not
be
used
alone
to
determine
biofilter
performance.
The
commenters
also
noted
some
problems
associated
with
continuous
measurement
of
pH.
According
to
the
commenters,

some
biofilter
units
operate
with
periodic
irrigation
of
the
bed,
such
that
the
effluent
flow
is
not
constant
and
continuous
monitoring
is
not
possible.
The
commenters
also
pointed
to
an
NCASI
survey
that
confirmed
that
continuous
pH
monitoring
would
be
impractical
for
the
facilities
surveyed.

The
commenters
stated
that,
because
none
of
the
PCWP
facilities
surveyed
could
find
a
link
between
pH
alone
and
biofilter
performance,
none
of
those
facilities
currently
have
continuous
pH
monitors
on
their
biofilters.

In
addition,
several
commenters
requested
changes
to
the
173
proposed
requirement
to
monitor
the
inlet
temperature
of
the
biofilter.
These
commenters
agreed
that
temperature
is
a
parameter
that
should
be
monitored
for
biofilters,
but
argued
that
the
location
of
the
temperature
monitor
should
be
changed
from
the
biofilter
inlet
to
the
biofilter
bed
or
biofilter
outlet.
The
commenters
noted
that
the
biofilter
bed
temperature
has
the
greatest
impact
on
biological
activity.
According
to
the
commenters,
the
biofilter
inlet
temperature
is
not
a
good
indicator
of
bed
temperature
and
can
change
very
rapidly
depending
upon
the
operating
rate
of
the
press,
the
humidity,
and
the
ambient
temperature.

Response:
We
agree
with
the
commenters
that
increases
in
pressure
drop
will
occur
over
time
and
will
not
necessarily
equate
to
a
reduction
in
control
efficiency,

making
an
absolute
limit
on
pressure
drop
ineffective
in
demonstrating
continuous
compliance.
Therefore,
we
have
removed
the
requirement
to
monitor
pressure
drop
from
the
operating
requirements
for
biofilters
in
the
final
PCWP
rule.
We
have
also
removed
the
requirement
to
monitor
pH
from
the
final
rule.
Although
pH
is
an
indicator
of
the
health
of
the
microbial
population
inside
the
biofilter,
we
agree
with
the
commenters
that
including
continuous
pH
monitoring
as
an
operating
requirement
for
biofilters
may
not
be
appropriate.

We
also
agree
with
the
commenters
that
the
biofilter
bed
temperature
has
the
greatest
impact
on
biological
activity
174
and
that
the
location
for
monitoring
the
biofilter
temperature
should
be
changed.
We
did
not
propose
monitoring
of
biofilter
bed
temperature
because
we
thought
that
monitoring
of
biofilter
inlet
temperature
would
be
simpler
because
only
one
thermocouple
would
be
required.

The
temperature
inside
the
biofilter
bed
can
change
in
different
areas
of
the
bed,
and
therefore,
depending
on
the
biofilter,
multiple
thermocouples
may
be
necessary
to
get
an
accurate
picture
of
the
temperature
conditions
inside
the
biofilter
bed.
Prior
to
proposal
we
rejected
the
idea
of
monitoring
the
biofilter
exhaust
temperature
because
temperature
measured
at
this
location
can
be
affected
by
ambient
temperature
(
especially
for
biofilters
with
short
stacks)
more
than
the
temperature
inside
the
biofilter
bed.

We
now
conclude
that
there
is
no
better,
more
representative
way
to
monitor
the
temperature
to
which
the
biofilter
microbial
population
is
exposed
than
to
directly
monitor
the
temperature
of
the
biofilter
bed.
According
to
our
MACT
survey
data,
most
facilities
with
biofilters
are
already
monitoring
biofilter
bed
temperature.
Therefore,
the
final
rule
requires
continuous
monitoring
of
the
temperature
inside
the
biofilter
bed.

The
proposed
rule
would
have
allowed
facilities
to
specify
their
own
monitoring
methods,
monitoring
frequencies,
and
averaging
times
for
the
proposed
biofilter
operating
parameters
(
i.
e.,
inlet
temperature,
effluent
pH,
175
and
pressure
drop).
However,
monitoring
of
temperature
is
not
as
subjective
as
monitoring
biofilter
effluent
pH
and
pressure
drop;
therefore,
as
an
outgrowth
of
our
decision
to
not
require
monitoring
of
biofilter
effluent
pH
and
pressure
drop,
the
final
rule
specifies
the
monitoring
method,

frequency,
and
averaging
time
for
biofilter
bed
temperature
monitoring.
The
final
rule
requires
that
each
thermocouple
be
placed
in
a
representative
location
and
clarifies
that
multiple
thermocouples
may
be
used
in
different
locations
within
the
biofilter
bed.
The
temperature
data
(
i.
e.,

average
temperature
across
all
the
thermocouples
located
in
the
biofilter
bed
if
multiple
thermocouples
are
used)
must
be
monitored
continuously
and
reduced
to
a
24­
hour
block
average.
A
24­
hour
block
average
was
selected
for
biofilter
temperature
monitoring
because
we
recognize
that
there
may
be
some
diurnal
variation
in
temperature.
Facilities
wishing
to
reflect
a
diurnal
temperature
variation
when
establishing
their
biofilter
temperature
may
wish
to
perform
some
test
runs
during
peak
daily
temperatures
and
other
test
runs
early
in
the
morning,
when
temperatures
are
at
their
lowest.

Facilities
may
choose
to
observe
parameters
other
than
biofilter
bed
temperature,
but
will
not
be
required
to
record
or
control
them
for
the
PCWP
rule.
We
believe
that
many
factors
can
affect
biofilter
performance,
either
alone
(
e.
g.,
a
media
change)
or
in
concert
with
one
another
(
e.
g.,
176
a
loss
of
water
flow
results
in
a
sharp
change
in
temperature
and
pH).
The
factors
that
have
the
greatest
effect
on
biofilter
performance
are
likely
to
be
sitespecific
However,
based
on
the
comments
we
have
received,

we
conclude
that
extensive
biofilter
parameter
monitoring
is
not
the
best
method
for
ensuring
continuous
compliance.
To
promote
enforceability
of
the
PCWP
rule,
we
have
added
a
requirement
to
perform
periodic
testing
of
biofilters.
The
final
rule
requires
facilities
to
conduct
a
repeat
test
at
least
every
2
years
and
within
180
days
after
a
portion
of
the
biofilter
bed
is
replaced
with
a
new
type
of
media
or
more
than
50
percent
(
by
volume)
of
the
biofilter
media
is
replaced
with
the
same
type
of
media.
Each
repeat
test
must
be
conducted
within
2
years
of
the
previous
test
(
e.
g.,
2
years
after
the
initial
compliance
test,
or
2
years
after
the
test
following
a
media
change).
We
are
requiring
repeat
testing
after
a
partial
or
wholesale
change
to
another
media
type
(
considered
a
modification
of
the
biofilter)
because
such
a
modification
can
impact
the
performance
of
the
biofilter.
Facilities
that
replace
biofilter
media
with
a
new
type
of
media
(
e.
g,
bark
versus
synthetic
media)
must
also
re­
establish
the
limits
of
the
biofilter
bed
temperature
range.
We
believe
that
substantial
replacement
of
the
biofilter
media
(
e.
g.,
replacement
of
more
than
50
percent
of
the
media)
with
the
same
type
of
media
may
affect
short­
term
performance
of
the
biofilter
while
the
177
replacement
media
becomes
acclimated,
and
therefore,
the
final
rule
requires
a
repeat
performance
test
following
this
type
of
media
replacement.
However,
PCWP
facilities
that
replace
biofilter
media
with
the
same
type
of
media
are
not
required
to
re­
establish
the
biofilter
bed
temperature
range.
In
the
case
of
"
same­
media"
replacements,
we
believe
it
is
appropriate
for
PCWP
facilities
to
be
able
to
use
data
from
previous
performance
tests
to
establish
the
limits
of
the
temperature
range.
During
repeat
testing
following
replacement
with
the
same
type
of
media,
facilities
can
verify
that
the
biofilter
remains
within
the
temperature
range
established
previously
or
establish
a
new
compliant
temperature
range.
Facilities
using
a
THC
CEMS
that
choose
to
comply
with
the
THC
compliance
options
(
i.
e.,
90
percent
reduction
in
THC
or
outlet
THC
concentration
less
than
or
equal
to
20
ppmvd)
may
use
the
data
from
their
CEMS
in
lieu
of
conducting
repeat
performance
testing.

Comment:
Several
commenters
requested
that
the
final
rule
allow
new
biofilters
a
longer
period
than
180
days
to
establish
operating
parameter
levels.
These
commenters
suggested
a
1­
year
period,
because
that
would
be
long
enough
to
observe
the
full
seasonal
variation
in
parameters
and
find
the
true
operating
maxima
and
minima.

Response:
We
disagree
that
more
than
180
days
is
necessary
to
establish
operating
parameter
limits
for
biofilters.
As
mentioned
previously,
we
have
eliminated
the
178
proposed
requirement
to
establish
operating
limits
for
pH
and
pressure
drop.
Today's
final
rule
contains
two
options
for
biofilter
operating
parameter
limits:
biofilter
bed
temperature
range
and
outlet
THC
concentration.
While
allowing
1
year
to
establish
the
biofilter
bed
temperature
operating
range
is
reasonable
due
to
seasonal
temperature
variations,
1
year
is
not
necessary
for
establishing
an
outlet
THC
concentration
limit.
Furthermore,
the
final
rule
already
allows
facilities
to
expand
their
operating
ranges
(
see
§
63.2262(
m)(
3))
through
additional
emissions
testing.

The
compliance
date
for
existing
facilities
is
3
years
after
promulgation
of
the
final
PCWP
rule,
and
existing
facilities
are
allowed
180
days
following
the
compliance
date
to
conduct
performance
testing
and
establish
the
operating
parameter
limits.
If
there
is
concern
that
180
days
is
not
long
enough
for
a
new
biofilter
installation
to
operate
under
the
full
range
of
biofilter
bed
temperatures,

then
existing
facilities
should
begin
operation
of
their
biofilter
well
before
the
compliance
date
(
e.
g.,
180
days
prior
to
the
compliance
date
if
1
year
is
needed).

Facilities
also
have
the
option
of
testing
their
biofilter
prior
to
the
compliance
date
to
establish
one
extreme
of
their
biofilter
bed
temperature
range.
The
compliance
date
for
new
PCWP
facilities
is
the
effective
date
of
the
rule
(
if
startup
is
before
the
effective
date)
or
upon
initial
startup
(
if
the
initial
startup
is
after
the
effective
date
179
of
the
rule),
and
biofilters
installed
at
new
PCWP
facilities
would
have
up
to
180
days
following
the
compliance
date
to
establish
the
operating
parameter
limits.

To
address
situations
where
a
new
biofilter
is
installed
at
an
existing
facility
more
than
180
days
after
the
compliance
date
(
e.
g.,
to
replace
an
existing
RTO),
we
have
included
section
§
63.2262(
m)(
2)
to
the
final
PCWP
rule,
which
allows
existing
sources
that
install
new
biofilters
up
to
180
days
following
the
initial
startup
date
of
the
biofilter
to
establish
the
operating
parameter
limits.
Thus,
new
biofilter
installations
are
given
time
for
establishment
of
operating
parameter
limits
regardless
of
where
they
are
installed
at
new
or
existing
sources.

Comment:
Multiple
commenters
supported
the
option
to
continuously
monitor
THC
at
control
device
outlets
to
demonstrate
compliance,
but
suggested
that
either
the
procedure
for
determining
the
operating
limits
or
the
length
of
the
averaging
periods
be
altered.
The
commenters
stated
that
THC
concentration
at
a
control
device
outlet
is
not
a
parameter
that
can
be
easily
adjusted
by
operators
over
short
periods
of
time.
The
commenters
stated
that
3
hours
is
not
a
long
enough
block
to
avoid
deviations
from
compliance
given
the
variability
of
the
process.
The
commenters
provided
an
analysis
of
THC
data
from
a
biofilter
outlet
that
showed
multiple
deviations
occurring
over
a
two
month
period
when
a
3­
hour
block
average
was
used
and
few
to
180
zero
deviations
when
a
24­
hour
or
7­
day
block
average
was
used
for
the
operating
limits.
The
commenters
stated
that
because
HAP
destruction
efficiency
of
biofilters
does
not
vary
much
with
time,
the
longer
block
average
would
not
be
environmentally
harmful.

Response:
While
THC
emissions
at
the
outlet
of
a
biofilter
may
vary,
the
THC
emissions
at
the
outlet
of
a
thermal
or
catalytic
oxidizer
should
not
vary
greatly.

Although,
as
stated
by
the
commenters,
the
HAP
destruction
efficiency
of
biofilters
is
not
subject
to
large
short­
term
variations,
the
same
is
not
true
for
thermal
and
catalytic
oxidizers
(
e.
g.,
a
sudden
significant
decrease
in
temperature
could
result
in
a
sudden
decrease
in
HAP
reduction).
Therefore,
we
believe
it
is
appropriate
to
maintain
the
3­
hour
block
averaging
requirement
for
THC
monitoring
for
thermal
and
catalytic
oxidizers.
However,
we
have
expanded
the
THC
averaging
requirement
for
biofilters
to
a
24­
hour
block
average
to
provide
more
flexibility.
The
THC
operating
limit
for
biofilters
would
be
established
as
the
maximum
of
three
15­
minute
recorded
readings
during
emissions
testing.
We
also
note
the
continuous
monitoring
of
THC
is
not
required
for
all
APCD,
but
is
an
alternative
to
continuous
monitoring
of
temperature.
Furthermore,

facilities
can
conduct
multiple
performance
tests
at
different
operating
conditions
to
increase
their
maximum
THC
concentration
operating
limit.
181
6.
Selection
of
Monitoring
Requirements
for
Uncontrolled
Process
Units
Comment:
Several
commenters
recommended
that
we
change
the
title
of
proposed
section
63.2262
(
n)
(
How
do
I
conduct
performance
tests
and
establish
operating
requirements?
­

Establishing
uncontrolled
process
unit
operating
requirements)
to
"
Establishing
operating
requirements
for
production­
based
compliance
option
process
units"
for
the
final
rule.
The
commenters
stated
that
the
proposed
title
implied
that
no
controls
of
any
kind
are
being
applied
to
these
process
units,
when
in
fact
facilities
may
be
using
pollution
prevention
techniques
to
reduce
emissions.
The
commenters
also
objected
to
wording
within
the
proposed
section
that
suggests
that
temperature
is
the
only
parameter
affecting
HAP
emissions
from
the
process
units.
The
commenters
suggested
that
the
requirements
be
revised
in
the
final
rule
to
give
sources
more
flexibility
in
identifying
and
documenting
those
process
unit
operating
parameters
that
are
critical
to
maintaining
compliance
with
the
PBCO
limits.

Response:
At
proposal,
our
intention
was
to
establish
operating
requirements
for
those
process
units
complying
with
rule
requirements
without
the
use
of
an
APCD.
There
are
two
situations
in
the
PCWP
rule
where
process
units
may
not
have
an
add­
on
control
device:
(
1)
when
process
units
meet
the
PBCO,
or
(
2)
when
process
units
used
to
generate
emissions
averaging
debits
do
not
have
an
add­
on
APCD
that
182
partially
controls
emissions.
To
clarify
this
for
the
final
rule
and
to
address
the
commenters'
concern
regarding
applicability
of
§
63.2262(
n),
we
changed
the
title
of
the
section
to
"
Establishing
operating
requirements
for
process
units
meeting
compliance
options
without
a
control
device."

We
agree
with
the
commenters
that
temperature
alone
is
not
necessarily
the
sole
factor
affecting
HAP
emissions
from
some
process
units.
A
variety
of
factors
can
affect
HAP
emissions,
and
the
controlling
parameter
for
one
process
unit
may
be
different
than
the
controlling
parameter
for
another
process
unit.
Therefore,
the
final
rule
gives
sources
more
flexibility
in
selecting
and
establishing
operating
limits
for
process
units
without
add­
on
controls.

The
final
rule
requires
facilities
to
identify
and
document
the
operating
parameter(
s)
that
affect
HAP
emissions
from
the
process
unit
and
to
establish
appropriate
monitoring
methods
and
monitoring
frequencies.
We
recognize
that
it
is
not
practical
to
continuously
monitor
every
process­

unitspecific
factor
that
could
affect
uncontrolled
emissions
(
e.
g.,
there
is
no
way
to
monitor
and
determine
a
3­
hour
block
average
of
wood
species
mix
for
a
particleboard
plant).
However,
some
parameters
are
suitable
for
continuous
monitoring
(
e.
g.,
process
operating
temperature,

furnish
moisture
content)
and
are
already
monitored
as
part
of
normal
operation
but
not
for
compliance
purposes.
We
believe
that
daily
records
of
most
parameters
would
be
183
sufficient
to
ensure
ongoing
compliance
(
e.
g.,
daily
average
process
operating
temperature,
furnish
moisture,
resin
type,

wood
species
mix)
if
the
parameters
do
not
deviate
from
the
ranges
for
these
parameters
during
the
initial
compliance
test.
Therefore,
in
the
final
PCWP
rule,
we
have
replaced
the
proposed
3­
hour
block
average
temperature
monitoring
requirements
for
process
units
without
control
devices
with
a
requirement
to
maintain,
on
a
daily
basis,
the
process
unit
operating
parameter(
s)
within
the
ranges
established
during
the
performance
test.
This
gives
facilities
the
flexibility
to
decide
which
parameters
they
will
monitor
and
control,
while
providing
enforcement
personnel
with
records
that
can
be
used
to
assess
and
compare
the
day­
to­
day
operation
of
the
process
unit
to
the
controlling
operating
parameters.
Facilities
are
also
allowed
to
decide
for
each
parameter
the
appropriate
monitoring
methods,
monitoring
frequencies,
and
averaging
times
(
not
to
exceed
24
hours
for
continuously
monitored
parameters
such
as
temperature
and
wood
furnish
moisture).
Also,
to
ensure
that
the
HAP
emissions
measured
during
the
compliance
tests
are
representative
of
actual
emissions,
the
final
rule
requires
testing
at
representative
operating
conditions,
as
defined
in
the
rule.

7.
Data
Collection
and
Handling
Comment:
Several
commenters
requested
clarifications
and
changes
to
the
proposed
requirements
related
to
data
184
collection
and
handling
for
CPMS.
The
commenters
stated
that
the
requirement
that
a
valid
hour
of
data
must
include
"
at
least
three
equally
spaced
data
values
for
that
hour"
is
ambiguous
and
should
be
revised.
The
commenters
recommended
that
the
final
rule
require
facilities
to
average
at
least
three
data
points
taken
at
constant
intervals,
provided
the
interval
is
less
than
or
equal
to
15
minutes.
The
commenters
further
noted
that
a
better
approach
would
be
to
drop
the
concept
of
an
hourly
average
altogether
and
simply
calculate
the
block
average
as
the
average
of
all
evenly
spaced
measurements
in
the
block
period
with
a
maximum
measurement
interval
of
15
minutes.
The
commenters
also
noted
that
the
proposed
rule
did
not
specify
how
to
calculate
the
3­
hour
block
average
when
one
or
more
of
the
individual
hours
does
not
contain
at
least
three
valid
data
values.

Commenters
also
requested
that
the
final
rule
consolidate
and
clarify
the
requirements
in
proposed
§
§
63.2268
and
63.2270
regarding
data
that
should
be
excluded
from
block
averages.
The
commenters
recommended
that
the
final
rule
explicitly
state
that
any
monitoring
data
taken
during
periods
when
emission
control
equipment
are
not
accepting
emissions
from
the
production
processes
should
be
excluded
from
hourly
or
block
averages.
The
commenters
also
noted
inconsistencies
in
the
proposed
rule
language
that
seemed
to
imply
that
data
collected
during
production
185
downtime
and
SSM
events
would
be
included
in
the
hourly
averages
but
not
in
the
block
averages.
The
commenters
stated
that,
because
SSM
events
occur
when
the
process
is
not
in
operation,
there
is
no
need
to
collect
data
from
these
periods.

Response:
We
agree
with
the
commenters
that
the
proposed
rule
language
regarding
acceptable
data
and
data
averaging
was
somewhat
ambiguous
and
have
revised
the
language
accordingly.
Following
the
commenters'

recommendation,
we
removed
the
concept
of
an
hourly
average
from
the
rule
to
allow
block
averages
to
be
calculated
as
the
average
of
all
evenly
spaced
measurements
in
the
3­
hour
or
24­
hour
block
period
with
a
maximum
measurement
interval
of
15
minutes.
In
place
of
the
requirement
for
a
valid
hourly
average
to
contain
at
least
three
equally
spaced
data
values
for
that
hour,
we
added
a
minimum
data
availability
requirement.
The
minimum
data
availability
requirement
specifies
that
to
calculate
data
averages
for
each
3­
hour
or
24­
hour
averaging
period,
you
must
have
at
least
75
percent
of
the
required
recorded
readings
for
that
period
using
only
recorded
readings
that
are
based
on
valid
data.
The
minimum
data
availability
requirement
appears
in
§
63.2270(
f)
of
today's
final
rule.
To
clarify
what
constitutes
valid
data
and
how
to
calculate
block
averages,
we
rearranged
proposed
§
§
63.2268
and
63.2270.
We
moved
proposed
§
§
63.2268(
a)(
3)

and
(
4)
to
final
§
63.2270
(
now
§
63.2270(
d)
and
(
e))
of
186
today's
final
rule.
Rather
than
repeating
which
data
should
be
excluded
from
data
averages
in
§
63.2270(
d)
and
(
e),
these
new
sections
now
refer
to
§
63.2270(
b)
and
(
c)
when
discussing
data
that
should
not
be
included
in
data
averages.
We
also
added
data
recorded
during
periods
of
startup,
shutdown,
and
malfunction
to
the
list
of
data
that
should
be
excluded
from
data
averages
in
§
63.2270.
We
believe
these
changes
to
the
structure
and
wording
of
the
rule
should
fully
address
the
commenters'
concerns.

Comment:
Several
commenters
noted
that
the
proposed
PCWP
rule
does
not
provide
any
alternatives
to
the
definition
of
a
1­
hour
period
found
in
the
MACT
general
provisions
(
40
CFR
63.2),
which
states
that
a
1­
hour
period
is
any
60­
minute
period
"
commencing
on
the
hour."
These
commenters
requested
that
facilities
be
given
the
option
of
beginning
a
1­
hour
period
at
a
time
that
is
convenient
depending
on
shift
changes,
employee
duties
at
the
end
of
a
shift,
and
settings
on
the
systems
that
record
data.

Response:
We
agree
with
the
commenters
and
have
included
a
definition
of
1­
hour
period
in
today's
final
rule
that
omits
the
phrase
"
commencing
on
the
hour."

8.
Performance
Specifications
for
CPMS
Comment:
Several
commenters
requested
that
we
revise
sections
of
the
rule
language
that
address
temperature
measurement.
The
commenters
stated
that
the
phrase
"
minimum
tolerance
of
0.75
percent,"
found
in
proposed
sections
187
63.2268(
b)(
2),
63.2268(
c)(
3),
and
63.2268(
e)(
2),
should
be
revised
to
read
"
accurate
within
0.75
percent
of
sensor
range."
The
commenters
argued
that,
because
tolerances
usually
refer
to
physical
dimensions,
this
revision
more
accurately
reflects
the
intent
of
the
PCWP
rule.
Commenters
also
recommended
that
the
sensitivity
for
chart
recorders
be
changed
from
a
sensitivity
in
the
"
minor
division
of
at
least
20
°
F"
to
"
minor
divisions
of
not
more
than
20
°
F."
The
commenters
noted
that
the
wording
in
the
proposed
rule
means
that
minor
divisions
could
be
30
°
F
or
50
°
F,
but
assumed
that
we
probably
meant
that
20
°
F
is
the
largest
minor
division
that
a
facility
can
use,
and
therefore,
stated
that
the
suggested
revision
is
more
accurate.

Response:
We
agree
that
the
proposed
temperature
measurement
requirements
should
be
clarified.
In
today's
final
rule,
we
changed
the
requirement
in
§
63.2269(
b)(
2)

(
formerly
proposed
§
63.2268(
b)(
2))
to
read
"
minimum
accuracy
of
0.75
percent
the
temperature
value."
We
eliminated
proposed
sections
§
§
63.2268(
c)
and
63.2268(
e)
from
the
final
rule
because
we
deleted
the
requirements
for
monitoring
of
pressure
or
flow.
We
also
revised
proposed
§
63.2268(
b)(
3)

to
state
that
"
If
a
chart
recorder
is
used,
it
must
have
a
sensitivity
with
minor
divisions
of
not
more
than
20oF."

Comment:
Several
commenters
requested
changes
to
the
proposed
work
practice
requirements
for
dry
rotary
dryers
and
veneer
redryers
related
to
moisture
monitoring.
The
188
commenters
noted
that
the
proposed
requirement
to
use
a
moisture
monitor
with
a
minimum
accuracy
of
1
percent
was
appropriate
for
rotary
dry
dryers
in
the
25
to
35
percent
moisture
content
range.
However,
the
commenters
stated
that
less
stringent
accuracy
requirements
should
be
included
for
veneer
redryers
to
better
correspond
with
current
practices
at
softwood
plywood
and
veneer
facilities.
Specifically,

the
commenters
requested
that
the
final
rule
revise
the
proposed
performance
specifications
for
moisture
monitors
for
veneer
redryers
to
allow
the
use
of
monitors
with
an
accuracy
of
±
3
percent
in
the
15
to
25
percent
moisture
range.
Several
commenters
also
requested
that
the
proposed
calibration
procedures
for
moisture
monitors
be
revised
in
the
final
rule
to
eliminate
grab
sampling
and
to
allow
facilities
to
follow
the
calibration
procedures
recommended
by
the
manufacturer.
The
commenters
argued
that
the
proposed
grab
sampling
procedure
is
impractical
and
that
obtaining
a
representative
grab
sample
would
be
difficult.

Response:
We
agree
with
the
commenters
that
the
proposed
moisture
monitoring
requirements
should
be
revised
in
the
final
rule
and
have
made
the
requested
changes
to
the
accuracy
requirements
for
moisture
monitors
used
with
rotary
dry
dryers
and
veneer
redryers.
We
have
also
revised
the
calibration
procedures
in
the
final
rule
to
eliminate
grab
sampling
and
to
allow
facilities
to
follow
the
manufacturer's
recommended
calibration
procedures
for
189
moisture
monitors.

I.
Routine
Control
Device
Maintenance
Exemption
(
RCDME)

Comment:
Several
commenters
requested
that
the
proposed
requirements
for
the
RCDME
be
modified
in
the
final
rule
to
give
PCWP
facilities
more
flexibility.
First,
the
commenters
requested
that
the
proposed
RCDME
allowances
(
expressed
as
a
percentage
of
the
process
unit
operating
hours)
be
increased.
The
commenters
argued
that
the
proposed
downtime
allowance
periods
are
too
short
to
allow
for
proper
maintenance.
The
commenters
noted
that
the
NCASI
survey
that
was
used
to
set
the
downtime
allowance
only
included
data
from
1999,
and
many
facilities
may
have
conducted
nonannual
maintenance
and
repairs
in
the
years
preceding
or
following
that
year.
According
to
the
commenters,
the
1999
survey
was
also
limited
in
that
the
majority
of
the
RTOs
included
in
the
survey
were
less
than
5
years
old,
and
as
the
equipment
ages
over
a
lifetime
of
5
to
15
years,
performance
will
degrade
below
the
levels
seen
in
the
1999
survey.
Therefore,
the
commenters
suggested
that
we
reexamine
the
NCASI
downtime
data
and
use
the
79th
percentile
instead
of
the
50th
percentile
to
select
downtime
allowances
that
represent
the
time
needed
for
nonannual
events.

Response:
After
reviewing
our
previous
analysis
of
the
downtime
data,
we
maintain
that
the
percentage
downtime
we
proposed
(
3
percent
for
some
process
units
and
0.5
percent
190
for
others)
calculated
on
an
annual
basis
is
appropriate
for
the
final
PCWP
rule.
The
downtime
allowance
allowed
under
the
RCDME
is
intended
to
allow
facilities
limited
time
to
perform
routine
maintenance
on
their
APCD
without
shutting
down
the
process
units
being
controlled
by
the
APCD.
We
included
the
downtime
allowance
in
the
proposed
rule
because
we
recognize
that
frequent
maintenance
must
be
performed
to
combat
particulate
and
salt
buildup
in
some
RTO
and
RCO
for
PCWP
drying
processes.
The
downtime
allowance
is
not
intended
to
cover
every
APCD
maintenance
activity,
only
those
maintenance
activities
that
are
routine
(
e.
g.,

bakeouts,
washouts,
partial
or
full
media
replacements)
and
do
not
coincide
with
process
unit
shutdowns.
Most
APCD
maintenance
should
occur
during
process
unit
shutdowns;
the
RCDME
is
a
downtime
allowance
in
addition
to
the
APCD
maintenance
downtime
that
occurs
during
process
unit
shutdowns.
We
note
that
most
PCWP
plants
do
not
operate
8,760
hours
per
year
without
shutdowns.
For
example,
the
MACT
survey
responses
indicate
that
softwood
plywood
plants
operate
for
an
average
7,540
hours
per
year,
which
would
allow
1,220
hours
for
control
device
maintenance
without
the
RCDME.
Furthermore,
the
RCDME
is
allowed
in
addition
to
APCD
downtime
associated
with
SSM
events
covered
by
the
SSM
plan
(
e.
g.,
electrical
problems,
mechanical
problems,

utility
supply
problems,
and
pre­
filter
upsets).
For
these
reasons,
the
final
rule
retains
the
RCDME
allowances
191
included
in
the
proposed
rule.

Comment:
Several
commenters
objected
to
the
proposed
requirement
that
the
maintenance
be
scheduled
at
the
beginning
of
the
semiannual
period.
The
commenters
argued
that
scheduling
maintenance
activities
at
the
beginning
of
each
semiannual
period
is
neither
consistent
with
industry
practice
nor
practical.
The
commenters
noted
that
downtime
for
maintenance
is
scheduled
as
the
need
arises,
and
downtime
schedules
change
with
need
and
production
requirements.
The
commenters
stated
that
most
facilities
have
a
general
idea
of
when
they
intend
to
conduct
routine
maintenance
activities
and
will
schedule
those
activities
whenever
possible
to
coincide
with
process
downtime
as
it
approaches.
The
commenters
further
noted
that
the
proposed
PCWP
rule
does
not
clarify
what
would
happen
if
maintenance
were
necessary
before
the
scheduled
date.
Therefore,
the
commenters
concluded
that
deleting
the
requirement
to
set
the
maintenance
schedule
at
the
beginning
of
each
semiannual
period
would
eliminate
confusion
and
better
represent
industry
practice.

Response:
We
agree
with
the
commenters
and
have
deleted
the
requirement
to
record
the
control
device
maintenance
schedule
for
the
semiannual
period
in
the
final
rule.
We
agree
that
the
proposed
requirement
would
be
impractical
because
process
unit
shutdowns
are
not
scheduled
semiannually.
Also,
the
SSM
provisions
do
not
require
192
scheduling
of
maintenance,
and
therefore,
requiring
scheduling
of
routine
maintenance
covered
under
the
RCDME
would
be
more
restrictive
than
the
requirements
for
SSM.
To
the
extent
possible,
APCD
maintenance
should
be
scheduled
at
the
same
time
as
process
unit
shutdowns.
Thus,
today's
final
rule
retains
the
requirement
that
startup
and
shutdown
of
emission
control
systems
must
be
scheduled
during
times
when
process
equipment
is
also
shut
down.

Comment:
Commenters
also
requested
that
the
proposed
RCDME
requirement
that
facilities
must
"
minimize
emissions
to
the
greatest
extent
possible"
during
maintenance
periods
be
revised
to
require
that
facilities
"
make
reasonable
efforts
to
minimize
emissions"
during
maintenance.
The
commenters
stated
that
this
revision
is
necessary
because
the
proposed
wording
could
be
interpreted
to
mean
that
sources
should
limit
production
or
shut
down
entirely
during
maintenance
periods,
which
is
contrary
to
the
intent
of
the
RCDME.

Response:
We
agree
with
the
commenters
and
have
modified
the
referenced
requirement
as
suggested
by
the
commenters.

J.
Startup,
Shutdown,
and
Malfunction
(
SSM)

Comment:
Several
commenters
noted
inconsistencies
between
the
proposed
rule
and
the
NESHAP
General
Provisions
(
40
CFR
63,
Subpart
A)
and
requested
that
these
inconsistencies
be
resolved
by
making
the
final
PCWP
rule
193
consistent
with
the
latest
version
of
the
General
Provisions.

Response:
Approximately
1
month
prior
to
publication
of
the
proposed
PCWP
rule,
we
published
proposed
amendments
to
the
NESHAP
General
Provisions
concerning
SSM
procedures
(
67
FR
72875,
December
9,
2002)
and
promulgated
them
in
May
2003
(
68
FR
32585,
May
30,
2003).
Due
to
the
timing
of
the
these
rulemakings,
the
proposed
PCWP
rule
language
did
not
reflect
our
most
recent
decisions
regarding
SSM.
To
avoid
confusion
and
promote
consistency,
we
have
revised
the
final
rule
to
reference
the
NESHAP
General
Provisions
directly,
where
applicable,
and
to
be
more
consistent
with
other
recently
promulgated
MACT
standards.
Although
the
amendments
to
the
NESHAP
General
Provisions
regarding
SSM
plans
are
currently
involved
in
litigation,
the
rule
requirements
promulgated
on
May
30,
2003,
apply
to
the
PCWP
NESHAP
unless
and
until
we
promulgate
another
revision.
In
response
to
suggestions
made
by
commenters,
we
also
consolidated
several
sections
to
clarify
the
requirements
related
to
SSM
and
to
eliminate
redundancies
in
the
final
rule.
Specifically,
we
combined
proposed
§
63.2250(
d)
with
proposed
§
63.2250(
a)
and
revised
the
resulting
§
63.2250(
a)
to
clarify
that
the
SSM
periods
mentioned
in
proposed
§
63.2250(
a)
apply
to
both
process
units
and
control
devices
and
to
clarify
when
the
compliance
options,
operating
requirements,
and
work
practice
requirements
do
and
do
not
apply.
We
also
deleted
proposed
194
§
63.2250(
e)
from
the
final
rule
because
it
was
a
duplication
of
proposed
§
63.2251(
e)
regarding
control
device
maintenance
schedules.
In
addition,
we
deleted
proposed
§
63.2250(
f)

related
to
RCO
catalyst
maintenance
because
this
section
was
misplaced
and
is
not
consistent
with
the
RCO
monitoring
requirements
in
today's
final
rule.

K.
Risk­
Based
Approaches
The
preamble
to
the
proposed
PCWP
rule
requested
comment
on
whether
there
might
be
further
ways
to
structure
the
PCWP
final
rule
to
focus
on
the
facilities
which
pose
significant
risks
and
avoid
the
imposition
of
high
costs
resulting
from
compliance
with
the
MACT
floor
standards
on
facilities
pose
little
risk
to
public
health
and
the
environment.

Specifically,
in
addition
to
an
emission
concentration­
based
applicability
exemption
discussed
in
the
promulgation
BID,

we
requested
comment
on
the
technical
and
legal
viability
of
two
risk­
based
approaches:
(
1)
an
applicability
cutoff
for
"
threshold"
pollutants
under
the
authority
of
section
112(
d)(
4);
and
(
2)
subcategorization
and
delisting
of
lowrisk
sources
under
the
authority
of
sections
112(
c)(
1)
and
(
9).
See
68
FR
at
1296­
1302.
We
indicated
that
we
would
evaluate
all
comments
before
determining
whether
either
approach
would
be
included
in
the
final
PCWP
rule.
Numerous
commenters
submitted
detailed
comments
during
the
public
comment
period
on
these
risk­
based
approaches.
These
comments
are
summarized
in
the
PCWP
promulgation
BID
(
see
195
SUPPLEMENTARY
INFORMATION
section).
In
addition,
industry
commenters
continued
to
submit
their
views
on
the
risk­
based
approaches
after
the
close
of
the
comment
period.
These
comments
are
also
included
in
the
docket
for
today's
rulemaking.

Based
on
our
consideration
of
the
comments
received
and
other
factors,
we
have
decided
to
include
one
of
the
riskbased
approaches
in
today's
final
PCWP
rule,
the
subcategorization
and
delisting
of
low­
risk
sources
under
CAA
sections
112(
c)(
1)
and
(
9).
We
do
not
expect
to
further
explore
the
use
of
section
112(
d)(
4)
of
the
CAA
to
exempt
PCWP
sources
from
the
MACT
floor
on
a
case­
by­
case
basis
or
to
set
alternative
standards,
because
PCWP
sources
emit
HAP
for
which
no
health
thresholds
have
been
established
and
because
the
legislative
history
to
the
1990
Amendments
to
the
CAA
indicates
that
Congress
considered
and
rejected
allowing
EPA
to
grant
such
source­
specific
exemptions
from
the
MACT
floor.
(
See,
e.
g.,
1
Legis.
Hist.
at
866,
877;
2
Legis.
Hist.
at
2141­
42,
3939.)

Nonetheless,
in
today's
final
rule
we
are
identifying
the
criteria
we
will
use
to
identify
low­
risk
PCWP
sources,

and
request
that
any
candidate
sources
submit
information
to
us
based
on
those
criteria
so
that
we
can
evaluate
whether
they
might
be
low­
risk.
Today's
final
rule
also
establishes
a
low­
risk
PCWP
subcategory
based
on
the
criteria
and
delists
the
subcategory
based
on
our
finding
that
no
source
196
that
would
be
eligible
to
be
included
in
the
subcategory
based
on
our
adopted
criteria
emits
HAP
at
levels
that
exceed
the
thresholds
specified
in
section
112(
c)(
9)(
B)
of
the
CAA.
To
be
found
eligible
to
be
included
in
the
delisted
source
category
sources
will
have
to
demonstrate
to
EPA
that
they
meet
the
criteria
established
by
today's
final
rule
and
assume
federally
enforceable
limitations
that
ensure
their
HAP
emissions
do
not
subsequently
increase
to
exceed
levels
reflected
in
their
eligibility
demonstrations.

V.
Statutory
and
Executive
Order
Reviews
A.
Executive
Order
12866:
Regulatory
Planning
and
Review
Under
Executive
Order
12866
[
58
FR
51735
(
October
4,

1993)],
the
Agency
must
determine
whether
the
regulatory
action
is
"
significant"
and
therefore
subject
to
Office
of
Management
and
Budget
(
OMB)
review
and
the
requirements
of
the
Executive
Order.
The
Order
defines
"
significant
regulatory
action"
as
one
that
is
likely
to
result
in
a
rule
that
may:

(
1)
have
an
annual
effect
on
the
economy
of
$
100
million
or
more
or
adversely
affect
in
a
material
way
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health
or
safety,
or
State,
local,
or
tribal
governments
or
communities;
197
(
2)
create
a
serious
inconsistency
or
otherwise
interfere
with
an
action
taken
or
planned
by
another
agency;

(
3)
materially
alter
the
budgetary
impact
of
entitlements,
grants,
user
fees,
or
loan
programs,
or
the
rights
and
obligation
of
recipients
thereof;
or
(
4)
raise
novel
legal
or
policy
issues
arising
out
of
legal
mandates,
the
President's
priorities,
or
the
principles
set
forth
in
the
Executive
Order.

Pursuant
to
the
terms
of
Executive
Order
12866,
it
has
been
determined
that
this
final
rule
is
a
"
significant
regulatory
action"
because
the
annual
costs
of
complying
with
the
final
rule
are
expected
to
exceed
$
100
million.
As
such,
this
action
was
submitted
to
OMB
for
EO
12866
review.

Changes
made
in
response
to
OMB
suggestions
or
recommendations
are
documented
in
the
public
record
(
see
ADDRESSEES
section
of
this
preamble).

We
did
not
estimate
health
and
welfare
benefits
associated
with
changes
in
emissions
of
HAP,
CO,
VOC,
PM,

NOx
and
SO2
for
this
final
rule.

B.
Paperwork
Reduction
Act
The
information
collection
requirements
in
this
rule
have
been
submitted
for
approval
to
the
OMB
under
the
Paperwork
Reduction
Act,
44
U.
S.
C.
3501
et
seq.
The
information
collection
requirements
are
not
enforceable
until
OMB
approves
them.

The
information
requirements
are
based
on
notification,
198
recordkeeping,
and
reporting
requirements
in
the
NESHAP
General
Provisions
(
40
CFR
part
63,
subpart
A),
which
are
mandatory
for
all
operators
subject
to
national
emission
standards.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
CAA
(
42
U.
S.
C.
7414).
All
information
submitted
to
the
EPA
pursuant
to
the
recordkeeping
and
reporting
requirements
for
which
a
claim
of
confidentiality
is
made
is
safeguarded
according
to
Agency
policies
set
forth
in
40
CFR
part
2,

subpart
B.

Today's
final
rule
will
require
maintenance
inspections
of
the
control
devices
but
will
not
require
any
notifications
or
reports
beyond
those
required
by
the
NESHAP
General
Provisions.
The
recordkeeping
requirements
require
only
the
specific
information
needed
to
assure
compliance.

The
annual
monitoring,
reporting,
and
recordkeeping
burden
for
this
collection
(
averaged
over
the
first
3
years
after
the
effective
date
of
the
rule)
is
estimated
to
be
4,692
labor
hours
per
year,
at
a
total
annual
cost
of
$
250,528.
This
estimate
includes
notifications
that
facilities
are
subject
to
the
rule;
notifications
of
performance
tests;
notifications
of
compliance
status,

including
the
results
of
performance
tests
and
other
initial
compliance
demonstrations
that
do
not
include
performance
tests;
startup,
shutdown,
and
malfunction
reports;

semiannual
compliance
reports;
and
recordkeeping.
In
199
addition
to
the
requirements
of
40
CFR
part
63,
subpart
A,

facilities
that
wish
to
implement
emissions
averaging
provisions
must
submit
an
emissions
averaging
plan.

Facilities
may
also
submit
a
request
for
a
routine
control
device
maintenance
exemption
to
justify
the
need
for
routine
maintenance
on
the
control
device
and
to
show
how
the
facilities
plan
to
minimize
emissions
to
the
greatest
extent
possible
during
the
maintenance.
The
average
number
of
respondents
during
the
3­
year
period
after
the
effective
date
of
the
rule
is
220,
and
the
average
number
of
responses
estimated
to
be
submitted
is
197.
The
resulting
estimated
burden
per
response
is
24
hours.
Total
capital/
startup
costs
associated
with
the
testing,
monitoring,
reporting,

and
recordkeeping
requirements
over
the
3­
year
period
of
the
ICR
are
estimated
to
be
$
122,040,
with
operation
and
maintenance
costs
of
$
5,178.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,

or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,

validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
200
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
The
OMB
control
numbers
for
the
information
collection
requirements
in
the
final
rule
will
be
listed
in
an
amendment
to
40
CFR
part
9
in
a
subsequent
Federal
Register
document
after
OMB
approves
the
ICR.

C.
Regulatory
Flexibility
Analysis
EPA
has
determined
that
it
is
not
necessary
to
prepare
a
regulatory
flexibility
analysis
in
connection
with
this
final
rule.
The
EPA
has
also
determined
that
the
final
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

For
purposes
of
assessing
the
impacts
of
today's
final
rule
on
small
entities,
small
entity
is
defined
as:
(
1)
a
small
business
ranging
from
500
to
750
employees
depending
on
the
businesses
NAICS
code;
(
2)
a
small
governmental
jurisdiction
that
is
a
government
of
a
city,
county,
town,

school
district
or
special
district
with
a
population
of
less
than
50,000;
and
(
3)
a
small
organization
that
is
any
201
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field.

After
considering
the
economic
impact
of
today's
final
rule
on
small
entities,
EPA
has
concluded
that
this
action
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
We
have
determined
that,
based
on
SBA
size
definitions
for
the
affected
industries
and
reported
sales
and
employment
data,
17
of
the
52
companies,

or
32
percent,
owning
affected
facilities
are
small
businesses.
Although
small
businesses
represent
32
percent
of
the
companies
within
the
source
category,
they
are
expected
to
incur
only
8
percent
of
the
total
industry
compliance
costs
of
$
142
million.
There
are
only
three
small
firms
with
compliance
costs
equal
to
or
greater
than
3
percent
of
their
sales.
In
addition,
there
are
seven
small
firms
with
cost­
to­
sales
ratios
between
1
and
3
percent.

We
performed
an
economic
impact
analysis
to
estimate
the
changes
in
product
price
and
production
quantities
for
the
firms
affected
by
this
rule.
The
analysis
shows
that
of
the
32
facilities
owned
by
affected
small
firms,
only
one
would
be
expected
to
shut
down
rather
than
incur
the
cost
of
compliance
with
the
rule.
Although
any
facility
closure
is
cause
for
concern,
it
should
be
noted
that
the
baseline
economic
condition
of
the
facilities
predicted
to
close
affects
the
closure
estimate
provided
by
the
economic
model.

Facilities
which
are
already
experiencing
adverse
economic
202
conditions
for
reasons
unconnected
to
this
rule
are
more
vulnerable
to
the
impact
of
any
new
costs
than
those
that
are
not.

The
analysis
indicates
that
the
rule
should
not
generate
a
significant
economic
impact
on
a
substantial
number
of
small
entities
for
the
PCWP
manufacturing
source
category
for
the
following
reasons.
First,
of
the
ten
small
firms
that
have
compliance
costs
greater
than
1
percent
of
sales,

only
three
have
compliance
costs
of
greater
than
3
percent
of
sales.
Second,
the
results
of
the
economic
impact
analysis
show
that
only
one
facility
owned
by
a
small
firm
out
of
the
32
facilities
owned
by
affected
small
firms
may
close
due
to
the
implementation
of
this
rule.
The
facility
that
may
close
rather
than
incur
the
cost
of
compliance
appears
to
have
low
profitability
levels
currently.
It
also
should
be
noted
that
the
estimate
of
compliance
costs
for
this
facility
is
likely
to
be
an
overestimate
due
to
the
lack
of
facility­
specific
data
available
to
assign
a
precise
control
cost
in
this
case.

Although
this
final
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities,

EPA
nonetheless
has
tried
to
reduce
the
impact
of
this
rule
on
small
entities.
First,
we
considered
subcategorization
based
on
production
and
throughput
level
to
determine
whether
smaller
process
units
would
have
a
different
MACT
floor
than
larger
process
units.
Our
data
show
that
203
subcategorization
based
on
size
would
not
result
in
a
less
stringent
level
of
control
for
the
smaller
process
units.

Second,
we
chose
to
set
the
control
requirements
at
the
MACT
floor
control
level
and
not
at
a
control
level
more
stringent.
Thus,
the
control
level
specified
in
the
PCWP
rule
is
the
least
stringent
allowed
by
the
CAA.
Third,
the
rule
contains
multiple
compliance
options
to
provide
facilities
with
the
flexibility
to
comply
in
the
least
costly
manner
while
maintaining
a
workable
and
enforceable
rule.
The
compliance
options
include
emissions
averaging
and
PBCO
which
allow
inherently
low­
emitting
process
units
to
comply
without
installing
add­
on
control
devices
and
facilities
to
use
innovative
technology
and
pollution
prevention
methods.
Fourth,
the
rule
includes
multiple
test
method
options
for
measuring
methanol,
formaldehyde,
and
total
HAP.
Fifth,
the
final
rule
allows
PCWP
facilities
to
demonstrate
eligibility
for
the
delisted
low­
risk
subcategory
and
thereby
avoid
MACT
altogether.
In
addition,

we
worked
with
various
trade
associations
during
the
development
of
the
rule.

D.
Unfunded
Mandates
Reform
Act
Title
II
of
the
Unfunded
Mandates
Reform
Act
of
1995
(
UMRA),
Public
Law
104­
4,
establishes
requirements
for
Federal
agencies
to
assess
the
effects
of
their
regulatory
actions
on
State,
local,
and
tribal
governments
and
the
private
sector.
Under
section
202
of
the
UMRA,
EPA
204
generally
must
prepare
a
written
statement,
including
a
cost­
benefit
analysis,
for
proposed
and
final
rules
with
"
Federal
mandates"
that
may
result
in
expenditures
by
State,

local,
and
Tribal
governments,
in
aggregate,
or
by
the
private
sector,
of
$
100
million
or
more
in
any
1
year.

Before
promulgating
an
EPA
rule
for
which
a
written
statement
is
needed,
section
205
of
the
UMRA
generally
requires
EPA
to
identify
and
consider
a
reasonable
number
of
regulatory
alternatives
and
adopt
the
least­
costly,
most
cost­
effective,
or
least­
burdensome
alternative
that
achieves
the
objectives
of
the
rule.
The
provisions
of
section
205
do
not
apply
when
they
are
inconsistent
with
applicable
law.
Moreover,
section
205
allows
EPA
to
adopt
an
alternative
other
than
the
least­
costly,
most
cost­
effective,
or
least­
burdensome
alternative
if
the
Administrator
publishes
with
the
final
rule
an
explanation
why
that
alternative
was
not
adopted.
Before
EPA
establishes
any
regulatory
requirements
that
may
significantly
or
uniquely
affect
small
governments,

including
tribal
governments,
it
must
have
developed
under
section
203
of
the
UMRA
a
small
government
agency
plan.
The
plan
must
provide
for
notifying
potentially
affected
small
governments,
enabling
officials
of
affected
small
governments
to
have
meaningful
and
timely
input
in
the
development
of
EPA
regulatory
proposals
with
significant
Federal
intergovernmental
mandates,
and
informing,
205
educating,
and
advising
small
governments
on
compliance
with
the
regulatory
requirements.

Since
this
rule
is
estimated
to
impose
costs
to
the
private
sector
in
excess
of
$
100
million
per
year,
it
is
considered
a
significant
regulatory
action.
Therefore,
we
have
prepared
the
following
statement
with
respect
to
sections
202
through
205
of
the
UMRA.

1.
Statutory
Authority
This
final
rule
establishes
control
requirements
for
existing
and
new
PCWP
sources
pursuant
to
section
112
of
the
CAA.
The
CAA
requires
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
is
commonly
referred
to
as
MACT.
Section
112(
d)(
3)
further
defines
a
minimum
level
of
control
that
can
be
considered
for
MACT
standards,
commonly
referred
to
as
the
MACT
floor,

which
for
new
sources
is
the
level
of
control
achieved
by
the
best
controlled
similar
source,
and
for
existing
sources
is
the
level
of
control
achieved
by
the
average
of
the
best
performing
12
percent
of
sources
in
the
category
(
or
the
best­
performing
five
sources
for
categories
with
fewer
than
30
sources).

Control
technologies
and
their
performance
are
discussed
in
the
background
information
document
for
this
proposal
(
Docket
numbers
A­
98­
44
and
OAR­
2003­
0048).
We
considered
emission
reductions,
costs,
environmental
impacts,
and
energy
impacts
in
selecting
the
MACT
standards.
The
final
206
standards
achieve
sizable
reductions
in
HAP
and
other
pollutant
emissions.

2.
Social
Costs
and
Benefits
The
regulatory
analyses
prepared
for
this
final
rule,

including
our
assessment
of
costs
and
benefits,
is
detailed
in
the
"
Regulatory
Impact
Analysis
for
the
Plywood
and
Composite
Wood
Products
NESHAP"
in
Docket
A­
98­
44.
Based
on
estimated
compliance
costs
associated
with
this
final
rule
and
the
predicted
change
in
prices
and
production
in
the
affected
industries,
the
estimated
social
costs
of
this
proposed
rule
are
$
135.1
million
(
1999
dollars).
The
social
costs
of
this
final
rule
are
the
costs
imposed
upon
society
as
a
result
of
efforts
toward
compliance,
and
include
the
effects
upon
consumers
of
products
made
by
the
affected
facilities.

It
is
estimated
that
3
years
after
implementation
of
the
final
rule,
HAP
would
be
reduced
by
9,700
Mg/
yr
(
11,000
tons/
yr)
due
to
reductions
in
formaldehyde,
acetaldehyde,

acrolein,
methanol
and
other
HAP
from
PCWP
sources.

Formaldehyde
and
acetaldehyde
have
been
classified
as
"
probable
human
carcinogens."
Acrolein,
methanol
and
the
other
HAP
are
not
considered
carcinogenic,
but
produce
several
other
toxic
effects.
The
requirements
of
this
proposed
rule
would
also
achieve
reductions
of
10,000
Mg/
yr
(
11,000
tons/
yr)
of
CO,
approximately
11,000
Mg/
yr
(
13,000
tons/
yr)
of
PM10,
and
approximately
25,000
Mg/
yr
(
27,000
207
tons/
yr)
of
VOC
(
approximated
as
THC).
Exposure
to
CO
can
effect
the
cardiovascular
system
and
the
central
nervous
system.
The
PM
emissions
can
result
in
fatalities
and
many
respiratory
problems
(
such
as
asthma
or
bronchitis).
These
estimates
will
be
reduced
to
the
extent
facilities
demonstrate
eligibility
to
be
included
in
the
delisted
lowrisk
subcategory.
These
estimated
reductions
occur
from
existing
sources
in
operation
3
years
after
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
(
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.

As
mentioned
earlier
in
section
III.
H
of
this
preamble,

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
208
potential
number
of
cancer
cases
avoided
and
cancer
risk
reduced
as
a
result
of
the
imposition
of
the
MACT
level
of
control
on
this
source
category.
Our
analysis
suggests
that
imposition
of
the
MACT
level
of
control
would
reduce
cancer
cases
by
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.

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
these
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
209
concentrations,
which
could
lead
to
impacts
on
human
health
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
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.
210
These
general
uncertainties
in
the
underlying
scientific
and
economics
literatures
are
discussed
in
detail
in
the
RIA
and
its
supporting
documents
and
references.

3.
Regulatory
Alternatives
Considered
The
final
standards
reflect
the
MACT
floor,
the
least
stringent
regulatory
alternative
required
under
the
CAA.
In
addition,
the
final
rule
includes
the
least
burdensome
and
most
flexible
monitoring,
reporting,
and
recordkeeping
requirements
that
we
believe
will
assure
compliance
with
the
compliance
options
and
rule
requirements.
Therefore,
the
standards
reflect
the
least
costly,
most
cost­
effective,
and
least
burdensome
regulatory
option
that
achieves
the
objectives
of
the
final
rule.

4.
Effects
on
the
National
Economy
The
economic
impact
analysis
for
this
final
rule
estimates
effects
upon
employment
and
foreign
trade
for
the
industries
affected
by
this
rule.
The
total
reduction
in
employment
for
the
affected
industries
is
0.3
percent
of
the
current
employment
level
(
or
225
employees).
This
estimate
includes
the
increase
in
employment
among
firms
in
these
industries
that
do
not
incur
any
cost
associated
with
the
final
rule.
There
is
also
minimal
change
in
the
foreign
trade
behavior
for
the
firms
in
these
industries
since
the
level
of
imports
of
affected
composite
wood
products
only
increases
by
less
than
0.1
percent.
211
5.
Consultation
with
Government
Officials
Throughout
the
development
of
this
final
rule,
we
interacted
with
representatives
of
affected
State
and
local
officials
to
inform
them
of
the
progress
of
our
rulemaking
efforts.
We
also
consulted
with
representatives
from
other
entities
affected
by
the
final
rule,
such
as
the
American
Forest
&
Paper
Association,
National
Council
for
Air
and
Stream
Improvement,
APA­
The
Engineered
Wood
Association,

Composite
Panel
Association,
American
Hardboard
Association,

Hardwood
Plywood
and
Veneer
Association,
and
representatives
from
affected
companies.

The
number
of
small
entities
that
are
significantly
affected
by
today's
final
PCWP
standards
is
not
expected
to
be
substantial.
This
final
rule
contains
no
regulatory
requirements
that
might
significantly
affect
small
governments
because
no
PCWP
facilities
are
owned
by
such
governments.
The
full
analysis
of
potential
regulatory
impacts
on
small
organizations,
small
governments,
and
small
businesses
is
included
in
the
economic
impact
analysis
in
the
docket
and
is
listed
at
the
beginning
of
today's
action
under
SUPPLEMENTARY
INFORMATION.
Because
the
number
of
small
entities
that
are
likely
to
experience
significant
economic
impacts
as
a
result
of
today's
final
standards
is
not
expected
to
be
substantial,
no
plan
to
inform
and
advise
small
governments
is
required
under
section
203
of
the
UMRA.

E.
Executive
Order
13132:
Federalism
212
Executive
Order
13132
(
64
FR
43255,
August
10,
1999)

requires
EPA
to
develop
an
accountable
process
to
ensure
"
meaningful
and
timely
input
by
State
and
local
officials
in
the
development
of
regulatory
policies
that
have
federalism
implications."
"
Policies
that
have
federalism
implications"

is
defined
in
the
Executive
Order
to
include
regulations
that
have
"
substantial
direct
effects
on
the
States,
on
the
relationship
between
the
national
government
and
the
States,

or
on
the
distribution
of
power
and
responsibilities
among
the
various
levels
of
government."
Under
Executive
Order
13132,
the
EPA
may
not
issue
a
regulation
that
has
federalism
implications,
that
imposes
substantial
direct
compliance
costs,
and
that
is
not
required
by
statute,

unless
the
Federal
government
provides
the
funds
necessary
to
pay
the
direct
compliance
costs
incurred
by
State
and
local
governments,
or
EPA
consults
with
State
and
local
officials
early
in
the
process
of
developing
the
proposed
regulation.
The
EPA
also
may
not
issue
a
regulation
that
has
federalism
implications
and
that
preempts
State
law
unless
EPA
consults
with
State
and
local
officials
early
in
the
process
of
developing
the
proposed
regulation.

If
EPA
complies
by
consulting,
Executive
Order
13132
requires
EPA
to
provide
to
OMB,
in
a
separately
identified
section
of
the
preamble
to
the
rule,
a
federalism
summary
impact
statement
(
FSIS).
The
FSIS
must
include
a
description
of
the
extent
of
EPA's
prior
consultation
with
213
State
and
local
officials,
a
summary
of
the
nature
of
their
concerns
and
EPA's
position
supporting
the
need
to
issue
the
regulation,
and
a
statement
of
the
extent
to
which
the
concerns
of
State
and
local
officials
have
been
met.
Also,

when
EPA
transmits
a
draft
final
rule
with
federalism
implications
to
OMB
for
review
pursuant
to
Executive
Order
12866,
it
must
include
a
certification
from
EPA's
Federalism
Official
stating
that
EPA
has
met
the
requirements
of
Executive
Order
13132
in
a
meaningful
and
timely
manner.

Today's
final
rule
does
not
have
federalism
implications.
It
will
not
have
substantial
direct
effects
on
the
States,
on
the
relationship
between
the
national
government
and
the
States,
or
on
the
distribution
of
power
and
responsibilities
among
the
various
levels
of
government,

as
specified
in
Executive
Order
13132.
None
of
the
affected
facilities
are
owned
or
operated
by
State
governments,
and
the
final
rule
requirements
will
not
supercede
State
regulations
that
are
more
stringent.
Thus,
the
requirements
of
Executive
Order
13132
do
not
apply
to
the
final
rule.

F.
Executive
Order
13175:
Consultation
and
Coordination
with
Indian
Tribal
Governments
Executive
Order
13175,
entitled
"
Consultation
and
Coordination
with
Indian
Tribal
Governments"
(
65
FR
67249,

November
6,
2000),
requires
EPA
to
develop
an
accountable
process
to
ensure
"
meaningful
and
timely
input
by
tribal
officials
in
the
development
of
regulatory
policies
that
214
have
tribal
implications."
"
Policies
that
have
tribal
implications"
is
defined
in
the
Executive
Order
to
include
regulations
that
have
"
substantial
direct
effects
on
one
or
more
Indian
tribes,
on
the
relationship
between
the
Federal
government
and
the
Indian
tribes,
or
on
the
distribution
of
power
and
responsibilities
between
the
Federal
government
and
Indian
tribes."

Today's
final
rule
does
not
have
tribal
implications.

It
will
not
have
substantial
direct
effects
on
tribal
governments,
on
the
relationship
between
the
Federal
government
and
Indian
tribes,
or
on
the
distribution
of
power
and
responsibilities
between
the
Federal
government
and
Indian
tribes,
as
specified
in
Executive
Order
13175.

No
affected
plant
sites
are
owned
or
operated
by
Indian
tribal
governments.
Thus,
Executive
Order
13175
does
not
apply
to
this
final
rule.

G.
Executive
Order
13045:
Protection
of
Children
from
Environmental
Health
&
Safety
Risks
Executive
Order
13045
(
62
FR
19885,
April
23,
1997)

applies
to
any
rule
that:
(
1)
is
determined
to
be
"
economically
significant,"
as
defined
under
Executive
Order
12866,
and
(
2)
concerns
an
environmental
health
or
safety
risk
that
EPA
has
reason
to
believe
may
have
a
disproportionate
effect
on
children.
If
the
regulatory
action
meets
both
criteria,
the
EPA
must
evaluate
the
environmental
health
or
safety
effects
of
the
planned
rule
215
on
children
and
explain
why
the
planned
regulation
is
preferable
to
other
potentially
effective
and
reasonably
feasible
alternatives
considered
by
the
Agency.

The
Agency
does
not
have
reason
to
believe
that
the
environmental
health
or
safety
risks
associated
with
the
emissions
addressed
by
today's
final
rule
present
a
disproportionate
risk
to
children.
This
demonstration
is
based
on
the
fact
that
the
noncancer
human
health
values
we
used
in
our
analysis
(
e.
g.,
RfC)
are
determined
to
be
protective
of
sensitive
subpopulations,
including
children.

Also,
while
the
cancer
human
health
values
do
not
always
expressly
account
for
cancer
effects
in
children,
the
cancer
risks
posed
by
PCWP
facilities
that
meet
the
eligibility
criteria
for
being
included
in
the
delisted
low­
risk
subcategory
will
be
sufficiently
low
so
as
not
to
be
a
concern
for
anyone
in
the
population,
including
children.

H.
Executive
Order
13211:
Actions
that
Significantly
Affect
Energy
Supply,
Distribution,
or
Use
Executive
Order
13211,
"
Actions
Concerning
Regulations
That
Significantly
Affect
Energy
Supply,
Distribution,
or
Use"
(
66
FR
28355,
May
22,
2001),
provides
that
agencies
shall
prepare
and
submit
to
the
Administrator
of
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
a
Statement
of
Energy
Effects
for
certain
actions
identified
as
"
significant
energy
actions."
Section
4(
b)
of
Executive
Order
13211
defines
"
significant
energy
216
actions"
as
"
any
action
by
an
agency
(
normally
published
in
the
Federal
Register)
that
promulgates
or
is
expected
to
lead
to
the
promulgation
of
a
final
rule
or
regulation,

including
notices
of
inquiry,
advance
notices
of
proposed
rulemaking,
and
notices
of
proposed
rulemaking:
(
1)
(
i)
that
is
a
significant
regulatory
action
under
Executive
Order
12866
or
any
successor
order,
and
(
ii)
is
likely
to
have
a
significant
adverse
effect
on
the
supply,
distribution,
or
use
of
energy;
or
(
2)
that
is
designated
by
the
Administrator
of
the
Office
of
Information
and
Regulatory
Affairs
as
a
significant
energy
action."
The
final
rule
is
not
a
"
significant
energy
action"
because
it
is
not
likely
to
have
a
significant
adverse
effect
on
the
supply,

distribution,
or
use
of
energy.
The
basis
for
the
determination
is
as
follows.

This
final
rule
affects
manufacturers
in
the
softwood
veneer
and
plywood
(
NAICS
321212),
reconstituted
wood
products
(
NAICS
321219),
and
engineered
wood
products
(
NAICS
321213)
industries.
There
is
no
crude
oil,
fuel,
or
coal
production
from
these
industries.
Hence,
there
is
no
direct
effect
on
such
energy
production
related
to
implementation
of
this
proposal.
In
fact,
as
previously
mentioned
in
this
preamble,
there
will
be
an
increase
in
energy
consumption,

and
hence
an
increase
in
energy
production,
resulting
from
installation
of
RTO
and
WESP
likely
needed
for
sources
to
meet
the
requirements
of
the
final
rule.
This
increase
in
217
1U.
S.
Department
of
Energy,
Energy
Information
Administration.
Annual
Energy
Review,
End­
Use
Energy
Consumption
for
1998.
Located
on
the
Internet
at
http://
www.
eia.
doe.
gov/
emeu/
aer/
enduse.
html.

2
Ibid.
energy
consumption
is
equal
to
718
million
kilowatthours
year
(
kWh/
yr)
for
electricity
and
45
million
cubic
meters/
year
(
m3/
yr)
for
natural
gas.
These
increases
are
equivalent
to
0.012
percent
of
1998
U.
S.
electricity
production
and
0.000001
percent
of
1998
U.
S.
natural
gas
production.
1
It
should
be
noted,
however,
that
the
reduction
in
demand
for
product
output
from
these
industries
may
lead
to
a
negative
indirect
effect
on
such
energy
production,
for
the
output
reduction
will
lead
to
less
energy
use
by
these
industries
and
thus
some
reduction
in
overall
energy
production.

For
fuel
production,
the
result
of
this
indirect
effect
from
reduced
product
output
is
a
reduction
of
only
about
1
barrel
per
day
nationwide,
or
a
0.00001
percent
reduction
nationwide
based
on
1998
U.
S.
fuel
production
data.
2
For
coal
production,
the
resulting
indirect
effect
from
reduced
product
output
is
a
reduction
of
only
2,000
tons
per
year
nationwide,
or
only
a
0.00001
percent
reduction
nationwide
based
on
1998
U.
S.
coal
production
data.
For
electricity
production,
the
resulting
indirect
effect
from
reduced
product
output
is
a
reduction
of
42.8
million
kWh/
yr,
or
only
a
0.00013
percent
reduction
nationwide
based
on
1998
218
3U.
S.
Department
of
Energy,
Energy
Information
Administration.
1998
Manufacturing
Energy
Consumption
Survey.
Located
on
the
Internet
at
http://
www.
eia.
doe.
gov/
emeu/
mecs/
mecs98/
datatables/
contents.
html.
U.
S.
electricity
production
data.
Given
that
the
estimated
price
increase
for
product
output
from
any
of
the
affected
industries
is
no
more
than
2.5
percent,
there
should
be
no
price
increase
for
any
energy
type
by
more
than
this
amount.

The
cost
of
energy
distribution
should
not
be
affected
by
this
proposal
at
all
since
the
rule
does
not
affect
energy
distribution
facilities.
Finally,
with
changes
in
net
exports
being
a
minimal
percentage
of
domestic
output
(
0.01
percent)
from
the
affected
industries,
there
will
be
only
a
negligible
change
in
international
trade,
and
hence
in
dependence
on
foreign
energy
supplies.
No
other
adverse
outcomes
are
expected
to
occur
with
regards
to
energy
supplies.
Thus,
the
net
effect
of
this
final
rule
on
energy
production
is
an
increase
in
electricity
output
of
0.012
percent
compared
to
1998
output
data,
and
a
negligible
change
in
output
of
other
energy
types.
All
of
the
results
presented
above
account
for
the
passthrough
of
costs
to
consumers,
as
well
as
the
cost
impact
to
producers.
These
results
also
account
for
how
energy
use
is
related
to
product
output
for
the
affected
industries.
3
For
more
information
on
the
estimated
energy
effects,
please
refer
to
219
4U.
S.
Environmental
Protection
Agency.
"
Energy
Impact
Analysis
of
the
Proposed
Plywood
and
Composite
Wood
Products
NESHAP."
July
30,
2001.
the
background
memo4
to
these
calculations
and
the
economic
impact
analysis
for
the
rule.
The
background
memo
and
economic
impact
analysis
are
available
in
the
public
docket.

Therefore,
we
conclude
that
the
final
rule
is
not
likely
to
have
a
significant
adverse
effect
on
the
supply,

distribution,
or
use
of
energy.

I.
National
Technology
Transfer
and
Advancement
Act
Section
12(
d)
of
the
National
Technology
Transfer
and
Advancement
Act
(
NTTAA)
of
1995
(
Public
Law
No.
104­
113;

15
U.
S.
C.
272
note)
directs
the
EPA
to
use
voluntary
consensus
standards
in
their
regulatory
and
procurement
activities
unless
to
do
so
would
be
inconsistent
with
applicable
law
or
otherwise
impractical.
Voluntary
consensus
standards
are
technical
standards
(
e.
g.,
materials
specifications,
test
methods,
sampling
procedures,
business
practices)
developed
or
adopted
by
one
or
more
voluntary
consensus
bodies.
The
NTTAA
directs
EPA
to
provide
Congress,
through
annual
reports
to
the
Office
of
Management
and
Budget
(
OMB),
with
explanations
when
an
agency
does
not
use
available
and
applicable
voluntary
consensus
standards.

This
rulemaking
involves
technical
standards.
The
EPA
cites
the
following
standards
in
this
rule:
EPA
Methods
1,

1A,
2,
2A,
2C,
2D,
2F,
2G,
3,
3A,
3B,
4,
18,
25A,
and
29
in
220
40
CFR
part
60,
appendix
A;
204
and
204A
through
F
in
40
CFR
part
51,
appendix
M;
308,
316,
and
320
in
40
CFR
part
63
appendix
A;
EPA
Method
0011
in
EPA
publication
no.
SW
846
("
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods")
for
formaldehyde;
and
two
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.,
(
NCASI)

methods:
NCASI
Method
CI/
WP­
98.01
(
1998),
"
Chilled
Impinger
Method
For
Use
At
Wood
Products
Mills
to
Measure
Formaldehyde,
Methanol,
and
Phenol,"
and
NCASI
Method
IM/
CAN/
WP­
99.02
(
2003),
"
Impinger/
Canister
Source
Sampling
Method
For
Selected
HAPs
and
Other
Compounds
at
Wood
Products
Facilities."

Consistent
with
the
NTTAA,
EPA
conducted
searches
to
identify
voluntary
consensus
standards
in
addition
to
these
EPA
methods/
performance
specifications.
No
applicable
voluntary
consensus
standards
were
identified
for
EPA
Methods
1A,
2A,
2D,
2F,
2G,
204,
204A
through
204F,
308,
and
316.
The
search
and
review
results
have
been
documented
and
are
placed
in
Docket
numbers
OAR­
2003­
0048
and
A­
98­
44
for
the
final
rule.

One
voluntary
consensus
standard
was
identified
as
an
acceptable
alternative
to
EPA
test
methods
for
the
purposes
of
this
rule.
The
voluntary
consensus
standard
ASTM
D6348­

03,
"
Standard
Test
Method
for
Determination
of
Gaseous
Compounds
by
Extractive
Direct
Interface
Fourier
Transform
Infrared
(
FTIR)
Spectroscopy,"
is
an
acceptable
alternative
221
to
EPA
Method
320
provided
that
the
%
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70%
and
less
than
or
equal
to
130%.
Also,
the
moisture
determination
in
ASTM
D6348­
03
is
an
acceptable
alternative
to
the
measurement
of
moisture
using
EPA
Method
4.

In
addition
to
the
voluntary
consensus
standards
the
EPA
uses
in
this
rule,
the
search
for
emissions
measurement
procedures
identified
13
other
voluntary
consensus
standards.
The
EPA
determined
that
11
of
those
13
voluntary
consensus
standards
identified
for
measuring
emissions
of
the
HAP
or
surrogates
subject
to
emission
standards
in
the
rule
were
impractical
alternatives
to
EPA
test
methods
for
the
purposes
of
the
rule.
Therefore,
EPA
does
not
intend
to
adopt
those
standards
for
that
purpose.
The
reasons
for
the
determination
for
the
11
methods
are
discussed
below.

The
voluntary
consensus
standard
ASTM
D3154­
00,

"
Standard
Method
for
Average
Velocity
in
a
Duct
(
Pitot
Tube
Method),"
is
impractical
as
an
alternative
to
EPA
Methods
1,

2,
2C,
3,
3B,
and
4
for
the
purposes
of
this
rulemaking
since
the
standard
appears
to
lack
in
quality
control
and
quality
assurance
requirements.
Specifically,
ASTM
D3154­
00
does
not
include
the
following:
1)
proof
that
openings
of
standard
pitot
tube
have
not
plugged
during
the
test;
2)
if
differential
pressure
gauges
other
than
inclined
manometers
(
e.
g.,
magnehelic
gauges)
are
used,
their
calibration
must
be
checked
after
each
test
series;
and
3)
the
frequency
and
222
validity
range
for
calibration
of
the
temperature
sensors.

The
voluntary
consensus
standard
ASTM
D3464­
96
(
2001),

"
Standard
Test
Method
Average
Velocity
in
a
Duct
Using
a
Thermal
Anemometer,"
is
impractical
as
an
alternative
to
EPA
Method
2
for
the
purposes
of
this
rulemaking
primarily
because
applicability
specifications
are
not
clearly
defined,
e.
g.,
range
of
gas
composition,
temperature
limits.

Also,
the
lack
of
supporting
quality
assurance
data
for
the
calibration
procedures
and
specifications,
and
certain
variability
issues
that
are
not
adequately
addressed
by
the
standard
limit
EPA's
ability
to
make
a
definitive
comparison
of
the
method
in
these
areas.

The
voluntary
consensus
standard
ISO
10780:
1994,

"
Stationary
Source
Emissions
 
Measurement
of
Velocity
and
Volume
Flowrate
of
Gas
Streams
in
Ducts,"
is
impractical
as
an
alternative
to
EPA
Method
2
in
this
rulemaking.
The
standard
recommends
the
use
of
an
L­
shaped
pitot,
which
historically
has
not
been
recommended
by
EPA.
The
EPA
specifies
the
S­
type
design
which
has
large
openings
that
are
less
likely
to
plug
up
with
dust.

The
voluntary
consensus
standard,
CAN/
CSA
Z223.2­

M86(
1986),
"
Method
for
the
Continuous
Measurement
of
Oxygen,

Carbon
Dioxide,
Carbon
Monoxide,
Sulphur
Dioxide,
and
Oxides
of
Nitrogen
in
Enclosed
Combustion
Flue
Gas
Streams,"
is
unacceptable
as
a
substitute
for
EPA
Method
3A
since
it
does
not
include
quantitative
specifications
for
measurement
223
system
performance,
most
notably
the
calibration
procedures
and
instrument
performance
characteristics.
The
instrument
performance
characteristics
that
are
provided
are
nonmandatory
and
also
do
not
provide
the
same
level
of
quality
assurance
as
the
EPA
methods.
For
example,
the
zero
and
span/
calibration
drift
is
only
checked
weekly,
whereas
the
EPA
methods
requires
drift
checks
after
each
run.

Two
very
similar
standards,
ASTM
D5835­
95,
"
Standard
Practice
for
Sampling
Stationary
Source
Emissions
for
Automated
Determination
of
Gas
Concentration,"
and
ISO
10396:
1993,
"
Stationary
Source
Emissions:
Sampling
for
the
Automated
Determination
of
Gas
Concentrations,"
are
impractical
alternatives
to
EPA
Method
3A
for
the
purposes
of
this
rulemaking
because
they
lack
in
detail
and
quality
assurance/
quality
control
requirements.
Specifically,
these
two
standards
do
not
include
the
following:
1)
sensitivity
of
the
method;
2)
acceptable
levels
of
analyzer
calibration
error;
3)
acceptable
levels
of
sampling
system
bias;
4)
zero
drift
and
calibration
drift
limits,
time
span,
and
required
testing
frequency;
5)
a
method
to
test
the
interference
response
of
the
analyzer;
6)
procedures
to
determine
the
minimum
sampling
time
per
run
and
minimum
measurement
time;

and
7)
specifications
for
data
recorders,
in
terms
of
resolution
(
all
types)
and
recording
intervals
(
digital
and
analog
recorders,
only).

The
voluntary
consensus
standard
ISO
12039:
2001,
224
"
Stationary
Source
Emissions­­
Determination
of
Carbon
Monoxide,
Carbon
Dioxide,
and
Oxygen­­
Automated
Methods,"
is
not
acceptable
as
an
alternative
to
EPA
Method
3A.
This
ISO
standard
is
similar
to
EPA
Method
3A,
but
is
missing
some
key
features.
In
terms
of
sampling,
the
hardware
required
by
ISO
12039:
2001
does
not
include
a
3­
way
calibration
valve
assembly
or
equivalent
to
block
the
sample
gas
flow
while
calibration
gases
are
introduced.
In
its
calibration
procedures,
ISO
12039:
2001
only
specifies
a
two­
point
calibration
while
EPA
Method
3A
specifies
a
three­
point
calibration.
Also,
ISO
12039:
2001
does
not
specify
performance
criteria
for
calibration
error,
calibration
drift,
or
sampling
system
bias
tests
as
in
the
EPA
method,

although
checks
of
these
quality
control
features
are
required
by
the
ISO
standard.

The
voluntary
consensus
standard
ASTM
D6060­
96
(
2001),

"
Practice
for
Sampling
of
Process
Vents
with
a
Portable
Gas
Chromatograph,"
is
an
impractical
alternative
for
EPA
Method
18
for
the
purposes
of
this
rulemaking
because
this
standard
lacks
key
quality
control
and
assurance
requirements
included
in
EPA
Method
18.
For
example,
ASTM
D6060:
1)
lacks
the
requirement
of
three
reference
standards
in
triplicate;
2)
lacks
the
calibration
acceptance
criteria
that
the
triplicate
calibration
standards
agree
within
5
percent
of
their
average;
3)
lacks
a
post­
sampling
volume
flow
rate
check
and
requirement
to
repeat
the
test
if
the
225
pre­
and
post­
test
flowrates
differ
by
more
than
20
percent;

4)
lacks
triplicate
samples
for
recovery
tests
and
allows
a
15
percent
difference
between
the
pre­
test
and
recovery
test
data
vs.
10
percent
for
Method
18;
4)
lacks
the
accuracy
performance
criteria
of
10
percent
of
the
preparation
value
for
audit
samples;
5)
lacks
reporting/
documentation
requirements.
Also,
ASTM
D6060
does
not
include
procedures
for
sample
collection
using
other
media,
such
as
bags
and
solid
sorbents.

Two
voluntary
consensus
standards,
EN
12619:
1999
"
Stationary
Source
Emissions­
Determination
of
the
Mass
Concentration
of
Total
Gaseous
Organic
Carbon
at
Low
Concentrations
in
Flue
Gases­­
Continuous
Flame
Ionization
Detector
Method"
and
ISO
14965:
2000(
E)
"
Air
Quality­

Determination
of
Total
Nonmethane
Organic
Compounds­

Cryogenic
Preconcentration
and
Direct
Flame
Ionization
Method,"
are
impractical
alternatives
to
EPA
Method
25A
for
the
purposes
of
this
rulemaking
because
the
standards
do
not
apply
to
solvent
process
vapors
in
concentrations
greater
than
40
ppm
(
EN
12619)
and
10
ppm
carbon
(
ISO
14965).

Methods
whose
upper
limits
are
this
low
are
too
limited
to
be
useful
in
measuring
source
emissions,
which
are
expected
to
be
much
higher.

The
voluntary
consensus
standard
EN
13211:
2001,
"
Air
Quality­­
Stationary
Source
Emissions­­
Determination
of
the
Concentration
of
Total
Mercury,"
is
not
acceptable
as
an
226
alternative
to
the
mercury
portion
of
EPA
Method
29
primarily
because
it
is
not
validated
for
use
with
impingers,
as
in
the
EPA
method,
although
the
method
describes
procedures
for
the
use
of
impingers.
This
European
standard
is
validated
for
the
use
of
fritted
bubblers
only
and
requires
the
use
of
a
side
(
split)
stream
arrangement
for
isokinetic
sampling
because
of
the
low
sampling
rate
of
the
bubblers
(
up
to
3
liters
per
minute,

maximum).
Also,
only
two
bubblers
(
or
impingers)
are
required
by
EN
13211,
whereas
EPA
Method
29
require
the
use
of
six
impinges.
In
addition,
EN
13211
does
not
include
many
of
the
quality
control
procedures
of
EPA
Method
29,

especially
for
the
use
and
calibration
of
temperature
sensors
and
controllers,
sampling
train
assembly
and
disassembly,
and
filter
weighing.

Two
of
the
13
voluntary
consensus
standards
identified
in
the
search
were
not
available
at
the
time
the
review
was
conducted
for
the
purposes
of
the
final
rule
because
they
are
under
development
by
a
voluntary
consensus
standards
organizational
body:
ASME/
BSR
MFC
13M,
"
Flow
Measurement
by
Velocity
Traverse,"
for
EPA
Method
2
(
and
possibly
1);
and
ASME/
BSR
MFC
12M,
"
Flow
in
Closed
Conduits
Using
Multiport
Averaging
Pitot
Primary
Flowmeters,"
for
EPA
Method
2.

Table
4
to
40
CFR
part
63
subpart
DDDD
lists
the
EPA
testing
methods
included
in
the
regulation.
Under
§
63.7(
f)

and
§
63.8(
f)
of
Subpart
A
of
the
General
Provisions,
a
227
source
may
apply
to
EPA
for
permission
to
use
alternative
test
methods
or
alternative
monitoring
requirements
in
place
of
any
of
the
EPA
testing
methods,
performance
specifications,
or
procedures.

J.
Congressional
Review
Act
The
Congressional
Review
Act,
5
U.
S.
C.
§
801
et
seq.,
as
added
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996,
generally
provides
that
before
a
rule
may
take
effect,
the
agency
promulgating
the
rule
must
submit
a
rule
report,
which
includes
a
copy
of
the
rule,
to
each
House
of
the
Congress
and
to
the
Comptroller
General
of
the
United
States.
EPA
will
submit
a
report
containing
this
rule
and
other
required
information
to
the
U.
S.
Senate,
the
U.
S.

House
of
Representatives,
and
the
Comptroller
General
of
the
United
States
prior
to
publication
of
the
rule
in
the
Federal
Register.
A
major
rule
cannot
take
effect
until
60
days
after
it
is
published
in
the
Federal
Register.
This
action
is
a
"
major
rule"
as
defined
by
5
U.
S.
C.
§
804(
2).

This
rule
will
be
effective
[
INSERT
DATE
60
DAYS
AFTER
DATE
OF
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
NESHAP:
Plywood
and
Composite
Wood
Products­­
Page
228
of
228
List
of
Subjects
in
40
CFR
Part
63
Environmental
protection,
Administrative
practice
and
procedure,
Air
pollution
control,
Hazardous
substances,

Intergovernmental
relations,
Incorporation
by
reference,

Reporting
and
recordkeeping
requirements.

______________________

Dated:

______________________

Michael
O.
Leavitt,

Administrator.
Prom_
rule2.
wpd
For
the
reasons
stated
in
the
preamble,
title
40,
chapter
I,

part
63
of
the
Code
of
Federal
Regulations
is
amended
as
follows:

PART
63­­[
AMENDED]

1.
The
authority
citation
for
part
63
continues
to
read
as
follows:

Authority:
42
U.
S.
C.
7401
et
seq.

SUBPART
A­­[
AMENDED]

2.
Section
63.14
is
amended
by
revising
paragraphs
(
b)
and
(
f)
to
read
as
follows:

§
63.14
Incorporation
by
reference.

*
*
*
*
*

(
b)
The
following
materials
are
available
for
purchase
from
at
least
one
of
the
following
addresses:
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.

(
1)
*
*
*

(
30)
ASTM
D6348­
03,
Standard
Test
Method
for
Determination
of
Gaseous
Compounds
by
Extractive
Direct
Interface
Fourier
Transform
Infrared
(
FTIR)
Spectroscopy,

IBR
approved
for
subpart
DDDD
of
this
part
as
specified
in
the
subpart.

*
*
*
*
*

(
f)
The
following
material
is
available
from
the
2
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
(
NCASI),
P.
O.
Box
133318,
Research
Triangle
Park,
NC
27709­
3318
or
at
http://
www.
ncasi.
org.

(
1)
NCASI
Method
DI/
MEOH­
94.02,
Methanol
in
Process
Liquids
GC/
FID
(
Gas
Chromatography/
Flame
Ionization
Detection),
August
1998,
Methods
Manual,
NCASI,
Research
Triangle
Park,
NC,
IBR
approved
for
§
63.457(
c)(
3)(
ii)
of
subpart
S
of
this
part.

(
2)
NCASI
Method
CI/
WP­
98.01,
Chilled
Impinger
Method
For
Use
At
Wood
Products
Mills
to
Measure
Formaldehyde,

Methanol,
and
Phenol,
1998,
Methods
Manual,
NCASI,
Research
Triangle
Park,
NC,
IBR
approved
for
Sec.
63.2262
of
subpart
DDDD
of
this
part.

(
3)
NCASI
Method
IM/
CAN/
WP­
99.02,
Impinger/
Canister
Source
Sampling
Method
For
Selected
HAPs
and
Other
Compounds
at
Wood
Products
Facilities,
2003,
Methods
Manual,
NCASI,

Research
Triangle
Park,
NC,
IBR
approved
for
Sec.
63.2262
of
subpart
DDDD
of
this
part.

*
*
*
*
*

3.
Part
63
is
amended
by
adding
subpart
DDDD
to
read
as
follows:

Subpart
DDDD­­
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products
Sec.

What
This
Subpart
Covers
63.2230
What
is
the
purpose
of
this
subpart?
63.2231
Does
this
subpart
apply
to
me?
3
63.2232
What
parts
of
my
plant
does
this
subpart
cover?
63.2233
When
do
I
have
to
comply
with
this
subpart?

Compliance
Options,
Operating
Requirements,
and
Work
Practice
Requirements
63.2240
What
are
the
compliance
options
and
operating
requirements
and
how
must
I
meet
them?
63.2241
What
are
the
work
practice
requirements
and
how
must
I
meet
them?

General
Compliance
Requirements
63.2250
What
are
the
general
requirements?
63.2251
What
are
the
requirements
for
the
routine
control
device
maintenance
exemption?

Initial
Compliance
Requirements
63.2260
How
do
I
demonstrate
initial
compliance
with
the
compliance
options,
operating
requirements,
and
work
practice
requirements?
63.2261
By
what
date
must
I
conduct
performance
tests
or
other
initial
compliance
demonstrations?
63.2262
How
do
I
conduct
performance
tests
and
establish
operating
requirements?
63.2263
Initial
compliance
demonstration
for
a
dry
rotary
dryer.
63.2264
Initial
compliance
demonstration
for
a
hardwood
veneer
dryer.
63.2265
Initial
compliance
demonstration
for
a
softwood
veneer
dryer.
63.2266
Initial
compliance
demonstration
for
a
veneer
redryer.
63.2267
Initial
compliance
demonstration
for
a
reconstituted
wood
product
press
or
board
cooler.
63.2268
Initial
compliance
demonstration
for
a
wet
control
device.
63.2269
What
are
my
monitoring
installation,
operation,
and
maintenance
requirements?

Continuous
Compliance
Requirements
63.2270
How
do
I
monitor
and
collect
data
to
demonstrate
continuous
compliance?
63.2271
How
do
I
demonstrate
continuous
compliance
with
the
compliance
options,
operating
requirements,
and
work
practice
requirements?

Notifications,
Reports,
and
Records
63.2280
What
notifications
must
I
submit
and
when?
63.2281
What
reports
must
I
submit
and
when?
63.2282
What
records
must
I
keep?
63.2283
In
what
form
and
how
long
must
I
keep
my
records?
4
Other
Requirements
and
Information
63.2290
What
parts
of
the
General
Provisions
apply
to
me?
63.2291
Who
implements
and
enforces
this
subpart?
63.2292
What
definitions
apply
to
this
subpart?

Tables
to
Subpart
DDDD
of
Part
63
Table
1A
to
Subpart
DDDD
of
Part
63
­
Production­
Based
Compliance
Options
Table
1B
to
Subpart
DDDD
of
Part
63
­
Add­
On
Control
Systems
Compliance
Options
Table
2
to
Subpart
DDDD
of
Part
63
­
Operating
Requirements
Table
3
to
Subpart
DDDD
of
Part
63
­
Work
Practice
Requirements
Table
4
to
Subpart
DDDD
of
Part
63
­
Requirements
for
Performance
Tests
Table
5
to
Subpart
DDDD
of
Part
63
­
Performance
Testing
and
Initial
Compliance
Demonstrations
for
the
Compliance
Options
and
Operating
Requirements
Table
6
to
Subpart
DDDD
of
Part
63
­
Initial
Compliance
Demonstrations
for
Work
Practice
Requirements
Table
7
to
Subpart
DDDD
of
Part
63
­
Continuous
Compliance
With
the
Compliance
Options
and
Operating
Requirements
Table
8
to
Subpart
DDDD
of
Part
63
­
Continuous
Compliance
With
the
Work
Practice
Requirements
Table
9
to
Subpart
DDDD
of
Part
63
­
Requirements
for
Reports
Table
10
to
Subpart
DDDD
of
Part
63
­
Applicability
of
General
Provisions
to
Subpart
DDDD
Appendix
Appendix
A
to
Subpart
DDDD
of
Part
63
 
Alternative
Procedure
to
Determine
Capture
Efficiency
from
Enclosures
Around
Hot
Presses
in
the
Plywood
and
Composite
Wood
Products
Industry
Using
Sulfur
Hexafluoride
Tracer
Gas
What
This
Subpart
Covers
§
63.2230
What
is
the
purpose
of
this
subpart?

This
subpart
establishes
national
compliance
options,

operating
requirements,
and
work
practice
requirements
for
hazardous
air
pollutants
(
HAP)
emitted
from
plywood
and
composite
wood
products
manufacturing
facilities.
This
subpart
also
establishes
requirements
to
demonstrate
initial
and
continuous
compliance
with
the
compliance
options,
5
operating
requirements,
and
work
practice
requirements.

§
63.2231
Does
this
subpart
apply
to
me?

This
subpart
applies
to
you
if
you
meet
the
criteria
in
paragraphs
(
a)
and
(
b)
of
this
section.

(
a)
You
own
or
operate
a
plywood
and
composite
wood
products
(
PCWP)
manufacturing
facility.
A
PCWP
manufacturing
facility
is
a
facility
that
manufactures
plywood
and/
or
composite
wood
products
by
bonding
wood
material
(
fibers,
particles,
strands,
veneers,
etc.)
or
agricultural
fiber,
generally
with
resin
under
heat
and
pressure,
to
form
a
structural
panel
or
engineered
wood
product.
Plywood
and
composite
wood
products
manufacturing
facilities
also
include
facilities
that
manufacture
dry
veneer
and
lumber
kilns
located
at
any
facility.
Plywood
and
composite
wood
products
include
(
but
are
not
limited
to)

plywood,
veneer,
particleboard,
oriented
strandboard,

hardboard,
fiberboard,
medium
density
fiberboard,
laminated
strand
lumber,
laminated
veneer
lumber,
wood
I­
joists,

kilndried
lumber,
and
glue­
laminated
beams.

(
b)
The
PCWP
manufacturing
facility
is
located
at
a
major
source
of
HAP
emissions.
A
major
source
of
HAP
emissions
is
any
stationary
source
or
group
of
stationary
sources
within
a
contiguous
area
and
under
common
control
that
emits
or
has
the
potential
to
emit
any
single
HAP
at
a
rate
of
9.07
megagrams
(
10
tons)
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
22.68
megagrams
(
25
tons)
or
6
more
per
year.

§
63.2232
What
parts
of
my
plant
does
this
subpart
cover?

(
a)
This
rule
applies
to
each
new,
reconstructed,
or
existing
affected
source
at
a
PCWP
manufacturing
facility.

(
b)
The
affected
source
is
the
collection
of
dryers,

refiners,
blenders,
formers,
presses,
board
coolers,
and
other
process
units
associated
with
the
manufacturing
of
plywood
and
composite
wood
products.
The
affected
source
includes,
but
is
not
limited
to,
green
end
operations,

refining,
drying
operations,
resin
preparation,
blending
and
forming
operations,
pressing
and
board
cooling
operations,

and
miscellaneous
finishing
operations
(
such
as
sanding,

sawing,
patching,
edge
sealing,
and
other
finishing
operations
not
subject
to
other
NESHAP).
The
affected
source
also
includes
onsite
storage
and
preparation
of
raw
materials
used
in
the
manufacture
of
plywood
and/
or
composite
wood
products,
such
as
resins;
onsite
wastewater
treatment
operations
specifically
associated
with
plywood
and
composite
wood
products
manufacturing;
and
miscellaneous
coating
operations
(
defined
in
§
63.2292).
The
affected
source
includes
lumber
kilns
at
PCWP
manufacturing
facilities
and
at
any
other
kind
of
facility.

(
c)
An
affected
source
is
a
new
affected
source
if
you
commenced
construction
of
the
affected
source
after
January
9,
2003,
and
you
meet
the
applicability
criteria
at
the
time
you
commenced
construction.
7
(
d)
An
affected
source
is
reconstructed
if
you
meet
the
criteria
as
defined
in
§
63.2.

(
e)
An
affected
source
is
existing
if
it
is
not
new
or
reconstructed.

§
63.2233
When
do
I
have
to
comply
with
this
subpart?

(
a)
If
you
have
a
new
or
reconstructed
affected
source,
you
must
comply
with
this
subpart
according
to
paragraph
(
a)(
1)
or
(
2)
of
this
section,
whichever
is
applicable.

(
1)
If
the
initial
startup
of
your
affected
source
is
before
the
effective
date
of
the
subpart,
then
you
must
comply
with
the
compliance
options,
operating
requirements,

and
work
practice
requirements
for
new
and
reconstructed
sources
in
this
subpart
no
later
than
the
effective
date
of
the
subpart.

(
2)
If
the
initial
startup
of
your
affected
source
is
after
the
effective
date
of
the
subpart,
then
you
must
comply
with
the
compliance
options,
operating
requirements,

and
work
practice
requirements
for
new
and
reconstructed
sources
in
this
subpart
upon
initial
startup
of
your
affected
source.

(
b)
If
you
have
an
existing
affected
source,
you
must
comply
with
the
compliance
options,
operating
requirements,

and
work
practice
requirements
for
existing
sources
no
later
than
the
date
3
years
after
the
effective
date
of
the
subpart.
8
(
c)
If
you
have
an
area
source
that
increases
its
emissions
or
its
potential
to
emit
such
that
it
becomes
a
major
source
of
HAP,
you
must
be
in
compliance
with
this
subpart
by
the
date
3
years
after
the
effective
date
of
the
subpart
or
upon
initial
startup
of
your
affected
source
as
a
major
source,
whichever
is
later.

(
d)
You
must
meet
the
notification
requirements
according
to
the
schedule
in
§
63.2280
and
according
to
40
CFR
part
63,
subpart
A.
Some
of
the
notifications
must
be
submitted
before
you
are
required
to
comply
with
the
compliance
options,
operating
requirements,
and
work
practice
requirements
in
this
subpart.

Compliance
Options,
Operating
Requirements,
and
Work
Practice
Requirements
§
63.2240
What
are
the
compliance
options
and
operating
requirements
and
how
must
I
meet
them?

You
must
meet
the
compliance
options
and
operating
requirements
described
in
Tables
1A,
1B,
and
2
of
this
subpart
and
in
paragraph
(
c)
of
this
section
by
using
one
or
more
of
the
compliance
options
listed
in
paragraphs
(
a),

(
b),
and
(
c)
of
this
section.
The
process
units
subject
to
the
compliance
options
are
listed
in
Tables
1A
and
1B
and
are
defined
in
§
63.2292.
You
need
only
to
meet
one
of
the
compliance
options
outlined
in
paragraphs
(
a)
through
(
c)
of
this
section
for
each
process
unit.
You
cannot
combine
9
compliance
options
in
paragraphs
(
a),
(
b),
or
(
c)
for
a
single
process
unit.
(
For
example,
you
cannot
use
a
production­
based
compliance
option
in
paragraph
(
a)
for
one
vent
of
a
veneer
dryer
and
an
add­
on
control
system
compliance
option
in
paragraph
(
b)
for
another
vent
on
the
same
veneer
dryer.
You
must
use
either
the
production­
based
compliance
option
or
an
add­
on
control
system
compliance
option
for
the
entire
dryer.)

(
a)
Production­
based
compliance
options.
You
must
meet
the
production­
based
total
HAP
compliance
options
in
Table
1A
of
this
subpart
and
the
applicable
operating
requirements
in
Table
2
of
this
subpart.
You
may
not
use
an
add­
on
control
system
or
wet
control
device
to
meet
the
production­
based
compliance
options.

(
b)
Compliance
options
for
add­
on
control
systems.

You
must
use
an
emissions
control
system
and
demonstrate
that
the
resulting
emissions
meet
the
compliance
options
and
operating
requirements
in
Tables
1B
and
2
of
this
subpart.

If
you
own
or
operate
a
reconstituted
wood
product
press
at
a
new
or
existing
affected
source
or
a
reconstituted
wood
product
board
cooler
at
a
new
affected
source,
and
you
choose
to
comply
with
one
of
the
concentration­
based
compliance
options
for
a
control
system
outlet
(
presented
as
option
numbers
2,
4,
and
6
in
Table
1B
of
this
subpart),
you
must
have
a
capture
device
that
either
meets
the
definition
of
wood
products
enclosure
in
§
63.2292
or
achieves
a
capture
10
efficiency
of
greater
than
or
equal
to
95
percent.

(
c)
Emissions
averaging
compliance
option
(
for
existing
sources
only).
Using
the
procedures
in
paragraphs
(
c)(
1)
through
(
3)
of
this
section,
you
must
demonstrate
that
emissions
included
in
the
emissions
average
meet
the
compliance
options
and
operating
requirements.
New
sources
may
not
use
emissions
averaging
to
comply
with
this
subpart.

(
1)
Calculation
of
required
and
actual
mass
removal.

Limit
emissions
of
total
HAP,
as
defined
in
§
63.2292,
to
include
acetaldehyde,
acrolein,
formaldehyde,
methanol,

phenol,
and
propionaldehyde
from
your
affected
source
to
the
standard
specified
by
Equations
1,
2,
and
3
of
this
section.

(
Eq.
1)
RMR
UCEP
OH
i
i
i
n
=
×
×






=

090
1
.

(
Eq.
2)
AMR
CD
OCEP
OH
i
i
i
i
1
n
=
×
×






=

(
Eq.
3)
AMR
RMR
 

Where:

RMR
=
required
mass
removal
of
total
HAP
from
all
process
units
generating
debits
(
i.
e.,
all
process
units
that
are
subject
to
the
compliance
options
in
Tables
1A
and
1B
of
this
subpart
and
that
are
either
uncontrolled
or
under­
controlled),
pounds
per
semiannual
period
AMR
=
actual
mass
removal
of
total
HAP
from
all
process
units
generating
credits
(
i.
e.,
all
11
process
units
that
are
controlled
as
part
of
the
Emissions
Averaging
Plan
including
credits
from
debit­
generating
process
units
that
are
under­
controlled),
pounds
per
semiannual
period
UCEPi
=
mass
of
total
HAP
from
an
uncontrolled
or
under­
controlled
process
unit
(
i)
that
generates
debits,
pounds
per
hour
OHi
=
number
of
hours
a
process
unit
(
i)
is
operated
during
the
semiannual
period,
hours
per
6­
month
period
CDi
=
control
system
efficiency
for
the
emission
point
(
i)
for
total
HAP,
expressed
as
a
fraction,
and
not
to
exceed
90
percent,
unitless
[
Note:
To
calculate
the
control
system
efficiency
of
biological
treatment
units
that
do
not
meet
the
definition
of
biofilter
in
§
63.2292
of
this
subpart,
you
must
use
40
CFR,
part
63,
Appendix
C,
Determination
of
the
Fraction
Biodegraded
(
Fbio)
in
a
Biological
Treatment
Unit.]
OCEPi
=
mass
of
total
HAP
from
a
process
unit
(
i)
that
generates
credits
(
including
credits
from
debit­
generating
process
units
that
are
undercontrolled
pounds
per
hour
0.90
=
required
control
system
efficiency
of
90
percent
multiplied,
unitless
(
2)
Requirements
for
debits
and
credits.
You
must
calculate
debits
and
credits
as
specified
in
paragraphs
(
c)(
2)(
i)
through
(
vi)
of
this
section.

(
i)
You
must
limit
process
units
in
the
emissions
average
to
those
process
units
located
at
the
existing
affected
source,
as
defined
in
§
63.2292.

(
ii)
You
cannot
use
nonoperating
process
units
to
generate
emissions
averaging
credits.
You
cannot
use
process
units
that
are
shut
down
to
generate
emissions
averaging
debits
or
credits.

(
iii)
You
may
not
include
in
your
emissions
average
process
units
controlled
to
comply
with
a
State,
Tribal,
or
12
Federal
rule
other
than
this
subpart.

(
iv)
You
must
use
actual
measurements
of
total
HAP
emissions
from
process
units
to
calculate
your
required
mass
removal
(
RMR)
and
actual
mass
removal
(
AMR).
The
total
HAP
measurements
must
be
obtained
according
to
§
63.2262(
b)

through
(
d),
(
g),
and
(
h),
using
the
methods
specified
in
Table
4
of
this
subpart.

(
v)
Your
initial
demonstration
that
the
creditgenerating
process
units
will
be
capable
of
generating
enough
credits
to
offset
the
debits
from
the
debitgenerating
process
units
must
be
made
under
representative
operating
conditions.
After
the
compliance
date,
you
must
use
actual
operating
data
for
all
debit
and
credit
calculations.

(
vi)
Do
not
include
emissions
from
the
following
time
periods
in
your
emissions
averaging
calculations:

(
A)
Emissions
during
periods
of
startup,
shutdown,
and
malfunction
as
described
in
the
startup,
shutdown,
and
malfunction
plan
(
SSMP).

(
B)
Emissions
during
periods
of
monitoring
malfunctions,
associated
repairs,
and
required
quality
assurance
or
control
activities
or
during
periods
of
control
device
maintenance
covered
in
your
routine
control
device
maintenance
exemption.
No
credits
may
be
assigned
to
credit­
generating
process
units,
and
maximum
debits
must
be
assigned
to
debit­
generating
process
units
during
these
13
periods.

(
3)
Operating
requirements.
You
must
meet
the
operating
requirements
in
Table
2
of
this
subpart
for
each
process
unit
or
control
device
used
in
calculation
of
emissions
averaging
credits.

§
63.2241
What
are
the
work
practice
requirements
and
how
must
I
meet
them?

(
a)
You
must
meet
each
work
practice
requirement
in
Table
3
of
this
subpart
that
applies
to
you.

(
b)
As
provided
in
§
63.6(
g),
we,
the
EPA,
may
choose
to
grant
you
permission
to
use
an
alternative
to
the
work
practice
requirements
in
this
section.

(
c)
If
you
have
a
dry
rotary
dryer,
you
may
choose
to
designate
your
dry
rotary
dryer
as
a
green
rotary
dryer
and
meet
the
more
stringent
compliance
options
and
operating
requirements
in
§
63.2240
for
green
rotary
dryers
instead
of
the
work
practices
for
dry
rotary
dryers.
If
you
have
a
hardwood
veneer
dryer
or
veneer
redryer,
you
may
choose
to
designate
your
hardwood
veneer
dryer
or
veneer
redryer
as
a
softwood
veneer
dryer
and
meet
the
more
stringent
compliance
options
and
operating
requirements
in
§
63.2240
for
softwood
veneer
dryer
heated
zones
instead
of
the
work
practices
for
hardwood
veneer
dryers
or
veneer
redryers.

General
Compliance
Requirements
§
63.2250
What
are
the
general
requirements?

(
a)
You
must
be
in
compliance
with
the
compliance
14
options,
operating
requirements,
and
the
work
practice
requirements
in
this
subpart
at
all
times,
except
during
periods
of
process
unit
or
control
device
startup,
shutdown,

and
malfunction;
prior
to
process
unit
initial
startup;
and
during
the
routine
control
device
maintenance
exemption
specified
in
§
63.2251.
The
compliance
options,
operating
requirements,
and
work
practice
requirements
do
not
apply
during
times
when
the
process
unit(
s)
subject
to
the
compliance
options,
operating
requirements,
and
work
practice
requirements
are
not
operating,
or
during
scheduled
startup
and
shutdown
periods,
and
during
malfunctions.

These
startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary
for
these
events.

(
b)
You
must
always
operate
and
maintain
your
affected
source,
including
air
pollution
control
and
monitoring
equipment,
according
to
the
provisions
in
§
63.6(
e)(
1)(
i).

(
c)
You
must
develop
and
implement
a
written
SSMP
according
to
the
provisions
in
§
63.6(
e)(
3).

(
d)
Shutoff
of
direct­
fired
burners
resulting
from
partial
and
full
production
stoppages
of
direct­
fired
softwood
veneer
dryers
or
over­
temperature
events
shall
be
deemed
shutdowns
and
not
malfunctions.
Lighting
or
relighting
any
one
or
all
gas
burners
in
direct­
fired
softwood
veneer
dryers
shall
be
deemed
startups
and
not
malfunctions.

§
63.2251
What
are
the
requirements
for
the
routine
control
device
maintenance
exemption?
15
(
a)
You
may
request
a
routine
control
device
maintenance
exemption
from
the
Administrator
for
routine
maintenance
events
such
as
control
device
bakeouts,

washouts,
media
replacement,
and
replacement
of
corroded
parts.
Your
request
must
justify
the
need
for
the
routine
maintenance
on
the
control
device
and
the
time
required
to
accomplish
the
maintenance
activities,
describe
the
maintenance
activities
and
the
frequency
of
the
maintenance
activities,
explain
why
the
maintenance
cannot
be
accomplished
during
process
shutdowns,
describe
how
you
plan
to
make
reasonable
efforts
to
minimize
emissions
during
the
maintenance,
and
provide
any
other
documentation
required
by
the
Administrator.

(
b)
The
routine
control
device
maintenance
exemption
must
not
exceed
the
percentages
of
process
unit
operating
uptime
in
paragraphs
(
b)(
1)
and
(
2)
of
this
section.

(
1)
If
the
control
device
is
used
to
control
a
green
rotary
dryer,
tube
dryer,
rotary
strand
dryer,
or
pressurized
refiner,
then
the
routine
control
device
maintenance
exemption
must
not
exceed
3
percent
of
annual
operating
uptime
for
each
process
unit
controlled.

(
2)
If
the
control
device
is
used
to
control
a
softwood
veneer
dryer,
reconstituted
wood
product
press,

reconstituted
wood
product
board
cooler,
hardboard
oven,

press
predryer,
conveyor
strand
dryer,
or
fiberboard
mat
dryer,
then
the
routine
control
device
maintenance
exemption
16
must
not
exceed
0.5
percent
of
annual
operating
uptime
for
each
process
unit
controlled.

(
3)
If
the
control
device
is
used
to
control
a
combination
of
equipment
listed
in
both
paragraphs
(
b)(
1)

and
(
2)
of
this
section,
such
as
a
tube
dryer
and
a
reconstituted
wood
product
press,
then
the
routine
control
device
maintenance
exemption
must
not
exceed
3
percent
of
annual
operating
uptime
for
each
process
unit
controlled.

(
c)
The
request
for
the
routine
control
device
maintenance
exemption,
if
approved
by
the
Administrator,

must
be
incorporated
by
reference
in
and
attached
to
the
affected
source's
title
V
permit.

(
d)
The
compliance
options
and
operating
requirements
do
not
apply
during
times
when
control
device
maintenance
covered
under
your
approved
routine
control
device
maintenance
exemption
is
performed.
You
must
minimize
emissions
to
the
greatest
extent
possible
during
these
routine
control
device
maintenance
periods.

(
e)
To
the
extent
practical,
startup
and
shutdown
of
emission
control
systems
must
be
scheduled
during
times
when
process
equipment
is
also
shut
down.

Initial
Compliance
Requirements
§
63.2260
How
do
I
demonstrate
initial
compliance
with
the
compliance
options,
operating
requirements,
and
work
practice
requirements?

(
a)
To
demonstrate
initial
compliance
with
the
17
compliance
options
and
operating
requirements,
you
must
conduct
performance
tests
and
establish
each
site­
specific
operating
requirement
in
Table
2
of
this
subpart
according
to
the
requirements
in
§
63.2262
and
Table
4
of
this
subpart.

Combustion
units
that
accept
process
exhausts
into
the
flame
zone
are
exempt
from
the
initial
performance
testing
and
