National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plywood
and
Composite
Wood
Products
Manufacturing
Background
Information
for
Final
Standards
Summary
of
Public
Comments
and
Responses
ii
This
page
intentionally
left
blank.
iii
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plywood
and
Composite
Wood
Products
Background
Information
for
Final
Standards
Summary
of
Public
Comments
and
Responses
Contract
No.
68­
D­
01­
079
Work
Assignment
No.
2­
12
Project
No.
95/
11
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Emission
Standards
Division
Research
Triangle
Park,
North
Carolina
27711
February
2004
iv
v
Disclaimer
This
report
has
been
reviewed
by
the
Emission
Standards
Division
of
the
Office
of
Air
Quality
Planning
and
Standards,
EPA,
and
approved
for
publication.
Mention
of
trade
names
or
commercial
products
is
not
intended
to
constitute
endorsement
or
recommendation
for
use.
vi
TABLE
OF
CONTENTS
Page
Chapter
1
Summary
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1­
1
1.1
SUMMARY
OF
CHANGES
SINCE
PROPOSAL
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1­
1
Chapter
2
Summary
of
Public
Comments
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1
2.1
APPLICABLITY
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2­
5
2.1.1
Affected
source
and
major
source
determination
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2­
5
2.1.2
Equipment
groups
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2­
11
2.1.3
Lumber
kilns
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2­
20
2.1.4
Effluent
guidelines
for
timber
products
processing
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2­
21
2.1.5
Overlap
with
Boilers/
Process
Heaters
NESHAP
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2­
25
2.1.6
Overlap
with
Wood
Building
Products
NESHAP
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2­
28
2.1.7
Overlap
with
Wood
Furniture
Manufacturing
NESHAP
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2­
32
2.1.8
Overlap
with
New
Source
Review
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2­
33
2.2
HEALTH
EFFECTS
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2­
38
2.3
EXISTING
SOURCE
MACT
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2­
41
2.3.1
Process
unit
groups
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2­
41
2.3.2
Basis
for
MACT
floor
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2­
63
2.3.3
Beyond­
the­
floor
analysis
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2­
88
2.4
NEW
SOURCE
MACT
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2­
90
2.5
AIR
POLLUTION
CONTROL
DEVICES
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2­
92
2.5.1
General
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2­
92
2.5.2
Definition
of
control
device
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2­
93
2.5.3
Regenerative
thermal
and
catalytic
oxidizers
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2­
96
2.5.4
Biofilters
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2­
96
2.5.5
Availability
of
APCDs
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2­
97
2.6
COMPLIANCE
OPTIONS
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2­
102
vii
2.6.1
Multiple
compliance
options
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2­
102
2.6.2
Add­
on
control
systems
compliance
options
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2­
104
2.6.3
Production­
based
compliance
options
(
PBCO)
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2­
112
2.6.4
Emissions
averaging
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2­
122
2.6.5
Concentration­
based
applicability
criteria
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2­
141
2.7
TESTING
AND
MONITORING
REQUIREMENTS
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2­
151
2.7.1.
Emission
measurement
test
methods
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2­
151
2.7.2
Capture
efficiency
test
methods
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2­
154
2.7.3
General
monitoring
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2­
159
2.7.4
Block
averaging
period
for
operating
requirements
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2­
159
2.7.5
Testing
at
boundary
conditions
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2­
161
2.7.6
Compliance
exemption
during
performance
testing
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2­
162
2.7.7
Post­
deviation
performance
testing
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2­
163
2.7.8
Location
for
inlet
sampling
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2­
165
2.7.9
Data
collection
and
handling
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2­
165
2.7.10
Selection
of
operating
parameter
limits
 
general
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2­
170
2.7.11
Selection
of
RTO
and
RCO
monitoring
parameters
.
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2­
171
2.7.12
Process
incineration
monitoring
requirements
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2­
180
2.7.13
Selection
of
biofilter
monitoring
parameters
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2­
184
2.7.14
Continuous
THC
monitoring
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2­
192
2.7.15
Selection
of
monitoring
parameters
for
uncontrolled
process
units
.
2­
193
2.7.16
Performance
specifications
for
temperature
monitors
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2­
196
2.7.17
Performance
specifications
for
pressure
monitors
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2­
197
2.7.18
Performances
specifications
for
flow
monitors
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2­
198
2.7.19
Performance
specifications
for
moisture
monitors
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2­
198
2.7.20
Work
practice
requirements
for
dryers
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2­
201
2.8
COMPLIANCE
DURING
PERIODS
OF
NON­
ROUTINE
OPERATION
.
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2­
206
2.8.1
Control
device
downtime
allowance
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2­
206
2.8.2
Veneer
dryer
burner
relights
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2­
219
2.8.3
SSM
plan
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2­
222
2.8.4
Deviations
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2­
230
2.9
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
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2­
232
viii
2.10
COST
AND
ECONOMIC
ASSUMPTIONS
AND
IMPACTS
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2­
235
2.10.1
Cost
and
economic
impacts
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2­
235
2.10.2
Cost­
benefits
analyses
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2­
241
2.10.3
Air
impacts
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2­
245
2.10.4
Water
impacts
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2­
251
2.10.5
Energy
impacts
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2­
256
2.10.6
Life
cycle
analysis
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2­
258
2.11
RISK­
BASED
APPROACHES
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2­
264
2.12
MISCELLANEOUS
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.
2­
265
LIST
OF
TABLES
Page
Table
2­
1.
List
of
Commenters
on
Proposed
NESHAP
for
PCWP
Manufacturing
.
.
.
.
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.
2­
2
Table
2­
2.
Total
HAP
Emissions
Exhaust
Gas
Characteristics
for
one
wet/
wet
Hardboard
Production
Line
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
48
Table
2­
3.
Comparison
of
PBCO
with
Emissions
from
Outlet
of
Control
Devices
.
.
.
.
.
.
.
2­
117
Table
2­
4.
Effect
of
Combining
Compliance
Options
on
Emission
Reductions
Achieved
.
.
2­
133
Table
2­
5.
NESHAP
with
Concentration­
Based
Applicability
Cutoffs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
143
Table
2­
6.
Comparison
of
Emission
Sources
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
147
Table
2­
7.
Summary
of
NCASI
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
147
Table
2­
8.
Flow
Rate
Versus
Mass
Emissions
for
50
Ppmv
Methanol
Emission
Stream
.
.
.
2­
148
Table
2­
9.
Summary
of
Non­
HAP
Air
Impacts
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
248
Table
2­
10.
Annual
Wastewater
Generation
Rates
for
RTO
Washouts
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
253
1­
1
Chapter
1
Summary
On
January
9,
2003,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
proposed
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
plywood
and
composite
wood
products
(
PCWP)
manufacturing
(
68
FR
1276)
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
public
comment
period
remained
open
from
January
9,
2003
to
March
10,
2003.

Fifty­
seven
public
comment
letters
were
received
during
the
public
comment
period
from
sources
consisting
mainly
of
PCWP
manufacturers,
control
device
vendors,
environmental
organizations,

various
industry
trade
associations,
and
government
agencies.

All
of
the
comments
that
were
submitted
during
the
public
comment
period
and
the
responses
to
those
comments
are
summarized
in
this
document.
This
summary
is
the
basis
for
the
revisions
made
to
the
standards
between
proposal
and
promulgation.

1.1
SUMMARY
OF
CHANGES
SINCE
PROPOSAL
Several
changes
have
been
made
since
the
proposal
of
these
standards.
Major
changes
include
(
1)
dividing
tube
dryers
into
two
separate
process
units,
primary
and
secondary
tube
dryers,
and
adding
a
new
production­
based
compliance
option
for
secondary
tube
dryers;
(
2)

revising
Maximum
Achievable
Control
Technology
(
MACT)
floor
for
conveyor
strand
dryers
to
require
control
for
zone
1
for
existing
dryers
and
zones
1
and
2
for
new
dryers;
(
3)
changing
the
press
and
board
cooler
enclosure
requirement
from
Method­
204­
certified
permanent
total
enclosure
(
PTE)
to
wood
products
enclosure,
essentially
an
enclosure
designed
and
maintained
to
capture
all
emissions,
but
not
Method
204
certified;
(
4)
allowing
facilities
to
assume
zero
for
1­
2
nondetect
data
if
the
detection
limit
is
less
than
or
equal
to
1
ppmvd
and
all
three
runs
are
below
the
detection
limit
when
determining
if
they
can
meet
the
production­
based
compliance
options;

(
5)
exempting
combustion
units
from
testing
and
monitoring
requirements
if
the
exhaust
gas
to
be
treated
enters
the
combustion
unit
flame
zone;
(
6)
removing
the
requirement
to
monitor
the
static
pressure
or
flow
rate
for
thermal
and
catalytic
oxidizers,
and
clarifying
requirements
for
temperature
monitoring;
(
7)
adding
a
requirement
for
catalytic
oxidizers
to
check
catalyst
activity
of
a
representative
sample
annually;
(
8)
revising
the
biofilter
monitoring
requirements
by
removing
the
requirement
to
monitor
the
pH
and
static
pressure,
changing
the
location
of
the
biofilter
temperature
monitor,
allowing
sources
one
year
to
establish
the
operating
range
for
new
and
modified
biofilters,
and
requiring
repeat
performance
tests
every
two
years
and
every
time
more
than
half
of
the
bed
media
is
replaced;
(
9)
providing
flexibility
for
monitoring
process
units
that
meet
compliance
options
without
the
use
of
a
control
device;
(
10)
revising
wastewater
impacts;

(
11)
excluding
wastewater
from
regenerative
thermal
oxidizer/
regenerative
catalytic
oxidizer
(
RTO/
RCO)
washouts,
wet
electrostatic
precipitators
(
WESPs)
upstream
of
RTO/
RCO,
and
biofilters
from
effluent
guidelines;
(
12)
including
a
definition
of
wet
control
device
and
requiring
facilities
using
only
wet
control
devices
to
control
hazardous
air
pollutants
(
HAP)
to
submit
a
plan
detailing
how
they
plan
to
contain
or
destroy
the
HAP
collected
in
the
water;
(
13)
requiring
use
of
non­
HAP
coatings
for
certain
miscellaneous
coating
operations;
(
14)
revising
the
accuracy
requirements
and
calibration
procedures
for
moisture
monitors
used
with
rotary
dry
dryers
and
veneer
redryers;
(
15)
removing
the
requirement
to
schedule
maintenance
at
the
beginning
of
each
semi­
annual
period
and
modifying
requirement
to
minimize
emissions
during
periods
of
startup,

shutdown,
and
malfunction;
and
(
16)
consolidating
and
clarifying
the
entire
section
outlining
requirements
during
startup,
shutdown,
and
malfunction
(
SSM).

Other
changes
have
been
made
to
revise
certain
portions
of
the
rule
that
were
unclear
to
the
commenters,
including
(
1)
specifying
that
the
sampling
location
for
a
series
of
control
devices
should
be
the
functional
inlet
of
the
control
sequence;
(
2)
clarifying
that
facilities
cannot
combine
production­
based
compliance
options,
add­
on
controls,
and
emissions
averaging
for
a
single
process
unit
and
that
the
States
should
determine
how
multiple
add­
on
control
options
may
be
applied
and
included
in
a
permit;
and
(
3)
clarifying
the
classifications
of
credit­
generating
process
units
and
debit­
generating
process
units
for
the
emissions
averaging
compliance
option.
In
1­
3
addition,
in
order
to
eliminate
inconsistency
between
the
PCWP
NESHAP
and
revisions
of
the
MACT
General
Provisions,
various
sections
of
the
rule
were
revised
to
reference
the
General
Provisions
directly.
Finally,
multiple
definitions
were
added,
removed,
and
revised
within
the
definitions
section
of
the
rule.

In
addition
to
the
changes
mentioned
above,
the
final
PCWP
rule
includes
an
option
that
would
allow
individual
facilities
to
be
found
eligible
for
membership
in
a
delisted
low­
risk
subcategory
if
they
demonstrate
that
they
do
not
pose
a
significant
risk
to
human
health
or
the
environment.
The
low­
risk
subcategory
delisting
in
the
final
PCWP
rule
is
based
on
EPA's
authority
under
CAA
sections
112(
c)(
1)
and
(
9).
The
criteria
defining
the
low­
risk
subcategory
of
PCWP
facilities
are
included
in
Appendix
B
to
the
final
PCWP
rule.
Facilities
will
have
to
demonstrate
that
their
emissions
qualify
them
to
be
included
in
the
low­
risk
subcategory
using
the
methodology
and
criteria
in
Appendix
B.
Facilities
that
are
part
of
the
low­
risk
subcategory
are
not
be
subject
to
the
MACT
compliance
options
included
in
the
final
PCWP
rule.
2­
1
Chapter
2
Summary
of
Public
Comments
The
EPA
received
a
total
of
57
letters
commenting
on
the
proposed
standards
and
supporting
technical
memoranda
for
the
proposed
standards.
A
list
of
commenters,
their
affiliations,
and
the
EPA
docket
item
number
assigned
to
their
correspondence
is
provided
in
Table
2­
1.

To
achieve
an
organized
presentation,
we
have
grouped
the
comments
under
the
following
topics:

1.
Applicability;

2.
Health
effects;

3.
Existing
source
MACT;

4.
New
source
MACT;

5.
Air
pollution
control
devices;

6.
Compliance
options;

7.
Testing
and
monitoring
requirements;

8.
Cost
and
economic
assumptions
and
impacts;

9.
Startup,
shutdown,
and
malfunction
(
SSM);

10.
Risk­
based
approaches;
and
11.
Miscellaneous.
2­
2
The
comments,
the
issues
they
address,
and
EPA's
responses
are
discussed
in
the
following
sections
of
this
chapter.

Table
2­
1.
List
of
Commenters
on
Proposed
NESHAP
for
PCWP
Manufacturing
Docket
Item
No.
a
Commenter/
Affiliation
IV­
D­
01
L.
L.
Eagan,
Director,
Bureau
of
Air
Management,
State
of
Wisconsin,
Department
of
Natural
Resources,
Madison,
WI.

IV­
D­
02
J.
W.
Anderson,
President
of
the
Board
of
Supervisors,
Perry
County,
New
Augusta,
MS.

IV­
D­
03
M.
L.
Steele,
Environmental
Engineer,
CraftMaster
Manufacturing
Inc.
(
CMI),
Towanda,
PA.

IV­
D­
04
J.
D.
Thornton,
Manager,
Policy
&
Planning
Division,
Minnesota
Pollution
Control
Agency,
St.
Paul,
MN.

IV­
D­
05
J.
Wallen,
Environmental
Officer,
Hambro
Forest
Products
Inc.,
Crescent
City,
CA.

IV­
D­
06
R.
W.
Gore,
Chief,
Air
Division,
Alabama
Department
of
Environmental
Management
(
ADEM).

IV­
D­
07
J.
W.
Sanders,
Forest
Supervisor,
U.
S.
Department
of
Agriculture,
Duluth,
MN.

IV­
D­
08
J.
S.
Spadaro,
President,
SDS
Lumber
Company,
Bingen,
WA.

IV­
D­
09
P.
B.
Barringer
II,
Chairman
&
CEO,
Coastal
Lumber
Company,
Weldon,
NC.

IV­
D­
10
J.
R.
Ferlin,
President,
Brooks
Manufacturing
Co.,
Bellingham,
WA.

IV­
D­
11
J.
T.
Higgins,
Director,
Bureau
of
Stationary
Sources
Division
of
Air
Resources,
New
York
State
Department
of
Environmental
Conservation,
Albany,
NY.

IV­
D­
12
J.
Bradfield,
Director
of
Environmental
Affairs,
Composite
Panel
Association,
Gaithersburg,
MD.

IV­
D­
13
P.
Quosai,
Manager,
Environment
Health
&
Safety,
Norbord
Industries
Inc.,
Toronto,
Ontario,
Canada.

IV­
D­
14
D.
J.
Hejna,
Environmental
Manager,
Potlatch
Corp.,
Bemidji,
MN.

IV­
D­
15
R.
Freres,
Vice
President,
Freres
Lumber
Company
Inc.,
Lyons,
OR.
Docket
Item
No.
a
Commenter/
Affiliation
2­
3
IV­
D­
16
E.
Piliaris,
General
Manager,
Hardel
Mutual
Plywood
Corp.,
Chehalis,
WA.

IV­
D­
17
T.
J.
Davis,
Mayor,
Town
of
Havana,
Havana,
FL.

IV­
D­
18
L.
Eagan,
Chair,
State
and
Territorial
Air
Pollution
Program
Administrators
(
STAPPA)
Air
Toxics
Committee
and
R.
Colby,
Association
of
Local
Air
Pollution
Control
Officials
(
ALAPCO)
Air
Toxics
Committee,
Washington,
DC.

IV­
D­
19
P.
J.
Vasquez,
Senior
Manager,
Environmental
Engineering
­
Wood
Products,
Georgia­
Pacific
Corp.,
Atlanta,
GA.

IV­
D­
20
D.
H.
Word,
Ph.
D.,
Program
Manager,
National
Council
for
Air
and
Stream
Improvement
Inc.
(
NCASI),
Gainesville,
FL.

IV­
D­
21
S.
E.
Woock,
Federal
Regulatory
Affairs
Manager,
Weyerhaeuser,
New
Bern,
NC.

IV­
D­
22
L.
S.
Hyde,
Manager
Environmental
Department
for
Koppers
Industries
Inc.,
B.
Crossman
for
Atlantic
Wood
Industries,
J.
Ferlin
for
Brooks
Manufacturing
Co.,
M.
Lodgeon
for
Fontana
Wood
Preserving
Inc.,
D.
Devries
for
Thunderbolt
Wood
Treating
Company
Inc.,
and
M.
Wright
for
Wood
Preservers
Inc.

IV­
D­
23
R.
Strader,
Environmental
Manager,
Boise
Building
Solutions,
Boise
Cascade
Corp.,
Boise,
ID.

IV­
D­
24
R.
S.
Frye,
Counsel
for
Louisiana­
Pacific
Corp.,
Collier
Shannon
Scott
PLLC,
Washington,
DC.

IV­
D­
25
V.
Ughetta,
Director
Stationary
Sources,
The
Alliance
of
Automobile
Manufacturers,
Washington,
DC.

IV­
D­
26
J.
Walke,
D.
McIntosh,
J.
Devine,
Natural
Resources
Defense
Council,
Washington,
DC.

IV­
D­
27
T.
G.
Hunt,
Senior
Director,
Air
Quality
Programs,
American
Forest
&
Paper
Association,
Washington,
DC.

IV­
D­
28
J.
M.
Tracy,
Vice
President
East
Coast
Operations,
Moncure,
NC.

IV­
D­
29
D.
Burns,
Vice
President,
Southeastern
Lumber
Manufacturers
Association
(
SLMA).

IV­
D­
30
S.
Ngo,
Private
Citizen,
Houston,
TX.
Docket
Item
No.
a
Commenter/
Affiliation
2­
4
IV­
D­
31
J.
P.
Mieure
Ph.
D.,
President,
The
Formaldehyde
Epidemiology,
Toxicology,
and
Environmental
Group
Inc.
(
FETEG),
Washington,
DC.

IV­
D­
32
C.
Morretta,
Administrative
Director,
Mercatus
Center
at
George
Mason
University,
Arlington,
VA.

IV­
D­
33
M.
A.
Round,
Senior
Air
Toxics
Program
Analyst,
The
Northeast
States
for
Coordinated
Air
Use
Management
(
NESCAUM),
Boston,
MA.

IV­
D­
34
G.
Grimes,
Environmental
Director,
Timber
Products
Company,
Medford,
OR.

IV­
D­
35
D.
S.
Hill,
Executive
Vice
President,
Southern
Oregon
Timber
Industries
Association
(
SOTIA),
Medford,
OR.

IV­
D­
36
R.
J.
Spahr,
Mayor,
City
of
Chehalis,
Chehalis,
WA.

IV­
D­
37
B.
M.
Martin
II,
Director
Environmental
Affairs,
Huber
Engineered
Woods,
Dayton,
TN.

IV­
D­
38
L.
Dailey,
Mayor,
Town
of
Beaumont,
Beaumont,
MS.

IV­
D­
39
J.
Galloway,
President,
Hood
Industries,
Hattiesburg,
MS.

IV­
D­
40
D.
Hatten,
President,
Stone
County
Board
of
Supervisors,
Wiggins,
MS.

IV­
D­
41
T.
H.
O'Melia
Jr.,
President,
Scotch
Plywood
Company,
Fulton,
AL.

IV­
D­
42
K.
Adams,
Vice
President
Operations,
Southern
Veneer
Products,
Fitzgerald,
GA.

IV­
D­
43
D.
J.
Harvey,
Director
of
Environmental
Affairs,
Louisiana­
Pacific
Corporation,
Portland,
OR.

IV­
D­
44
J.
O.
Rabby,
President,
Bank
of
Wiggins,
Wiggins,
MS.

IV­
D­
45
W.
L.
Gramm,
Director,
Regulatory
Studies
Program,
and
S.
E.
Dudley,
Senior
Research
Fellow,
George
Mason
University,
Mercatus
Center,
Arlington,
VA.

IV­
D­
46
M.
E.
Rock,
President
&
Senior
Principal,
Omni
Professional
Environmental
Assoc.,
Research
Triangle
Park,
NC.

IV­
D­
47
R.
Childers,
Environmental
Coordinator,
U.
S.
Forest
Industries
Inc.,
Grants
Pass,
OR.

IV­
D­
48
T.
DeVore,
Plant
Environmental
Manager,
Collins
Products
LLC,
Klamath
Falls,
OR.
Docket
Item
No.
a
Commenter/
Affiliation
2­
5
IV­
D­
49
J.
P.
Witkowski,
Air
Subcommittee
Chair,
Environmental/
Technical
Committee,
South
Carolina
Chamber
of
Commerce,
Columbia,
SC.

IV­
D­
50
S.
Bruggeman,
South
Coast
Lumber
Company
&
Pacific
Wood
Laminates
Inc.,
Brookings,
OR.

IV­
D­
51
S.
Boone,
P.
E.,
URS
Corporation.

IV­
D­
52
T.
Noteboom,
Corporate
Environmental
Engineer,
Pella
Corporation.

IV­
D­
53
J.
Murphy,
Vice
President/
COO,
Murphy
Plywood,
Sutherlin,
OR.

IV­
D­
54
D.
Wylie,
Chief,
Air
Division,
Mississippi
Department
of
Environmental
Quality,
State
of
Mississippi.

IV­
D­
55
M.
Peters,
McKinney
&
Stringer,
P.
C.
(
comments
on
behalf
of
Dominance
Industries,
Inc.
d/
b/
a
Pan
Pacific
Products,
Inc.).

IV­
D­
56
A.
Casey,
Sr.
Environmental
Engineer,
Masonite,
Chicago,
IL.

IV­
D­
57
R.
S.
Frye,
Counsel
for
Louisiana­
Pacific
Corp.,
Collier
Shannon
Scott
PLLC,
Washington,
DC.

aThe
docket
number
for
the
PCWP
Manufacturing
NESHAP
is
A­
98­
44.

2.1
APPLICABLITY
2.1.1
Affected
source
and
major
source
determination
2.1.1.1
Comment:
Commenters
requested
that
EPA
clarify
that
the
PCWP
affected
source
includes
refining
and
resin
preparation
activities
such
as
mixing,
formulating,
blending,
and
chemical
storage,
and
suggested
that
boilers
be
excluded.
Commenters
also
recommended
changing
the
definition
of
affected
source
by
revising
the
definition
of
"
plant
site,"
which
is
used
in
the
affected
source
definition.

Commenter
IV­
D­
27
suggested
that
EPA
modify
the
definition
of
"
affected
source"
by
adding
refining
and
resin
preparation
as
process
operations
and
by
excluding
boilers.
Commenters
IV­
D­
21
and
IV­
D­
27
requested
that
mixing,
formulating,
blending
and
storage
of
various
chemicals
at
PCWP
plants
be
subject
to
the
proposed
PCWP
NESHAP.
The
commenters
2­
6
contended
that
the
HAP
emissions
from
these
four
activities
at
PCWP
plants
are
insignificant,
and
the
emissions
associated
with
them
would
be
impractical
to
control.

Commenter
IV­
D­
27
noted
that
they
also
had
submitted
comments
on
the
proposed
miscellaneous
organic
NESHAP
(
MON)
rule
requesting
that
such
activities
at
PCWP
facilities
be
excluded
from
the
requirements
of
the
MON.
1
In
those
comments,
the
commenter
specifically
requested
that
EPA
include
language
in
subpart
FFFF
(
Miscellaneous
Organic
Chemical
Manufacturing
NESHAP)
and
subpart
HHHHH
(
Miscellaneous
Coating
Manufacturing
NESHAP)
to
the
effect
that
those
subparts
would
apply
to
the
manufacture
of
chemical
products
rather
than
to
activities
associated
with
the
use
of
a
coating
by
an
end
user,
including
mixing
and
storage
of
coatings
prior
to
using
them.
The
commenter
expressed
concern
that
the
proposed
MON
rule
could
suggest
that
a
unit
process
is
exempt
from
the
MON
rule
only
if
MACT
standards
for
another
source
category
establish
control
requirements
for
that
particular
unit
process.
If
the
MON
were
interpreted
this
way,
any
activities
such
as
mixing,
blending,
and
storage
of
various
chemicals
at
PCWP
facilities
that
would
not
be
required
to
be
controlled
under
the
PCWP
NESHAP
could
be
subject
to
control
requirements
in
the
MON
rule.
Therefore,

commenters
requested
that
EPA
unambiguously
state
in
the
PCWP
rule
that
chemical
mixing,

formulating,
blending,
and
storage
activities
that
occur
at
PCWP
facilities
are
covered
by
the
PCWP
NESHAP
and
are
not
subject
to
other
NESHAP,
including
the
MON
rule.

Commenters
IV­
D­
27
and
IV­
D­
21
recommended
changing
the
definition
of
affected
source
by
revising
the
definition
of
"
plant
site,"
which
is
used
in
the
affected
source
definition.

The
commenters
want
EPA
to
make
the
definition
of
"
plant
site"
consistent
with
the
definition
of
"
major
source"
as
defined
for
title
V
permitting
in
40
CFR
§
70.2.
According
to
the
commenters,

the
proposed
definition
of
"
plant
site"
expanded
the
definition
of
a
source
beyond
that
used
for
title
V
permitting
or
MACT
applicability
in
general.
Based
on
the
definition
of
"
major
source"

below,
the
commenters
requested
that
wording
be
added
to
the
proposed
definition
of
"
plant
site"

to
limit
a
source
to
a
single
major
industrial
grouping
and
that
the
last
sentence
in
the
proposed
definition
of
plant
site
be
removed.

"
Major
source
means
any
stationary
source
(
or
any
group
of
stationary
sources
that
are
located
on
one
or
more
contiguous
or
adjacent
properties,
and
are
under
common
control
of
the
same
person
(
or
persons
under
common
control))
belonging
to
a
single
major
2­
7
industrial
grouping
and
that
are
described
in
paragraph
(
1),
(
2),
or
(
3)
of
this
definition.
For
the
purposes
of
defining
"
major
source,"
a
stationary
source
or
group
of
stationary
sources
shall
be
considered
part
of
a
single
industrial
grouping
if
all
of
the
pollutant
emitting
activities
at
such
source
or
group
of
sources
on
contiguous
or
adjacent
properties
belong
to
the
same
Major
Group
(
i.
e.,
all
have
the
same
two­
digit
code)
as
described
in
the
Standard
Industrial
Classification
Manual,
1987."

Industry's
recommended
changes
to
the
definitions
of
"
affected
source"
and
"
plant
site"

are
as
follows
(
additions
are
in
italics
and
deletions
are
in
strikeout
format):

Affected
source
means
the
collection
of
dryers,
refiners,
blenders,
formers,
presses,
board
coolers,
and
other
process
units
associated
with
the
manufacturing
of
plywood
and
composite
wood
products
at
a
plant
site.
The
affected
source
includes,
but
is
not
limited
to,
green
end
operations,
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
elsewhere
in
this
section).
The
affected
source
includes
lumber
kilns
at
PCWP
manufacturing
facilities
and
at
any
other
kind
of
facility.
The
affected
source
does
not
include
boilers.

Plant
site
means
all
contiguous
or
adjoining
property
belonging
to
a
single
major
industrial
grouping
that
is
under
common
control,
including
properties
that
are
separated
only
by
a
road
or
other
public
right­
of­
way.
Common
control
includes
properties
that
are
owned,
leased,
or
operated
by
the
same
entity,
parent
entity,
subsidiary,
or
any
combination
thereof.

Response:
For
the
final
rule,
we
changed
the
proposed
definition
of
affected
source
as
follows:

Affected
source
means
the
collection
of
dryers,
refiners,
blenders,
formers,
presses,
board
coolers,
and
other
process
units
associated
with
the
manufacturing
of
plywood
and
composite
wood
products
at
a
plant
site.
The
affected
source
includes,
but
is
not
limited
to,
green
end
operations,
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
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
2­
8
elsewhere
in
this
section).
The
affected
source
includes
lumber
kilns
at
PCWP
manufacturing
facilities
and
at
any
other
kind
of
facility.

We
added
refining
and
resin
preparation
activities
to
the
definition
of
"
affected
source"
to
clarify
that
these
activities
are
part
of
the
PCWP
source
category
and
are
not
subject
to
the
MON.

We
believe
these
changes
are
appropriate
because
MACT
for
refining
and
resin
preparation
activities
was
determined
under
the
PCWP
rulemaking.
Resin
preparation
includes
any
mixing,

blending,
or
diluting
of
resins
used
in
the
manufacture
of
PCWP
products
that
occurs
at
the
PCWP
manufacturing
facility.
We
determined
that
MACT
for
new
and
existing
atmospheric
refiners,
blenders,
and
resin
storage/
mixing
tanks
is
no
emission
reduction.
For
new
and
existing
pressurized
refiners,
we
determined
that
MACT
is
based
on
the
use
of
incineration­
based
control
or
a
biofilter.
The
MON
subparts
FFFF
and
HHHHH
exclude
activities
included
as
part
of
the
affected
source
for
other
source
categories.
Thus,
refining
and
resin
preparation
are
not
subject
to
the
MON
Subparts
FFFF
or
HHHHH.

We
deleted
the
proposed
definition
of
"
plant
site"
from
the
final
rule
to
eliminate
confusion.
The
term
"
plant
site"
was
used
only
in
the
proposed
definitions
of
"
affected
source"

and
"
plywood
and
composite
wood
products
manufacturing
facility."
The
term
"
plant
site"
was
eliminated
from
the
proposed
definition
of
"
affected
source"
and
was
replaced
by
the
word
"
facility"
in
the
definition
of
"
plywood
and
composite
wood
products
manufacturing
facility."

These
changes
leave
to
title
V
permit
writers
the
discretion
to
determine
the
boundaries
around
each
facility
for
purposes
of
both
title
V
and
MACT.
We
believe
deleting
the
term
"
plant
site"

clarifies
that
the
requirements
of
the
final
rule
would
apply
only
to
the
affected
source,
which
is
the
PCWP
manufacturing
facility.
However,
we
note
that
any
major
source
determination
would
be
based
on
total
emissions
from
operations
that
are
co­
located
and
under
common
control
according
to
the
definition
of
major
source
in
the
General
Provisions
(
40
CFR
part
63,
subpart
A).

We
did
not
remove
the
phrase
"
not
subject
to
other
NESHAP"
from
the
list
of
miscellaneous
finishing
operations
in
the
definition
of
"
affected
source"
as
suggested
by
the
commenter.
The
phrase
was
retained
to
avoid
overlap
between
the
PCWP
and
Wood
Building
2­
9
Products
rules.
We
also
did
not
add
"
and
preparation
of
raw
materials"
because
this
change
is
not
necessary
given
the
addition
of
"
resin
preparation"
earlier
in
the
definition.

We
did
not
add
the
commenter's
suggested
statement
that
"
the
affected
source
does
not
include
boilers"
because
it
is
possible
for
a
boiler
to
be
subject
to
both
the
PCWP
NESHAP
and
Boilers/
Process
Heaters
NESHAP
(
e.
g.,
if
a
portion
of
the
boiler
exhaust
is
used
to
direct­
fire
dryers
while
the
remaining
portion
of
the
boiler
exhaust
is
vented
to
the
atmosphere).
However,

in
most
cases
combustion
units
would
only
be
subject
to
one
NESHAP
(
either
the
PCWP
NESHAP
for
combustion
units
dedicated
to
directly
firing
process
units
or
the
Boilers/
Process
Heaters
NESHAP
for
combustion
units
that
are
not
used
to
direct­
fire
process
units).

2.1.1.2
Comment:
Commenters
IV­
D­
08,
IV­
D­
09,
IV­
D­
15,
IV­
D­
39,
IV­
D­
41,
IV­
D­

42,
and
IV­
D­
53
requested
that
EPA
modify
the
definition
of
major
source
to
exclude
certain
low­
HAP
resins
from
plant­
wide
HAP
emission
calculations
at
softwood
plywood
plants.
These
commenters
contended
that
the
source
of
most
of
the
emissions
from
softwood
plywood
plants
is
the
resin;
all
of
these
commenters
(
except
IV­
D­
08
and
IV­
D­
41)
provided
a
facility­
specific
mass
balance
to
support
their
assertion.
According
to
the
commenters,
if
a
plant
uses
a
resin
with
minimal
HAP
content,
then
that
pollutant
should
be
omitted
from
the
emission
calculations
around
the
press.
The
commenters
noted
that
the
resins
used
20
years
ago
had
high
HAP
contents,
but
since
then
chemical
companies
have
reduced
the
HAP
content
at
the
plywood
companies'
request.

The
reporting
thresholds
of
the
Toxics
Release
Inventory
(
TRI)
program
under
the
Superfund
Amendments
and
Reauthorization
Act
(
SARA)
title
III,
section
313,
are
less
than
1
percent
of
any
HAP
and
less
than
0.1
percent
of
any
carcinogenic
HAP.
Most
of
the
resins
used
in
today's
PCWP
plants
meet
those
standards.
The
commenters
requested
that
EPA
adopt
these
reporting
thresholds
into
the
PCWP
rule
such
that
if
the
resin
contains
less
than
1
percent
of
any
HAP
or
less
than
0.1
percent
of
any
carcinogenic
HAP,
the
press
emissions
should
be
excluded
from
the
emission
calculations.
In
addition,
the
commenters
stated
that
emissions
of
any
HAP
in
an
undiluted
stream
that
are
less
than
Occupational
Safety
and
Health
Administration
(
OSHA)

Permissible
Exposure
Limit
(
PEL)
also
should
be
excluded
from
the
calculations
because
these
low
levels
do
not
pose
a
threat
to
the
environment
or
human
health.
The
commenters
suggested
the
following
addition
to
section
63.2231(
b)
(
Does
this
subpart
apply
to
me?):
2­
10
"
For
the
purposes
of
this
subpart,
emissions
from
presses
where
the
resin
contains
less
than
1
percent
of
any
HAP
and
less
than
0.1
percent
of
any
HAP
that
is
a
carcinogen
will
be
excluded
from
these
emission
calculations.
Also,
any
emission
of
a
HAP
in
an
undiluted
process
stream
that
is
present
at
concentrations
below
the
PEL
established
by
OSHA
shall
be
excluded
from
these
emission
calculations.
The
HAP
content
in
the
resin
shall
be
supplied
by
the
resin
manufacturer
as
required
by
CFR
Part
1910.1200.
The
emissions
of
HAP
in
process
streams
shall
be
determined
by
engineering
assessments,
process
knowledge,
or
test
data
using
EPA
approved
methods."

Response:
The
language
suggested
by
the
commenters
is
not
included
in
the
final
PCWP
NESHAP.
The
CAA
requires
that
major
source
status
be
determined
by
accounting
for
emissions
from
all
HAP­
emitting
processes
at
a
facility.
According
to
the
proposal
background
information
document
(
BID),
HAP
emissions
from
softwood
plywood
presses
are
generally
around
7
tons
per
year
(
tpy)
and
HAP
emissions
from
veneer
dryers
are
typically
around
5
tpy.
A
typical
softwood
plywood
plant
has
at
least
one
press
and
multiple
veneer
dryers,
and
therefore
can
easily
exceed
the
10/
25­
tpy
major
source
thresholds.

The
HAP
emissions
from
softwood
plywood
plants
include
emissions
associated
with
wood
drying;
therefore,
determination
of
HAP
emissions
involves
more
than
documenting
resin
HAP
content
as
is
done
for
TRI
reporting.
Also,
OSHA
sets
PELs
to
protect
workers
against
the
health
effects
of
exposure
to
hazardous
substances.
The
PELs
are
regulatory
limits
on
the
amount
or
concentration
of
a
substance
in
the
air
to
which
a
worker
is
exposed.
The
OSHA
PEL
is
designed
to
protect
workers,
not
for
the
express
purpose
of
protecting
the
environment.
The
CAA
requires
NESHAP
based
on
MACT
for
softwood
plywood
facilities,
and
MACT
for
softwood
plywood
facilities
is
determined
differently
(
i.
e.,
technology­
based
standard
determination)
and
for
a
different
purpose
(
i.
e.,
protection
of
the
environment)
than
the
OSHA
PEL.
For
these
reasons,
we
disagree
that
calculations
associated
with
TRI
or
the
OSHA
PEL
have
any
bearing
on
facility
status
as
a
HAP
major
source
for
purposes
of
the
PCWP
NESHAP.

2.1.1.3
Comment:
Commenter
IV­
D­
47
claimed
that
the
emission
factor
data
upon
which
major
source
determinations
must
be
made
is
variable
and
"
unsubstantiated."
As
an
example,
the
commenter
pointed
out
that
the
EPA's
AP­
42
emission
factor
for
methanol
emissions
from
a
plywood
press
is
high
enough
to
classify
almost
all
plywood
plants
as
major
2­
11
sources,
but
if
the
NCASI
factor
is
applied
to
the
same
plants,
they
might
be
well
below
the
major
source
level.
The
commenter
stated
that
a
lot
of
the
emissions
data
used
to
support
the
emissions
factor
development
were
collected
from
facilities
with
unique
situations
and
may
not
be
completely
accurate
for
all
situations.
The
commenter
noted
that
the
alternative
to
using
emissions
factors
is
to
test
potential
sources
of
HAP
at
each
facility;
however,
the
commenter
argued
that
some
of
the
EPA's
test
methods
are
unreliable.

Response:
It
is
the
responsibility
of
permitting
authorities
to
decide
what
data
are
to
be
used
in
major/
area
source
determinations
(
e.
g.,
emissions
test
data,
AP­
42
emission
factors).

Various
EPA
and
NCASI
methods
are
available
for
testing
PCWP
emissions.
For
example,
the
final
PCWP
rule
lists
five
methods
that
can
be
used
for
measuring
formaldehyde
emissions
and
four
methods
that
can
be
used
to
measure
methanol
emissions.

As
further
explained
in
response
to
comment
2.2,
emissions
data
from
three
sources
were
used
in
development
of
the
MACT
standards:
(
1)
data
used
to
develop
the
September
1997
Plywood
AP­
42
section
10.5,
(
2)
data
from
NCASI's
29­
mill
sampling
program
submitted
to
EPA
in
1999,
and
(
3)
data
from
test
reports
collected
by
EPA
in
1998.
The
Plywood
AP­
42
section
10.5
was
revised
to
incorporate
the
new
emissions
test
data
received
through
EPA's
industry
survey
and
the
NCASI
sampling
program.
The
final
revised
AP­
42
section
was
placed
on
our
Web
site
(
http://
www.
epa.
gov/
ttn/
chief/
ap42/
ch10/)
in
January
2002.
We
also
note
that
along
with
the
revised
AP­
42
section,
a
spreadsheet
of
emission
test
results
used
in
developing
the
AP­
42
emission
factors
has
been
placed
on
our
Web
site.
If
allowed
by
the
permitting
authority,

facilities
can
select
data
from
these
spreadsheets
that
better
depict
their
operations
(
e.
g.,
by
choosing
only
the
indirect­
fired
veneer
dryer,
Douglas
fir
emission
factors
as
opposed
to
the
indirect­
fired
softwood
veneer
dryer
factors).

2.1.2
Equipment
groups
2.1.2.1
Comment:
Commenters
IV­
D­
19
and
IV­
D­
27
recommended
that
a
number
of
definitions
be
added
to
the
rule
to
better
define
those
processes
and
process
unit
groups
for
which
there
are
no
control
requirements
under
subpart
DDDD.
The
commenters
recommended
that
the
following
definitions
be
added
to
the
rule:
2­
12
Adhesive/
additive
preparation
unit
means
a
production
unit
designed
to
prepare
or
transport
adhesives,
resins
and
additives
for
subsequent
use
in
the
production
of
plywood
and
composite
panels.
Preparation
includes
chemical
mixing,
formulating,
and
blending
activities.
An
adhesive/
additive
preparation
unit
is
a
process
unit.

Agricultural
fiber
means
the
fiber
of
an
annual
agricultural
crop.
Examples
of
agricultural
fibers
include
(
but
are
not
limited
to)
wheat
straw,
rice
straw,
and
bagasse.

Agricultural
fiber
board
press
means
a
press
used
in
the
production
of
an
agricultural
fiber
based
composite
wood
product.
An
agricultural
fiber
board
press
is
a
process
unit.

Atmospheric
refiner
means
a
piece
of
equipment
operated
under
atmospheric
pressure
for
refining
(
rubbing
or
grinding)
the
wood
material
into
fibers
or
particles.
Atmospheric
refiners
are
operated
with
continuous
infeed
and
outfeed
of
wood
material
and
atmospheric
pressures
throughout
the
refining
process.
An
atmospheric
refiner
is
a
process
unit.

Blender
means
an
enclosed
system
designed
to
mix
adhesive
and
other
additives
with
the
(
wood)
furnish
of
the
composite
panel.
The
blender
does
not
include
process
units
for
storage
of
adhesives
or
additives
or
process
units
that
prepare
adhesives
or
additives
for
use.
A
blender
is
a
process
unit.

Engineered
wood
product
press
means
a
composite
wood
product
press,
curing
chamber
or
clamping
system
used
in
the
production
of
wood
I­
Joists,
glue­
laminated
beams,
laminated
strand
lumber
(
LSL),
parallel
strand
lumber
(
PSL)
and
laminated
veneer
lumber
(
LVL)
and
similar
products.
An
engineered
wood
product
press
is
a
process
unit.

Fiber
washer
means
a
unit
in
which
water­
soluble
components
of
wood
(
hemicellulose
and
derived
five
carbon
sugars)
that
have
been
produced
during
digesting
and
refining
are
removed
from
the
wood
fiber.
Typically
wet
fiber
leaving
a
refiner
is
further
diluted
with
water
and
then
passed
over
wire
covered
drum
filter
leaving
the
cleaned
fiber
on
the
surface
of
the
drum
where
it
is
picked
up
and
carried
to
the
next
step,
a
device
that
produces
a
composite
wood
product
mat
either
through
dry
forming
or
wet
forming.
A
fiber
washer
is
a
process
unit.

Former
means
a
device
that
produces
a
composite
wood
product
mat
either
through
dry
forming
or
wet
forming.
A
former
is
a
process
unit.
2­
13
Humidifier
means
a
process
unit
used
to
increase
the
moisture
content
of
hardboard
following
pressing
or
after
post­
baking.
Typically,
water
vapor
saturated
air
is
blown
over
the
hardboard
surfaces
in
a
closed
cabinet.
A
humidifier
is
a
process
unit.

Maintenance
operation
means
equipment
associated
with
maintenance
operations
at
plywood
and
composite
wood
products
plants.
Maintenance
operations
include
but
are
not
limited
to
all
metal
working,
vehicle
maintenance,
and
building
maintenance
activities.

Miscellaneous
processing
operation
means
equipment
that
processes
material
for
plywood
and
composite
wood
product
operations
that
is
separate
from
controlled
equipment
defined
in
the
rule.
Miscellaneous
processing
operations
include
but
are
not
limited
to
all
conveyors
(
including
pneumatic
conveyors)
for
material
transfer,
recycling
or
waste
removal,
and
screens.
Miscellaneous
processing
operations
are
process
units.

Plywood
press
means
a
composite
wood
product
press
used
in
the
production
of
plywood.
A
plywood
press
is
a
process
unit.

Raw
material
processing
operation
means
equipment
that
processes
raw
material
for
plywood
and
composite
wood
product
operations
prior
to
the
refiners
and
dryers
defined
in
the
rule.
Raw
material
processing
operations
include
but
are
not
limited
to
all
raw
material
storage
buildings,
raw
material
unloading
and
transfer
equipment,
outside
raw
material
storage
operations,
wood
fuel
storage
piles,
log
decks,
log
vats
and
their
related
water
handling
systems
(
heaters,
screens,
pumps,
tanks,
etc.),
debarkers,
chippers,
hogs,
conveyors,
screens
and
board
breakers.
Raw
material
processing
operations
are
process
units.

Rotary
agricultural
fiber
dryer
means
a
rotary
dryer
operated
at
elevated
temperature
and
used
to
reduce
the
moisture
of
agricultural
fiber.
A
dry
rotary
dryer
is
a
process
unit.

Shipping
and
warehousing
operation
means
equipment
associated
with
final
preparation
shipping
of
plywood
and
composite
wood
products.
Shipping
and
warehousing
operations
include
but
are
not
limited
to
all
truck
and
rail
loading
and
unloading,
wrapping,
and
warehousing.
Shipping
and
warehousing
operations
are
process
units.

Stand
alone
digester
means
a
pressure
vessel
used
to
heat
and
soften
wood
chips
before
the
chips
are
sent
to
a
separate
process
unit
for
refining
into
fiber.
A
stand
alone
digester
is
a
process
unit.
2­
14
Storage
tank
means
any
storage
tank,
stock
chest,
bin,
silo,
container
or
vessel
connected
to
plywood
and
composite
wood
product
production.
Storage
tanks
include
but
are
not
limited
to
storage
tanks
for
in­
process
material,
adhesives,
resins,
additives,
and
fuel.
A
storage
tank
is
a
process
unit.

Wastewater/
process
water
operation
means
equipment
that
processes
water
in
plywood
or
composite
wood
product
facilities
for
reuse
or
disposal.
Wastewater/
process
water
operations
includes
but
is
not
limited
to
pumps,
holding
ponds
and
tanks,
cooling
and
heating
operations,
settling
systems,
filtration
systems,
aeration
systems,
clarifiers,
pH
adjustment
systems,
log
storage
ponds,
log
vats,
pollution
control
device
water
(
including
wash
water),
vacuum
distillation
systems,
sludge
drying
and
disposal
systems,
spray
irrigation
fields,
and
connections
to
POTW
facilities.
Wastewater/
process
water
operations
are
process
units.

Wood
product
machining
operation
means
equipment
that
cuts,
mills,
or
machines
wood
products
to
meet
either
a
process
requirement
or
produce
an
end
product
feature.
Machining
operations
include
but
are
not
limited
to
all
saws,
sanders,
grooving
machines,
planers,
edge
molding,
and
tongue
and
groove
operations.
Wood
product
machining
operations
are
process
units.

Response:
We
disagree
that
it
is
necessary
or
appropriate
to
define
terms
that
are
not
used
in
the
text
of
the
final
PCWP
rule.
Equipment
or
operations
that
are
not
HAP
emission
sources
and/
or
have
no
regulatory
requirements
are
not
defined
in
the
rule,
and
adding
definitions
for
such
equipment
would
complicate
the
rule
rather
than
providing
clarity.
Therefore,
most
of
the
definitions
provided
by
the
commenter
are
not
included
in
the
final
PCWP
rule.

The
term
"
agricultural
fiber"
appears
in
our
definition
of
"
plywood
and
composite
wood
products
facility;"
therefore,
we
added
the
commenters'
suggested
definition
of
"
agricultural
fiber"
to
the
final
rule.
Note
that
the
definitions
of
"
particle"
and
"
fiber"
also
mention
"
cellulosic
material"
to
account
for
use
of
agricultural
fiber.

2.1.2.2
Comment:
Commenters
IV­
D­
03
and
IV­
D­
27
requested
that
the
definition
of
a
tube
dryer
in
section
63.2292
of
the
proposed
rule
be
changed
so
that
stages
in
multistage
tube
dryers
are
considered
as
separate
tube
dryers.
Commenter
IV­
D­
03
stated
that,
under
the
current
definition,
a
multistage
dryer
with
more
than
one
control
device
and
emissions
point
would
be
considered
one
process
unit.
Commenter
IV­
D­
03
stated
that
modifying
the
tube
dryer
definition
2­
15
will
allow
facilities
to
choose
the
most
cost­
effective
compliance
option.
With
the
modifications
(
in
italics)
recommended
by
the
commenters,
the
tube
dryer
definition
would
read
as
follows:

Tube
dryer
means
a
single­
stage
dryer
or
a
stage
in
a
multistage
dryer
system
operated
at
elevated
temperature
and
used
to
reduce
the
moisture
of
wood
fibers
or
particles
as
they
are
conveyed
(
usually
pneumatically)
through
the
dryer.
Resin
may
or
may
not
be
applied
to
the
wood
material
before
it
enters
the
tube
dryer.
A
tube
dryer
is
a
process
unit.

Response:
Tube
dryers
are
either
single­
stage
or
multistage
drying
systems.
Single­
stage
tube
dryers
include
only
a
primary
tube
dryer.
Multistage
tube
drying
systems
incorporate
two
stages
in
series,
a
primary
tube
dryer
and
a
secondary
tube
dryer,
which
are
separated
by
an
emission
point
(
e.
g.,
a
cyclonic
collector).
Annual
uncontrolled
HAP
emissions
from
primary
tube
dryers
average
around
65
tpy,
while
annual
uncontrolled
HAP
emissions
form
secondary
tube
dryers
average
around
2
tpy.
2
In
developing
the
PCWP
proposal,
we
noted
that
the
function
of
tube
dryers
is
the
same
regardless
of
single­
stage
or
multistage
configuration
(
i.
e.,
to
reduce
the
wood
furnish
moisture
from
an
initial
level
to
some
lower
level)
and
that
distinguishing
between
dryer
configurations
would
not
change
the
results
of
the
MACT
floor
analysis
and
could
unnecessarily
complicate
the
PCWP
regulation.
Therefore,
we
made
no
distinction
between
single­
stage
and
multistage
tube
dryers.
3
We
agree
with
the
commenter
that
defining
the
stages
of
multistage
tube
dryers
separately
would
allow
facilities
the
flexibility
of
choosing
different
compliance
options
for
each
stage
of
the
tube
dryer.
Each
stage
of
a
multistage
tube
dryer
functions
as
an
individual
dryer,
and
the
MACT
floor
for
both
primary
tube
dryers
and
secondary
tube
dryers
is
the
same
(
e.
g.,
incineration­
based
control).
For
example,
a
facility
with
a
multistage
tube
dryer
could
use
an
add­
on
air
pollution
control
device
(
APCD)
to
reduce
emissions
from
the
primary
tube
dryer
and
could
use
emissions
averaging
to
offset
the
emissions
from
the
secondary
tube
dryer.

The
final
PCWP
rule
includes
definitions
of
"
primary
tube
dryer"
and
"
secondary
tube
dryer."
The
final
rule
also
contains
separate
production­
based
compliance
options
(
PBCO)
for
these
two
types
of
dryers,
reflecting
the
difference
in
emissions
from
primary
and
secondary
tube
dryers.
The
change
to
the
"
tube
dryer"
definition
suggested
by
the
commenter
was
not
used
because
it
did
not
adequately
distinguish
between
the
two
types
of
dryers
and
would
have
allowed
2­
16
the
higher
primary
tube
dryer
PBCO
to
be
applied
to
both
primary
and
secondary
tube
dryers.

Our
inclusion
of
separate
definitions
of
"
primary
tube
dryer"
and
"
secondary
tube
dryer"
provides
the
flexibility
to
choose
different
compliance
options
for
each
stage
of
a
multistage
tube
dryer
as
requested
by
the
commenter
without
creating
a
loophole
under
the
PBCO.

2.1.2.3
Comment:
Commenter
IV­
D­
27
recommended
that
a
number
of
definitions
included
in
the
proposed
rule
be
revised
to
better
distinguish
among
particleboard,
medium
density
fiberboard
(
MDF),
and
hardboard
and/
or
to
be
consistent
with
definitions
developed
by
the
American
National
Standards
Institute
(
ANSI).
The
commenter's
suggested
revisions
are
as
follows
(
suggested
additions
are
in
italics
and
suggested
deletions
are
in
strikeout
format):

Fiber
means
the
slender
threadlike
discrete
elements
of
wood
or
similar
cellulosic
material,
which
are
separated
by
chemical
and/
or
mechanical
means,
as
in
refining
and
used
as
the
aggregate
for
a
fiberboard,
hardboard
and
MDF
pulping,
that
can
be
formed
into
boards.
This
definition
of
fiber
can
include
cellulosic
fibers
reclaimed
from
other
post­
consumer
or
post­
industrial
sources
including
but
not
limited
to
newsprint,
corrugated
boxes,
office
waste,
and
printer
remands.
(
Source:
ANSI
A208.2).

Particle
means
a
discrete,
small
piece
of
cellulosic
material
(
usually
wood
or
agricultural
fiber)
distinct
fraction
of
wood
or
other
cellulosic
material
produced
mechanically
and
used
as
the
aggregate
for
a
particleboard.
Particles
are
larger
in
size
than
fibers.
(
Source:
ANSI
A208.1)

Hardboard
means
a
composite
panel
composed
of
inter­
felted
cellulosic
fibers
which
are
consolidated
under
heat
and
pressure
in
a
hot
press
to
a
density
made
by
dry
or
wet
forming
and
pressing
of
a
resinated
fiber
mat.
Hardboard
has
a
density
of
0.50
to
1.20
grams
per
cubic
centimeter
(
31.5
to
75
pounds
per
cubic
foot)
or
greater.
Other
materials
may
be
added
to
improve
certain
properties,
such
as
stiffness,
hardness,
finishing
properties,
resistance
to
abrasion
and
moisture,
as
well
as
to
increase
strength,
durability
and
utility.
The
resinated
mat
used
to
produce
the
panel
is
made
by
dry
or
wet
forming
and
pressing
is
either
dry
or
wet
and
a
bake
oven/
humidification
step
follows
the
press.

°
Dry
Process
Hardboard
means
hardboard
that
has
been
produced
using
both
dry
forming
and
dry
pressing.

°
Wet
Process
Hardboard
means
hardboard
that
has
been
produced
using
fiber
mats
pressed
directly
after
a
wet
forming
machine.
2­
17
°
Wet/
Dry
Process
Hardboard
means
hardboard
that
has
been
produced
using
fiber
mats
that
have
undergone
drying
to
near
zero
percent
moisture
in
fiberboard
ovens
before
being
placed
in
the
hardboard
press.

Medium
density
fiberboard
(
MDF)
means
a
composite
panel
composed
primarily
of
cellulosic
fibers
(
usually
wood
or
agricultural
fiber)
and
a
bonding
system
cured
under
heat
and
pressure
and
which
may
contain
additives.
MDF
density
is
typically
between
500
kg/
m3
(
31
lbs/
ft3)
and
1000
kg/
m3
(
62
lbs/
ft3).
The
resinated
mat
used
to
produce
the
panel
is
made
by
dry
forming.
made
by
dry
forming
and
pressing
of
a
resinated
fiber
mat.

Particleboard
means
a
composite
panel
primarily
composed
of
cellulosic
materials
(
usually
wood
or
agricultural
fiber),
generally
in
the
form
of
discrete
pieces
or
particles,
as
distinguished
from
fibers,
which
are
pressed
together
with
resin,
bonded
together
using
a
bonding
system
and
a
press,
and
which
may
contain
additives.

In
addition,
commenter
IV­
D­
27
recommended
revisions
to
definitions
included
in
the
proposed
rule
as
follows
(
suggested
additions
are
in
italics
and
suggested
deletions
are
in
strikeout
format):

Dry
forming
means
the
process
of
making
a
mat
of
resinated
fiber
with
a
former.
Dry
formed
mats
can
subsequently
to
be
compressed
into
a
reconstituted
wood
product
such
as
particleboard,
oriented
strand
board
(
OSB),
medium
density
fiberboard
(
MDF),
or
dry
process
hardboard.

Wet
forming
means
the
process
of
making
a
slurry
of
water,
fiber,
and
additives
into
a
mat
of
fibers
with
a
former
to
be
compressed
into
a
fiberboard
or
hardboard
product.

Plywood
means
a
panel
product
consisting
of
layers
of
wood
veneers
with
the
grains
of
the
wood
in
each
layer
typically
being
at
right
angles
to
each
other
hot
pressed
together
with
resin.
Plywood
includes
panel
products
made
by
hot
pressing
(
with
resin)
veneers
to
a
substrate
such
as
particleboard,
MDF,
or
lumber.

Fiberboard
mat
dryer
means
a
dryer
used
to
reduce
the
moisture
of
non­
chemical
pulp
wet­
formed
wood
fiber
mats
by
operation
at
elevated
temperature.
A
fiberboard
mat
dryer
is
a
process
unit.
2­
18
Reconstituted
wood
product
board
cooler
means
a
piece
of
equipment
designed
to
reduce
the
temperature
of
a
board
by
means
of
forced
air
or
convection
within
a
controlled
time
period
after
the
board
exits
the
reconstituted
wood
product
press
unloader.
Board
coolers
include
wicket
and
star
type
coolers
commonly
found
at
MDF
and
particleboard
plants.
Board
coolers
do
not
include
cooling
sections
of
dryers
(
e.
g.,
veneer
dryers
or
fiberboard
mat
dryers)
or
coolers
integrated
into
or
following
hardboard
bake
ovens
or
humidifiers
or
flatline
conveyors.
A
reconstituted
wood
product
board
cooler
is
a
process
unit.

Response:
For
the
final
rule,
we
revised
five
of
the
definitions
discussed
by
the
commenter.
The
definitions
we
have
revised
for
the
final
rule
are
as
follows:

Fiber
means
the
slender
threadlike
discrete
elements
of
wood
or
similar
cellulosic
material,
which
are
separated
by
chemical
and/
or
mechanical
means,
as
in
pulping
refining,
that
can
be
formed
into
boards.

Hardboard
means
a
composite
panel
composed
of
inter­
felted
cellulosic
fibers
made
by
dry
or
wet
forming
and
pressing
of
a
resinated
fiber
mat.
Hardboard
generally
has
a
density
of
0.50
to
1.20
grams
per
cubic
centimeter
(
31.5
to
75
pounds
per
cubic
foot)
or
greater.

Medium
density
fiberboard
(
MDF)
means
a
composite
panel
composed
of
cellulosic
fibers
(
usually
wood
or
agricultural
fiber)
made
by
dry
forming
and
pressing
of
a
resinated
fiber
mat.

Particle
means
a
discrete,
small
piece
of
cellulosic
material
(
usually
wood
or
agricultural
fiber)
distinct
fraction
of
wood
or
other
cellulosic
material
produced
mechanically
and
used
as
the
aggregate
for
a
particleboard.
Particles
are
larger
in
size
than
fibers.

Particleboard
means
a
composite
panel
composed
primarily
of
cellulosic
materials
(
usually
wood
or
agricultural
fiber)
generally
in
the
form
of
discrete
pieces
or
particles,
as
distinguished
from
fibers,
which
are
pressed
together
with
resin.

Most
of
the
changes
to
the
definitions
suggested
by
the
commenter
are
not
necessary
for
purposes
of
the
PCWP
rule
and
are
discussed
below.
We
do
not
believe
it
is
necessary
for
the
PCWP
rulemaking
to
be
consistent
with
ANSI
definitions,
because
the
PCWP
rule
has
a
different
structure
and
purpose
than
ANSI
standards.
In
addition,
we
note
that
the
changes
suggested
by
the
commenter
for
the
definitions
of
"
fiber,"
"
particle,"
"
hardboard,"
"
medium
density
fiberboard,"
and
"
particleboard"
are
not
completely
consistent
with
existing
ANSI
definitions.
2­
19
The
final
rule
directly
incorporates
the
commenter's
suggested
definition
of
"
particle"
to
be
more
consistent
with
the
ANSI
definition
and
to
clarify
that
agricultural
fiber
is
included.

We
did
not
add
the
last
sentence
of
the
commenter's
suggested
definition
of
"
fiber"

because
we
are
not
aware
of
facilities
using
newsprint,
corrugated
boxes,
office
waste,
or
printer
remands
to
manufacture
PCWP;
these
materials
sound
more
characteristic
of
pulp
and
paper
manufacturing
than
PCWP
manufacturing.
We
also
chose
not
to
limit
the
definition
of
"
fiber"
to
material
used
in
the
manufacture
of
fiberboard,
hardboard,
and
MDF
because
we
believe
other
PCWP
that
are
variations
of
these
products
could
be
developed
in
the
future.

Our
goal
in
developing
definitions
of
the
various
PCWP,
including
hardboard,

particleboard,
and
MDF,
was
to
broadly
define
the
products.
Narrow
definitions
of
the
different
PCWP
would
not
account
for
variations
in
the
products.
For
example,
particleboard
can
be
made
with
extruders
rather
than
hot
platen
presses
(
although
this
practice
is
uncommon).
Extruders
are
not
considered
to
be
presses,
and
if
particleboard
is
defined
narrowly
then
particleboard
dryers
at
plants
making
extruded
particleboard
may
not
be
considered
subject
to
the
PCWP
rule.
Also,
we
note
that
products
such
as
a
hybrid
between
particleboard
and
MDF
and
thin
high
density
fiberboard
(
another
variation
of
MDF)
are
entering
the
PCWP
marketplace.
The
same
manufacturing
processes
that
are
covered
by
the
PCWP
rule
are
used
to
manufacture
these
newer
products.
For
this
reason,
we
believe
it
would
be
inappropriate
to
include
the
density
range
in
the
MDF
definition
as
suggested
by
the
commenter.
The
new
thin
high
density
fiberboard
product
can
have
a
density
of
up
to
65
lb/
ft3,
which
exceeds
the
range
suggested
by
the
commenter
for
MDF.
The
PCWP
is
written
to
encompass
existing
and
future
processes
that
use
wood
and
resin
and/
or
pressure
to
produce
PCWP.
In
keeping
with
that
goal,
the
word
"
generally"
has
been
added
to
the
definitions
of
"
fiberboard"
and
"
softwood
veneer
dryer"
to
ensure
that
these
definitions
are
not
interpreted
too
narrowly.

The
term
"
resin"
was
defined
in
the
proposed
PCWP
rule
and
is
included
in
the
final
rule
as
follows:

Resin
means
the
synthetic
adhesive
(
including
glue)
or
natural
binder,
including
additives,
used
to
bond
wood
or
other
cellulosic
materials
together
to
produce
plywood
and
composite
wood
products.
2­
20
Because
resin
is
already
defined,
we
elected
to
use
the
term
"
resin"
instead
of
the
commenter's
suggested
term
"
bonding
system"
in
the
definitions
of
the
various
PCWP.
We
also
note
that
the
term
"
resin"
includes
additives,
so
it
is
not
necessary
to
mention
additives
in
the
definitions
of
the
various
PCWP
products.

As
discussed
in
response
to
comment
2.1.2.1,
we
are
not
including
a
definition
of
"
former"
in
the
final
PCWP
rule.
Thus,
we
disagree
that
the
commenter's
suggested
changes
to
the
definitions
of
"
dry
forming"
and
"
wet
forming"
are
necessary.
Also,
as
discussed
elsewhere
in
this
document,
the
final
rule
does
not
distinguish
between
wet
and
dry
hardboard
processes.

Therefore,
we
disagree
that
it
is
necessary
to
add
to
the
definition
of
"
hardboard"
the
last
sentence
and
bullets
suggested
by
the
commenter
which
describe
wet
versus
dry
forming
and
pressing.

2.1.3
Lumber
kilns
2.1.3.1
Comment:
Several
commenters
(
IV­
D­
10,
IV­
D­
22,
and
IV­
D­
29)
opposed
including
lumber
kilns
that
operate
outside
of
PCWP
facilities
in
the
PCWP
rule.
Commenters
IV­
D­
10
and
IV­
D­
29
stated
that,
due
to
the
low
level
of
HAP
emissions,
lumber
kiln
emissions
do
not
warrant
control
and
should
not
be
categorized
with
PCWP
facilities.
Commenter
IV­
D­
29
added
that,
while
including
lumber
kilns
at
stand­
alone
facilities
in
this
rule
"
would
cause
no
negative
effects
at
this
time,
any
changes
that
are
made
to
the
category
in
general
at
a
later
date
could
have
harmful
effects."
Commenters
IV­
D­
10
and
IV­
D­
22
stated
that,
if
the
rule
is
promulgated
with
the
inclusion
of
lumber
kilns,
the
owners
and
operators
of
kilns
that
are
not
located
at
a
PCWP
facility
may
be
subject
to
other
requirements
of
the
rule
that
do
not
truly
apply
to
them,
including
costly
monitoring,
recordkeeping,
and
reporting
requirements.
Commenter
IVD
22
contended
that
kilns
are
included
in
the
proposed
PCWP
rule
solely
for
the
convenience
of
the
owners
and
operators
of
PCWP
facilities,
which
is
unlawful
according
to
section
112
of
the
CAA.
Commenter
IV­
D­
22
was
also
concerned
that
the
owners
and
operators
of
kilns
that
are
not
located
at
a
PCWP
facility
could
find
themselves
in
violation
of
the
May
15,
2002
"
MACT
Hammer"
deadline,
even
though
they
did
not
anticipate
being
included
in
the
rule,
and
thus,
did
not
apply
for
the
case­
by­
case
consideration.

Response:
It
is
more
efficient
for
EPA,
state
regulators,
and
lumber
kiln
operators
for
EPA
to
include
all
lumber
kilns
in
the
PCWP
NESHAP.
The
EPA's
alternatives
include
listing
2­
21
and
regulate
non­
co­
located
lumber
kilns
as
a
separate
source
category
under
section
112(
c)
of
the
CAA
or
requiring
the
case­
by­
case
MACT
determinations
under
the
section112(
g)
provisions
of
the
CAA.
It
is
not
likely
that
EPA
will
consider
making
any
revisions
to
the
PCWP
NESHAP
until
EPA
performs
the
residual
risk
analysis
required
8
years
after
the
PCWP
NESHAP
is
promulgated.
The
residual
risk
analysis
will
reveal
if
any
requirements
for
non­
co­
located
lumber
kilns
are
needed.

Since
the
MACT
floor
determination
is
no
emissions
reduction
for
all
lumber
kilns,
there
will
not
be
a
significant
monitoring,
recordkeeping,
and
reporting
burden
for
facilities
with
only
non­
co­
located
lumber
kilns.
Only
those
facilities
that
are
major
sources
of
HAP
emissions
are
subject
to
the
PCWP
NESHAP.
Facilities
with
non­
co­
located
lumber
kilns
that
are
classified
as
major
sources
of
HAP
must
submit
the
initial
notification
form
required
by
the
PCWP
NESHAP
in
addition
to
the
Part
1
"
MACT
Hammer"
application
required
by
section
112(
j)
of
the
CAA.

We
note
that
both
of
these
forms
simply
ask
the
facilities
to
identify
themselves
to
EPA;
therefore,

these
forms
should
not
cause
a
large
time
or
cost
burden.
We
acknowledge
that
operators
of
nonco
located
lumber
kilns
were
not
aware
that
they
were
included
in
the
PCWP
source
category
until
the
proposed
PCWP
NESHAP
was
printed
in
the
Federal
Register
on
January
9,
2003,
and
therefore,
would
not
have
known
to
submit
a
Part
1
application
by
May
15,
2002.

2.1.4
Effluent
guidelines
for
timber
products
processing
2.1.4.1
Comment:
Several
commenters
(
IV­
D­
03,
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27)

requested
that
EPA
address
potential
conflicts
between
the
PCWP
rule
and
the
effluent
guidelines
for
the
Timber
Products
Processing
Point
Source
Category.
The
commenters
noted
that
the
effluent
guidelines
state
that
"
there
shall
be
no
discharge
of
process
wastewater
pollutants
into
navigable
waters."
However,
according
to
the
commenters,
at
the
time
that
statement
was
written,
air
pollution
controls
were
not
common,
and
EPA
was
not
aware
of
the
large
volumes
of
water
that
can
be
produced
by
APCDs.
Commenters
IV­
D­
19,
IV­
D­
20,
and
IV­
D­
27
recommended
that
EPA
address
this
issue
by
revising
the
effluent
guidelines.
Specifically,
these
commenters
recommended
that
EPA
exclude
wastewater
generated
by
the
operation
and
maintenance
of
air
pollution
control
equipment
at
PCWP
facilities
from
the
prohibition
on
the
discharge
of
process
wastewater
contained
in
relevant
subparts
of
the
effluent
guidelines
and
2­
22
standards
for
the
Timber
Products
Processing
Point
Source
Category.
These
commenter
referred
to
EPA's
request
for
comments
on
this
issue
in
the
preamble
to
the
proposed
PCWP
rule
and
noted
that
the
language
EPA
included
in
the
preamble
to
the
proposed
rule
would
generally
accomplish
this
purpose
(
See
68
Fed.
Reg.
1276
at
1305).
For
clarity,
however,
the
commenters
requested
that
the
language
be
modified
slightly
to
read
as
follows
(
suggested
additions
are
in
italics):

"
The
term
`
process
wastewater'
specifically
excludes...
wastewater
from
air
pollution
control
equipment
installed
or
used
to
comply
with
the
proposed
or
final
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
plywood
and
composite
wood
products
(
PCWP)
facilities
(
40
C.
F.
R
part
63,
subpart
DDDD)."

The
commenters
also
provided
rationale
and
data
to
support
their
recommendation.
The
commenters
contended
that
EPA
(
1)
underestimated
the
volume
of
wastewater
that
would
be
generated
by
the
application
of
MACT
and,
as
a
result,
underestimated
the
associated
costs
of
disposing
of
this
wastewater;
(
2)
failed
to
address
the
achievability/
feasibility
of
MACT
if
the
discharge
of
air
pollution
control
wastewaters
is
prohibited;
and
(
3)
did
not
consider
wastewater
from
APCDs
when
the
Timber
Products
"
zero
discharge"
effluent
guidelines
were
originally
developed.
Commenters
IV­
D­
19
and
IV­
D­
27
submitted
several
case
studies
to
demonstrate
the
variability
in
the
volume
of
wastewater
generated
at
various
PCWP
facilities
and
to
show
how
each
facility
currently
recycles,
reuses,
and
disposes
of
wastewater
generated
from
the
operation
and
maintenance
of
RTOs,
WESPs
and
biofilters.
The
case
studies
also
included
an
analysis
of
wastewater
from
an
RTO
washout
for
one
facility
and
information
on
the
costs
associated
with
trucking
wastewater
to
offsite
disposal
sites.

Commenters
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27
also
took
issue
with
the
two
reasons
EPA
gave
in
the
proposal
preamble
for
not
including
the
requested
exemption
for
APCD
wastewaters
in
the
proposal.
According
to
the
commenters,
the
first
reason
was
that
many
PCWP
facilities
are
already
disposing
of
APCD
wastewaters
in
compliance
with
the
existing
regulations,
and
the
second
reason
was
that
EPA
lacked
comprehensive
information
on
these
wastewaters,
including
the
volumes
of
wastewater
generated
and
the
pollutants
present
in
these
wastewaters.
The
commenters
contended
that
the
first
reason
is
invalid
because
(
1)
the
case
studies
show
that
even
those
facilities
that
already
have
some
or
all
of
the
control
technology
required
for
MACT
2­
23
compliance
are
having
problems
managing
the
wastewater
that
equipment
generates;
(
2)

additional
restrictions
on
publically
owned
treatment
works
(
POTW)
availability
and
regulatory
resistance
to
spray
irrigation
may
further
erode
the
ability
of
PCWP
facilities
to
manage
APCD
wastewaters;
and
(
3)
the
fact
that
some
mills
currently
are
able
to
manage
wastewater
generated
by
their
APCD
does
not
mean
that
EPA
can
"
ignore
the
issue
with
respect
to
other
facilities"
that
may
not
have
access
to
a
POTW
or
have
available
land
(
and
regulatory
approvals)
for
evaporation
ponds
or
spray
irrigation
fields.
Regarding
EPA's
concern
about
a
lack
of
"
comprehensive
information"
available
on
the
APCD
wastewaters,
the
commenters
stated
that
developing
a
complete
and
accurate
characterization
of
the
quantity
and
quality
of
the
APCD
wastewaters
resulting
from
implementation
of
the
MACT
standards
would
be
very
difficult.
The
commenters
pointed
to
the
case
studies
as
evidence
that
the
nature
of
the
APCD
wastewaters
that
may
have
to
be
discharged
"
varies
greatly
from
facility
to
facility,
depending
upon
the
air
pollution
control
equipment,
the
extent
of
opportunities
for
internal
recycling
of
wastewater,
and
availability
of
other
process
uses
for
wastewater."
For
these
reasons,
the
commenters
asserted
that
the
most
appropriate
way
to
deal
with
APCD
wastewaters
would
be
to
"
require
individual
facilities
seeking
a
discharge
permit
to
characterize
their
wastewaters,
so
that
the
permit
writer
could
determine
the
appropriate
effluent
limitations,
taking
into
account
receiving
water
quality,
any
applicable
state
water
quality
standards,
and
facility­
specific
information
on
available
wastewater
management
technologies."
The
commenters
further
stated
that,
"
it
is
both
legally
and
technically
appropriate
for
EPA
to
acknowledge
that
these
wastewaters
are
not
within
the
scope
of
the
existing
effluent
guidelines
and
to
subject
them
to
case­
by­
case
permitting
if
a
mill
needs
to
discharge
them
to
surface
waters."
Commenter
IV­
D­
03
concurred
with
the
suggestion
to
allow
water
discharges
by
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
on
a
case­
by­
case,
and
noted
that
simply
changing
the
definition
of
process
wastewater
to
exclude
APCD
wastewaters
in
the
effluent
guidelines
would
not
help
them
because
all
the
water
in
their
facility
is
combined
and
treated
together,
and
additional
storage
within
the
existing
system
is
not
possible.

Finally,
commenters
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27
disagreed
with
EPA's
suggestion
that
EPA
would
need
to
use
the
mechanism
of
a
"
direct
final
rule"
should
EPA
choose
to
exclude
these
wastewaters
from
the
effluent
guidelines
definition
of
"
process
wastewater,"
rather
than
simply
incorporating
the
regulatory
language
into
the
rest
of
the
final
rule
promulgating
MACT
2­
24
standards
for
the
PCWP
category
(
68
FR
1276
at
1305).
The
commenters
also
noted
that,
in
the
PCWP
proposal
preamble,
EPA
asserts
that,
if
EPA
receives
adverse
comment
on
the
wastewater
disposal
issue
in
response
to
the
PCWP
proposed
rule,
the
Agency
would
not
use
a
direct
final
rule,
but
rather
would
propose
the
amendment
to
40
CFR
429.11(
c)
for
additional
comment
prior
to
promulgating
the
final
rule.
The
commenters
contended
that,
because
the
preamble
to
the
proposed
rule
directly
identifies
the
issue,
there
would
not
be
a
need
for
any
additional
comment
period
because
the
exclusion
would
be
a
logical
outgrowth
of
the
proposal.
To
support
their
interpretation
of
EPA's
"
logical
outgrowth
doctrine,"
the
commenter
cited
two
D.
C.
circuit
court
cases
(
First
Am.
Disc.
Corp.
v.
CFTC,
222
F.
3d
1008,
1016
[
D.
C.
Cir.
2003]
and
Husqvarna
AB
v.
EPA,
254
F.
3d
195,
203
[
D.
C.
Cir.
2001]).
The
commenters
further
stated
that,
because
the
proposed
rule
specifically
identifies
the
possibility
of
amending
the
term
"
process
wastewater"
to
exclude
wastewater
from
APCDs,
"
any
entity
that
might
consider
taking
an
adverse
position
to
the
possibility
of
changing
the
term
is,
without
question,
on
notice."
According
to
the
commenters,
to
allow
"
an
additional
round
of
comments
on
the
matter
would
be
superfluous
on
both
legal
and
common­
sense
grounds."

Response:
We
have
carefully
reviewed
these
comments
and
supporting
materials
(
e.
g.,

Appendix
K
to
comment
IV­
D­
27).
While
supporting
information
and
data
are
helpful
in
understanding
these
comments,
substantial
additional
information
and
data
are
needed
to
develop
a
more
complete
profile
regarding
the
range
of
this
industry's
practices,
including
manufacturing
processes
and
related
APCDs,
wastewater
and
pollutant
generation
rates,
wastewater
treatment
technologies
and
disposal
methods,
costs,
and
effluent
reduction
benefits.
However,
sufficient
information
is
available
for
us
to
conclude
preliminarily
that
the
volume
of
wastewaters
generated
by
APCDs
we
expect
to
be
installed
to
comply
with
the
PCWP
NESHAP
and
available
wastewater
disposal
options
may
not
allow
consistent
compliance
by
facilities
subject
to
40
CFR
Part
429,
subpart
B
(
Veneer
subcategory),
subpart
C
(
Plywood
subcategory),
subpart
D
(
Dry
Process
Hardboard
subcategory),
and
subpart
M
(
Particleboard
subcategory)
with
the
existing
regulation,
which
does
not
allow
discharge
of
process
wastewater
pollutants.
Therefore,
we
are
excluding
wastewater
generated
by
three
processes
and
associated
APCDs
necessary
to
meet
the
PCWP
NESHAP
from
coverage
by
the
existing
effluent
limitations
guidelines..
These
three
processes
and
associated
process
wastewaters
are:
(
1)
washing
out
RTOs
or
RCOs;
(
2)
WESPs
2­
25
used
upstream
of
RTOs/
RCOs
to
protect
them
from
plugging
with
particulate;
and
(
3)
biofilters.

We
are
amending
the
definition
of
"
process
wastewater"
found
at
§
429.11(
c)
to
read
as
follows
(
new
language
in
italics):

The
term
"
process
wastewater"
specifically
excludes
non­
contact
cooling
water,
material
storage
yard
runoff
(
either
raw
material
or
processed
wood
storage),
boiler
blowdown,
and
wastewater
from
washout
of
thermal
oxidizers
or
catalytic
oxidizers,
wastewater
from
biofilters,
or
wastewater
from
wet
electrostatic
precipitators
used
upstream
of
thermal
oxidizers
or
catalytic
oxidizers
installed
by
facilities
covered
by
Subparts
B,
C,
D,
or
M
to
comply
with
the
national
emissions
standards
for
hazardous
air
pollutants
(
NESHAP)
for
plywood
and
composite
wood
products
(
PCWP)
facilities
(
40
CFR
part
63,
subpart
DDDD).
For
the
dry
process
hardboard,
veneer,
finishing,
particleboard,
and
sawmills
and
planing
mills
subcategories,
fire
control
water
is
excluded
from
the
definition.

Thereafter,
appropriate
allowances
for
effluent
discharges
generated
by
compliance
with
the
PCWP
NESHAP
rule
can
be
determined
on
a
case­
by­
case
basis
by
NPDES
permitting
authorities
using
their
best
professional
judgment
(
see
40
CFR
§
125.3).
At
a
later
date,
as
a
part
of
its
planning
process
under
section
304(
m)
of
the
Clean
Water
Act,
EPA
will
consider
amending
the
existing
regulations
for
the
Timber
Products
Processing
Industry,
40
CFR
Part
429,
subparts
C,

D,
and
M,
to
provide
technology­
based
effluent
limitations
guidelines
that
cover
wastewaters
generated
by
these
three
processes
and
associated
APCDs.

2.1.5
Overlap
with
Boilers/
Process
Heaters
NESHAP
2.1.5.1.
Comment:
Two
commenters
(
IV­
D­
21
and
IV­
D­
27)
expressed
support
for
EPA's
proposed
intention
to
include
combustion
units
associated
with
direct­
fired
dryers
in
the
PCWP
NESHAP
and
to
exclude
them
from
the
requirements
of
other
combustion­
related
NESHAP,
specifically
the
Boiler
NESHAP
and
the
Process
Heaters
NESHAP,
because
the
emissions
from
these
combustion
units
will
be
covered
under
the
proposed
PCWP
NESHAP.

However,
the
commenters
expressed
concern
about
potential
NESHAP
applicability
that
could
arise
during
periods
when
the
exhaust
gases
from
these
combustion
units
are
not
exhausting
through
the
dryers
and
would
bypass
any
controls
applied
to
these
dryers.
The
commenters
noted
that
in
some
of
the
combustion
units
associated
with
direct­
fired
dryers,
a
small
percentage
of
combustion
gas
is
routed
to
indirect
heat
exchange
and
then
is
normally
and
predominantly
routed
to
direct­
fired
gas
flow.
According
to
the
commenter,
in
these
"
hybrid
units,"
typically
only
a
2­
26
small
fraction
of
combustion
gas
(
e.
g.,
30
MMBTU/
hr
of
250
 
300
MMBTU,
or
less
than
10
percent
of
total
capacity)
is
routed
to
indirect
heat
exchange
for
hot
oil/
steam.
This
gas
generally
exhausts
through
the
direct­
fired
system.
The
commenters
contended
that
many
systems
configured
this
way
were
included
in
the
PCWP
MACT
floor
calculation
and
are
covered
under
the
PCWP
NESHAP,
as
opposed
to
the
Boiler
or
Process
Heater
NESHAP.
However,
under
certain
circumstances
(
e.
g.,
during
startups,
shutdowns,
emergencies,
or
periods
when
dryers
are
down
for
maintenance
and
steam/
thermal
oil
is
needed
for
plant
and/
or
press
heat)
some
systems
may
exhaust
directly
to
the
atmosphere
without
mixing
with
the
direct­
fired
system.
The
commenters
recommended
that
this
small
subset
of
direct­
fired
systems
be
assigned
a
"
primary
purpose"
(
based
on
the
predominant
allocation
of
BTU
capacity
and/
or
predominant
mode
of
operation)
and
regulated
accordingly.
In
the
above
example,
the
commenters
assumed
that
the
primary
purpose
is
as
a
direct­
fired
dryer,
such
that
the
equipment
would
be
subject
to
the
PCWP
NESHAP
and
not
the
Boiler
NESHAP.

Response:
There
are
many
configurations
of
combustion
units,
dryers,
and
thermal
oil
heaters
in
the
PCWP
industry.
While
some
systems
have
the
"
hybrid"
configurations
described
by
the
commenters,
whereby
a
portion
of
the
combustion
gas
is
routed
to
indirect
heat
exchange,

other
systems
do
not
(
i.
e.,
all
of
the
combustion
gas
remains
within
the
direct­
fired
system
such
that
combustion
emissions
are
mixed
with
dryer
emissions).
We
do
not
have
sufficient
information
(
and
no
such
information
was
provided
by
the
commenters)
to
fully
evaluate
the
need
for
a
"
primary
purpose"
designation
for
PCWP
combustion
units,
to
establish
the
percent­

ofoperating
time
or
BTU
limits
for
such
a
"
primary
purpose"
designation,
or
to
determine
MACT
for
combustion
units
that
would
meet
the
"
primary
purpose"
designation.
For
example,
we
do
not
know
how
many
combustion
units
are
configured
to
incorporate
both
indirect
and
direct
heat
exchange,
and
for
these
units
we
do
not
know
the
amount
of
time
or
the
percent
of
BTU
allocation
that
is
devoted
to
indirect
heat
exchange
or
the
controls
used
to
reduce
emissions
during
indirect
heat
exchange.
We
expect
that
all
of
these
factors
vary
substantially
from
facility
to
facility
for
those
facilities
that
have
these
"
hybrid"
combustion
units.
We
also
lack
information
on
the
emission
reduction
techniques
(
e.
g.,
control
devices)
applied
to
combustion
units
associated
with
direct­
fired
PCWP
dryers
that
may
bypass
the
dryers
for
some
unknown
percentage
of
time.
Therefore,
we
believe
it
would
be
inappropriate
for
us
to
establish
a
"
primary
2­
27
purpose"
designation
that
could
inadvertently
allow
for
facilities
to
configure
their
systems
to
direct
a
portion
of
their
uncontrolled
emissions
to
the
atmosphere
without
these
emissions
being
subject
to
the
Industrial
Boilers
and
Process
Heaters
NESHAP.
A
permit
writer
would
be
supplied
the
facility­
specific
information
needed
to
make
case­
by­
case
determinations
regarding
NESHAP
applicability.
A
facility
could
propose
in
its
SSM
plan
to
route
exhaust
through
the
thermal
oil
heater
during
periods
of
dryer
downtime.
The
SSM
provisions
cover
dryer
downtime,

and
a
permit
writer
can
decide
on
a
facility­
specific
basis
if
heating
of
the
thermal
oil
heater
should
be
allowed
during
dryer
SSM
considering
the
amount
of
time
that
this
condition
occurs,
the
fraction
of
combustion
unit
BTU
used
to
heat
the
thermal
oil
heater,
and
the
type
of
control
used
to
reduce
combustion
unit
emissions.

Facilities
have
alternatives
to
avoid
having
their
combustion
units
be
subject
to
both
the
PCWP
and
Industrial
Boilers
and
Process
Heaters
NESHAP.
Many
facilities
do
not
have
the
"
hybrid"
combustion
units
mentioned
by
the
commenters;
thus,
one
option
is
for
facilities
to
avoid
routing
combustion
emissions
to
indirect
heat
exchange
without
remixing
them
with
the
directfired
combustion
exhaust.
Facilities
could
use
a
separate
combustion
unit
to
heat
their
thermal
oil
heater
instead
of
the
system
used
for
dryers,
and
this
separate
combustion
unit
could
be
covered
(
or
exempted)
under
the
Industrial
Boilers
and
Process
Heaters
NESHAP
accordingly.
Some
facilities
can
switch
to
natural
gas
when
firing
only
the
thermal
oil
heater.
4
Natural
gas
combustion
units
do
not
have
emission
limits
(
other
than
a
carbon
monoxide
[
CO]
limit
for
new
gaseous
fuel
units)
under
the
Industrial
Boilers
and
Process
Heaters
NESHAP,
and
the
Industrial
Boilers
and
Process
Heaters
NESHAP
requires
"
no
emission
reduction"
for
small
(
less
than
10
MMBTU/
hr)
boilers.
There
is
also
a
category
of
limited
use
units
in
the
Industrial
Boilers
and
Process
Heaters
NESHAP
(
i.
e.,
large
units
with
capacity
utilizations
less
than
or
equal
to
10
percent
as
required
in
a
federally
enforceable
permit).
Thus,
we
believe
facilities
can
configure
their
combustion
systems
in
a
way
that
complies
with
both
NESHAP
rules,
or
so
that
their
systems
are
only
subject
to
one
NESHAP
rule.

2.1.6
Overlap
with
Wood
Building
Products
NESHAP
2.1.6.1
Comment:
Commenter
IV­
D­
12
expressed
support
for
the
categories
and
differentiations
developed
by
the
EPA
in
the
proposed
PCWP
rule
and
encouraged
EPA
to
ensure
2­
28
that
there
were
no
conflicts
with
the
Wood
Building
Products
(
Surface
Coating)
NESHAP.

Three
other
commenters
(
IV­
D­
09,
IV­
D­
21,
and
IV­
D­
27)
expressed
concern
about
the
limited
scope
of
the
definition
of
"
miscellaneous
coating
operations"
under
both
the
PCWP
NESHAP
and
the
Wood
Building
Products
(
Surface
Coating)
NESHAP.
Two
of
the
commenters
(
IV­
D­
21
and
IV­
D­
27)
noted
that
EPA
has
proposed
no
control
requirements
for
"
miscellaneous
coating
operations"
as
defined
in
the
proposed
PCWP
rule
and
that
the
current
definition
of
"
miscellaneous
coating
operations"
only
applies
to
miscellaneous
coating
operations
at
PCWP
facilities.
These
commenters
stated
that
similar
coating
operations
at
lumber
and
veneer­
only
facilities
should
also
be
included
in
the
definition
of
"
miscellaneous
coating
operations,"
and
thus
be
exempted
from
control
requirements.
These
commenters
contended
that
both
panels
and
lumber
will
need
to
apply
antifungal/
moisture
retardants
to
address
mold­
related
concerns.

According
to
the
commenters,
these
wood
treatment
chemicals
typically
are
applied
in
dilute
form,
by
nonpressure
means,
as
a
temporary
measure
to
protect
against
surface
moisture
absorption
and
bacterial
and
fungal
growth.
To
address
this
issue,
the
two
commenters
requested
that
EPA
include
lumber
and
veneer­
only
operations
in
the
definition
of
"
miscellaneous
coating
operations"
and
include
explicit
language
to
allow
wood
products
plants
to
apply
antifungals/
moisture
retardants
under
the
PCWP
NESHAP,
as
opposed
to
having
to
debate
the
coverage
of
these
activities
under
the
Wood
Building
Products
(
Surface
Coating)
NESHAP.
The
commenters'
suggested
changes
to
the
definition
of
"
miscellaneous
coating
operations"
are
as
follows
(
suggested
additions
are
in
italics):

Miscellaneous
coating
operations
means
application
of
any
of
the
following
to
plywood
or
composite
wood
products:
edge
seals,
moisture
sealants,
anti­
skid
coatings,
company
logos,
trademark
or
grade
stamps,
nail
lines,
synthetic
patches,
wood
patches,
wood
putty,
concrete
forming
oils,
glues
for
veneer
composing,
antifungal/
moisture
retardants,
and
shelving
edge
fillers.
Miscellaneous
coating
operations
also
include
the
application
of
coatings
to
full
sheets
of
panel
products
such
as
primer
to
OSB
siding
or
fills
to
create
a
smooth
surface
that
occurs
at
the
same
site
as
OSB
manufacture.

In
addition,
commenter
IV­
D­
09
requested
that
the
phrase
"
glues
for
foil
or
paper
applicators"
be
added
to
the
definition
of
"
miscellaneous
coating
operations"
to
avoid
subjecting
a
plant
to
more
than
one
NESHAP.
2­
29
Response:
Veneer­
only
operations
are
already
included
in
the
definition
of
"
plywood
and
composite
wood
products
manufacturing
facility."
The
definition
of
"
plywood
and
composite
wood
products
manufacturing
facility"
includes
lumber
kilns,
but
not
entire
lumber
manufacturing
facilities.
As
proposed,
only
kiln­
dried
lumber
(
not
all
lumber)
is
considered
to
be
a
PCWP.

Therefore,
application
of
coatings
such
as
antifungals/
moisture
retardants
to
lumber
is
outside
of
the
scope
of
the
PCWP
source
category.

We
reviewed
information
submitted
by
commenters
on
the
proposed
Wood
Building
Products
(
Surface
Coating)
rule
relating
to
application
of
wood
treatments,
fire
retardants,
and
antifungal
coatings
to
PCWP
products.
We
determined
that
these
chemicals
can
be
applied
using
different
techniques
during
different
stages
of
production
(
e.
g.,
during
blending
or
forming
of
the
substrate,
or
after
manufacturing
of
the
substrate
is
complete).
Application
of
wood
treatments,

fire
retardants,
and
antifungal
coatings
to
PCWP
that
occurs
after
the
substrate
manufacturing
process
(
i.
e.,
following
completion
of
hot
pressing)
are
subject
to
the
Wood
Building
Products
(
Surface
Coating)
rule.
Likewise,
we
determined
that
laminates
(
e.
g.,
foils
and
paper)
applied
to
PCWP
prior
to
pressing
of
the
substrate
would
be
covered
by
the
PCWP
rule,
while
laminates
applied
following
pressing
are
covered
by
the
Wood
Building
Products
(
Surface
Coating)
rule.
5
We
believe
that
wholesale
exclusion
of
broadly
defined
coating
operations
(
e.
g.,
wood
treatments,

antifungal
coatings,
laminating
adhesives)
is
not
justified
because
future
coating
technologies
involving
different
chemicals
could
result
in
increased
HAP
emissions.
Antifungal
coatings
are
an
example
of
newer
wood
treatments
that
will
increasingly
be
applied
to
wood
products
in
the
future,
and
at
this
time,
there
is
little
certainty
as
to
the
chemical
makeup
and
best
application
technique
for
these
coatings.
Incidental
coating
users
can
utilize
the
low
coating­
usage
applicability
cutoff
included
in
the
final
Wood
Building
Products
(
Surface
Coating)
rule.
Also,

commercial
manufacturers
that
use
less
than
1,100
gallons
(
4,170
liters)
per
year
of
surface
coatings
on
wood
building
products
are
not
required
to
achieve
emissions
reductions
under
wood
building
products
rule.
Therefore,
we
believe
it
is
appropriate
that
these
wood
treatment
chemical
coatings
be
considered
by
permitting
authorities
under
the
applicable
MACT
standards.

The
commenter
did
not
provide
any
rationale
for
their
suggested
change
to
the
last
sentence
of
the
definition
of
"
miscellaneous
coating
operations,"
nor
did
the
commenter
provide
2­
30
information
on
the
types
of
coatings
would
be
applied
to
full
sheets
of
OSB.
Therefore,
we
did
not
include
the
commenter's
suggested
changes
to
the
last
sentence
of
the
definition.

We
received
public
comments
on
the
proposed
Wood
Building
Products
(
Surface
Coating)
NESHAP
relating
to
asphalt­
coated
fiberboard
and
ceiling
tiles.
Commenters
asserted
that
neither
product
is
coated
with
HAP­
containing
materials
and
regulating
such
products
would
be
burdensome.
We
further
evaluated
the
types
of
coatings
and
processes
used
to
make
asphaltcoated
fiberboard
and
found
that
only
a
few
facilities
in
the
United
States
make
these
products,

with
varying
manufacturing
and
coating
processes.
An
asphalt
emulsion
can
be
added
during
the
fiberboard
forming
process,
or
asphalt
can
be
applied
to
the
fiberboard
substrate.
Depending
on
the
company
and
the
process,
the
coating
can
be
applied
before
or
after
the
final
dryer,
with
the
product
allowed
to
air
dry.
Ceiling
tiles
are
usually
coated
using
slurries
of
titanium
dioxide
and
various
clays.
Although
non­
HAP
wetting
agents
or
defoamers
are
occasionally
added,
no
organic
solvents
are
used.
These
coatings
cure
by
drying
and
not
by
chemical
reaction
and
are
considered
durable
only
for
dry,
noncontact
indoor
exposure.
Because
most
of
the
coatings
associated
with
these
types
of
products
are
applied
during
the
substrate
forming
process
(
i.
e.,
to
the
wet
mat
being
formed)
or
prior
to
the
final
substrate
drying
operation,
fiberboard
coating
operations
(
including
those
used
in
the
manufacture
of
asphalt­
coated
fiberboard
and
ceiling
tiles)

will
be
covered
under
the
final
PCWP
rule.
These
products
will
not
be
subject
to
the
final
rule
for
the
surface
coating
of
wood
building
products.
Therefore,
we
have
changed
the
definition
of
"
miscellaneous
coating
operations"
as
follows
(
additions
in
italics):

Miscellaneous
coating
operations
means
application
of
any
of
the
following
to
plywood
or
composite
wood
products:
edge
seals,
moisture
sealants,
anti­
skid
coatings,
company
logos,
trademark
or
grade
stamps,
nail
lines,
synthetic
patches,
wood
patches,
wood
putty,
concrete
forming
oils,
glues
for
veneer
composing,
shelving
edge
fillers.
Miscellaneous
coating
operations
also
include
the
application
of
primer
to
OSB
siding
that
occurs
at
the
same
site
as
OSB
manufacture
and
application
of
asphalt,
clay
slurry,
or
titanium
dioxide
coatings
to
fiberboard
at
the
same
site
of
fiberboard
manufacture.

As
discussed
later
in
response
to
comment
2.3.2.2,
we
have
also
added
a
definition
of
"
group
1
miscellaneous
coating
operations"
to
the
final
PCWP
rule.
The
final
PCWP
rule
requires
that
non­
HAP
coatings
be
used
for
group
1
miscellaneous
coating
operations.
2­
31
2.1.6.2
Comment:
Commenter
IV­
D­
52
asked
EPA
to
clarify
the
applicability
of
the
PCWP
NESHAP
and
the
Wood
Building
Products
NESHAP
to
several
processes,
including
the
application
of
hardwood
veneer
to
softwood
substrate,
finger­
jointing,
mortise­
tenoning,
and
edge
gluing.
These
processes
either
strengthen
the
product
(
covered
under
PCWP
NESHAP)
or
provide
final
finishing
touches
(
covered
by
Wood
Building
Products
NESHAP).
The
commenter
stated
that
the
company
is
prepared
to
apply
the
PCWP
NESHAP
to
all
of
the
above
processes,

but
they
want
clarification
to
ensure
that
there
is
no
question
of
compliance.

Response:
We
did
not
change
the
rule
in
response
to
this
comment.
The
application
of
hardwood
veneer
to
a
softwood
substrate
is
covered
under
the
PCWP
rule.
Hot
pressing
of
a
hardwood
veneer
to
a
softwood
substrate
is
common
in
hardwood
plywood
manufacturing.
As
defined
in
the
proposed
and
final
PCWP
rule:

Plywood
means
a
panel
product
consisting
of
layers
of
wood
veneers
hot
pressed
together
with
resin.
Plywood
includes
panel
products
made
by
hot
pressing
(
with
resin)
veneers
to
a
substrate
such
as
particleboard,
MDF,
or
lumber.

The
definition
of
"
plywood"
is
not
specific
regarding
whether
the
product
is
made
of
hardwood
or
softwood
veneers,
and
therefore,
includes
both
hardwood
and
softwood
plywood.
The
final
rule
includes
no
requirements
for
hardwood
or
softwood
plywood
presses.

Mortise­
tenoning
involves
cutting
a
mortise
(
a
rectangular
hole)
into
one
piece
of
wood,

and
fitting
the
mortise
with
a
tenon
(
the
piece
of
wood
that
fits
into
the
hole).
An
adhesive
may
or
may
not
be
used
in
the
mortise­
tenoning
process,
and
the
joint
is
typically
clamped
and
allowed
to
air
dry.
We
did
not
consider
mortise­
tenoning
in
development
of
the
PCWP
rule
because
this
process
usually
occurs
at
furniture
or
door
and
window
manufacturing
plants,
as
opposed
to
PCWP
plants.

We
considered
finger­
jointing
processes
at
engineered
wood
products
plants
(
i.
e.,
glu­
lam
and
I­
joist
plants).
Finger­
jointing
involves
cutting
a
zig­
zag
pattern,
or
fingers,
into
the
end
of
a
wood
product
such
as
lumber
or
LVL,
and
then
adhering
the
ends
of
multiple
pieces
of
the
wood
product
together
to
form
an
end­
to­
end
joint.
The
finger­
jointing
resin
is
usually
a
phenolresorcinol
formaldehyde
resin,
and
the
end­
to­
end
joint
is
cured
by
radio
frequency
(
RF)
energy.

We
did
not
have
emissions
data
for
RF
finger­
joint
curing
devices;
therefore,
we
estimated
2­
32
emissions
for
finger­
jointing
based
on
resin
mass
balance
calculations.
6
The
resin
mass
balance
calculations
resulted
in
very
low
levels
of
HAP.
We
know
of
no
methods
that
are
being
used
to
reduce
emissions
from
RF­
curing
devices,
and
therefore,
we
determined
that
MACT
for
RF
curing
devices
is
"
no
emissions
reduction."

Edge
seals
applied
to
an
exposed
edge
of
a
panel
to
prevent
moisture
from
being
absorbed
or
wicked
up
into
the
interior
of
the
board
are
included
in
the
definition
of
"
miscellaneous
coating
operation."
If
edge
gluing
is
similar
to
the
process
of
edge
sealing,
then
edge
gluing
is
a
PCWP
process.

2.1.7
Overlap
with
Wood
Furniture
Manufacturing
NESHAP
2.1.7.1
Comment:
Commenter
IV­
D­
46
requested
a
"
de
minimus"
exemption
for
any
facility
that
is
already
covered
by
the
Wood
Furniture
Manufacturing
(
WFM)
NESHAP
and
has
an
output
of
PCWP
less
than
15
percent
of
the
facility's
total
annual
production.
The
commenter
asked
for
exemption
language
to
be
added
to
the
rule
to
cut
down
on
excess
paperwork
for
facilities
that
are
minimally
affected.
The
commenter
contended
that
the
majority
of
the
HAP
emissions
have
already
been
reduced
from
these
plants
and
the
processes
that
would
be
affected
by
the
PCWP
NESHAP
emit
relatively
low
amounts
of
HAP.

Response:
The
preamble
to
the
proposed
WFM
NESHAP
(
59
FR
62652,
December
6,

1994)
indicated
that
operations
using
urea­
formaldehyde
resins
were
excluded
from
the
WFM
NESHAP,
but
would
be
considered
under
the
forthcoming
PCWP
NESHAP.
Urea­
formaldehyde
resins
are
used
by
some
furniture
manufacturers
to
produce
particleboard
and
hardwood
plywood
products.
Process
units
at
furniture
manufacturing
plants
that
are
covered
by
the
PCWP
NESHAP
include
dry
or
green
rotary
particle
dryers,
particleboard
presses
or
extruders,
plywood
presses,
hardwood
or
softwood
veneer
dryers,
and
lumber
kilns.
We
note
that
the
PCWP
rule
does
not
include
any
requirements
for
particleboard
extruders,
plywood
presses,
or
lumber
kilns
and
that
work
practices,
not
add­
on
controls,
are
required
for
dry
rotary
particle
dryers
and
hardwood
veneer
dryers.
Wood
furniture
manufacturing
facilities
could
choose
to
produce
PCWP
other
than
plywood
and
particleboard
or
to
increase
PCWP
production
in
the
future,
and
therefore,
inclusion
of
a
production
exemption
could
create
a
loophole
for
large
manufacturing
plants.
Furthermore,
a
15
percent
production
cutoff
would
not
be
meaningful
because
the
control
2­
33
requirements
in
the
PCWP
rulemaking
are
based
on
process
unit
type
as
opposed
to
end
product
(
e.
g.,
PCWP
versus
wood
furniture),
and
production
of
PCWP
is
often
measured
in
terms
of
square
feet
of
product
(
as
opposed
to
number
of
furniture
units
produced).
Finally,
it
has
long
been
EPA's
policy
and
legal
position
that
de
minimis
exemptions
from
MACT
are
not
allowed
by
section
112
of
the
CAA.
See
NLA
v.
EPA,
233
F.
3d
625
(
D.
C.
Cir.
2000).
For
these
reasons,

we
disagree
that
it
is
appropriate
to
provide
an
exemption
in
the
final
PCWP
rule
for
facilities
covered
by
the
WFM
NESHAP
that
also
produce
PCWP.

2.1.8
Overlap
with
New
Source
Review
Three
commenters
addressed
the
overlap
of
the
PCWP
rule
and
the
December
31,
2002
major
New
Source
Review
(
NSR)
rule.
These
comments
are
described
in
more
detail
below.

2.1.8.1
Comment:
Three
commenters
addressed
EPA's
"
pollution
control
project"
(
PCP)

policy
as
part
of
the
major
NSR
reform
rule.
Commenters
IV­
D­
27
and
IV­
D­
56
stated
that
the
final
PCWP
NESHAP
preamble
should
be
revised
to
be
consistent
with
recently
promulgated
reforms
to
the
NSR
rule.
These
commenters
noted
that
the
preamble
to
the
proposed
PCWP
rule
mentions
only
RTOs
and
refers
to
the
language
of
EPA's
1994
PCP
policy,
which
can
be
used
by
States
and
other
permitting
authorities
to
grant
RTOs
case­
by­
case
exclusions
from
NSR.
The
commenters
asserted
that
EPA's
NSR
reform
rule
(
67
FR
802384,
December
31,
2002)
states
that
a
wide
range
of
pollution
control
technologies,
including
regenerative
thermal
oxidizers,

catalytic
oxidizers,
thermal
incinerators,
adsorbers
and
absorbers,
condensers,
and
biofilters,
are
presumed
to
be
"
environmentally
beneficial."
Unless
the
permitting
authority
determines
that
the
"
environmentally
beneficial"
finding
is
unjustified
for
a
device,
the
"
environmentally
beneficial"

label
gives
sources
the
freedom
to
construct
the
devices
without
being
subject
to
major
NSR
as
long
as
they
first
give
appropriate
notice
to
the
permitting
authority
(
see
40
CFR
52.21(
z)(
4)).

Therefore,
the
two
commenters
stated
that
EPA
needs
to
revise
the
discussion
of
NSR
in
the
final
PCWP
preamble
to
reflect
the
"
environmentally
beneficial"
presumption
for
these
technologies
and
to
include
all
current
pollution
control
devices
as
well
as
new
pollution
control
devices
that
may
be
developed
to
comply
with
the
PCWP
rule.
The
commenters
also
stated
that,
in
keeping
with
the
NSR
reform
rule,
the
PCP
exclusion
should
apply
in
non­
attainment
areas
as
well
as
2­
34
attainment
areas,
so
that
sources
in
non­
attainment
areas
will
not
have
to
install
lowest
achievable
emission
rate
(
LAER)
on
qualifying
projects.

Commenter
IV­
D­
26
disagreed
with
the
preceeding
two
commenters
and
stated
that
ignoring
the
increases
in
NO
x
emissions
from
pollution
control
devices
(
such
as
RTOs)
as
new
sources
of
pollution
subject
to
NSR
is
unlawful.
The
commenter
also
noted
that
in
one
section
of
the
preamble
to
proposed
the
PCWP
NESHAP
(
68
FR
at
1302),
EPA
acknowledged
that
NO
x
emissions
have
harmful
health
effects,
yet
in
another
section
(
68
FR
at
1304),
EPA
suggested
that
NO
x
emissions
increases
should
be
allowed
to
escape
control.
The
commenter
took
issue
with
the
rationale
in
the
NSR
rule
for
why
PCPs
should
not
be
considered
modifications
covered
by
major
NSR
and
prevention
of
significant
deterioration
(
PSD)
rules.
The
commenter
contended
that
the
NSR
preamble
failed
to
identify
any
legal
authority
on
which
to
base
this
assumption,
and
instead
relied
on
"
a
policy
argument
coupled
with
an
unsupported,
unsupportable
statement
of
supposed
Congressional
intent."
The
commenter
also
stated
that
EPA
failed
to
explain
why
significant
increases
in
regulated
air
pollutants
from
these
activities
are
any
different,
less
dangerous,
or
less
subject
to
regulation
than
emissions
increases
from
any
other
type
of
activity.
For
these
reasons,

the
commenter
argued
that
the
reading
of
the
modification
definition
on
which
EPA
relied
is
unlawful
and
arbitrary.

Response:
Our
discussion
of
the
PCP
issue
in
the
preamble
to
the
PCWP
proposal
was
not
intended
to
recommend
or
establish
any
new
policy
or
approach
regarding
how
potential
PCPs
could
be
addressed
in
implementing
the
NSR
program.
This
issue
is
beyond
the
scope
of
any
NESHAP
rulemaking
that
is
focused
on
just
an
individual
source
category,
and
can
be
appropriately
and
comprehensively
addressed
only
within
the
context
of
the
NSR
program
and
rulemakings
regarding
that
program.
When
setting
MACT
standards
under
section
112(
d)
of
the
CAA,
EPA
is
not
charged
with
simultaneously
establishing
new
or
revised
NSR
policy,
which
is
taken
under
other
provisions
of
the
Act.
Neither
the
1994
policy
guidance
identified
by
commenters,
the
December
2002
final
NSR
rules,
nor
the
petition
for
reconsideration
of
those
rules
is
the
subject
of
this
PCWP
NESHAP
rulemaking.
We
will
respond
to
comments
pertaining
to
issues
such
as
those
regarding
the
treatment
of
potential
PCPs
and
NSR
applicability
in
the
appropriate
forum,
to
the
extent
commenters
raise
them
in
that
context.
2­
35
2.1.8.2
Comment:
Commenters
IV­
D­
27
and
IV­
D­
56
requested
that
EPA
address
certain
NSR
applicability
issues
that
were
not
addressed
in
the
NSR
reform
rule.
Specifically,
the
commenters
requested
that
EPA
(
1)
confirm
that
all
methods
of
PCWP
NESHAP
compliance
are
environmentally
beneficial
and
qualify
for
a
PCP
exclusion;
and
(
2)
confirm
the
right
of
PCWP
sources
to
assume
that
MACT
compliance
measures
will
not
increase
"
source
activity
levels."
The
commenters
stated
that
incinerators
are
not
necessarily
environmentally
beneficial
when
installed
on
low­
risk
sources,
but
they
should
be
presumed
to
be
environmentally
beneficial
if
they
are
needed
to
comply
with
MACT.
The
commenters
further
noted
that,
in
the
original
"
cluster"
rule
for
the
forest
products
industry
(
63
FR
18531),
EPA
stated
that
add­
on
control
devices
would
be
"
environmentally
beneficial"
and
would
qualify
for
an
exclusion
from
NSR
requirements.
The
commenters
stated
that
similar
language
should
be
included
in
the
PCWP
final
preamble
to
make
sure
that
both
the
combustion
of
HAP
in
existing
boilers
and
pollution
prevention
projects
qualify
for
the
exclusion
and
provided
text.

The
commenters
also
stated
that
the
final
rule
needs
to
clarify
how
to
determine
"
future
actual
emissions"
for
purposes
of
air
quality
analysis.
The
commenters
noted
that
the
NSR
reform
rule
allows
sources
to
evaluate
the
impact
of
a
control
project
on
air
quality
by
comparing
past
actual
emissions
to
expected
future
actual
emissions
caused
by
the
project.
The
EPA's
1994
policy
expressly
stated
that,
in
evaluating
air
quality
impact,
States
should
assume
that
the
installation
of
add­
on
controls
would
not
increase
the
operating
level
of
the
source.
Under
this
approach,
the
emissions
increase
from
a
qualifying
project
is
determined
by
subtracting
the
product
of
the
existing
operating
rate
and
the
pre­
project
actual
emissions
from
the
product
of
the
post­
project
hourly
potential
emissions
from
the
unit
and
the
unit's
existing
operating
rate.
The
commenters
requested
that
EPA
confirm
in
the
final
PCWP
rule
that
this
prior
approach
continues
to
be
acceptable
under
the
NSR
reform
rule.
The
commenters
also
asked
that
EPA
extend
the
right
of
sources
to
use
this
same
approach
to
evaluating
air
quality
impacts
to
both
the
oxidation
of
HAPs
in
existing
boilers
and
pollution
prevention
(
P2)
projects.
The
commenters
stated
that
previous
EPA
concerns
that
P2
projects
could
improve
source
efficiency,
resulting
in
higher
operating
rates
and
emissions
increases,
are
unjustified
in
the
context
of
the
PCWP
rule.
The
commenters
contended
that,
even
if
P2
measures
result
in
cost
savings,
no
single
PCWP
facility
will
increase
its
market
share
as
a
result
because
many
of
its
competitors
will
implement
the
same
2­
36
P2
measures
at
the
same
time.
To
address
these
issues,
the
commenters
provided
text
to
be
included
in
the
final
PCWP
rule
preamble.

Response:
See
our
response
in
section
2.1.8.1
above.

2.1.8.3
Comment:
Commenters
IV­
D­
27
and
IV­
D­
56
requested
that
EPA
remove
language
in
the
proposal
preamble
that
they
believe
encourages
"
dual
regulation"
of
sources
subject
to
both
MACT
and
NSR
requirements.
The
commenters
stated
that,
even
if
EPA
revises
the
preamble
language
to
exclude
MACT
projects
from
NSR
(
as
suggested
by
the
commenters),

cases
will
still
arise
where
both
MACT
requirements
and
NSR
apply
to
a
given
unit.
The
commenters
acknowledged
that
legally,
both
MACT
and
NSR
can
apply
to
the
same
unit;

however
they
argued
that
States
should
be
allowed
to
assume
that
MACT
controls
would
also
be
sufficient
to
satisfy
best
available
control
technology
(
BACT)
requirements.
The
commenters
contended
that,
instead
of
addressing
this
issue,
the
proposal
preamble
promotes
dual
regulation
of
such
units
rather
than
seeking
to
avoid
it.
The
commenters
requested
that
EPA
include
specific
text
in
the
preamble
to
the
final
rule.

The
commenters
stated
that,
if
EPA
does
not
make
these
changes,
then
the
regulatory
impact
analysis
(
RIA)
supporting
the
rule
will
be
inadequate
because
it
does
not
discuss
the
extra
costs
associated
with
NSR
triggered
by
MACT
compliance
efforts.
The
commenters
further
contended
that,
if
EPA
does
not
revise
the
rule
to
avoid
such
results,
then
EPA
must
redo
the
RIA
to
discuss
this
issue
and
comply
with
the
requirements
of
the
governing
statutes
and
Executive
Orders.

Response:
Regarding
issues
concerning
NSR
applicability,
see
our
response
in
section
2.1.8.1
above.

In
addition,
we
note
that
BACT
or
LAER
and
MACT
might
not
always
be
the
same
for
PCWP
facilities.
First,
the
PCWP
rule
includes
emissions
averaging
provisions
that
will
allow
existing
PCWP
facilities
to
relax
controls
on
some
emission
units
while
increasing
controls
on
other
emission
units
such
that
the
net
overall
emissions
reductions
are
equivalent
to
MACT
levels.

In
some
cases,
that
could
mean
that
a
total
hydrocarbon
(
THC)
emitting
source
could
be
"

undercontrolled
such
that
the
control
method
in
use
is
less
stringent
than
MACT
or
BACT
for
the
individual
emissions
unit,
although
the
overall
HAP
emission
reductions
at
the
source
are
2­
37
equivalent
to
MACT
levels.
We
note
that,
because
the
PCWP
rule
broadly
defines
the
"
affected
source"
as
the
entire
PCWP
facility,
only
"
green­
field"
or
reconstructed
PCWP
facilities
would
be
precluded
from
using
the
emissions
averaging
option.

Second,
because
the
production­
based
emissions
limits
are
based
on
HAP
emissions,
it
is
possible
that
an
emission
unit
with
high
THC
emissions
but
low
HAP
emissions
could
be
exempted
from
installing
add­
on
controls
under
the
PCWP
rule;
in
such
cases,
MACT
could
be
less
stringent
than
BACT.
For
example,
softwood
veneer
dryers
tend
to
emit
much
greater
quantities
of
THC
than
HAP
because
some
of
the
THC
compounds
emitted,
such
as
pinenes,
are
not
classified
as
HAP.

Third,
for
some
PCWP
process
units,
we
determined
that
the
MACT
floor
was
equivalent
to
"
no
emission
reduction,"
and
that
the
application
of
beyond­
the­
floor
add­
on
controls
for
HAP
was
not
cost­
effective.
Because
cost­
effectiveness
is
calculated
by
dividing
the
annualized
costs
of
control
by
the
total
mass
of
pollutant
abated,
the
cost­
per­
ton
values
decrease
(
i.
e.

costeffectiveness
improves)
as
the
mass
of
pollutant
abated
increases.
Therefore,
a
process
unit
that
emits
substantially
more
THC
than
HAP
may
be
considered
cost­
effective
to
control
under
BACT
even
though
additional
beyond­
the­
floor
controls
were
rejected
under
MACT
as
not
being
costeffective

Regarding
the
comment
that
we
should
redo
the
RIA
for
the
PCWP
rulemaking,
we
disagree
that
it
is
necessary
or
appropriate
to
account
for
additional
costs
of
NSR
in
the
national
impacts
of
this
rule.
In
light
of
the
existing
NSR
policy
regarding
PCPs,
as
reflected
in
the
Agency's
guidance
and
recent
NSR
rulemaking,
we
do
not
expect
that
compliance
with
this
NESHAP
will
trigger
major
NSR
in
a
widespread
or
frequent
manner.
We
believe
our
RIA
fully
accounts
for
the
costs
of
the
PCWP
rule
as
required
by
the
Executive
Order,
and
direct
the
commenters
to
the
RIA
for
our
analysis.

2.2
HEALTH
EFFECTS
2.2.1
Comment
:
Commenters
IV­
D­
02,
IV­
D­
08,
IV­
D­
09,
IV­
D­
15,
IV­
D­
16,
IV­
D­

17,
IV­
D­
35,
IV­
D­
36,
IV­
D­
38,
IV­
D­
39,
IV­
D­
40,
IV­
D­
41,
IV­
D­
42,
IV­
D­
44,
IV­
D­
50,
and
2­
38
IV­
D­
53
stated
that
they
do
not
believe
emissions
from
plywood
plants
are
a
threat
to
human
health
or
the
environment,
and
that
the
expensive
controls
mandated
by
the
proposed
rule
are
unnecessary.
The
commenters
noted
that
the
softwood
plywood
industry
has
existed
in
the
Pacific
Northwest
since
1905
and
the
Southeast
since
1963,
and
there
have
never
been
any
documented
cases
of
damage
to
human
health
or
the
environment.
Commenter
IV­
D­
09
stated
that
they
do
not
believe
that
their
PCWP
plant,
as­
is,
poses
a
significant
risk
to
public
health
or
the
environment.
The
commenters
stated
that
this
is
evident
based
on
the
lack
of
any
history
of
health
or
environmental
damage
caused
by
these
plants
over
the
last
100
years.
Several
of
the
commenters
(
IV­
D­
15,
IV­
D­
39,
IV­
D­
41,
IV­
D­
42,
and
IV­
D­
53)
stated
that,
in
the
1997
emission
factor
manual
(
AP­
42),
EPA
did
not
list
any
HAP
emissions
for
softwood
plywood
plants
using
only
phenol­
formaldehyde
(
PF)
resin,
and
emission
factors
for
these
HAP
were
not
added
to
AP­
42
until
January
2002,
yet
these
same
plants
are
now
expected
to
spend
millions
of
dollars
to
control
emissions
that
EPA
believed
to
be
"
unlikely"
a
few
years
ago.

Commenter
IV­
D­
12
stated
that
the
proposed
rule
discusses
a
reduction
in
cancer
risk
rates
from
0.09
cases
per
year
to
0.02
cases
per
year.
The
commenter
pointed
out
that
it
is
difficult
to
show
an
impact
on
a
risk
level
that
is
already
extremely
low.
The
commenter
also
stated
that,
given
the
conservative
nature
of
the
risk
estimates,
it
is
unlikely
that
emissions
from
a
worst
case
particleboard/
fiberboard/
MDF
plant
site
have
ever
caused
an
incidence
of
cancer.

Finally,
the
commenter
pointed
out
that
new
source
MACT
requirements,
coupled
with
normal
economic
forces
that
require
the
replacement
of
old
equipment
in
this
industry,
make
it
unlikely
that
a
particleboard/
fiberboard/
MDF
plant
site
will
ever
cause
any
incidences
of
cancer.

Response:
Section
112(
b)
of
the
CAA
contains
a
list
of
HAP
and
authorizes
EPA
to
list
additional
pollutants
which
present,
or
may
present,
adverse
effects
to
human
health
or
the
environment.
Section
112(
c)
of
the
CAA
requires
us
to
list
all
categories
and
subcategories
of
major
and
area
sources
of
HAP
and
to
establish
NESHAP
for
the
listed
source
categories
and
subcategories
under
section
112(
d)
of
the
CAA.
The
CAA
imposes
this
requirement
without
regard
to
whether
the
listed
source
category
or
subcategory
itself
presents
a
risk
of
adverse
effects
or
has
caused
a
"
documented
case
of
damage."
Major
sources
of
HAP
are
those
stationary
sources
or
groups
of
stationary
sources
that
are
located
within
a
contiguous
area
under
2­
39
common
control
that
emit
or
have
the
potential
to
emit,
considering
controls,
9.07
Mg/
yr
(
10
[
tpy])
or
more
of
any
one
HAP
or
22.68
Mg/
yr
(
25
tpy)
or
more
of
any
combination
of
HAP.

Area
sources
are
those
stationary
sources
or
groups
of
stationary
sources
that
are
not
major
sources.
(
See
CAA
sections
112(
a)(
1)
and
112(
a)(
2),
and
40
CFR
section
63.2).

Plywood/
particle
board
manufacturing
was
listed
as
a
category
of
major
sources
on
the
initial
source
category
list
published
in
the
Federal
Register
on
July
16,
1992
(
57
FR
31576).
The
name
of
the
source
category
was
later
changed
to
plywood
and
composite
wood
products
manufacturing
to
better
reflect
the
types
of
facilities
covered
by
the
standards.
The
source
category
name
change
was
published
in
the
Federal
Register
on
November
18,
1999
(
64
FR
63025).
Standards
for
the
PCWP
manufacturing
source
category,
which
includes
facilities
that
are
major
sources
of
HAP,
were
then
proposed
in
the
Federal
Register
on
January
9,
2003
(
68
FR
1275).
Because
PCWP
manufacturing
is
a
source
category
containing
major
sources
of
HAP,
we
are
required
by
the
CAA
to
establish
NESHAP
for
the
source
category.
Softwood
plywood,

particleboard,
MDF,
and
fiberboard
manufacturing
are
included
in
the
PCWP
source
category
(
along
with
manufacturing
of
other
PCWP).
Many
facilities
that
manufacture
PCWP
are
major
sources
of
HAP.
Therefore,
it
follows
that
we
are
required
by
the
CAA
to
establish
NESHAP
for
the
manufacturing
of
PCWP.

Section
112(
d)(
2)
requires
us
to
base
NESHAP
on
MACT.
Because
the
CAA
requires
us
to
set
technology­
based
standards
for
HAP
from
listed
source
categories
such
as
the
PCWP
source
category,
we
are
not
required
to
make
any
demonstrations
relating
emissions
of
particular
HAP
from
PCWP
facilities
to
particular
health
risks,
and
any
such
findings
would
not
be
relevant
to
the
MACT
decision,
were
we
to
make
them.

We
acknowledge
that
the
1997
AP­
42
Section
10.5
on
plywood
manufacturing
contained
few
HAP
emission
factors
(
i.
e.,
only
formaldehyde
emission
factors
were
included
for
ureaformaldehyde
(
UF)
presses
and
indirect­
fired
veneer
dryers).
We
develop
and
update
AP­
42
sections
periodically
based
on
emissions
test
data
that
we
have
received.
The
September
1997
Plywood
AP­
42
section
10.5
was
based
on
review
of
emissions
data
from
five
emission
test
reports,
NCASI
Technical
Bulletin
No.
405,
and
the
plywood
portion
of
NCASI
Technical
Bulletin
No.
694.
At
the
time
when
the
1997
AP­
42
Section
10.5
was
developed,
we
did
not
2­
40
have
the
HAP
emissions
data
that
we
have
now.
In
1998,
we
conducted
a
survey
of
the
PCWP
industry.
In
this
survey,
we
requested
that
facilities
submit
HAP
emission
test
reports
for
tests
conducted
in
1995
or
later.
We
obtained
additional
test
reports
that
contained
HAP
emission
data
for
softwood
plywood
manufacturing
processes
(
e.
g.,
veneer
dryers
or
presses)
in
response
to
the
survey.
In
addition,
a
large
amount
of
HAP
emissions
test
data
was
submitted
to
us
by
NCASI
in
1999.
The
NCASI
conducted
a
29­
mill
emissions
testing
program
to
characterize
HAP
and
volatile
organic
chemical
(
VOC)
emissions
from
PCWP
manufacturing
facilities.
The
purpose
of
the
NCASI
sampling
effort
was
to
provide
emissions
test
data
which
could
be
used
by
the
industry
and
EPA
in
development
of
the
MACT
standards.
The
NCASI
testing
program
provided
emissions
data
for
approximately
20
HAP.
Six
of
the
29
mills
tested
by
NCASI
produce
softwood
plywood.
7
The
Plywood
AP­
42
section
was
revised
to
incorporate
the
new
emissions
test
data
received
through
our
industry
survey
and
the
NCASI
sampling
program.
The
final
revised
AP­
42
section
was
placed
on
our
Web
site
(
http://
www.
epa.
gov/
ttn/
chief/
ap42/
ch10/)
in
January
2002.

We
would
like
to
point
out
that
MACT
standards
are
based
on
the
emissions
information
that
is
available
to
EPA,
and
that
we
are
not
limited
by
the
emissions
information
that
is
included
in
AP­
42
when
setting
MACT
standards.
We
disagree
with
the
commenters'
statement
that
"
plants
are
now
expected
to
spend
millions
of
dollars
to
control
emissions
that
EPA
believed
to
be
unlikely
a
few
years
ago."
Less
HAP
emissions
data
were
available
in
1997
than
are
available
today,
but
this
does
not
mean
that
we
deemed
it
"
unlikely"
that
HAP
are
emitted
from
softwood
plywood
facilities.

2.2.2
Comment:
Commenter
IV­
D­
31
stated
that
the
proposal
suggests
that
pregnancy
problems
and
menstrual
disorders
have
been
reported
in
connection
with
formaldehyde.
The
source
of
this
information
is
unclear,
and
recent
peer­
reviewed
literature
(
Collins
et
al.,
A
Review
of
Adverse
Pregnancy
Outcomes
and
Formaldehyde
Exposure
in
Human
and
Animal
Studies,
34
Reg.
Toxicology
and
Pharmacology
17
(
2001))
concludes
that
formaldehyde
is
not
a
reproductive
hazard
or
developmental
toxicant,
and
find
that
"[
g]
iven
formaldehyde's
rapid
metabolism
and
reactivity,
reproductive
and
developmental
effects
appear
unlikely
from
low
inhalation
and
dermal
exposure."
2­
41
Response:
The
preamble
to
the
proposed
rule
inadvertently
emphasized
results
from
an
epidemiological
study
in
which
confounding
factors
may
have
played
a
role
in
the
reported
results.

We
have
revised
the
discussion
of
formaldehyde
health
effects
such
that
it
n
longer
refers
to
reproductive
effects.

2.3
EXISTING
SOURCE
MACT
2.3.1
Process
unit
groups
2.3.1.1
Comment:
Commenter
IV­
D­
12
requested
that
EPA
group
"
conventional"

particleboard
presses
with
nonconventional
particleboard
presses
(
i.
e,
press
molds
and
extruders)

and
agriboard
presses,
instead
of
grouping
them
with
reconstituted
wood
products
presses,
for
the
purpose
of
determining
the
MACT
floor.
The
commenter
stated
that
making
these
changes
to
the
press
groupings
would
reduce
the
impacts
of
the
rule
on
existing
particleboard
plants.
The
commenter
noted
that,
while
EPA's
proposed
process
unit
groupings
are
logical,
they
are
not
necessarily
practical
given
the
current
and
projected
economic
status
of
the
particleboard
industry.

The
commenter
contended
that
creation
of
this
new
press
grouping
would
not
violate
any
technical
principles
already
being
applied
in
the
MACT
floor
analysis
because
the
pressing
technologies
are
similar
within
the
suggested
grouping
(
i.
e.,
all
are
hot
pressing
operations)
and
the
product
markets
generally
overlap.
The
commenter
noted
that,
if
the
suggested
realignment
were
performed,
then
only
3.5
percent
of
particleboard
presses
would
be
controlled,
resulting
in
a
MACT
floor
for
existing
particleboard
presses
of
"
no
control."
The
realignment
would
also
force
all
new
particleboard
presses,
including
molded,
extruded,
and
agriboard
presses,
to
install
controls
whereas
the
proposed
rule
does
not
require
new
molded
particleboard
presses,

particleboard
extruders,
or
agriboard
presses
to
be
controlled.
According
to
the
commenter,
this
more
stringent
requirement
for
new
sources
would
not
be
an
added
burden
because
"
controls
for
new
presses
would
be
required
by
PSD/
NSR
anyway."

The
commenter
also
requested
that
hardboard
presses
be
divided
into
three
separate
groups
according
to
process
type
(
i.
e.,
wet
process,
wet/
dry
process,
and
dry
process).
The
commenter
stated
that
making
this
change
would
result
in
each
hardboard
press
group
having
less
than
30
presses
with
only
1
controlled
press
per
group,
resulting
in
an
existing
source
MACT
floor
of
"
no
control"
for
each
group.
The
commenter
further
noted
that,
if
the
presses
mentioned
2­
42
above
were
exempted
from
the
proposed
control
requirements,
then
plants
would
have
the
option
to
control
the
presses
to
earn
emissions
averaging
credits.

To
help
determine
the
applicability
of
the
proposed
realignments,
the
commenter
suggested
that
EPA
use
the
existing
plant
list
based
on
the
document
"
Plywood
and
Composite
Wood
Products
Plant
List,"
which
identifies
the
specific
PCWP
produced
at
each
plant
(
Docket
Item
No.
II­
B­
012).
The
commenter
also
suggested
that
including
definitions
of
particleboard
and
hardboard
based
on
EPA's
proposed
definitions
and
the
changes
recommended
by
the
American
Forest
and
Paper
Association
(
Commenter
IV­
D­
27)
would
assist
with
applicability
determinations
and
would
prevent
a
facility
from
switching
to
the
production
of
products
where
control
was
required.

Response:
Section
112(
d)(
1)
of
the
CAA
allows
us
to
distinguish
among
classes,
types,

and
sizes
of
sources
when
establishing
emission
standards
However,
the
CAA
does
not
allow
us
to
group
equipment
for
the
sole
purpose
of
generating
a
MACT
floor
of
no
emissions
reduction,

unrelated
to
determining
what
emissions
limitations
the
equipment
used
at
sources
are
able
to
achieve.
We
believe
that
the
commenter's
suggestions
of
grouping
particleboard
press
molds,

particleboard
extruders,
agriboard
presses,
and
conventional
particleboard
presses
has
little
technical
merit,
and
would
only
serve
to
manufacture
a
no
emissions
reduction
MACT
floor
for
particleboard
presses
in
a
way
that
would
mask
the
emissions
levels
achieved
by
better
performing
sources.
Similar
results
would
be
obtained
if
we
distinguished
among
presses
included
in
the
different
hardboard
manufacturing
processes.
The
commenter
does
not
provide
valid
technical
reasons
for
making
the
suggested
equipment
distinctions,
but
rationalizes
the
suggested
distinctions
by
the
effect
the
equipment
groupings
would
have
on
the
MACT
floor.
Therefore,

we
believe
the
commenter's
suggestions
would
be
inappropriate
and
inconsistent
with
the
goals
of
the
CAA.

For
purposes
of
determining
the
MACT
floor
for
PCWP,
we
grouped
process
units
with
respect
to
similar
design,
operation,
and
emissions.
Molded
particleboard
plants
operate
numerous
press
molds,
which
are
designed
very
differently
from
the
platen
particleboard
presses.

In
addition,
some
plants
produce
particleboard
panels
using
extruders
instead
of
multi­
opening
presses.
The
annual
HAP
emissions
from
press
molds
and
extruders
are
estimated
to
be
only
a
fraction
of
the
annual
HAP
emissions
from
conventional
particleboard
presses.
Given
the
2­
43
differences
in
design
and
annual
HAP
emissions,
both
press
molds
and
extruders
were
included
in
process
unit
groups
separate
from
panel
presses
used
at
hardboard,
MDF,
OSB,
particleboard,

agriboard,
and
plywood
plants
for
purposes
of
determining
the
MACT
floor
for
PCWP
presses.

We
determined
that
the
MACT
floors
for
press
molds
and
extruders
were
based
on
no
emissions
reduction
because
none
of
these
equipment
are
controlled.

Agriboard
presses
are
typically
smaller
(
i.
e.,
have
fewer
openings)
with
much
lower
annual
throughput
compared
to
conventional
particleboard
presses.
Agriboard
is
made
with
agricultural
fiber
that
is
pressed
using
methylene
diphenyl
diisocyante
(
MDI)
resin.
The
small
amount
of
information
available
on
agriboard
press
emissions
suggests
that
the
emissions
of
MDI
are
very
low.
Due
to
the
difference
in
emissions
from
agriboard
presses
and
conventional
particleboard
presses,
we
treated
agriboard
presses
separately
from
the
particleboard
presses
for
purposes
of
determining
the
MACT
floor.
We
determined
that
the
MACT
floor
for
agriboard
presses
was
no
emissions
reduction
because
none
of
these
presses
are
controlled.

We
further
distinguished
among
plywood
presses
and
reconstituted
wood
product
presses
(
used
at
hardboard,
MDF,
OSB,
and
particleboard
plants)
because
of
different
emissions
characteristics
and
the
fact
that
plywood
presses
are
often
manually
loaded
and
unloaded
(
unlike
reconstituted
wood
product
presses
that
have
automated
loaders
and
unloaders).
We
determined
that
the
MACT
floor
for
plywood
presses
was
no
emissions
reduction
because
no
plywood
presses
are
controlled.

We
chose
not
to
distinguish
among
reconstituted
wood
product
presses
used
to
manufacture
hardboard,
MDF,
OSB,
and
particleboard
because
these
presses
are
of
similar
design
and
the
HAP
emissions
from
these
types
of
presses
are
similar.
The
MACT
floor
for
new
and
existing
reconstituted
wood
products
presses
is
the
emission
reduction
achievable
with
a
control
system
that
incorporates
an
enclosure
and
incineration­
based
controls
or
biofilters.

Our
conclusions
regarding
the
MACT
floor
for
the
different
types
of
presses
are
unchanged
from
the
MACT
floors
we
proposed
(
except
as
explained
elsewhere
that
a
"
wood
products
enclosure"
is
now
required
in
lieu
of
an
EPA
Method­
204­
certified
PTE).
Had
we
separated
reconstituted
wood
product
presses
according
to
product
at
proposal,
MACT
control
technology
(
i.
e.,
incineration­
based
control
or
biofilter)
would
have
been
the
same
for
MDF,

OSB,
hardboard,
and
particleboard
presses;
however,
the
capture
requirements
for
particleboard
2­
44
and
hardboard
presses
would
have
been
undefined
(
because
less
than
6
percent
of
these
presses
were
believed
to
have
PTEs).
The
reconstituted
wood
product
board
cooler
equipment
grouping
was
based
on
the
same
criteria
as
the
reconstituted
wood
product
press
equipment
grouping,
and
therefore,
the
MACT
floor
determination
for
reconstituted
wood
product
board
coolers
would
also
have
been
different
if
we
had
made
product
distinctions.
The
MACT
floor
for
new
and
existing
MDF
board
coolers
and
for
new
hardboard
board
coolers
would
have
been
based
on
a
PTE
and
incineration­
based
control
and
biofilter,
which
for
MDF
and
hardboard
is
more
stringent
that
the
proposed
MACT
floor
for
board
coolers.
Regardless
of
what
the
MACT
floor
determinations
for
each
product
type
would
have
been
prior
to
proposal,
we
maintain
that
it
would
be
inappropriate
to
distinguish
among
particleboard,
MDF,
hardboard,
and
OSB
presses
because
these
presses
have
similar
design
and
similar
HAP
emissions.
As
discussed
in
response
to
comment
2.3.1.2,
we
also
maintain
that
separating
hardboard
presses
according
to
process
type
(
i.
e.,
wet
process,
wet/
dry
process,
and
dry
process)
for
purposes
of
determining
the
MACT
floor
is
not
justified.

The
rationale
behind
our
decision
not
to
separate
reconstituted
wood
product
presses
by
product
is
not
concern
that
facilities
will
switch
products
(
as
the
commenter
seems
to
suggest).

Our
rationale
is
based
on
technical
distinctions
in
the
design
and
emissions
characteristics
of
the
pressing
equipment.
In
addition,
we
note
that
MDF
and
particleboard
compete
in
the
same
market,
and
that
hardboard
manufactured
using
both
dry
and
wet
pressing
competes
in
the
same
market.
There
are
new
hybrid
products
coming
into
the
marketplace
such
as
thin
high
density
fiberboard
and
a
particleboard/
MDF
combination.
Molded
particleboard
and
extruded
particleboard
are
usually
found
in
captive
markets
(
e.
g.,
used
internally
at
wood
furniture
plants)

as
opposed
to
commercial
markets
like
those
of
particleboard
and
MDF
panels.
The
requirements
for
presses
(
and
for
other
equipment
used
to
make
different
products
such
as
tube
dryers,
strand
dryers,
etc.)
in
the
final
rule
apply
uniformly
to
PCWP
competing
in
the
same
markets,
which
will
ease
applicability
determinations
and
prevent
creation
of
an
unfair
advantage.

2.3.1.2
Comment:
Commenter
IV­
D­
57
argued
that
hardboard
presses,
specifically
wet/
wet­
process
hardboard
presses
and
especially
short­
cycle
wet
hardboard
presses,
are
fundamentally
different
from
other
"
reconstituted
wood
products
presses"
and
should
be
evaluated
separately
when
determining
the
MACT
floor.
Of
the
40
hardboard
presses
surveyed
2­
45
by
EPA,
only
one
had
an
incineration­
based
control
device,
yet
EPA
established
the
floor
requirements
at
a
permanent
total
enclosure
and
a
thermal
oxidation
device.
The
commenter
stated
that
when
they
examined
the
BID
and
supporting
documents,
they
did
not
find
any
reasoned
analysis
by
EPA
as
to
why
hardboard
presses,
and
especially
wet/
wet­
process
presses,

which
traditionally
have
been
accorded
their
own
emission
factors
(
in
EPA
publication
AP­
42,
for
example)
and
have
been
regulated
separately
from
other
wood
panel
manufacturing
processes
(
e.
g.,
effluent
guidelines
for
the
Wet
Process
Hardboard
subcategory
in
40
CFR
part
429,
subpart
E),
should
be
lumped
in
with
other
types
of
presses
for
purposes
of
determining
a
MACT
floor.

The
commenter
also
stated
that
plywood
presses
are
considered
separate
from
other
presses,
but
there
is
no
explanation
for
that
decision.
The
EPA
should
consider
hardboard
presses
separately
as
well,
since
there
are
a
number
of
practical
considerations
in
terms
of
available
control
technology.
Hardboard
presses
have
lower
emission
rates
than
other
reconstituted
wood
products
presses.
Like
plywood
presses,
very
few
hardboard
presses
are
currently
enclosed
because
of
the
maintenance
that
must
be
performed
manually
by
human
operators.
If
EPA
had
properly
separated
hardboard
presses
from
other
reconstituted
wood
products
presses,
then
the
MACT
floor
would
have
been
correctly
set
at
"
no
control."
The
commenter
pointed
out
that
the
arguments
for
creating
a
separate
MACT
floor
are
even
stronger
for
wet/
wet­
process
hardboard
presses.
The
commenter
stated
that
the
large
amounts
of
water
involved,
both
being
pressed
out
of
the
mat
and
exiting
the
press
in
exhaust
gases,
makes
these
presses
both
much
more
problematic
to
enclose
and
much
more
costly
and
difficult
to
control.
Other
characteristics
of
these
presses
that
set
them
apart
from
other
hardboard
presses
are
a
much
higher
exhaust
gas
flow
and
a
much
lower
exhaust
gas
temperature.
The
commenter
pointed
out
that
EPA
has
recognized
that
"
it
is
appropriate
to
consider
differences
in
processes,
exhaust
gas
flow
rates,
emissions
characteristics,
and
air
pollution
control
device
viability
in
determining
whether
to
create
a
subcategory
of
emission
sources.
See
68
Fed.
Reg.
1302."
Based
on
all
of
the
above
reasons,

EPA
should
place
wet/
wet­
process
hardboard
presses
in
their
own
subcategory
and
conclude
that
the
MACT
floor
is
"
no
control."

The
commenter
stated
that
to
their
knowledge,
the
only
short­
cycle
wet
hardboard
press
units
still
in
operation
in
the
United
States
are
the
two
presses
at
their
facility.
The
presses
at
this
facility
are
unique
because
they
do
not
bake
the
hardboard
until
the
moisture
levels
are
low.
2­
46
Instead,
the
press
cycle
is
short,
usually
five
minutes
or
less
when
producing
a
board
with
nominal
thickness
of
7/
16
to
5/
8
inch,
and
the
press
only
reduces
the
moisture
content
from
67
percent
water
to
20
percent
water
by
weight,
dry
basis.
The
temperature
ranges
from
125
º
F
at
the
inlet
to
160
º
F
at
the
press
outlet.
Once
the
board
leaves
the
press,
it
enters
a
bake
oven,
where
it
is
completely
dried.
The
board
is
in
the
oven
for
about
4.5
hours,
and
the
temperature
can
reach
310
º
F.
For
comparison,
other
wet
press
process
units
have
a
press
cycle
of
up
to
28
minutes,

and
the
board
is
dried
to
less
than
5
percent
moisture
content.
The
commenter
pointed
out
that
no
other
short­
cycle
wet
press
process
unit
has
an
add­
on
control
device,
and
they
do
not
know
of
any
wet
hardboard
presses
that
are
controlled.
Another
difficulty
with
a
press
enclosure
would
be
avoiding
degradation
of
the
equipment
when
it
is
enclosed
in
a
relatively
low­
temperature,

highmoisture
environment.

The
commenter
explained
that
about
240,000
gallons
of
water
flow
from
the
press
unit
into
the
wastewater
treatment
center
every
day.
Some
of
that
water
is
squeezed
out
of
the
press
and
some
is
emitted
as
water
vapor
that
condenses
in
the
hood
above
the
press.
Because
the
press
cycle
is
so
short,
there
is
no
point
at
which
the
emissions
are
relatively
dry.
These
factors
will
make
it
difficult
to
design
and
build
an
enclosure
to
control
this
facility's
press
vents.
The
large
amount
of
water
removes
substantial
amounts
of
HAP
from
the
press
exhaust
and
the
condensing
water
vapor
acts
as
a
basic
scrubber
for
the
gases
exiting
the
press.
Wastewater
tested
at
the
facility's
biological
treatment
system
had
a
HAP
concentration
of
95
ppm.
The
water
flow
is
important
to
the
removal
of
HAP
and
it
will
be
difficult
to
maintain
negative
pressure
inside
a
press
enclosure
without
disrupting
that
water
flow.

The
commenter
stated
that
press
enclosures
will
present
safety
problems
for
the
press
operators.
Every
time
the
press
is
opened,
an
operator
must
inspect
the
press
and
remove
any
boards
that
are
stuck
to
the
press.
Removing
boards
could
involve
removing
the
entire
screen,

bar,
and
board.
Operators
also
change
the
caul
plates,
which
emboss
various
patterns
onto
the
board,
several
times
a
day.
If
the
operators
are
forced
to
work
inside
a
press
enclosure,
then
they
will
be
exposed
to
hot,
foggy
conditions
in
an
unsafe,
if
not
uninhabitable,
workplace.
The
commenter
noted
that
they
have
considered
video
cameras
or
automation,
but
no
technique
is
available
that
could
completely
replace
the
operators.
The
commenter
provided
a
video
2­
47
demonstrating
the
duties
of
the
operators
on
November
15,
2002
and
stated
that
this
is
not
a
problem
that
can
be
easily
overcome.

The
commenter
argued
that
because
the
hardboard
mat
is
not
completely
dried
and
the
resin
is
not
set
in
the
press,
a
significant
amount
of
VOCs
exit
the
press
with
the
board
and
are
emitted
from
the
bake
oven.
Therefore,
the
emissions
from
the
short­
cycle
presses
are
"

highvolume
very
high
moisture,
relatively
low
temperature,
and
have
low
concentrations
of
VOCs
and
HAPs"
and
the
bake
oven
emissions
are
"
lower­
volume,
higher­
concentration
exhaust
gases."

Because
of
these
factors,
the
commenter
noted
that
the
emissions
from
the
presses
at
this
facility
are
a
smaller
portion
of
the
overall
emissions
than
the
press
emissions
at
other
hardboard
plants.

Table
2­
2
summarizes
total
HAP
(
sum
of
the
six
predominant
HAP)
emissions
and
exhaust
gas
characteristics
for
one
production
line
based
on
stack
tests
performed
in
December
2002.
The
commenter
noted
that
press
total
HAP
emissions
were
equivalent
to
0.52
lb/
thousand
square
foot
(
MSF),
7/
16
inch
(
equivalent
to
0.89
lb/
MSF,
3/
4
inch)
and
the
bake
oven
total
HAP
emissions
are
equivalent
to
0.46
lb/
MSF,
7/
16
inch
(
equivalent
to
0.13
lb/
MSF,
1/
8
inch).
(
No
thickness
basis
for
these
measurements
was
provided
in
the
comment
letter;
however
the
thicknesses
were
later
provided
during
a
meeting
with
the
commenter.
8)
The
commenter
pointed
out
that
the
total
HAP
emissions
from
one
press
at
this
facility
are
above
the
20
ppmv
limit
by
less
than
3
ppmv,
but
there
is
no
consistent
way
that
the
facility
can
ensure
that
they
could
keep
emissions
below
20
ppmv.
The
commenter
noted
that
the
hardboard
market
is
highly
competitive,
and
individual
facilities
work
to
minimize
chemical
and
production
costs.
There
are
currently
no
real
opportunities
for
raw
material
substitution,
and
it
seems
unlikely
that
practical
and
cost­
efficient
pollution
prevention
options
will
be
available
any
time
soon.
2­
48
Table
2­
2.
Total
HAP
Emissions
Exhaust
Gas
Characteristics
for
one
wet/
wet
Hardboard
Production
Line
Parameter
Press
Bake
oven
Sum
of
total
HAP,
ppmv
22.8
61.3
Sum
of
total
HAP,
lb/
hr
14.50
12.76
Stack
temperature,
°
F
137
211
Stack
gas
flow,
cfm
99,629
39,740
Stack
moisture,
%
14.1
20.0
Commenter
IV­
D­
57
stated
that
controlling
two
wet/
wet­
process
short­
cycle
hardboard
presses
will
be
very
costly.
The
total
exhaust
is
200,000
actual
cubic
feet
per
minute
(
acfm),
so
the
RTOs
will
have
to
be
large
and
will
require
large
amounts
of
natural
gas.
In
addition,
10,000
pounds
of
water
vapor
per
day
will
have
to
be
raised
from
about
140
º
F
to
the
temperature
necessary
for
destruction
of
the
HAP.
The
commenter
estimated
that
capital
costs
for
the
press
controls
alone
will
be
$
5.7
to
$
9.6
million
and
annualized
costs
will
be
about
$
3
million,
and
only
120
tpy
of
HAP
(
60
tpy
per
press)
will
be
controlled.
The
commenter
noted
that
this
facility
is
unique
among
wet/
wet­
process
hardboard
facilities
because
the
hardboard
is
completely
dried
in
a
bake
oven
rather
than
the
press.
As
a
result,
the
facility
will
have
to
control
the
bake
oven
as
well
as
the
press,
while
other
wet/
wet­
process
hardboard
facilities
will
only
have
to
control
one
unit,

putting
this
facility
at
an
economic
disadvantage.

The
commenter
noted
that
the
high
levels
of
moisture
in
the
emissions
would
quickly
degrade
the
media
in
an
RTO
or
an
RCO.
Also,
this
facility
would
need
an
extremely
large
RTO
or
RCO
unit
to
handle
all
of
the
emissions
from
the
presses.
Another
possible
control
device
is
a
biofilter,
but
the
commenter
believes
that
biofilters
are
untested
and
impracticable
for
a
gas
volume
as
large
as
that
of
their
facility's
press
vents.
The
commenter
pointed
out
that
according
to
the
BID,
a
biofilter
large
enough
to
handle
the
200,000
acfm
of
exhaust
would
have
to
have
a
surface
area
of
24,000
ft2
to
40,000
ft2,
and
the
BID
notes
that
a
6,000
ft2
Monsanto
unit
is
considered
a
"
large"
biofilter.
If
this
facility
were
to
attempt
to
use
six­
foot­
diameter
biocubes,

857
to
1,428
biocubes
would
be
required.
At
costs
ranging
from
$
27,000/
ton
of
HAP
removed
2­
49
(
using
a
wet
scrubber
and
biofilter)
to
$
35,000/
ton
of
HAP
removed
(
using
a
wet
scrubber
and
RCO),
any
control
device
chosen
for
this
facility
will
be
extremely
expensive
and
would
exceed
reasonable
BACT
cost
standards.
No
controls
would
be
the
best
VOC/
HAP
emission
control
option
for
the
facility.

The
commenter
suggested
two
possible
solutions
to
this
problem.
The
preferred
option
is
to
separate
hardboard
presses,
or
at
least
wet/
wet­
process
hardboard
presses,
into
a
new
subcategory
and
determine
that
the
MACT
floor
for
this
subcategory
is
"
no
control."

Beyondthe
floor
controls
should
not
be
considered
because
they
are
too
costly.
If
EPA
decides
not
to
create
a
separate
subcategory,
then
it
should
exclude
short­
cycle
wet
presses
that
do
not
dry
the
board
and
set
the
resin,
such
as
the
ones
at
this
facility,
from
the
MACT
requirements.
If
EPA
chooses
to
exclude
the
short­
cycle
presses,
then
the
following
statement
should
be
included
in
the
definition
of
"
reconstituted
wood
product
press:"
"
It
does
not
include
a
hardboard
press
where
the
daily
average
moisture
content
of
the
board
leaving
the
press
is
equal
to
or
greater
than
20%

by
weight
(
dry
basis)."

Response:
When
we
determined
the
MACT
floor
at
proposal,
we
grouped
process
units
based
on
similarities
in
equipment
design,
operation,
and
emissions.
We
grouped
the
wet/
wet
hardboard
presses
with
other
types
of
hardboard
presses
at
proposal
for
several
reasons:
(
1)

wet/
wet
hardboard
presses
manufacture
the
same
product
as
presses
at
dry/
dry
and
wet/
dry
hardboard
plants;
(
2)
wet/
wet
and
dry/
dry
hardboard
manufacturing
uses
phenol­
formaldehyde
resins;
and
(
3)
the
presses
at
wet/
wet
hardboard
plants
have
emissions
similar
to
those
from
presses
at
wet/
dry
and
dry/
dry
process
hardboard
plants.
We
also
grouped
all
hardboard
presses
with
presses
used
to
manufacture
MDF,
particleboard,
and
OSB
because
these
presses
are
of
similar
design
(
generally
multiplaten
presses
with
loader
and
unloader)
and
have
HAP
emissions
of
the
same
magnitude.
There
was
no
reason
to
believe
that
APCD
applicability
varied
according
to
product
because
similar
types
of
enclosures
and
add­
on
controls
were
used
on
multiple
presses
making
each
reconstituted
wood
product
(
hardboard,
MDF,
particleboard,
and
OSB).
We
distinguished
among
plywood
presses
and
reconstituted
wood
product
presses
because
of
different
emissions
characteristics
(
i.
e.,
plywood
press
emissions
are
much
lower)
and
factors
that
could
affect
the
ability
of
plywood
presses
to
be
enclosed
(
i.
e.,
the
fact
that
plywood
presses
are
often
manually
loaded
and
unloaded
and
require
constant
forklift
access
for
removal
of
stacks
of
2­
50
pressed
plywood).
We
determined
that
the
MACT
floor
for
new
and
existing
reconstituted
wood
product
presses
is
the
emission
reduction
achievable
with
a
control
system
that
incorporates
an
enclosure
and
incineration­
based
controls
or
biofilters.
We
determined
that
the
MACT
floor
for
plywood
presses
is
no
emissions
reduction
because
no
plywood
presses
are
controlled.

Documentation
of
the
proposed
process
unit
groups
and
MACT
floor
determinations
for
each
group
was
provided
in
a
memorandum
entitled
"
Determination
of
MACT
floors
and
MACT
for
the
Plywood
and
Composite
Wood
Products
Industry."
3
We
disagree
that
there
is
sufficient
technical
rationale
for
treating
wet/
wet
hardboard
presses
or
all
hardboard
presses
differently
for
purposes
of
determining
that
MACT
floor.
While
there
may
be
some
reasons
for
treating
wet/
wet
hardboard
presses
separately
(
i.
e.,
wet
mat
pressed),
there
are
also
reasons
for
not
treating
them
separately
(
i.
e.,
high
emissions
compared
to
other
reconstituted
wood
products
presses).
The
final
PCWP
rule
applies
uniformly
to
all
reconstituted
wood
products
presses,
including
wet/
wet
hardboard
presses.
The
following
discussion
explains
our
rationale
and
addresses
specific
points
raised
by
the
commenter.

The
commenter
correctly
noted
that
hardboard
presses
have
their
own
AP­
42
chapter;

however,
the
other
PCWP
(
including
MDF,
OSB,
particleboard,
plywood,
and
engineered
wood
products)
also
have
their
own
AP­
42
chapters.
Previous
EPA
publications,
such
as
AP­
42
emission
factors,
were
not
a
consideration
in
determining
the
PCWP
MACT
process
unit
groups.

Similarly,
while
we
acknowledge
that
there
are
separate
effluent
guidelines
for
wet
process
hardboard
(
because
wet
process
hardboard,
including
wet/
wet
and
wet/
dry
hardboard
processes,

is
the
only
PCWP
production
process
that
uses
water),
we
note
that
the
these
effluent
guidelines
were
developed
pursuant
to
the
Clean
Water
Act
and
were
not
a
considered
when
determining
the
PCWP
MACT
process
unit
groups.

The
commenter
claimed
that
hardboard
presses
have
lower
emission
rates
than
other
reconstituted
wood
products
presses,
and
stated
that
wet/
wet
hardboard
presses
have
a
much
higher
exhaust
gas
flow
and
a
much
lower
exhaust
gas
temperature
than
other
hardboard
presses.

Our
data
do
not
support
these
conclusions.
Our
data
show
that
hardboard
presses,
including
wet/
wet
hardboard
presses,
have
some
of
the
highest
uncontrolled
HAP
emission
factors
(
e.
g.,
2.2
and
3.0
lb/
MSF
3/
4")
within
the
reconstituted
press
grouping,
which
has
total
HAP
emissions
ranging
from
(
0.37
to
3.0
lb/
MSF
3/
4").
The
PBCO
for
the
reconstituted
wood
product
presses,
2­
51
which
was
based
on
the
maximum
of
our
uncontrolled
total
HAP
data,
was
based
on
the
emissions
of
a
wet/
wet
hardboard
press.
9
The
total
HAP
emissions
from
the
commenter's
press
(
0.89
lb/
MSF
3/
4")
are
lower
than
some
of
the
other
wet/
wet
hardboard
presses
for
which
we
have
data,
but
are
within
the
range
of
emissions
from
reconstituted
wood
products
presses.
In
terms
of
annual
emissions,
the
commenter's
wet/
wet
hardboard
presses
each
emit
60
tpy
of
HAP.
In
addition,
our
MACT
survey
data
do
not
show
a
large
difference
in
the
press
exhaust
flows
and
temperatures
from
wet/
wet
hardboard
presses
and
other
types
of
reconstituted
wood
products
presses.
10
We
acknowledge
that
wet/
wet
hardboard
presses
differ
from
other
types
of
reconstituted
wood
products
presses
because
wet/
wet
hardboard
presses
are
used
to
press
a
wet
mat.
Wet/
wet
hardboard
presses
have
water
that
cascades
down
the
sides
of
the
press
as
the
press
closes.
The
commenter
presented
concerns
regarding
potential
difficulty
with
a
full
enclosure
for
the
subject
facility,
including
equipment
degradation,
disruption
of
water
flow,
and
operator
safety
concerns.

Given
that
none
of
the
other
companies
with
wet/
wet
hardboard
presses
presented
these
concerns
to
us,
we
are
not
able
to
distinguish
which
of
these
concerns
are
specific
to
the
commenter's
facility
and
which
could
be
problems
for
other
wet/
wet
hardboard
presses.
Also,
it
is
unclear
how
pressing
equipment
that
has
water
cascading
down
its
sides
during
normal
operation
could
be
adversely
affected
by
a
low
temperature,
high
moisture
environment
inside
an
enclosure.
We
acknowledge
that
safety
of
the
operators
inside
an
enclosure
at
the
subject
facility
is
a
major
concern.
Although
a
wood
products
enclosure
is
required
to
meet
the
MACT
floor,
the
final
PCWP
rule
includes
alternative
options
that
would
minimize
operator
safety
concerns.
For
example,
another
process
unit
could
be
controlled
and
used
in
an
emissions
average
to
avoid
capturing
and
controlling
all
of
the
press
emissions.
Another
option
would
be
to
construct
and
test
a
partial
wood
products
enclosure
and
use
a
highly
efficient
control
device
to
achieve
a
combined
capture
and
control
efficiency
of
90
percent.
In
the
video
provided
by
the
commenter,

the
press
exhaust
appears
to
be
very
buoyant,
rising
rapidly
within
the
press
hood.
The
vapor
cloud
does
not
appear
to
spread
outside
of
the
hooded
area,
making
it
seem
feasible
that
the
facility
could
achieve
good
capture
using
a
partial
wood
products
enclosure.

The
commenter
stated
that
their
facility
is
unique
among
wet/
wet
hardboard
facilities
because
the
facility
uses
a
short
press
cycle
(
5
minutes
or
less)
and
uses
bake
ovens
to
complete
2­
52
drying
of
the
board
to
bone
dry
levels.
According
to
the
commenter,
other
facilities
press
for
up
to
28
minutes
and
do
not
have
bake
ovens
because
the
board
is
pressed
to
bone
dry
levels.
We
cannot
conclude
with
certainty
that
the
commenter's
facility
is
unique
because
our
MACT
survey
data
do
not
verify
the
commenter's
statements.
Our
MACT
survey
data
show
that
there
is
at
least
one
other
wet/
wet
hardboard
facility
with
bake
ovens.
The
survey
data
also
show
that
other
wet/
wet
facilities
use
short
press
cycles,
ranging
from
4
to
20
minutes.
We
do
not
have
data
on
board
outlet
moisture
content.

The
commenter
noted
that
the
sum
of
"
total
HAP"
for
their
wet/
wet
presses
is
above
20
ppm.
From
this
comment,
we
infer
that
the
commenter
believed
that
they
would
almost
be
able
to
comply
with
the
20
ppm
compliance
option
in
the
proposed
rule.
If
so,
it
appears
that
the
commenter
misunderstood
the
application
of
the
20
ppm
compliance
option
in
the
PCWP
rule.

The
20
ppm
value
is
in
terms
of
THC,
not
"
total
HAP."
Also,
the
20
ppm
THC
level
must
be
demonstrated
at
the
outlet
of
an
APCD.

The
commenter
concluded
that
there
is
no
good
way
to
control
the
emissions
from
their
facility
because
the
moisture
and
high
airflow
would
create
mechanical
difficulties
for
all
control
technologies.
We
disagree
with
this
assertion
because
high
flow
and
high
moisture
exhaust
streams
(
e.
g.,
20
to
25
percent
moisture
at
the
outlet
of
a
WESP)
are
treated
by
WESP/
RTO
systems
installed
on
OSB
rotary
dryers.
11
We
also
note
that
the
moisture
content
shown
in
Table
2­
1
above
for
the
bake
oven
exhaust
is
higher
than
that
for
the
press
exhaust.
We
further
disagree
that
wet/
wet
hardboard
press
exhaust
is
problematic
for
a
biofilter.
Biofilters
are
particularly
well
suited
to
treat
low
temperature
exhaust
streams
with
a
high
moisture
content.

The
commenter
dismissed
the
possibility
of
installing
a
biofilter
by
stating
that
a
biofilter
large
enough
to
handle
the
exhaust
from
their
two
wet/
wet
hardboard
presses
(
approximately
100,000
cfm
each)
has
never
been
constructed
or
tested.
To
the
contrary,
we
are
aware
of
a
biofilter
in
use
at
one
PCWP
facility
that
treats
600,000
cfm
of
exhaust.
12
In
addition,
the
commenter
also
determined
in
their
own
cost
analysis
that
a
wet
scrubber
and
biofilter
combination
would
be
the
most
cost­
effective
control
device
option.
That
cost
analysis
was
based
on
the
assumption
that
a
wet
scrubber
and
biofilter
combination
would
only
achieve
an
80
percent
HAP
reduction.
Based
on
the
data
that
we
have
collected,
biofilters
can
easily
achieve
at
least
90
percent
control
of
HAP
such
as
formaldehyde
and
methanol.
If
the
commenter
had
reflected
a
90
percent
HAP
control
2­
53
efficiency
in
their
cost
analysis,
then
the
cost­
effectiveness
of
the
biofilter
option
would
appear
more
favorable.

The
commenter
concluded
that
none
of
the
control
options
they
analyzed
would
be
considered
to
be
cost­
effective
for
a
BACT
determination
and
that
the
"
best"
control
option
for
their
facility
would
be
no
control.
We
note
that
BACT
and
MACT
levels
of
control
may
differ
and
that
the
CAA
does
not
allow
us
to
consider
cost
as
a
criteria
when
determining
the
MACT
floor.

The
commenter
pointed
out
that
if
we
had
separated
hardboard
presses
or
wet/
wet
hardboard
presses
into
their
own
subcategory,
the
MACT
floor
would
be
"
no
control"
because
only
one
hardboard
press
has
incineration­
based
control.
This
may
be
true
for
existing
hardboard
presses
(
and
for
new
and
existing
wet/
wet
hardboard
presses
if
they
were
placed
in
their
own
group),
but
it
would
not
be
true
for
new
hardboard
presses
because
MACT
for
new
sources
is
based
on
the
best
performing
similar
source,
and
some
hardboard
presses
are
enclosed
and
controlled.
The
MACT
floor
analysis
included
three
controlled
hardboard
presses
(
the
one
mentioned
by
the
commenter
with
incineration­
based
control,
plus
two
others
with
biofilters).

The
CAA
does
not
allow
us
to
group
equipment
for
the
sole
purpose
of
generating
a
MACT
floor
based
on
no
emissions
reduction
(
unrelated
to
determining
what
emissions
limitations
the
equipment
used
at
sources
are
able
to
achieve).
Even
if
wet/
wet
hardboard
presses
were
not
controlled
at
the
MACT
floor,
we
would
evaluate
beyond
the
floor
options.
Because
wet/
wet
presses
are
some
of
the
highest­
emitting
presses
in
the
PCWP
industry,
the
costs
of
a
beyond­
the
floor
control
option
would
likely
be
equivalent
to
control
costs
for
other
press
types
and
justifiable.

The
commenter
makes
reference
to
the
"
highly
competitive
nature
of
the
hardboard
market."
We
note
that
hardboard
is
manufactured
for
the
same
markets
and
applications,

regardless
of
the
manufacturing
process,
and
that
creating
a
subcategory
that
includes
some
hardboard
presses
and
excludes
others
could
change
the
competitive
makeup
of
the
hardboard
market.

2.3.1.3
Comment:
Commenter
IV­
D­
57
requested
that
EPA
consider
including
a
"
fundamentally
different
factors
variance"
in
the
final
PCWP
rule.
The
commenter
explained
that
the
NESHAP
apply
to
all
facilities
within
a
category
or
subcategory,
but
occasionally
there
is
one
2­
54
facility
that
is
different
from
all
other
facilities
within
a
category.
When
that
situation
occurs,

EPA
should
provide
a
variance
from
the
standards
because
that
facility
may
be
unable
to
achieve
the
standards.
In
this
case,
the
commenter
argued
that
their
short­
cycle
wet/
wet­
process
hardboard
press
is
fundamentally
different
from
other
wet/
wet­
process
hardboard
presses.
The
commenter
stated
that
there
is
precedent
and
legal
basis
for
providing
this
"
fundamentally
different
factors
variance"
in
the
PCWP
NESHAP,
and
excluding
it
would
"
constitute
a
fatal
legal
defect."
The
legal
rationale
for
this
variance
was
given
as
follows:

"
The
United
States
Supreme
Court
has
recognized
the
necessity
of
a
fundamentally
different
factors
variance
for
nationwide,
technology­
based
limitations.
In
the
context
of
reviewing
Best
Practicable
Technology
and
Best
Available
Technology
requirements
of
the
Clean
Water
Act,
the
Supreme
Court
approved
of
uniform,
technology­
based
limitations,
"
so
long
as
some
allowance
is
made
for
variations
in
individual
plants."
E.
I.
du
Pont
de
Nemours
&
Co.
v.
Train,
430
U.
S.
112,
128
(
1977).
See
also
U.
S.
Steel
Corp.
v.
Train,
556
F.
2d
822,
844­
45
(
7th
Cir.
1977).
In
fact,
with
respect
to
effluent
guidelines
for
the
pulp
and
paper
industry
in
particular,
the
D.
C.
Circuit
held
that
"
we
cannot
approve
the
regulations
without
finding
that
they
include
a
sufficiently
flexible
variance
provision."
Weyerhaeuser
Co.
v.
Costle,
590
F.
2d
1011,
1032
(
D.
C.
Cir.
1978).
The
D.
C.
Circuit
explained
that
"
t[
he]
importance
that
the
[
Supreme]
Court
assigned
to
a
meaningful
variance
as
a
prerequisite
to
valid
general
limitations
may
be
seen
 
in
its
use
of
the
mandatory
phrase
`
so
long
as'."
The
courts
have
inferred
the
need
for
a
"
safety
valve"
variance
even
where,
as
in
the
case
of
the
Best
Practicable
Technology
requirements
Federal
Water
Pollution
Control
Act
of
1972,
no
variance
was
included
in
the
statutory
language.
"
As
a
result
of
these
decisions,
in
1979
EPA
incorporated
into
its
water
pollution
regulations
an
explicit
fundamentally
different
factors
("
FDF")
variance,
in
40
C.
F.
R.
part
125,
Subpart
D.
The
Water
Quality
Act
of
1987
subsequently
incorporated
an
FDF
variance
into
the
Clean
Water
Act
as
section
301(
n).
For
the
same
reasons,
a
uniform,
technology­
based
standard
under
Clean
Air
Act
section
112
must
be
accompanied
by
some
variance
provision
that
would
allow
for
different
standards
to
be
applied
to
facilities
that
are
fundamentally
different
from
those
upon
which
the
MACT
standards
are
based.
"
The
Supreme
Court
has
acknowledged
that
variances
"
are
appropriate
to
the
regulatory
process."
Du
Pont,
430
U.
S.
at
138
(
quoting
the
underlying
Court
of
Appeals
in
E.
I.
du
Pont
de
Nemours
&
Co.
v.
Train,
541
F.
2d
1018,
1028
(
4th
Cir.
1976);
see
also
U.
S.
v.
Allegheny­
Ludlum
Steel
Corp.,
406
U.
S.
742,
755
(
1972).
("
It
is
well
established
that
an
agency's
authority
to
proceed
in
a
complex
area
 
by
means
of
rules
of
general
application
entails
a
concomitant
authority
to
provide
exemption
procedures
in
order
to
allow
for
special
circumstances.").
In
explaining
the
need
for
a
variance
provision,
the
Fourth
Circuit
relied
on
the
D.
C.
Circuit's
reasoning
that
"
a
regulatory
system
which
allows
flexibility,
and
a
lessening
of
firm
proscriptions
in
a
proper
case,
can
lend
strength
to
the
system
as
a
whole.
The
limited
safety
valve
permits
a
more
rigorous
adherence
to
an
effective
regulation."
Portland
Cement
Ass'n
v.
Ruckelshaus,
486
F.
2d
373,
399
(
D.
C.
2­
55
Cir.
1973)
(
citations
omitted),
cert.
denied
417
U.
S.
921.
The
Fourth
Circuit
also
cited
to
the
D.
C.
Circuit's
opinion
in
International
Harvester
v.
Ruckelshaus:
"
Considerations
of
fairness
will
support
comprehensive
and
firm,
even
drastic,
regulations,
provided
a
`
safety
valve'
is
also
provided."
478
F.
2d
615,
641
(
D.
C.
Cir.
1973)."

The
commenter
suggested
that
EPA
follow
the
Supreme
Court's
reasoning
and
provide
a
fundamentally
different
factors
variance
as
a
"
safety
valve"
for
the
PCWP
NESHAP.
This
situation
is
an
example
of
"
how
categorical
MACT
standards
that
are
achievable
and
applicable
to
most
facilities
in
a
source
category
or
subcategory
can
be
unreasonably
stringent
and
unachievable
at
a
particular
facility
due
to
fundamental
differences
in
its
situation,"
and
not
including
the
variance
could
result
in
requirements
that
are
unlawfully
stringent.

Response:
We
disagree
that
it
is
necessary
to
include
"
fundamentally
different
factors
variance"
in
the
final
PCWP
rule.
We
are
not
aware
of
any
facilities
that
would
need
such
a
"
safety
valve,"
including
the
wet/
wet
hardboard
facility
that
is
the
subject
of
this
comment
(
for
the
reasons
set
forth
in
response
to
comment
2.3.1.2
above).
EPA
has
not
included
such
variance
provisions
in
MACT
standards
under
section
112(
d)
of
the
CAA,
as
MACT
standards
are
established
to
apply
generally
to
categories
and
subcategories
under
section
112
(
d)(
1)
and
(
2),

and
are
required
to
meet
minimum
stringency
levels
under
section
112
(
d)(
3).
Moreover,
sections
112(
i)(
1)
and
(
3)
impose
compliance
deadlines
that
apply
to
"
any"
new
or
reconstructed
source
and
allow
"
no
person"
operating
an
existing
source
to
violate
a
MACT
standard.
As
a
result,

CAA
section
112
does
not
provide
authority
for
the
commenter's
requested
"
variance"
provision.

To
maximize
flexibility,
the
final
PCWP
rule
includes
three
sets
of
compliance
options
(
six
add­
on
APCD
compliance
options,
PBCOs,
and
emissions
averaging)
and
many
alternative
methods
for
emissions
testing
and
capture
efficiency
determination.
In
addition,
to
the
extent
any
individual
source
demonstrates
a
need
for
more
time
to
install
controls
to
meet
a
MACT
standard,
section
112(
i)(
3)(
B)
provides
for
specific
extensions
to
be
granted
by
permitting
authorities,
and
section
112(
i)(
4)
allows
the
President
to
grant
temporary
exemptions
to
sources
in
cases
where
implementing
technology
is
not
available
and
the
exemption
is
in
the
national
security
interests
of
the
United
States.
Congress
provided
for
no
other
type
of
"
variance"
from
MACT.

2.3.1.4
Comment:
Commenter
IV­
D­
13
requested
that
further
consideration
be
given
to
low­
temperature
OSB
strand
conveyor
dryers.
The
commenter
stated
that
the
current
(
proposed)
2­
56
definition
of
a
strand
dryer
is
not
specific
enough
to
determine
if
the
low­
temperature
OSB
dryers
fall
under
the
general
category
of
strand
dryers,
so
a
separate
definition
should
be
included
for
them
in
section
63.2292
(
What
definitions
apply
to
this
subpart?).
Also,
since
these
conveyor
strand
dryers
emit
less
HAP
than
rotary
strand
dryers
and
have
been
recognized
as
BACT
in
Minnesota,
the
commenter
contended
that
they
should
be
recognized
accordingly
and
exempted
from
section
63.2240
(
What
are
the
compliance
options
and
operating
requirements
and
how
must
I
meet
them?).
The
commenter
noted
that
the
12
conveyor
dryers
used
by
their
company
have
three
drying
zones,
each
with
its
own
heating
system
and
exhaust
vent.
When
drying
hardwoods,
no
VOC
control
is
required;
however,
when
drying
pine,
zones
1
and
2
are
controlled.
Zone
3
serves
as
a
final
conditioning
zone
and
is
exhausted
to
the
atmosphere
without
need
for
VOC
control.
The
commenter
stated
that
preliminary
HAP
emission
test
data
for
drying
southern
yellow
pine
indicates
that
the
strand
dryer
production­
based
emission
limit
(
PBEL)
may
be
achievable.
The
commenter
suggested
that
EPA
should
either
include
work
practice
requirements
for
temperature
control
of
low­
temperature
OSB
dryers
or
allow
facilities
operating
these
dryers
to
use
a
combination
of
PBELs
and
add­
on
compliance
options.

Response:
The
final
rule
does
not
allow
use
of
an
add­
on
APCD
to
meet
the
PBCOs
(
formerly
known
as
PBELs),
nor
does
the
final
rule
allow
combination
of
the
PBCOs
and
add­
on
compliance
options
(
e.
g.,
PBCO
for
exhaust
from
one
dryer
zone
and
one
of
the
six
add­
on
compliance
options
for
the
other
two
zones).
The
PBCO
was
developed
for
and
applies
to
the
entire
process
unit.

In
light
of
the
concerns
expressed
by
the
commenter,
we
reviewed
our
emissions
data
and
MACT
analysis
for
conveyor
strand
dryers.
The
MACT
analysis
we
conducted
at
proposal
treated
conveyor
strand
dryers
as
a
separate
equipment
group
from
rotary
strand
dryers.
We
noted
that
rotary
strand
dryers
operate
at
much
higher
inlet
temperatures
(
often

900
°
F)
than
do
conveyor
dryers
(
typically
<
400
°
F),
and
rotary
dryers
provide
greater
agitation
of
the
wood
strands
than
do
conveyor
dryers.
As
a
result,
the
emissions
from
conveyor
dryers
are
lower
than
the
emissions
from
rotary
strand
dryers.
The
emissions
test
data
we
have
for
conveyor
dryers
(
only
formaldehyde
and
THC
data
are
available)
indicate
that
formaldehyde
emissions
from
conveyor
dryers
are
one
to
two
orders
of
magnitude
less
than
for
rotary
strand
dryers.
The
THC
emissions
are
also
lower
for
conveyor
dryers
than
for
rotary
dryers.
Our
MACT
analysis
for
2­
57
conveyor
dryers
at
proposal
concluded
that
three
of
the
eight
conveyor
dryers
used
in
the
United
States
operated
with
process
incineration.
Because
there
are
fewer
than
30
conveyor
strand
dryers,
the
MACT
floor
was
based
on
the
control
level
achieved
by
the
third
best­
controlled
dryer.
Thus,
at
proposal,
we
determined
that
the
MACT
floor
control
system
for
new
and
existing
conveyor
strand
dryers
was
the
emission
reduction
achievable
with
incineration­
based
control.
We
included
one
definition
of
"
strand
dryers"
in
the
proposed
PCWP
rule,
since
MACT
for
both
rotary
and
conveyor
strand
dryers
was
represented
by
incineration­
based
control.

As
pointed
out
by
the
commenter,
conveyor
dryers
have
distinct
zones
with
their
own
heating
system
and
exhaust.
We
reviewed
our
MACT
survey
data
and
learned
that
all
of
the
conveyor
dryers
in
the
United
States
have
three
zones.
Upon
further
scrutiny
of
the
MACT
analysis
at
proposal,
we
learned
that
the
three
conveyor
dryers
that
formed
the
basis
for
the
MACT
floor
at
proposal
were
routing
the
emissions
from
zone
1
only
to
an
onsite
combustion
unit
for
incineration.
The
remaining
five
conveyor
dryers
have
no
HAP
control
(
four
have
an
electrified
filter
bed;
one
routes
80
percent
of
the
exhaust
from
each
zone
to
a
blend
chamber,

which
provides
no
HAP
control,
and
directs
the
remaining
20
percent
of
the
exhaust
to
the
atmosphere).
Thus,
our
conclusions
regarding
the
MACT
floor
for
conveyor
dryers
at
proposal
were
overstated.
Only
zone
1
of
the
third
best­
controlled
conveyor
dryer
has
incineration­
based
control,
as
opposed
to
all
zones.
Therefore,
we
revised
our
analysis
to
reflect
that
the
MACT
floor
for
existing
conveyor
dryers
is
the
emission
reduction
achieved
with
incineration­
based
control
on
zone
1.

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

Beyond­
the­
floor
control
options
for
existing
conveyor
dryers
could
include
incinerationbased
control
on
either
zone
2,
or
zones
2
and
3,
in
addition
to
zone
1.
A
beyond­
the­
floor
control
option
for
new
conveyor
dryers
could
be
incineration­
based
control
of
zone
3
in
addition
to
control
of
zones
1
and
2.
To
analyze
these
beyond­
the­
floor
options,
we
assumed
than
on
2­
58
RTO
would
be
installed
to
control
emissions
from
the
additional
zones
because
the
combustion
unit
used
to
control
emissions
from
zones
1
and/
or
2
may
be
unable
to
handle
the
exhaust
from
additional
zones.
13
We
determined
that
the
environmental
benefit
of
controlling
additional
conveyor
dryer
zones
would
not
justify
the
cost
for
existing
or
new
conveyor
strand
dryers.

2.3.1.5
Comment:
Commenter
IV­
D­
37
requested
that
the
EPA
divide
continuous
and
batch
presses
into
two
different
categories
for
the
purpose
of
this
rule.
The
commenter
argued
that
control
requirements
in
the
rule
were
designed
for
batch
presses,
but
continuous
presses
need
a
different
set
of
capture
and
control
criteria.
The
commenter
provided
information
from
environmental
engineering
firms
on
the
fundamental
differences
between
the
two
types
of
presses,

as
well
as
information
on
continuous
presses
from
suppliers.
The
commenter
noted
that
continuous
presses
are
much
longer
than
batch
presses,
reaching
lengths
of
200
feet,
which
makes
them
difficult
to
completely
enclose.
The
commenter
was
unaware
of
any
continuous
presses
that
have
been
Method
204
certified
as
having
PTEs.
They
stated
that
operational
problems
with
trying
to
enclose
a
continuous
press
include
heat
buildup
leading
to
mechanical
failures,
impaired
visibility
leading
to
undetected
problems
that
may
cause
unscheduled
downtime,
and
an
imbalance
of
heat
on
the
press
due
to
the
extraction
of
air
from
the
enclosure.
The
commenter
further
noted
that
safety
concerns
include
the
fire
risk
from
the
combination
of
heat
accumulation
and
lubrication
fluids,
the
possibility
of
unhealthy
levels
of
HAP
trapped
in
the
enclosure,
and
the
loss
of
mobility
that
could
result
if
workers
have
to
wear
protective
clothing.
The
commenter
noted
that
the
capital
and
operating
costs
of
PTEs
applied
to
continuous
presses
would
exceed
those
associated
with
batch
presses
due
to
the
large
size
of
the
enclosure
and
the
increased
maintenance
costs
resulting
from
heat
build­
up
within
the
enclosure.
In
addition,
the
commenter
provided
volatile
organic
emissions
data
for
one
of
their
continuous
presses
to
demonstrate
that
emissions
from
the
front
stages
are
minimal
and
that
the
"
overwhelming
majority"
of
emissions
are
from
the
last
40
percent
of
the
press
length,
referred
to
as
the
decompression
zone.
The
commenter
contended
that
gathering
the
emissions
from
all
stages
of
the
continuous
press
will
result
in
a
more
dilute
stream,
which
will
be
less
cost­
effective
to
treat,
and
that
the
large
volume
of
exhaust
to
be
treated
would
likely
preclude
the
use
of
biofilters,
which
are
more
practical
for
treating
smaller
volumes
of
air.
In
addition,
because
continuous
presses
have
"
multiple
direct
coupled
emission
extraction
points,"
the
use
of
the
proposed
tracer
gas
method
of
determining
capture
2­
59
efficiency
would
not
be
applicable
(
the
tracer
gas
method
would
only
measure
emissions
not
already
captured
by
the
multiple
direct
extraction
points).

To
remedy
the
situation,
the
commenter
recommended
that
EPA
divide
batch
and
continuous
presses
into
two
different
process
unit
groups
for
the
purpose
of
determining
the
MACT
floor.
Because
there
are
fewer
than
30
continuous
presses,
the
MACT
floor
for
existing
continuous
presses
would
be
determined
based
on
the
average
emissions
limitation
achieved
by
the
five
best­
performing
continuous
presses.
The
commenter
provided
information
to
support
their
contention
that
none
of
the
continuous
presses
achieved
100
percent
capture,
and
suggested
that
the
MACT
floor
for
capture
efficiency
is
80
percent
capture
of
emissions
from
the
decompression
stages.
The
commenter
also
stated
that
the
proposed
emission
limitations
in
Table
1B
of
the
proposed
rule
(
e.
g.,
90
percent
reduction)
should
only
apply
to
the
captured
emissions;

the
commenter
provided
revisions
to
Table
1B
that
would
incorporate
their
suggestion.
Finally,

the
commenter
provided
definitions
of
"
reconstituted
wood
product
batch
press,"
"
reconstituted
wood
product
continuous
press,"
and
"
decompression
stage"
that
could
be
included
in
the
final
PCWP
rule.

Response:
The
MACT
floor
determinations
for
PCWP
equipment
were
based
on
process
units
that
are
similar
with
respect
to
design,
operation,
and
emissions.
We
acknowledge
that
continuous
presses
have
a
different
design
than
multi­
opening
batch
presses.
However,
based
on
the
data
available
to
us,
continuous
presses
have
emissions
that
are
within
the
same
range
as
those
from
batch
presses
on
a
lb/
MSF
basis.
Therefore,
we
believe
it
is
reasonable
to
group
batch
and
continuous
together
for
purposes
of
determining
the
MACT
floor.
The
MACT
floor
for
continuous
presses
would
be
the
same
as
the
MACT
floor
for
batch
presses
regardless
of
whether
batch
and
continuous
presses
were
placed
in
separate
equipment
groups.
As
explained
below,
we
disagree
that
the
MACT
floor
capture
efficiency
for
continuous
presses
is
80
percent
as
suggested
by
the
commenter.

The
commenter
was
incorrect
in
suggesting
that
there
are
no
continuous
presses
with
Method
204
certified
PTEs.
On
the
contrary,
the
two
existing
press
enclosures
in
the
PCWP
industry
identified
as
being
Method
204
certified
surround
continuous
presses.
These
continuous
presses
are
41.5
ft
and
110
ft
long.
Due
to
the
presence
of
these
presses
in
the
industry,
the
MACT
floor
for
new
and
existing
continuous
presses
is
a
total
enclosure
and
incineration­
based
2­
60
control
or
biofilter
regardless
of
whether
or
not
batch
and
continuous
presses
are
treated
as
separate
equipment
groups.
In
addition
to
the
two
presses
with
PTE
mentioned
above,
there
is
a
Method­
204­
certified
PTE
around
a
181­
ft
long
continuous
press
at
a
newer
PCWP
facility;

however,
this
press
has
had
some
operational
problems
associated
with
the
PTE.
It
is
not
clear
if
the
operational
problems
experienced
by
this
181­
ft
long
press
are
the
result
of
poor
PTE
design.

Long
continuous
presses
are
generally
being
installed
at
new
PCWP
facilities,
as
opposed
to
being
retrofit
at
existing
facilities.
Given
that
there
is
at
least
one
long
continuous
press
(
110
ft)
with
a
Method­
204­
certified
PTE
that
has
not
experienced
operational
problems
associated
with
their
press
enclosure,
we
believe
that
wood
products
enclosures
(
as
defined
in
the
final
rule)

can
be
designed
around
long
continuous
presses.
We
recognize
that
higher
cost
may
be
associated
with
wood
products
enclosures
around
long
continuous
presses
than
for
batch
presses,

but
the
CAA
does
not
allow
us
to
consider
cost
at
the
MACT
floor
control
level.

Enclosures
greater
then
200
ft
in
length
are
not
unheard
of.
Such
enclosures
are
common
in
the
printing/
publishing
industry.
However,
we
do
recognize
there
are
differences
in
the
enclosures
used
in
the
printing/
publishing
industry
and
the
PCWP
industry.
Although
not
cyclical
in
operation
like
batch
presses,
continuous
presses
are
heated
operations
and
may
also
have
internal
pressurization
issues.
14
There
have
been
operational
problems
associated
with
heat
buildup
inside
the
enclosure
for
the
181­
ft
long
continuous
press.
Therefore,
we
believe
it
is
appropriate
for
the
same
definition
of
"
wood
products
enclosure"
promulgated
for
batch
presses
to
apply
to
long
continuous
presses
as
well
(
as
opposed
to
Method
204
certification).
As
discussed
in
more
detail
in
section
2.3.2.8,
the
definition
of
wood
products
enclosure
included
in
the
final
PCWP
rule
is
slightly
different
from
the
Method
204
PTE
design
criteria,
and
including
this
definition
in
the
final
PCWP
rule
eliminates
the
need
for
Method
204
certification
of
wood
products
enclosures.
Enclosures
meeting
the
definition
of
"
wood
products
enclosure"
in
the
final
PCWP
rule
are
assumed
for
all
practical
purposes
to
achieve
100
percent
capture.

As
an
alternative
to
wood
products
enclosures,
the
final
PCWP
rule
allows
use
of
partial
wood
products
enclosures.
The
capture
efficiency
of
the
partial
wood
products
enclosure
must
be
tested
using
either
the
tracer
gas
method
included
in
Appendix
A
of
the
final
PCWP
rule,
Methods
204
and
204A­
F,
or
an
alternative
method
that
is
approved
by
the
Administrator.
We
agree
with
the
commenter
that
the
tracer
gas
method
would
be
inappropriate
for
some
configurations
of
2­
61
partial
wood
products
enclosures
around
long
continuous
presses
(
e.
g.,
if
there
are
no
sampling
locations
that
can
be
used
to
distinguish
between
the
HAP
collected
by
the
pick­
up/
extraction
points
and
the
HAP
collected
by
exhaust
fans
in
the
general
press
area).
However,
the
tracer
gas
method
could
be
used
for
other
press
exhaust
capture
configurations
(
e.
g.,
for
a
partial
enclosure
covering
the
length
of
the
press
with
exhaust
ductwork
that
allows
for
separate
sampling
of
the
pick­
up/
extraction
point
exhaust
and
exhaust
from
inside
the
partial
enclosure).
In
addition,
the
final
rule
includes
Methods
204
and
204A­
F
for
testing
of
partial
wood
products
enclosures
whereby
a
Method
204
temporary
total
enclosure
(
TTE)
could
be
constructed
around
the
press
and
a
gas/
gas
method
such
as
Method
204D
could
be
used
to
determine
capture
efficiency.

2.3.1.6
Comment:
Commenter
IV­
D­
04
asked
for
clarification
of
the
definition
of
an
engineered
wood
products
(
EWP)
press
and
stated
that
the
EPA
classification
of
certain
presses
as
EWP
presses
may
not
always
be
valid.
The
commenter
was
aware
of
at
least
one
facility
in
Minnesota
that
is
a
major
source
of
HAP
and
that
operates
a
press
that
could
fit
the
definition
of
an
EWP
products
press.
The
facility
in
question
operates
an
LSL
press
that
the
commenter
contended
is
very
similar
in
operation
to
an
OSB
press.
The
commenter
suggested
that,
instead
of
assuming
that
these
presses
have
very
small
amounts
of
HAP,
the
emissions
should
be
tested
to
ensure
that
there
are
no
HAP
before
exempting
these
presses
from
emission
control
requirements
through
classification
as
EWP
presses.

Response:
Engineered
wood
product
presses
are
not
defined
in
the
regulatory
text
of
the
PCWP
NESHAP,
but
were
mentioned
in
the
preamble
to
the
proposed
rule.
Engineered
wood
products
presses
include
presses
at
LVL,
PSL,
LSL,
glulam,
and
I­
joist
plants.
Plants
manufacturing
engineered
wood
products
such
as
LVL,
PSL,
and
LSL
form
and
press
(
often
with
microwave
or
radio­
frequency)
billets
that
are
much
thicker
than
panels.
Glulam
plants
use
clamps
to
press
laminated
beams
at
room
temperature.
I­
joist
plants
do
not
use
presses,
but
use
curing
chambers
to
cure
the
adhesive
in
the
I­
joists.
The
emissions
from
EWP
presses
and
curing
devices
are
much
lower
then
the
total
annual
HAP
emissions
from
most
panel
presses.
Given
the
differences
in
design
and
annual
HAP
emissions,
we
treated
EWP
presses
and
panel
presses
separately
for
purposes
of
determining
the
MACT
floor.
Emissions
from
all
of
the
EWP
presses
and
curing
devices
in
the
PCWP
industry
are
uncontrolled;
therefore,
the
MACT
floor
for
new
and
existing
engineered
wood
product
presses
is
no
emission
reduction.
3
2­
62
The
commenter
questions
whether
LSL
presses
should
be
grouped
with
OSB
presses.

The
LSL
and
OSB
manufacturing
processes
are
somewhat
similar
in
that
whole
logs
are
debarked
and
sliced
into
wood
strands,
and
then
the
wood
strands
are
dried
using
rotary
or
conveyor
strand
dryers.
For
purposes
of
determining
the
MACT
floor
for
dryers,
we
included
OSB
and
LSL
rotary
strand
dryers
in
the
same
equipment
group
because
these
dryers
are
of
the
same
design
and
have
similar
emissions.
Similarly,
we
included
conveyor
strand
dryers
used
to
make
OSB
and
LSL
in
the
same
equipment
group.
Following
drying
and
resin
application,
LSL
and
OSB
strands
are
formed
into
a
mat
that
is
inserted
into
the
press.
We
differentiated
among
OSB
and
LSL
presses
for
purposes
of
determining
the
MACT
floor
because
of
design
differences
and
differences
in
the
emissions
from
OSB
and
LSL
presses.
The
presses
used
for
LSL
manufacture
are
singleopening
presses,
roughly
8
ft
long
and
4
ft
wide
(
32
ft2
press
area).
15
The
LSL
press
compacts
a
thick
mat
of
strands
into
a
billet
at
can
be
up
to
5.5
in
thick.
2
Multi­
opening
presses
with
10
to
28
openings
and
an
average
pressing
area
of
166
ft2
per
opening
are
most
typically
used
for
OSB
manufacture;
no
single­
opening
batch
presses
are
used
to
make
OSB.
The
OSB
panels
are
pressed
to
an
average
thickness
of
0.6
in.
10
Our
MACT
survey
data
indicate
that
the
billet
volume
pressed
annually
in
LSL
presses
ranges
from
4.9
to
5.4
million
ft3/
yr.
15
Our
data
show
that
OSB
press
throughput
ranges
from
172
to
380
MMSF
3/
8"
of
panels
per
year
(
equivalent
to
5.4
to
12
million
ft3/
yr).
10
In
addition
to
having
lower
throughput,
our
data
also
indicate
that
LSL
presses
have
lower
emissions
that
OSB
presses
on
a
lb/
1000
ft3
basis.
Our
data
show
that
emissions
of
formaldehyde
from
an
LSL
press
are
two
orders
of
magnitude
less
than
the
emissions
from
OSB
presses.
Given
the
design
and
size
differences
between
LSL
and
OSB
presses
and
the
difference
in
emissions,
we
maintain
that
it
would
not
be
appropriate
to
group
LSL
presses
with
OSB
presses
(
and
other
reconstituted
wood
products
presses).

2.3.2
Basis
for
MACT
floor
2.3.2.1
Comment:
Commenters
IV­
D­
27,
IV­
D­
21,
and
IV­
D­
56
agreed
that
EPA
properly
followed
section
112(
d)
of
the
CAA
in
establishing
the
PCWP
MACT
floor
and
supported
the
level
of
control
chosen
by
EPA
(
i.
e.,
90
percent
control
level
for
some
PCWP
process
units
and
no
reduction
for
others).
According
to
the
commenters,
EPA
correctly
based
the
MACT
floor
on
process
units
rather
than
entire
facilities
because
of
the
available
data
and
the
nature
of
these
facilities.
Because
pollution
control
techniques
are
not
widely
used
throughout
the
2­
63
industry
and
the
results
are
not
universal,
the
MACT
floor
appropriately
focuses
on
add­
on
control
techniques.
According
to
the
commenters,
EPA
correctly
concluded
that
oxidizers
and
biofilters
resulted
in
the
best
and
most
consistent
emission
control
and
used
the
94th
percentile
to
determine
the
best­
performing
control
device
for
each
process
unit
group.
The
commenters
stated
that
EPA's
decision
to
group
the
data
from
all
of
the
oxidizers
and
biofilters
together
in
order
to
determine
the
MACT
floor
was
appropriate
given
that
the
available
data
for
some
process
unit
groups
were
limited
and
not
universally
compatible.
The
commenters
supported
EPA's
conclusion
that
the
typical
reduction
in
HAP
emissions
by
oxidizers
and
biofilters
was
90
percent,
and
that
well­
maintained
control
devices
generally
only
achieve
less
than
90
percent
reduction
if
the
inlet
stream
has
a
low
HAP
concentration.
The
commenters
also
supported
the
inclusion
of
concentration­
based
limits
at
the
outlet
of
the
control
device
that
similarly
reflect
this
90
percent
removal
efficiency.
The
commenters
further
stated
that
the
MACT
floor
should
not
be
set
higher
than
90
percent
for
two
reasons.
First,
there
are
not
enough
data
to
support
the
conclusion
that
the
control
devices
are
regularly
capable
of
achieving
greater
than
90
percent
reduction.
Second,
regardless
of
how
well
an
oxidizer
is
installed
and
maintained,
the
inlet
concentration
to
the
oxidizer
is
the
factor
that
has
the
most
effect
on
the
reduction
efficiency.

The
commenters
noted
that
"
at
high
pollutant
loadings,
most
oxidizers
can
easily
achieve
90
percent
removal,
but
at
lower
pollutant
loadings,
even
the
same
well­
performing
oxidizer
will
have
a
lower
removal
efficiency."
The
commenters
asserted
that
the
90
percent
removal
levels
were
measured
under
"
peak
operating
levels,"
so
both
the
inlet
HAP
concentrations
and
the
removal
efficiencies
were
fairly
high.
The
commenters
noted
that
when
EPA
established
a
floor
of
90
percent
removal
efficiency,
it
recognized
that
control
devices
will
be
able
to
achieve
both
higher
and
lower
removal
efficiencies.
The
commenters
stated
that
requiring
a
removal
efficiency
higher
than
90
percent
would
penalize
sources
that
have
low
inlet
pollutant
concentrations.

"[
H]
aving
a
low
inlet
concentration
may
show
that
the
source
was
able
to
utilize
pollution
prevention
techniques
to
minimize
emissions,
an
activity
which
should
be
encouraged,
not
penalized."

In
contrast
to
the
previous
three
commenters,
commenter
IV­
D­
11
disagreed
with
EPA's
determination
of
an
across­
the­
board
MACT
floor
level
of
90
percent
control.
Although
the
commenter
supports
EPA's
use
of
the
median
of
the
top
12
percent
of
sources
(
94th
percentile),
2­
64
the
commenter
notes
that
the
preamble
does
not
state
that
the
90
percent
reduction
of
THC,

formaldehyde,
or
methanol
represents
the
94th
percentile.
The
commenter
pointed
out
that
the
preamble
does
state
that
incineration­
based
controls
and
biofilters
showed
THC,
methanol,
and
formaldehyde
emissions
reductions
"
equal
to
or
greater
than
90
percent."
The
commenter
further
noted
that
the
BID
shows
average
emissions
reduction
data,
not
median,
for
THC,

methanol,
and
formaldehyde
at
97
percent,
89
percent,
and
95
percent,
respectively.
The
commenter
contended
that
this
"
one
size
fits
all
approach"
of
choosing
a
90
percent
reduction
level
is
not
appropriate,
and
EPA
should
reevaluate
the
94th
percentile
for
the
individual
compliance
options
for
add­
on
controls.
The
commenter
agreed
that
concentration­
based
compliance
options
were
needed
as
an
alternative
to
the
percent
reduction
options
for
those
sources
with
dilute
emission
streams.
The
commenter
also
recommended
that
EPA
reserve
the
percent
reduction
options
for
those
sources
with
more
concentrated
emissions
streams
by
implementing
a
minimum
inlet
stack
concentration
level
for
sources
meeting
the
percent
reduction
compliance
options.

Response:
To
determine
the
MACT
floor
control
level,
we
reviewed
available
data
on
pollution
prevention
techniques
and
the
performance
of
add­
on
control
devices
and
identified
those
add­
on
control
systems
that
were
best
at
reducing
HAP
emissions.
We
were
unable
to
identify
pollution
prevention
measures
that
can
be
universally
applied
across
the
industry,
and
we
had
no
information
on
the
degree
of
emissions
reduction
that
can
be
achieved
through
pollution
prevention
measures.
Therefore,
our
MACT
analysis
focused
on
the
performance
of
add­
on
control
devices.
Total
hydrocarbon,
formaldehyde,
and
methanol
were
considered
in
our
analysis
of
control
device
performance
because
these
three
pollutants
are
the
most
prevalent
pollutants
emitted
from
the
PCWP
industry
and
represent
the
majority
of
the
available
data
on
control
device
performance.
We
concluded
that
only
two
types
of
add­
on
APCDs
consistently
and
continuously
reduced
HAP
emissions:
incineration­
based
controls
(
including
RTOs,
RCOs,
and
incineration
of
pollutants
in
onsite
process
combustion
equipment)
and
biofilters
(
used
to
control
PCWP
press
emissions).
The
performance
data
for
the
incineration­
based
controls
and
biofilters
showed
methanol
and
formaldehyde
emissions
reductions
equal
to
or
greater
than
90
percent,
except
in
those
cases
where
the
pollutant
loadings
of
the
emission
stream
entering
the
control
systems
were
very
low.
The
performance
data
for
THC
showed
that
incineration­
based
control
systems
could
2­
65
achieve
THC
emissions
reductions
equal
to
or
greater
than
90
percent.
The
average
THC
emissions
reductions
achieved
with
biofilters
was
about
80
percent.
However,
biofilters
can
achieve
HAP
emissions
reductions
equal
to
or
greater
than
90
percent.
Both
incineration­
based
controls
and
biofilters
can
achieve
identical
formaldehyde
and
methanol
emissions
reductions.

We
ranked
the
process
units
within
each
process
unit
group
according
to
the
HAP
control
devices
that
were
applied.
For
process
unit
groups
with
at
least
30
sources,
we
based
the
MACT
floor
on
the
emission
level
achieved
by
the
process
unit
and
its
control
system
that
is
at
the
bottom
of
the
top
6
percent
of
the
best­
performing
process
units
(
i.
e.,
the
94th
percentile).
For
those
process
unit
groups
where
there
were
fewer
than
30
but
at
least
five
process
units,
the
emission
level
achieved
by
the
process
unit
and
its
control
system
that
is
the
median
of
the
best­
performing
five
sources
(
i.
e.,
the
"
number
3"
source)
represents
the
MACT
floor
level
of
control.
When
a
process
unit
group
had
fewer
than
five
process
units,
we
determined
the
appropriate
control
technology
based
on
the
control
technology
used
by
the
majority
of
the
process
units
in
the
process
unit
group.

When
we
ranked
the
process
units,
we
treated
process
units
equipped
with
any
type
of
incineration­
based
control
system
or
biofilters
as
being
equivalent
with
respect
to
their
potential
to
reduce
HAP
emissions.
We
ranked
the
process
units
by
control
device
rather
than
actual
unit­
specific
emissions
reductions
because
we
have
limited
inlet/
outlet
data
on
which
to
calculate
control
efficiency.
We
are
not
aware
of
any
significant
design
or
operational
differences
among
control
systems
or
factors
other
than
the
type
of
control
system
used
that
would
affect
the
ranking
of
process
units.
For
example,
there
are
approximately
303
softwood
veneer
dryers
nationwide,

and
HAP
emissions
from
approximately
64
of
these
dryers
(
21
percent
nationwide)
are
controlled
using
incineration­
based
control
systems.
The
HAP
emissions
from
the
remainder
of
the
softwood
veneer
dryers
are
uncontrolled.
In
this
example,
the
94th
percentile
is
represented
by
the
control
system
applied
to
the
softwood
veneer
dryer
ranked
at
number
18
(
18/
303
=
6
percent),

which
is
an
incineration­
based
control
system.
We
only
have
control
efficiency
data
for
nine
veneer
dryers.
Data
are
not
available
for
the
18th
ranked
dryer.
In
order
to
associate
a
control
efficiency
with
the
18th
ranked
dryer,
it
was
necessary
to
conclude
that
the
control
efficiency
achieved
by
the
incineration­
based
controls
for
which
we
had
data
also
represented
the
control
efficiency
of
the
18th
ranked
veneer
dryer.
For
the
reasons
discussed
in
the
paragraphs
below,
we
2­
66
believe
this
conclusion
regarding
the
performance
of
APCDs
is
very
appropriate
for
incinerationbased
controls
and
biofilters
used
to
control
PCWP
process
units.
As
in
the
softwood
veneer
dryer
example,
we
were
able
to
identify
the
APCD
but
were
unable
to
associate
a
specific
control
efficiency
with
the
94th
percentile
unit
(
or
number
3
unit
for
process
groups
of
less
than
5
sources)

for
most
of
the
PCWP
process
unit
groups
because
control
efficiency
data
were
generally
unavailable
for
the
94th
percentile
(
or
number
3)
ranked
unit.
Thus,
ranking
process
units
based
on
actual
emissions
reduction
as
suggested
by
commenter
IV­
D­
11
is
not
possible.
We
believe
that
ranking
process
units
based
on
actual
emissions
reduction
(
as
opposed
to
ranking
by
APCD
type)
is
unnecessary
for
the
PCWP
source
category
for
the
reasons
described
below.

For
the
purpose
of
establishing
the
performance
level
of
the
MACT
floor
control
systems,

we
decided
to
group
all
of
the
available
data
on
incineration­
based
controls
and
biofilters
together.
When
we
reviewed
the
available
data,
we
found
that
the
data
do
not
show
any
correlation
between
the
types
of
process
units
controlled
(
e.
g.,
rotary
dryers
vs.
presses)
and
the
performance
of
the
HAP
control
systems.
That
is,
the
HAP
control
systems
can
achieve
the
same
level
of
control
(
e.
g.,
outlet
concentration,
percent
reduction)
regardless
of
the
type
of
process
unit
controlled.
Some
of
the
control
systems
treat
HAP
emissions
from
multiple
types
of
process
units,
such
as
tube
dryers,
reconstituted
panel
presses,
and
board
coolers.
In
those
cases,
separate
determinations
of
the
performance
of
the
control
system
on
emissions
from
each
type
of
process
unit
were
not
possible.
Also,
limited
or
no
inlet/
outlet
data
were
available
for
the
control
systems
applied
to
the
process
units
in
some
groups.
Also,
in
some
cases,
it
was
not
possible
to
directly
compare
the
performance
of
different
control
systems
because
data
were
not
available
for
the
same
pollutant.
For
example,
for
one
RTO,
we
might
only
have
THC
emissions
data,
and
for
another
RTO,
we
might
only
have
formaldehyde
data.
Our
ability
to
compare
the
performance
of
the
different
types
of
incineration­
based
control
systems
with
each
other
and
with
biofilters
was
also
hampered
by
variability
in
uncontrolled
emissions
being
treated
by
the
different
control
systems.
For
example,
the
available
THC
concentration
data
for
the
inlet
of
the
control
systems
ranged
from
as
low
as
45
ppmvd
to
as
high
as
5,100
ppmvd.
With
the
exception
of
some
control
systems
with
lower
pollutant
inlet
concentrations,
the
available
data
for
incineration­
based
controls
and
biofilters
show
that
these
control
systems
can
achieve
THC,
methanol,
or
formaldehyde
emissions
reductions
greater
than
or
equal
to
90
percent.
2­
67
To
account
for
the
variability
in
the
type
and
amount
of
HAP
in
the
uncontrolled
emissions
from
the
various
process
units
and
the
effect
of
this
variability
on
control
system
performance,
we
decided
to
base
the
MACT
floor
performance
level
on
all
three
of
the
pollutants
we
analyzed
and
include
maximum
concentration
levels
in
the
outlet
of
the
control
systems
as
an
alternative
to
emissions
reductions.
The
MACT
floor
performance
level
is
a
90
percent
reduction
in
THC
or
methanol
or
formaldehyde
emissions.
The
maximum
concentration
level
in
the
outlet
of
the
MACT
floor
control
system
is
20
ppmvd
for
THC,
1
ppmvd
for
methanol,
or
1
ppmvd
for
formaldehyde.
We
chose
20
ppmvd
as
the
alternative
maximum
concentration
for
THC
because
20
ppmvd
represents
the
practical
limit
of
control
for
THC.
We
chose
1
ppmvd
as
the
maximum
outlet
concentration
for
both
methanol
and
formaldehyde
because
this
concentration
is
achievable
by
MACT
control
systems
and
the
method
detection
limits
for
these
compounds
using
the
NCASI
impinger/
canister
method
(
NCASI
Method
IM/
CAN/
WP­
99.01,
proposed
to
be
incorporated
by
reference
in
today's
proposed
rule)
are
less
than
1
ppmvd.

We
acknowledge
that
some
incineration­
based
controls
and
biofilters
achieve
greater
than
90
percent
reduction
in
formaldehyde,
methanol,
or
THC.
However,
we
also
recognize
that
the
percent
reduction
achieved
varies
according
to
pollutant
inlet
concentration,
as
the
commenters
have
stated.
Other
unknown
factors
may
also
cause
variability
in
control
system
performance.
In
addition,
there
is
variability
related
to
emission
measurements.
For
example,
we
have
THC
percent
reduction
data
for
an
RTO
used
to
control
emissions
from
three
tube
dryers
and
a
press
at
an
MDF
plant
for
two
emission
tests
conducted
at
different
times.
In
1996,
the
RTO
achieved
92.7
percent
reduction
of
THC,
and
in
1998
the
same
RTO
achieved
98.9
percent
reduction
of
THC.
In
addition,
we
have
emissions
test
data
for
the
same
process
unit
and
control
system
for
multiple
years,
and
these
data
show
different
emission
factors,
indicating
that
variability
is
inherent
within
each
process
unit
and
control
system
combination.
We
disagree
with
commenter
IV­
D­
11
that
a
minimum
inlet
stack
concentration
is
needed
for
sources
meeting
the
percent
reduction
compliance
options
because
sources
with
low
inlet
concentrations
generally
would
have
more
difficulty
meeting
the
90
percent
reduction
requirement.

2.3.2.2
Comment:
Commenters
IV­
D­
27,
IV­
D­
27,
IV­
D­
21,
and
IV­
D­
56
concurred
with
the
no
emissions
reduction
MACT
floor
determinations
made
for
certain
process
units,

including
existing
fiberboard
mat
dryers,
existing
press
pre­
dryers,
and
existing
reconstituted
2­
68
wood
product
board
coolers.
The
commenters
stated
that
the
method
EPA
used
to
come
to
that
conclusion
is
proper
under
the
CAA;
Cement
Kiln
Recycling
Coalition
v.
EPA,
255
F.
3d
855
(
D.
C.
Cir.
2001);
and
National
Lime
Association
v.
EPA,
233
F.
3d
625
(
D.
C.
Cir.
2000).
First,

the
MACT
floor
is
appropriately
set
based
on
emissions
reductions
achieved
by
the
bestperforming
sources,
rather
than
on
emissions
data
alone,
and
is
consistent
with
section
112(
d)
of
the
CAA.
The
commenters
cited
two
provisions
of
the
CAA
and
language
from
a
D.
C.
Circuit
ruling
that
support
that
point.
Second,
EPA
identified
the
best­
performing
process
units
and
determined
that
neither
the
average
of
the
best­
performing
12
percent
of
sources
nor
the
one
bestperforming
source
was
achieving
emissions
reduction
through
the
use
of
an
emissions
control
system.
Therefore,
the
MACT
floor
was
set
at
no
emissions
reduction
for
both
existing
and
new
sources.
The
commenters
noted
that
§
112(
d)(
3)(
A)
of
the
CAA
clearly
states
that
the
maximum
degree
of
reduction
for
existing
sources
of
HAP
emissions
shall
not
be
less
stringent
than
"
the
average
emission
limitation
achieved
by
the
best
performing
12
percent
of
the
existing
sources
(
for
which
the
Administrator
has
emissions
information)[.]"
The
commenters
asserted
that,

although
pollution
prevention
techniques
are
used
at
some
facilities,
they
do
not
achieve
consistent
results
and
cannot
be
included
in
the
MACT
floor.
Because
the
median
best­
controlled
source
did
not
use
control
technology
and
because
EPA
has
identified
no
other
universally
applicable
variable
that
certain
PCWP
process
units
can
employ
to
reduce
HAP
emissions,
the
commenters
contended
that
EPA
properly
set
the
MACT
floor
at
no
emissions
reduction.
The
commenters
also
noted
that
EPA's
request
for
comment
on
the
MACT
floor
for
miscellaneous
coating
operations
and
wastewater
operations
included
concern
about
insufficient
data,
but
the
commenters
agreed
that
the
floor
is
"
no
control,"
and
that
this
accurately
reflects
current
PCWP
facility
practices.

The
commenters
further
noted
that
EPA
properly
addressed
the
concerns
noted
by
the
D.
C.
Circuit
in
Cement
Kiln
Recycling
Coalition
v.
EPA,
255
F.
3d
855
(
D.
C.
Cir.
2001)
(
Cement
Kiln)
and
National
Lime
Association
v.
EPA,
233
F.
3d
625
(
D.
C.
Cir.
2000)
(
National
Lime).

According
to
the
commenters,
in
Cement
Kiln,
EPA
identified
the
median
of
the
best­
performing
12
percent
of
sources
and
set
the
MACT
floor
at
the
worst
emission
level
achieved
by
any
source
using
the
same
emission
control
technology
that
was
used
by
most
of
the
top
12
percent.
The
D.
C.
Circuit
ruled
that
this
MACT
floor
was
not
a
valid
estimate
of
the
performance
of
the
best­
2­
69
performing
sources
in
practice.
EPA
assumed
that
control
technology
was
the
only
way
to
reduce
HAP
emissions,
but
other
factors
were
influencing
the
reduction
as
well.
Some
of
those
factors
could
have
been
inadequate
maintenance
or
inferior
operating
practices,
in
which
case
the
worstperforming
sources
would
certainly
not
be
an
estimate
of
the
best­
performing
sources
under
the
most
adverse
conditions.
The
court
noted
that
if
EPA
could
demonstrate
that
MACT
technology
significantly
controlled
emissions,
and
that
factors
other
than
the
control
had
a
negligible
effect,

the
MACT
approach
could
be
a
reasonable
means
of
satisfying
the
statute's
requirements.
The
commenters
noted
that,
in
developing
the
PCWP
rule,
EPA
again
followed
the
MACT
approach,

determining
that
the
average
of
the
best­
performing
12
percent
of
certain
existing
PCWP
process
units
did
not
reflect
the
use
of
any
control
technology.
EPA
further
determined
that
no
other
universally
applicable
variables
would
affect
HAP
emissions,
a
determination
it
did
not
make
in
Cement
Kiln.
For
the
PCWP
process
units
for
which
the
MACT
floor
is
90
percent,
EPA
again
determined
that
there
are
no
other
factors
that
significantly
impact
the
removal
efficiencies
of
the
add­
on
controls.
For
these
reasons,
the
commenters
contended
that
EPA
corrected
the
mistakes
made
in
the
Cement
Kiln
situation
when
developing
the
PCWP
MACT.

The
commenters
noted
that
in
National
Lime,
EPA
followed
a
similar
MACT
approach
to
Cement
Kiln,
but
it
had
insufficient
data
for
some
HAP.
If
EPA
found
an
insufficient
number
of
plants
in
its
database
controlling
a
particular
HAP
with
pollution
control
technology,
it
determined
that
the
emission
floor
was
"
no
control."
The
D.
C.
Circuit
ruled
that
if
EPA
did
not
consider
alternative
pollution­
reducing
measures,
it
could
not
decline
to
set
emissions
standards
on
the
grounds
that
the
best­
performing
sources
did
not
use
control
technology.

"
The
technologies,
practices
or
strategies
which
are
to
be
considered
in
setting
emission
standards
under
this
subsection
go
beyond
the
traditional
end­
of­
the­
stack
treatment
or
abatement
system.
The
Administrator
is
to
give
priority
to
technologies
or
strategies
which
reduce
the
amount
of
pollution
generated
through
process
changes
or
the
substitution
of
materials
less
hazardous.
Pollution
prevention
is
to
be
the
preferred
strategy
wherever
possible."
(
S.
Rep.
No.
101­
228,
168
(
1989))
(
emphasis
added).

The
commenters
stated
that
the
D.
C.
Circuit
ruling
in
National
Lime
does
not
prevent
EPA
from
setting
a
MACT
floor
of
no
emissions
reductions,
it
simply
means
that
EPA
must
examine
all
methods
of
removing
HAP
before
setting
a
floor.
According
to
the
commenters,
in
developing
the
PCWP
rule,
EPA
did
look
at
pollution
prevention
measures
and
other
approaches
to
determining
the
MACT
floor,
but
found
none
that
are
universally
applicable
to
reduce
HAP
2­
70
emissions.
Therefore,
the
commenters
contended
that
EPA
is
permitted
by
statute
to
set
the
MACT
floor
for
existing
sources
at
any
level
not
less
stringent
than
the
average
limitation
achieved
by
the
best­
performing
12
percent,
even
if
that
floor
level
reflects
no
reduction
in
emissions.

Commenter
IV­
D­
26
disagreed
with
the
four
previous
commenters
and
stated
that
not
establishing
emission
reduction
limits
for
operations
like
miscellaneous
coating
and
wastewater
is
unlawful.
The
commenter
argued
that
EPA
should
not
make
its
MACT
floor
decisions
based
on
"
insufficient
information"
and
the
fact
that
there
is
no
current
control
in
place.
The
commenter
stated
that,
according
to
National
Lime
Ass'n
v.
EPA,
233
F.
3d
625,
633­
634
(
D.
C.
Cir.
2000),

EPA
cannot
set
a
MACT
floor
of
"
no
control"
because
it
believes
that
a
pollutant
is
not
controlled
by
any
particular
technology.
The
commenter
stated
that
EPA
failed
to
explain
why
insufficient
data
are
available
and
what
additional
steps
could
be
taken
to
obtain
the
necessary
data.
For
these
reasons,
the
commenter
stated
that
EPA's
proposed
MACT
floor
levels
of
"
no
control"
are
"
unlawful,
arbitrary,
and
capricious."

Response:
For
those
process
units
not
required
to
meet
the
control
requirements
in
the
final
PCWP
rule,
we
determined
that
(
1)
the
MACT
floor
level
of
control
is
no
emissions
reductions
and
beyond­
the­
floor
control
options
are
too
costly
to
be
feasible;
or
(
2)
insufficient
information
is
available
to
conclude
that
the
MACT
floor
level
of
control
is
represented
by
any
emissions
reductions
(
miscellaneous
coating
operations
and
wastewater
operations).
We
based
our
MACT
floor
determinations
for
PCWP
emission
sources
on
the
presence
or
absence
of
an
add­
on
APCD
because
we
are
not
aware
of
any
demonstrated
pollution
prevention
techniques
that
can
be
universally
applied
across
the
industry,
and
we
have
no
information
on
the
degree
of
emissions
reduction
that
can
be
achieved
through
pollution
prevention
measures.
Therefore,
to
our
knowledge,
the
use
of
add­
on
APCD
is
the
only
way
in
which
PCWP
sources
can
currently
limit
HAP
emissions,
and
the
only
way
to
identify
the
MACT
floor
for
these
sources
is
to
identify
a
level
that
corresponds
to
that
achieved
by
the
use
of
add­
on
APCD.
When
determining
the
MACT
floor,
we
ranked
the
process
units
by
control
device
rather
than
by
actual
unit­
specific
emissions
reductions
because
we
have
limited
inlet/
outlet
data
(
i.
e.,
inlet/
outlet
data
are
not
available
for
every
controlled
process
unit)
on
which
to
calculate
control
efficiency
(
see
also
the
response
to
comment
No.
2.3.2.1
above).
Based
on
the
available
information,
we
are
not
aware
2­
71
of
any
significant
design
or
operational
differences
among
each
type
of
control
system
evaluated
that
would
affect
the
ranking
of
process
units.
Furthermore,
we
are
not
aware
of
factors
other
than
the
type
of
control
system
used
that
would
significantly
affect
the
ranking
of
process
units.

An
analysis
of
the
available
emissions
data
does
not
reveal
any
process
variables
that
can
be
manipulated
(
without
altering
the
product)
to
achieve
a
quantifiable
reduction
in
emissions.
13
Ranking
process
units
according
to
control
device,
we
determined
that
the
MACT
floor
is
no
emissions
reductions
for
several
PCWP
process
unit
groups,
including
press
pre­
dryers,

fiberboard
mat
dryers,
and
board
coolers
at
existing
affected
sources;
and
dry
rotary
dryers,

veneer
re­
dryers,
plywood
presses,
EWP
presses,
hardwood
veneer
dryers,
humidifiers,

atmospheric
refiners,
formers,
blenders,
rotary
agricultural
fiber
dryers,
agricultural
fiber
board
presses,
sanders,
saws,
fiber
washers,
chippers,
log
vats,
lumber
kilns,
storage
tanks,
wastewater
operations,
miscellaneous
coating
operations,
and
stand­
alone
digesters
at
new
and
existing
affected
sources.
We
also
determined
that
beyond­
the­
floor
control
options
are
too
costly
for
these
process
unit
groups.
13
For
miscellaneous
coating
operations
and
wastewater
operations,
we
determined
at
proposal
that
we
had
insufficient
information
to
conclude
that
the
MACT
floor
level
of
control
is
represented
by
any
emissions
reductions.
In
the
preamble
to
the
proposed
rule,
we
requested
comment
on
whether
a
MACT
floor
of
no
emissions
reductions
for
miscellaneous
coating
operations
and
for
wastewater
operations
was
appropriate,
and
we
requested
information
on
HAP
or
VOC
emissions
from
miscellaneous
coatings
and
wastewater
operations.
We
received
no
comments
containing
additional
information
on
emission
reduction
measures
or
HAP/
VOC
emissions
from
miscellaneous
coatings
and
wastewater
operations.
Following
proposal,
we
reviewed
our
MACT
analyses
for
miscellaneous
coating
and
wastewater
operations.
We
have
no
more
reason
to
believe
now
than
we
did
at
proposal
that
PCWP
wastewater
operations
are
in
fact
subject
to
any
emission
control
measures.
For
miscellaneous
coating
operations,
we
gathered
some
additional
information
and
were
able
to
revise
our
conclusions
regarding
the
MACT
floor
in
the
absence
of
specific
information
on
the
emissions
reduction
achieved.

Prior
to
proposal,
insufficient
information
was
available
for
miscellaneous
coating
operations
because
we
did
not
gather
information
on
measures
used
to
reduce
emissions
from
these
operations.
Insufficient
information
was
available
for
wastewater
operations
because
the
2­
72
PCWP
survey
responses
we
received
were
not
very
informative.
Potential
HAP
emissions
from
miscellaneous
coating
and
wastewater
operations
are
believed
to
be
minuscule
compared
to
the
emissions
from
PCWP
process
units
such
as
presses
or
dryers,
and
these
operations
have
not
been
the
focus
of
permit
requirements
or
consent
decree
actions.
Therefore,
our
PCWP
general
survey
(
which
was
sent
to
softwood
plywood
and
reconstituted
wood
products
plants)
did
not
gather
the
same
level
of
detailed
information
on
miscellaneous
coating
or
wastewater
operations
as
for
other
PCWP
process
units.

Our
PCWP
general
survey
asked
questions
regarding
the
use
of
miscellaneous
coating
operations
because
industry
trade
association
representatives
had
notified
us
of
some
minor
ancillary
processes
performed
at
PCWP
facilities
that
had
the
potential
to
be
considered
finishing
processes
under
the
Wood
Building
Products
NESHAP.
The
industry
representatives
requested
that
we
consider
these
processes
under
the
PCWP
rule
to
avoid
the
potential
for
PCWP
facilities
to
be
subjected
to
dual
coverage
under
two
NESHAP
for
processes
associated
with
PCWP
manufacturing.
The
intent
of
the
questions
related
to
miscellaneous
coating
operations
in
the
PCWP
survey
was
to
gather
information
so
we
could
determine
the
extent
to
which
these
processes
are
being
used
at
facilities
covered
under
the
PCWP
NESHAP
and
to
gauge
whether
these
processes
should
be
considered
under
the
PCWP
NESHAP
or
the
Wood
Building
Products
NESHAP.
The
PCWP
general
survey
requested
that
facilities
provide
information
on
the
types
of
materials
used
in
these
processes,
as
well
as
the
annual
quantities
of
the
materials
used.
10
The
survey
did
not
request
information
on
potential
emissions
from
these
operations
or
methods
for
reducing
emissions
from
these
miscellaneous
processes.
Prior
to
proposal,
we
noted
that
if
there
were
HAP
emissions
from
miscellaneous
coating
operations,
then
one
control
strategy
to
reduce
emissions
would
be
a
reduction
in
the
amount
of
HAP
contained
in
the
coatings
rather
than
application
of
an
emissions
capture
and
control
system.
However,
we
concluded
that
the
MACT
floor
for
miscellaneous
coating
operations
was
no
emissions
reduction
in
the
absence
of
specific
information
on
potential
emission
reductions
achievable
through
product
substitution.
We
revisited
our
MACT
analysis
for
miscellaneous
coating
operations
following
proposal.
Based
on
the
available
information,
we
have
no
basis
to
conclude
that
the
MACT
floor
for
new
or
existing
sources
is
represented
by
any
emission
reduction
for
several
miscellaneous
coating
processes
(
i.
e.,

anti­
skid
coatings,
primers,
wood
patches
applied
to
plywood,
concrete
forming
oil,
veneer
2­
73
composing,
and
fire
retardants
applied
during
forming),
and
we
determined
that
there
are
no
costeffective
beyond­
the­
floor
measures
to
reduce
HAP
from
these
coating
processes.
However,

some
facilities
reported
use
of
water­
based
(
non­
HAP)
coatings
in
their
PCWP
survey
responses
for
other
types
of
coatings
(
including
edge
seals,
nail
lines,
logo
paint,
shelving
edge
fillers,
and
trademark/
gradestamp
inks).
Other
facilities
reported
use
of
"
solvent­
based"
coatings
for
these
processes.
In
a
few
instances,
respondents
provided
information
on
the
percent
HAP
content
of
a
solvent­
based
coating.
Solvent­
based
coatings
do
not
always
contain
HAP
(
e.
g.,
the
solvent
may
be
mineral
oil,
which
does
not
contain
HAP).
Water­
based
coatings
typically
do
not
contain
HAP.
Thus,
the
water­
based
and
some
of
the
solvent­
based
coatings
reported
in
the
responses
to
the
PCWP
survey
are
"
non­
HAP"
coatings.
While
the
emission
reduction
that
will
be
achieved
as
a
result
of
these
coating
substitutions
cannot
be
determined,
it
is
clear
that
use
of
non­
HAP
coating
represents
the
MACT
floor
because
of
the
large
number
of
facilities
reporting
use
of
non­

HAP
coatings.
Beyond­
the­
floor
options
were
not
considered
for
edge
seals,
nail
lines,
logo
paint,
shelving
edge
fillers,
and
trademark/
gradestamp
inks
because
no
further
emissions
reductions
can
be
achieved
through
methods
other
than
use
of
non­
HAP
coatings.
Based
upon
our
revised
MACT
analysis,
the
final
PCWP
rule
requires
use
of
"
non­
HAP
coating"
for
processes
identified
as
"
Group
1
miscellaneous
coating
processes,"
where:

Non­
HAP
coating
means
a
coating
with
HAP
contents
below
0.1
percent
by
mass
for
OSHA­
defined
carcinogens
as
specified
in
29
CFR
1910.1200(
d)(
4),
and
below
1.0
percent
by
mass
for
other
HAP
compounds.

Group
1
miscellaneous
coating
operations
means
application
of
edge
seals,
nail
lines,
logo
(
or
other
information)
paint,
shelving
edge
fillers,
trademark/
gradestamp
inks,
and
wood
putty
patches
to
plywood
and
composite
wood
products
(
except
kiln­
dried
lumber)
on
the
same
site
where
the
plywood
and
composite
wood
products
are
manufactured.
Group
1
miscellaneous
coating
operations
also
include
application
of
synthetic
patches
to
plywood
at
new
affected
sources.

The
definition
of
non­
HAP
coating
was
based
on
the
description
of
non­
HAP
coatings
in
the
final
Wood
Building
Products
NESHAP
(
subpart
QQQQ).
This
definition
allows
for
unavoidable
trace
amounts
of
HAP
that
may
be
contained
in
the
raw
materials
used
to
produce
certain
coatings.

Kiln­
dried
lumber
is
excluded
from
the
requirement
to
use
non­
HAP
coatings
because
application
of
coatings
used
at
kiln­
dried
lumber
manufacturing
facilities
is
not
part
of
the
PCWP
source
category.
Although
trademarks/
gradestamps
are
applied
to
kiln­
dried
lumber,
lumber
kilns
are
the
2­
74
only
processes
at
kiln­
dried
lumber
manufacturing
facilities
covered
under
the
PCWP
source
category.

Our
PCWP
general
survey
asked
questions
regarding
process
water
and
wastewater
generation
and
wastewater
treatment
operations
at
each
plant
site.
The
purpose
of
these
questions
was
to
gather
information
on
the
quantity,
sources,
and
treatment
of
process
water
and
wastewater
at
the
plant
and
to
determine
the
potential
for
HAP
emissions
from
the
water.

Another
reason
for
gathering
the
process
water
and
wastewater
information
was
for
use
in
assessing
the
potential
impacts
(
and
disposal
costs)
of
requiring
add­
on
APCDs
that
may
create
new
sources
of
wastewater.
10
Our
PCWP
survey
requested
information
on
annual
wastewater
flow
rate,
HAP
content
of
the
wastewater,
and
how
the
wastewater
is
handled
and
treated.
The
responses
relating
to
wastewater
operations
were
difficult
to
interpret.
From
the
survey
responses,
we
learned
that
wastewater
operations
such
as
lagoons,
log
vats,
clarifiers,
and
settling
ponds
are
used
at
PCWP
plants
to
manage
wastewaters
because
most
PCWP
plants
are
not
allowed
to
discharge
wastewaters.
Wastewater
sources
at
PCWP
plants
include
hardboard
process
water,
various
wash
waters
(
e.
g.,
from
washing
of
the
glue
line,
blender,
dryers,
RTO),

control
device
recirculated
and
blowdown
water,
and
condensates.
Information
on
wastewater
flow
was
provided
in
the
nonconfidential
PCWP
survey
responses
for
241
wastewater
operations.

(
An
additional
92
wastewater
operations
were
reported,
but
no
flow
rates
were
provided.)

However,
HAP
concentration
data
were
provided
for
only
23
of
the
241
wastewater
operations
for
which
flow
rates
were
provided.
When
comparing
the
flow
rates
and
concentrations
provided
for
these
23
wastewater
operations
to
the
applicability
criteria
for
the
Hazardous
Organics
NESHAP
(
HON)
wastewater
provisions
(
40
CFR
63,
subpart
G),
it
was
determined
that
only
two
of
the
operations
could
emit
HAP
concentrations
high
enough
to
trigger
control
requirements
under
the
HON.
The
highest
reported
concentration
would
result
in
only
0.31
tpy
of
methanol
emitted
from
the
wastewater
stream.
The
results
from
sampling
of
water
streams
performed
by
the
NCASI
show
some
water
streams
with
methanol
concentrations
higher
than
those
reported
in
the
PCWP
survey
responses.
However,
no
information
on
the
flow
rate
is
available
to
use
in
calculating
potential
emissions
from
the
wastewater
operations
tested
by
NCASI,
and
the
samples
collected
from
the
wastewater
streams
may
not
be
representative
of
the
water
contained
in
settling
ponds,
lagoons,
etc.,
which
can
be
diluted
with
stormwater.
Potential
control
methods
for
2­
75
wastewater
operations
include
handling
of
the
wastewater
in
order
to
minimize
emissions
(
e.
g.,

through
hard
piping
or
a
closed
system),
use
of
activated
sludge
biological
treatment
systems,
or
use
of
closed
vent
systems
and
control
devices.
We
are
not
aware
of
any
PCWP
facilities
that
currently
employ
these
techniques
to
control
air
emissions
from
wastewater
operations.
We
have
no
data
to
suggest
that
HAP
emissions
from
wastewater
operations
are
the
subject
of
control
measures
that
could
correspond
to
an
identifiable
numerical
emission
level
or
reduction
rate.

Therefore,
based
on
the
available
information,
the
MACT
floor
for
new
and
existing
wastewater
operations
at
PCWP
facilities
was
determined
to
be
no
emission
reduction.
Furthermore,
given
that
our
best
data
show
that
the
emissions
from
wastewater
operations
are
less
than
1
tpy,
we
concluded
that
application
of
the
control
measures
mentioned
above
would
not
be
cost­
effective
beyond­
the­
floor
options.
13
There
are
115
wastewater
storage
tanks
listed
in
the
nonconfidential
responses
to
the
PCWP
survey.
The
HON
requires
that
certain
wastewater
storage
tanks
have
a
fixed
roof
and
requires
that
other
tanks
(
containing
liquid
with
higher
vapor
pressures)
use
a
fixed
roof
and
closed
vent
system
that
routes
vapors
to
a
control
device,
use
a
fixed
roof
and
an
internal
floating
roof,
or
use
an
external
floating
roof.
We
expect
that
PCWP
wastewater
storage
tanks
would
meet
the
HON
applicability
for
tanks
required
to
have
a
fixed
roof,
and
we
expect
that
most
PCWP
tanks
already
have
a
fixed
roof.
Use
of
a
fixed
roof
does
not
reduce
emissions
unless
coupled
with
a
control
device.
Therefore,
based
on
the
available
information,
we
determined
the
MACT
floor
for
new
and
existing
wastewater
storage
tanks
at
PCWP
facilities
to
be
no
emission
reduction.
Based
on
our
analysis
of
beyond­
the­
floor
control
measures
for
resin
tanks,
we
also
concluded
that
beyond­
the­
floor
control
measures
for
wastewater
tanks
are
not
cost
effective.

The
CAA
does
not
require
us
to
look
further;
we
based
our
MACT
floor
analyses
on
the
best
data
available
to
us.
However,
if
we
had
decided
to
collect
more
data,
we
could
have
resurveyed
facilities
to
ask
them
specifically
about
HAP
emissions
from
their
wastewater
operations
and
to
ask
the
facilities
if
they
are
taking
any
steps
to
reduce
HAP
emissions
from
these
operations.
However,
we
do
not
know
if
better
or
additional
information
could
be
obtained
from
another
survey.
The
fact
that
we
did
not
get
useful
information
on
wastewater
HAP
in
our
first
PCWP
survey
suggests
that
potential
HAP
from
wastewater
operations
is
not
something
facilities
have
been
required
to
track
for
permitting
purposes.
Re­
surveying
facilities
would
be
time
2­
76
consuming
and
burdensome
to
facilities.
Unlike
dryers
and
presses
at
PCWP
plants,
wastewater
operations
have
not
been
treated
by
permitting
authorities
as
being
significant
sources
of
HAP
emissions.
We
expended
much
effort
in
the
early
stages
of
the
project
gathering
complete
and
accurate
information
on
the
PCWP
processes
with
the
most
potential
for
HAP
emissions
and
the
greatest
potential
for
emission
control
(
i.
e.,
the
processes
that
have
been
the
focus
of
permit
requirements
limiting
HAP/
VOC
emissions).
Had
we
believed
that
there
were
emissions
control
measures
associated
with
wastewater
operations,
we
would
have
gathered
more
information
for
these
processes
earlier
in
the
project.
In
response
to
the
commenter's
objection
to
the
incompleteness
of
the
data
set
for
wastewater
operations,
we
note
that
the
D.
C.
Circuit
does
not
require
EPA
to
obtain
complete
data
as
long
as
we
are
able
to
otherwise
estimate
the
MACT
floor.
Sierra
Club
v.
EPA,
167
F.
3rd
658,
662
(
D.
C.
Cir.
1999).

2.3.2.3
Comment:
Commenter
IV­
D­
26
pointed
out
that
setting
control
standards
for
only
six
HAP
is
unlawful.
The
commenter
asserted
that,
according
to
the
CAA
and
National
Lime
Ass'n
v.
EPA,
233
F.
3d
625,
633­
634
(
D.
C.
Cir.
2000),
EPA
is
required
to
set
standards
for
every
HAP
listed
in
112(
b)(
1)
emitted
by
PCWP
operations,
not
just
the
ones
that
are
the
easiest
to
measure.
The
commenter
noted
that
EPA
stated
in
the
proposal
preamble
that
PCWP
facilities
emit
many
different
HAP,
including
metals
and
carcinogens
like
benzene
and
chloroform.
The
commenter
stated
that
EPA's
decision
not
to
regulate
certain
HAP
because
they
are
emitted
"
in
low
quantities
that
may
be
difficult
to
measure"
is
arbitrary,
and
EPA's
choice
of
wording
implies
that
EPA
does
not
know
whether
or
not
these
HAP
are
difficult
to
measure.
The
commenter
also
noted
that
EPA
provided
no
legal
basis
for
this
decision.

Commenter
IV­
D­
33
stated
that
EPA
provided
inadequate
information
on
the
selection
of
HAP
of
concern
from
PCWP
sources,
which
was
based
on
mass
of
emissions
only.
For
example,

the
proposal
does
not
provide
information
on
why
the
HAP
selected
for
regulation
include
six
out
of
at
least
12
HAP
emitted
from
PCWP
sources
and
exclude
benzene,
carbon
tetrachloride,

chloroform,
and
metals,
including
manganese
compounds.

Commenter
IV­
D­
27
disagreed
and
noted
that
a
requirement
that
EPA
impose
an
emissions
standard
for
every
listed
HAP,
without
regard
to
whether
or
not
there
are
applicable
methods
for
reducing
HAP
emissions
or
whether
the
MACT
floor
sources
actually
use
such
2­
77
method,
contradicts
the
plain
language
of
the
statute.
Commenter
IV­
D­
27
contended
that
the
statute
specifically
frames
the
inquiry
in
terms
of
degrees
of
reduction.

Response:
The
final
PCWP
rule
contains
numerical
emission
limits
in
terms
of
methanol,

formaldehyde,
THC,
or
"
total
HAP"
(
which
is
defined
in
the
final
rule
as
the
sum
of
the
six
HAP
acrolein,
acetaldehyde,
formaldehyde,
methanol,
phenol,
and
propionaldehyde).
In
the
proposal
preamble,
we
noted
that
other
HAP
are
sometimes
emitted
and
controlled
along
with
these
six
HAP,
but
in
low
quantities
that
may
be
difficult
to
measure.
Benzene,
chloroform,
and
other
HAP
have
been
detected
in
emissions
from
some
process
units
in
the
PCWP
industry.
We
estimate
that
the
nationwide
emissions
of
these
HAP
from
the
PCWP
industry
are
44
tpy
of
benzene
and
less
than
1.6
tpy
of
chloroform
(
0.2
percent
and
0.008
percent
of
the
nationwide
baseline
HAP
emissions
from
the
PCWP
source
category,
respectively).
Eighty­
seven
percent
of
the
benzene
emission
test
runs
(
over
600
runs)
in
our
emissions
data
base
for
uncontrolled
process
units
were
below
the
test
method
detection
limit.
Chloroform
was
detected
at
only
one
type
of
process
unit
(
green
furnish
rotary
particle
dryers).
Similarly,
HAP
other
than
the
six
HAP
comprising
"
total
HAP"
often
are
not
detected
in
uncontrolled
emissions
from
process
units;
if
detected,
they
are
emitted
in
very
low
mass
(
e.
g.,
less
than
100
tpy
nationwide)
compared
to
the
emissions
of
"
total
HAP."
The
nationwide
emissions
of
"
total
HAP"
are
18,190
tpy,
which
is
96
percent
of
the
nationwide
emissions
of
all
HAP
(
19,000
tpy).
The
six
HAP
that
comprise
"
total
HAP"
are
found
in
emissions
from
all
PCWP
product
sectors
that
contain
major
sources
and
in
emissions
from
most
process
units.

At
proposal,
when
we
stated
that
certain
HAP
are
emitted
"
in
low
quantities
that
may
be
difficult
to
measure,"
we
were
referring
to
HAP
that
are
often
emitted
at
levels
below
test
method
detection
limits.
We
disagree
with
the
suggestion
by
commenter
IV­
D­
26
that
we
do
not
know
whether
or
not
these
HAP
are
difficult
to
measure.
Our
data
clearly
show
that
these
HAP
are
difficult
or
impossible
to
measure
because
they
are
emitted
in
very
low
quantities.
Such
low
quantities
are
not
detectable
by
the
applicable
emission
testing
procedures
(
which
are
sensitive
enough
to
detect
HAP
at
concentrations
below
1
ppm).
As
in
the
examples
of
benzene
and
chloroform
above,
many
of
the
HAP
other
than
those
included
in
"
total
HAP"
were
detected
in
less
than
15
percent
of
test
runs,
or
for
only
one
type
of
process
unit.
2­
78
Based
on
our
emissions
data,
we
determined
that
methanol,
formaldehyde,
THC,
or
"
total
HAP"
are
appropriate
surrogates
for
measuring
all
HAP
emitted
by
the
PCWP
source
category.

The
PBCO
and
emissions
averaging
compliance
options
in
the
final
PCWP
rule
are
based
on
"
total
HAP."
Review
of
the
emission
factors
used
to
develop
the
emissions
estimates
for
the
PCWP
source
category
indicates
that
uncontrolled
emissions
of
HAP
(
other
than
the
six
HAP)
are
always
lower
than
emissions
of
the
six
HAP
for
every
process
unit
with
MACT
control
requirements.
Thus,
process
units
meeting
the
PBCO
based
on
total
HAP
also
would
have
low
emissions
of
other
HAP.
The
emissions
averaging
provisions
and
add­
on
control
device
compliance
options
involve
use
of
add­
on
APCD.
The
available
data
show
that
a
reduction
in
one
predominant
HAP
(
or
THC)
correlates
with
a
reduction
in
other
HAP
if
the
other
HAP
are
present
in
detectable
quantities
and
at
sufficient
concentration.
The
data
show
that
the
mechanisms
in
RTO,
RCO,
and
biofilter
control
devices
that
reduce
emissions
of
formaldehyde
and
methanol
also
reduce
emissions
of
the
remaining
organic
HAP.
In
addition,
an
analysis
of
the
physical
properties
of
the
organic
HAP
emitted
from
PCWP
processes
indicates
that
nearly
all
of
the
HAP
would
be
combusted
at
normal
thermal
oxidizer
operating
temperatures.
The
available
emissions
data
do
not
reveal
any
process
variables
that
could
be
manipulated
(
without
altering
the
product)
to
achieve
a
quantifiable
reduction
in
emissions.
Furthermore,
nothing
in
the
data
suggests
that
process
variables
could
be
manipulated
in
a
way
that
would
alter
the
relationship
between
formaldehyde
and
methanol
reduction
and
reduction
of
other
HAP.
16
We
determined
that
it
is
appropriate
for
the
final
PCWP
rule
to
contain
compliance
options
in
terms
of
"
total
HAP,"
THC,
formaldehyde,
or
methanol
because
the
same
measures
used
to
reduce
emissions
of
these
pollutants
also
reduce
emissions
of
other
organic
HAP.

With
regard
to
metal
HAP,
the
preamble
to
the
proposed
rule
mentioned
the
potential
for
metal
HAP
emissions
when
discussing
risk­
based
options.
The
PCWP
industry
uses
combustion
to
provide
process
heat
to
direct­
fired
processes
(
in
which
the
combustion
gases
mix
with
process
gases).
We
are
aware
that
combustion
of
certain
fuels
can
result
in
metal
HAP
emissions,
and
that
certain
metal
HAP
are
relatively
potent.
Thus,
metal
HAP
emissions
were
estimated
for
direct­
fired
PCWP
process
units
for
purposes
of
conducting
a
conservative
risk
screening
analysis
for
the
PCWP
source
category.
However,
we
have
no
industry­
specific
emissions
test
data
to
verify
that
there
are
indeed
metal
HAP
emissions
from
direct­
fired
PCWP
process
units.
Our
2­
79
PCWP
survey
requested
information
on
emissions
of
all
HAP.
Approximately
100
emissions
test
reports
containing
HAP
data
were
submitted
with
the
responses
to
the
PCWP
survey.
However,

no
emissions
test
data
for
metal
HAP
were
received.
In
the
absence
of
industry­
specific
data,
and
for
the
purposes
of
developing
a
conservative
risk
screening
analysis,
trace
element
emission
factors
from
AP­
42
section
1.6
(
Wood
Residue
Combustion
in
Boilers)
were
used
to
estimate
metal
HAP
emissions
from
the
PCWP
industry.
There
are
differences
in
the
types
of
combustion
units
used
in
PCWP
processes
(
e.
g.,
suspension
burners)
and
wood
residue
fired
boilers.
17
All
of
the
emission
tests
referenced
in
developing
the
AP­
42
trace
element
emission
factors
were
boilers
as
opposed
to
suspension
burners.
While
use
of
the
AP­
42
emission
factors
may
have
been
appropriate
for
purposes
of
developing
an
estimate
of
metal
HAP
emissions,
it
would
not
be
appropriate
to
use
these
same
emission
factors
for
purposes
of
establishing
numerical
emission
limits
for
PCWP
processes.
We
further
note
that
we
did
not
request
particulate
matter
(
PM)

emissions
data
in
our
PCWP
survey.
Thus,
we
have
neither
the
metal
HAP
data
nor
the
PM
data
necessary
to
demonstrate
that
PM
is
an
appropriate
surrogate
for
metal
HAP
for
the
PCWP
source
category
or
to
establish
a
PM
emissions
limit.

2.3.2.4
Comment:
Commenter
IV­
D­
30
stated
that
the
EPA
followed
the
CAA
Amendments
of
1990
well
in
defining
the
source
category
and
affected
source,
setting
the
MACT
standard,
determining
the
best
industrial
practices,
and
considering
health,
environmental,
and
cost
requirements.
However,
the
commenter
contended
that
although
EPA
analyzed
the
risks
to
children
per
Executive
Order
13045,
it
could
have
done
a
better
job
of
assessing
risks
to
other
groups
and
residual
risks
in
general.

Response:
Section
112
of
the
CAA
requires
that
we
establish
NESHAP
for
the
control
of
HAP
from
both
new
and
existing
major
sources.
The
CAA
requires
the
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
level
of
control
is
commonly
referred
to
as
the
MACT.
Thus,
MACT
standards
are
technology­
based,
not
riskbased
Section
112(
f)(
2)
of
the
CAA
requires
us
to
examine
the
post­
MACT­
standard
risk
(
residual
risk)
within
eight
years
after
promulgation
of
the
MACT
standard
to
ensure
that
the
standards
provide
an
ample
margin
of
safety
to
protect
public
health.
Therefore,
the
residual
risk
posed
by
PCWP
facilities
after
MACT
controls
are
implemented
will
be
assessed
at
a
later
date.

If
the
MACT
standards
"...
do
not
reduce
lifetime
excess
cancer
risk
to
the
individual
most
2­
80
exposed
to
the
emissions...
to
less
than
one
in
a
million,"
then
we
will
consider
further
measures
to
reduce
the
risk
to
acceptable
levels.

2.3.2.5
Comment:
Commenter
IV­
D­
14
argued
in
favor
of
a
MACT
floor
of
"
no
control"

for
small
and
medium­
sized
plywood
and
particleboard
mills.
The
commenter
contended
that
the
existing
MACT
floor
was
set
by
larger
mills
with
controlled
softwood
veneer
dryers
and
controlled
particleboard
presses,
which
is
not
reflective
of
smaller
facilities.
The
commenter
believes
that
two
of
its
mills
(
one
plywood
mill
and
one
particleboard
mill)
will
be
forced
to
shut
down
if
the
proposed
rule
is
promulgated
without
changes.
The
commenter
pointed
to
the
high
cost
of
compliance
and
minimal
health
risks
posed
by
these
facilities
as
justification
for
setting
the
MACT
floor
at
"
no
control"
for
small
and
medium­
sized
plywood
and
particleboard
mills.

Response:
We
did
not
distinguish
between
facility
size
or
total
facility
production
for
purposes
of
determining
the
MACT
floor.
We
applied
the
MACT
floor
methodology
at
the
process
unit
level
rather
than
the
facility
level
for
several
reasons:
(
1)
this
is
how
controls
are
installed
at
PCWP
facilities
(
i.
e.,
controls
are
installed
on
process
units,
rather
than
on
all
emission
sources
at
a
facility);
(
2)
we
had
more
accurate
and
complete
information
for
process
unit
emissions
and
emissions
reductions
than
for
facility­
wide
emissions
and
emissions
reductions;
and
(
3)
applying
the
MACT
floor
methodology
at
the
facility
level
would
have
produced
ambiguous
results
when
some
of
the
equipment
(
e.
g.,
dryers)
at
a
facility
were
controlled
and
other
equipment
(
e.
g.,
the
press)
remained
uncontrolled.
In
most
cases,
there
are
no
design
differences
in
PCWP
process
units
used
at
high­
production
plants
versus
low­
production
plants.
It
was
not
necessary
for
us
to
consider
plant
production
when
evaluating
which
process
units
had
similar
design
or
operation.
We
would
like
to
point
out
that
we
distinguished
among
particleboard
extruders
and
press
molds
(
used
by
smaller
particleboard
plants),
and
particleboard
panel
presses
(
used
by
larger
particleboard
plants)
based
on
differences
in
equipment
design.
We
also
distinguished
among
dry
and
green
rotary
particle
dryers
because
of
different
emissions
characteristics.
In
addition,
we
distinguished
among
plywood
presses
and
reconstituted
wood
products
presses
due
to
differences
in
emissions
and
design
(
e.
g.,
plywood
presses
commonly
do
not
have
a
loader
or
unloader
like
reconstituted
wood
products
presses).
These
equipment
distinctions
were
made
for
technical
reasons
(
i.
e.,
based
on
differing
emissions
characteristics
or
equipment
design).
We
do
not
believe
there
are
technical
reasons
for
distinguishing
among
2­
81
facilities
(
or
equipment
at
those
facilities)
according
to
facility
production.
The
CAA
does
not
allow
us
to
consider
costs
when
determining
the
MACT
floor
control
level
or
to
subcategorize
by
cost.

The
final
PCWP
rule
applies
only
to
facilities
that
are
major
sources
of
HAP
emissions;

therefore,
smaller
facilities
that
are
area
sources
are
exempt
from
the
rule.
Major
sources
of
HAP
are
those
stationary
sources
or
groups
of
stationary
sources
that
are
located
within
a
contiguous
area
under
common
control
that
emit
or
have
the
potential
to
emit,
considering
controls,
9.07
Mg/
yr
(
10
tpy)
or
more
of
any
one
HAP
or
22.68
Mg/
yr
(
25
tpy)
or
more
of
any
combination
of
HAP.
Area
sources
are
those
stationary
sources
or
groups
of
stationary
sources
that
are
not
major
sources.
Our
calculations
indicate
that
there
are
some
small
softwood
plywood
and
particleboard
facilities
that
are
area
sources.

2.3.2.6
Comment:
Two
commenters
(
IV­
D­
23
and
IV­
D­
35)
objected
to
the
inclusion
of
consent
decree
plants
in
MACT
floor
determinations.
Commenter
IV­
D­
23
stated
that
only
control
devices
installed
for
PSD,
not
those
at
companies
under
consent
decree,
should
be
included
in
the
determination
of
the
MACT
floor.
The
commenter
argued
that
control
technologies
that
were
installed
at
many
of
those
facilities
are
not
the
ones
that
the
companies
would
have
chosen
if
they
had
not
been
forced
to
use
that
specific
technology
by
law.
Both
commenters
contended
that
the
devices
that
are
in
use
at
these
plants
and
proposed
by
this
rule
have
many
technical
and
operational
problems,
including
massive
energy
requirements,
generation
of
non­
HAP
emissions,
maintenance
issues,
and
little
control
of
particulates.

Response:
We
disagree
that
controls
installed
as
a
result
of
the
consent
decrees
should
not
have
been
included
in
the
MACT
analysis.
The
reason
controls
are
installed
has
no
bearing
on
whether
they
are
included
in
the
MACT
analysis,
which
is
required
to
be
based
on
emissions
levels
achieved
for
any
reason.
However,
we
note
that
the
results
of
our
MACT
floor
calculations
would
have
been
the
same
regardless
of
whether
or
not
the
consent
decree
controls
were
included
in
the
calculations.

2.3.2.7
Comment:
Commenter
IV­
D­
45
stated
that
if
the
EPA
could
not
gather
enough
data
to
determine
the
best
12
percent
for
any
one
type
of
process
unit,
then
it
should
not
use
insufficient
data
as
a
basis
for
developing
a
MACT
floor
for
groups
that
contain
process
units
that
are
completely
different
from
one
another.
The
commenter
stated
that,
because
the
data
set
is
2­
82
incomplete
and
different
process
units
have
such
a
wide
range
of
operating
conditions,
EPA
should
not
automatically
assume
that
no
control
or
incineration­
based
controls
and
biofilters
are
the
best
choices
for
MACT
floors
for
every
type
of
unit.
The
commenter
further
stated
that
EPA
should
consider
several
factors
when
trying
to
determine
the
"
best"
control
technologies,

including
population
density
(
the
number
of
people
affected
by
the
HAP)
and
other
pollutants
emitted
by
the
device.
According
to
the
commenter,
choosing
the
control
device
for
the
MACT
floor
based
on
the
emissions
alone
also
tends
to
select
the
most
expensive
controls.

Response:
See
the
response
to
comment
2.3.2.2
regarding
insufficient
information
for
MACT
floor
determinations.
Section
112(
d)(
3)
of
the
CAA
dictates
the
minimum
control
level
allowed
for
NESHAP,
commonly
referred
to
as
the
"
MACT
floor."
Section
112(
d)(
3)
states
that
"
The
maximum
degree
of
reduction
in
emissions
that
is
deemed
achievable
for
new
sources
in
a
category
or
subcategory
shall
not
be
less
stringent
than
the
emission
control
that
is
achieved
in
practice
by
the
best
controlled
similar
source,
as
determined
by
the
Administrator.
Emission
standards
promulgated
under
this
subsection
for
existing
sources
in
a
category
or
subcategory
may
be
less
stringent
than
standards
for
new
sources
in
the
same
category
or
subcategory
but
shall
not
be
less
stringent,
and
may
be
more
stringent
than
­
(
A)
the
average
emission
limitation
achieved
by
the
best
performing
12
percent
of
the
existing
sources
(
for
which
the
Administrator
has
emissions
information)
......
in
the
category
or
subcategory
for
categories
and
subcategories
with
30
or
more
sources..."

The
CAA
requires
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
level
of
control
is
commonly
referred
to
as
MACT.
Section
112(
d)(
2)
of
the
CAA
dictates
how
we
must
establish
MACT.
The
MACT
can
either
be
established
at
the
MACT
floor,
or
can
be
some
control
level
more
stringent
than
the
MACT
floor
("
beyond
the
floor").
Section
112(
d)(
2)
states
that
"
Emissions
standards
promulgated
under
this
subsection
and
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
shall
require
the
maximum
degree
of
reduction
in
emissions
of
the
hazardous
air
pollutants
subject
to
this
section
(
including
a
prohibition
on
such
emissions,
where
achievable)
that
the
Administrator,
taking
into
consideration
the
cost
of
achieving
such
emission
reduction,
and
any
non­
air
quality
health
and
environmental
impacts
and
energy
requirements,
determines
is
achievable
for
new
or
existing
sources
in
the
category
or
subcategory
to
which
such
emission
standard
applies..."
2­
83
Section
112(
d)(
3)
of
the
CAA
does
not
allow
us
to
consider
cost
when
determining
MACT
floors.
This
is
evident
because
cost
is
not
mentioned
in
§
112(
d)(
3)
regarding
minimum
stringency
levels.
Cost
is
mentioned
in
§
112(
d)(
2)
for
purposes
of
assessing
the
feasibility
of
more
stringent
standards.
Thus,
we
are
only
allowed
to
consider
costs
and
other
non­
air
quality
environmental
or
energy
impacts
when
we
examine
beyond­
the­
floor
control
options
according
to
§
112(
d)(
2)
of
the
CAA.
Population
density
and
health
risk
are
not
considered
in
either
the
MACT
floor
or
MACT
analysis,
and
these
analyses
are
based
on
technology.

2.3.2.8
Comment:
Commenters
IV­
D­
19,
IV­
D­
21,
IV­
D­
27,
IV­
D­
34,
IV­
D­
35,
IV­
D­

37,
and
IV­
D­
56
argued
that
Method
204
compliance
should
not
be
a
part
of
the
PCWP
MACT
floor
because
most
of
the
press
enclosures
that
were
described
as
having
full,
PTEs
were
never
certified
by
Method
204
criteria.
Commenter
IV­
D­
27
argued
that
Method
204
cannot
be
applied
practically
to
the
hot
presses
that
are
used
at
PCWP
facilities.
The
commenter
stated
that
Method
204
was
developed
for
situations
where
the
gas
emissions
have
consistent
properties,
but
a
press
with
multiple
openings
emits
a
variety
of
gases
with
different
physical
properties,
and
heat
changes
those
properties
even
further.
According
to
the
commenter,
instead
of
mixing
and
exiting
the
enclosure,
the
layers
of
gases
can
accumulate
with
other
hazardous
substances
and
create
a
dangerous
environment
for
employees.
The
higher
layers
of
gas
have
a
greater
pressure
than
the
air
outside
the
press
and
the
lower
layers
have
a
pressure
less
than
that
of
the
air
outside
the
press.
The
commenter
maintained
that
to
force
the
gases
outside
the
enclosure,
the
operator
must
decrease
the
temperature
of
the
gas
or
increase
the
airflow
through
the
system.
To
force
the
gases
out
of
the
enclosure,
the
airflow
would
have
to
be
about
3
to
4
times
higher
than
would
be
necessary
for
an
enclosure
operating
at
a
homogenous
temperature.

The
commenter
noted
that
the
majority
of
the
industry's
press
enclosures
used
to
define
the
floor
were
retrofit
installations
around
existing
conventional
multiple­
opening
and
short
continuous
presses.
Most
of
these
enclosures
were
designed
according
to
Method
204
design
criteria,
but
their
permits
never
required
them
to
comply
fully
with
Method
204
certification.
Of
26
PTEs
surveyed
by
NCASI,
only
two
actually
met
Method
204
certification.
Commenter
IVD
27
noted
that
EPA
identified
a
total
of
207
non­
plywood
and
431
total
panel
presses,
and
the
minimum
number
of
presses
needed
to
establish
a
floor
is
about
12
for
6
percent
of
207
nonplywood
presses,
or
about
26
presses
for
6
percent
of
431
total
panel
presses.
However,
only
2
2­
84
presses
of
the
68
percent
that
responded
to
the
NCASI
survey
have
certified
enclosures,

indicating
that
Method
204
certification
should
not
define
the
MACT
floor.
Commenters
IV­
D­

34
and
IV­
D­
35
argued
that
the
proposed
"
containment
efficiencies"
(
capture
efficiencies)
should
be
reduced
or
eliminated
in
favor
of
a
"
best
practices"
approach
and
that
a
total
enclosure
should
only
be
considered
for
the
installation
of
a
new
press.
Commenter
IV­
D­
37
argued
that
neither
a
Method­
204­
certified
PTE
nor
a
95
percent
capture
efficiency
should
be
used
to
determine
the
MACT
floor.

Several
commenters
(
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27)
suggested
that
EPA
address
the
press
capture
efficiency
issue
by
implementing
work
practice
requirements.
To
reflect
this
change,
commenters
IV­
D­
19
and
IV­
D­
27
requested
that
EPA
modify
the
definition
of
permanent
total
enclosure
in
section
63.2292
(
What
definitions
apply
to
this
subpart?)
as
follows:

Permanent
Total
Enclosure
(
PTE)
means
a
permanently
installed
containment
that
was
designed
to
meet
the
following
physical
design
criteria:
1.
Any
NDO
shall
be
at
least
four
equivalent
opening
diameters
from
each
THC­
emitting
point
unless
otherwise
specified
by
the
Administrator.
The
MACT
floor
configuration
of
the
PTE
includes
capturing
emissions
from
the
press
unloader.
For
purposes
of
determining
compliance
with
criteria
1,
the
distance
from
the
THC­
emitting
point
will
be
considered
to
the
press.
2.
The
total
area
of
all
NDOs
shall
not
exceed
5
percent
of
the
surface
area
of
the
enclosure's
four
walls,
floor,
and
ceiling.
3.
The
average
facial
velocity
(
FV)
of
air
through
all
NDOs
shall
be
at
least
3,600
m/
hr
(
200
ft/
min).
The
direction
of
airflow
through
all
NDOs
shall
be
into
the
enclosure.
4.
All
access
doors
and
windows
whose
areas
are
not
included
in
section
2
and
are
not
included
in
the
calculation
of
FV
in
3
shall
be
closed
during
routine
operation
of
the
process.
5.
Fugitive
emissions
shall
be
minimized
through
appropriate
operation
and
maintenance
procedures
applied
to
the
PTE
system.

Commenter
IV­
D­
21
suggested
a
similar
definition
of
PTE,
but
with
different
wording
in
item
1
as
follows:

1.
Any
natural
draft
opening
(
NDO)
shall
be
at
least
four
equivalent
opening
diameters
from
each
VOC­
emitting
point,
except
where
mat
enter
the
enclosure
and
the
board
from
the
unloader
exists
the
enclosure,
or
unless
otherwise
specified
by
the
Administrator.

Commenters
IV­
D­
19
and
IV­
D­
27
further
suggested
that
the
following
definition
be
added
for
those
enclosures
that
do
not
meet
the
design
criteria
for
a
PTE
(
e.
g.,
partial
enclosures):
2­
85
Non­
Permanent
Total
Enclosure
(
Non­
PTE)
means
an
enclosure
that
does
not
meet
the
Permanent
Total
Enclosure
criteria
(
see
PTE).

Commenters
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27
suggested
that
any
press
enclosure
that
is
not
considered
a
PTE
should
be
required
to
demonstrate
a
combined
90
percent
capture
and
control
efficiency
using
the
tracer
gas
method,
EPA
Method
204A
through
204F,
or
some
other
method
subject
to
the
approval
of
the
Administrator,
along
with
the
appropriate
test
method
for
the
compliance
pollutant.
If
the
enclosure
does
not
achieve
90
percent
capture
efficiency,
the
commenters
suggested
that
it
could
be
balanced
either
by
emissions
averaging
or
by
achieving
a
higher
destruction
efficiency.

Response:
Although
EPA
Method
204
was
developed
for
enclosures
in
the
printing
and
publishing
industry,
EPA
Method
204
is
a
used
to
evaluate
enclosures
in
many
industries
other
than
the
printing
and
publishing
industry.
At
the
time
of
proposal,
we
believed
that
many
of
the
PCWP
press
enclosures
for
reconstituted
wood
products
presses
were
meeting
EPA
Method
204.

However,
based
on
review
of
available
permit
information,
we
agree
with
the
commenters'

assessment
that
few
permits
have
required
full
Method
204
certification
for
reconstituted
wood
products
press
enclosures,
although
many
of
these
press
enclosures
were
constructed
based
on
the
Method
204
design
criteria.
Prior
to
proposal,
industry
explained
the
technical
difficulties
associated
with
evacuating
PCWP
press
enclosures,
but
we
did
not
distinguish
between
press
enclosures
designed
to
meet
EPA
Method
204
versus
those
press
enclosures
that
are
actually
certified
as
meeting
Method
204.
We
now
understand
that
the
nature
of
the
batch
pressing
operations
in
the
PCWP
industry
makes
Method
204
certification
difficult.
Unlike
in
the
printing
and
publishing
industry,
operation
of
batch
PCWP
presses
is
cyclical
and
is
a
heated
operation.
A
resinated
wood
mat
enters
the
PCWP
press,
the
press
closes
and
presses
the
mat
under
heat
(
approximately
400
°
F)
and
pressure
for
about
5
minutes.
The
press
then
opens
and
the
hot
board
exits
the
press.
Some
steam
and
emissions
escape
from
the
board
while
the
press
is
closed,
but
the
majority
of
the
steam
and
emissions
are
exhausted
from
the
board
as
the
press
opens.
Steam
and
emissions
continue
to
off­
gas
from
the
board
in
the
press
unloader.
The
temperature
and
density
of
gases
inside
the
press
enclosure
change
as
the
press
opens
and
closes,
creating
layers
of
gases
with
different
physical
properties.
The
introduction
of
fresh
air
and/
or
heat
radiated
from
hot
pipes
around
and
underneath
the
press
adds
another
layer
of
gas
with
different
characteristics
2­
86
into
the
press
enclosure.
The
variation
in
physical
properties
in
these
layers
of
gases
prevents
the
gases
from
mixing,
moving,
and
exiting
the
press
enclosure.
Industry
experience
with
these
heated
enclosures
suggests
that
a
neutral
pressure
zone
is
formed
by
the
layers
of
gases,
and
this
zone
fluctuates
between
the
middle
and
upper
sections
of
the
hot
press.
The
top
of
the
enclosure
has
a
higher
pressure
than
the
air
outside
of
the
enclosure;
whereas
the
bottom
of
the
enclosure
has
a
lower
pressure
than
the
outside
of
the
enclosure.
Based
on
computational
fluid
dynamics
modeling,
the
industry
estimates
that
to
overcome
these
internal
pressure
zones,
the
exhaust
through
the
control
system
must
be
increased
significantly
(
e.
g.,
3
to
4
times
higher
than
if
the
enclosure
operated
at
a
homogeneous
temperature).
Because
of
the
internal
pressurization
within
PCWP
press
enclosures,
small
amounts
of
fugitive
emissions
may
appear
around
the
outside
of
these
enclosures.
Even
so,
the
PCWP
press
enclosure
is
capturing
essentially
100
percent
of
the
press
emissions.
The
concern
is
that
because
of
these
small
amounts
of
fugitive
emissions,

facilities
cannot
certify
that
their
Method
204
designed
press
enclosure
can
achieve
all
the
Method
204
criteria,
in
particular
the
criteria
in
Method
204
section
6.2
which
states
that
"
All
VOC
emissions
must
be
captured
and
contained
for
discharge
through
a
control
device."
While
we
believe
that
PCWP
press
enclosures
should
be
designed
to
capture
emissions
under
normal
conditions,
we
do
not
believe
it
is
necessary
for
PCWP
facilities
to
increase
the
flow
rate
from
their
press
enclosures
(
and
the
size
of
their
APCD)
3
to
4
times
to
overcome
the
pressurization
within
the
press
enclosure.
For
the
PCWP
industry,
we
believe
it
would
be
particularly
inappropriate
to
require
such
a
large
increase
in
exhaust
flow
to
the
APCD
because
the
exhaust
flow
from
PCWP
process
equipment,
including
presses,
is
a
high
volume
dilute
concentration
stream.
High
volume,
low
concentration
exhaust
streams
generally
are
more
costly
to
treat
than
low
volume,
concentrated
emission
streams.
The
best­
performing
press
enclosures
that
defined
the
MACT
floor
surround
heated
presses
and
are
all
believed
to
have
pressurization
within
the
press
enclosure.
In
addition,
we
note
that
board
cooler
exhaust
is
sometimes
directed
into
press
enclosures
and
that
enclosures
around
board
coolers
have
not
been
certified
according
to
EPA
Method
204.
Therefore,
instead
of
requiring
EPA
Method
204
certification
of
PCWP
press
and
board
cooler
enclosures
as
proposed,
today's
final
rule
sets
forth
slightly
different
criteria
for
press
and
board
cooler
enclosures.
These
criteria
are
based
on
the
design
criteria
for
PTEs
2­
87
included
in
EPA
Method
204.
Today's
final
rule
contains
the
following
definitions
of
"
wood
products
enclosure"
and
"
partial
wood
products
enclosure":

Wood
products
enclosure
means
a
permanently
installed
containment
that
was
designed
to
meet
the
following
physical
design
criteria:
1.
Any
natural
draft
opening
(
NDO)
shall
be
at
least
four
equivalent
opening
diameters
from
each
HAP­
emitting
point,
except
for
where
board
enters
and
exits
the
enclosure,
unless
otherwise
specified
by
the
Administrator.
2.
The
total
area
of
all
NDOs
shall
not
exceed
5
percent
of
the
surface
area
of
the
enclosure's
four
walls,
floor,
and
ceiling.
3.
The
average
facial
velocity
(
FV)
of
air
through
all
NDOs
shall
be
at
least
3,600
m/
hr
(
200
ft/
min).
The
direction
of
airflow
through
all
NDOs
shall
be
into
the
enclosure.
4.
All
access
doors
and
windows
whose
areas
are
not
included
in
2
and
are
not
included
in
the
calculation
of
FV
in
3
shall
be
closed
during
routine
operation
of
the
process.
5.
The
enclosure
is
designed
and
maintained
to
capture
all
emissions
for
discharge
through
a
control
device.

Partial
wood
products
enclosure
means
an
enclosure
that
does
not
meet
the
design
criteria
for
a
wood
products
enclosure,
as
defined
in
this
subpart.

The
"
wood
products
enclosures"
meeting
the
criteria
in
the
definition
above
are
assumed
to
achieve
100
percent
capture
of
emissions.
Because
the
capture
efficiency
of
"
partial
wood
products
enclosures"
is
unknown,
today's
final
rule
requires
facilities
to
test
the
capture
efficiency
of
partial
wood
products
enclosures
using
EPA
Methods
204
and
204A­
F
(
as
appropriate),
or
using
the
alternative
tracer
gas
procedure
included
in
Appendix
A
to
subpart
DDDD.
In
addition,

facilities
have
the
option
of
using
other
methods
for
determining
capture
efficiency
subject
to
the
approval
of
the
Administrator.
As
was
proposed
and
suggested
by
the
commenters,
today's
final
rule
requires
facilities
using
partial
wood
products
enclosures
to
demonstrate
a
combined
90
percent
capture
and
control
efficiency
for
those
facilities
showing
compliance
with
the
percent
reduction
requirements
for
APCDs
.
If
the
partial
wood
products
enclosure
does
not
achieve
high
capture
efficiency,
then
facilities
must
offset
the
needed
capture
efficiency
by
achieving
a
higher
destruction
efficiency
or
with
emissions
averaging
(
with
the
press
being
an
under0controlled
process
unit).

Today's
final
rule
also
requires,
as
proposed,
that
facilities
showing
compliance
with
one
of
the
APCD
outlet
concentration
compliance
options
must
meet
95
percent
capture.
The
95
2­
88
percent
capture
requirement
was
chosen
because
MACT
requires
a
90
percent
reduction
in
HAP
emissions.
Some
MACT
control
devices
that
perform
exceptionally
well
can
get
95
percent
control
provided
that
the
control
device
is
well
maintained
and
operated
over
time.
In
order
to
use
a
partial
wood
products
enclosure
that
achieves
less
than
100
percent
capture,
facilities
must
offset
the
lesser
capture
efficiency
by
a
greater
control
efficiency
(
i.
e.,
95
percent).
A
95
percent
control
efficiency
must
be
combined
with
a
95
percent
capture
efficiency
in
order
to
achieve
the
90
percent
reduction
required
to
meet
MACT.

2.3.3
Beyond­
the­
floor
analysis
2.3.3.1
Comment:
Commenter
IV­
D­
07
pointed
out
that
EPA
makes
a
good
argument
for
going
beyond
the
MACT
floor
in
the
discussion
of
the
emission
averaging
program
in
the
preamble
to
the
PCWP
rule.
The
commenter
pointed
to
language
in
the
preamble
stating
that
process
units
such
as
blenders
may
emit
the
same
amount
or
even
more
HAP
than
the
dryers
and
presses
that
the
rule
will
control,
and
they
usually
have
a
lower
volume
of
gas
to
treat.
However,

when
deciding
whether
or
not
to
go
beyond
the
MACT
floor,
EPA
says
that
the
environmental
benefit
of
controlling
these
units
would
not
justify
the
cost.
The
commenter
noted
that
74
percent
of
the
affected
facilities
will
have
to
install
new
control
devices,
and
because
these
other
process
units
have
a
low
exhaust
flow
rate,
it
would
not
be
difficult
to
design
the
control
devices
to
handle
the
additional
small
volume.

Response:
We
are
not
allowed
to
consider
costs
when
determining
the
MACT
floor,
and
therefore,
some
process
units
with
high
flow
rates
and
low
concentrations
of
pollutants
are
required
to
be
controlled
at
the
MACT
floor
control
level.
However,
the
CAA
gives
us
the
authority
to
consider
costs
and
environmental
benefits
when
looking
beyond
the
MACT
floor.

We
considered
going
beyond­
the­
floor
for
all
process
units.
We
determined
that
there
were
no
beyond­
the­
floor
control
options
for
process
units
groups
with
MACT
floors
based
on
incineration­
based
controls
or
biofilters
because
no
technology
is
currently
available
that
achieves
a
greater
reduction
in
emissions.
For
other
process
units,
we
considered
beyond­
the­
floor
measures
including
pollution
prevention
and
incineration­
based
controls.
The
commenter
is
correct
in
that
some
blenders
exhibit
comparable
HAP
emissions,
but
lower
exhaust
flow,
than
the
dryers
and
presses
with
a
MACT
floor
of
incineration­
based
control
or
biofilter
control.
In
fact,

blenders
have
the
some
of
the
highest
emissions
of
the
process
units
with
potential
beyond­
the­
2­
89
floor
options
(
e.
g.,
28
tpy).
Most
other
process
units
for
which
beyond­
the­
floor
control
options
were
considered
had
significantly
lower
emissions
(
e.
g.,
many
had
emissions
less
than
1
tpy).

At
the
time
of
proposal,
we
estimated
that
166
of
the
233
major
source
facilities
(
i.
e.,

74
percent)
would
need
to
install
new
APCDs
to
meet
the
MACT
standards.
Many
facilities
installed
APCDs
after
we
completed
our
proposal
analyses
(
which
were
based
on
April
2000
equipment
and
APCD
counts).
Thus,
many
facilities
have
APCDs
in
place
and
those
APCDs
are
unlikely
to
have
the
capacity
to
accept
additional
flow
from
process
units
such
as
blenders.
Also,

some
facilities
may
have
physical
difficulty
routing
emissions
from
green
end
operations
(
e.
g.,

blenders,
digesters)
to
APCDs
located
after
drying
or
pressing
operations,
because
the
dryers
and
presses
may
be
located
a
long
distance
away
from
the
green
end
emission
points.
In
addition,
our
analyses
indicated
that
several
plants
would
need
to
use
most
of
an
RTO's
capacity
to
control
emissions
from
process
units
with
a
MACT
floor
of
incineration­
based
control.
For
these
reasons,
we
determined
that
it
would
be
inappropriate
for
our
beyond­
to­
floor
analysis
to
assume
that
all
facilities
can
treat
emissions
in
RTOs
installed
to
meet
the
MACT
floor
requirements
for
most
dryers
and
presses.
In
our
beyond­
the­
floor
analysis,
we
determined
that
the
environmental
benefit
of
controlling
blenders
and
other
process
units
would
not
justify
the
cost,
especially
given
the
already
high
costs
of
the
PCWP
rule
at
the
MACT
floor
control
level.
We
maintain
that
we
did
the
beyond­
the­
floor
analysis
correctly,
and
that
going
beyond­
the­
floor
for
these
other
process
units
is
not
warranted.
Our
MACT
beyond­
the­
floor
analysis
for
each
process
unit
is
documented
in
a
separate
memorandum.
13
2.4
NEW
SOURCE
MACT
Comment:
Commenter
IV­
D­
11
noted
that
EPA
chose
to
assign
the
same
degree
of
control
for
new
and
existing
sources
for
many
process
units
based
on
the
fact
that
the
best
technology
is
the
same
for
new
and
existing
sources
(
i.
e.,
thermal
incineration
or
biofilters).

Based
on
the
BID,
the
commenter
pointed
out
that
the
maximum
percent
control
efficiency
is
in
the
upper
90'
s
for
THC,
formaldehyde,
or
methanol.
The
commenter
noted
that
the
CAA
requires
the
MACT
floor
to
be
based
on
the
degree
of
emissions
reduction
achieved
in
practice
by
the
best­
controlled
similar
source.
Thus,
the
commenter
requested
that
EPA
add
new
source
MACT
2­
90
requirements
for
process
units
based
upon
the
greatest
reductions
recorded
and
included
in
the
final
rule.

Response:
To
determine
the
MACT
floor
control
level
for
new
sources,
we
used
an
approach
similar
to
the
approach
used
for
existing
sources
(
see
response
to
comment
2.3.2.1
for
details).
First,
based
on
available
data,
we
determined
that
incineration­
based
controls
(
including
RTOs,
RCOs,
and
incineration
of
pollutants
in
onsite
process
combustion
equipment
used
to
control
emissions
from
various
PCWP
process
units)
and
biofilters
(
used
to
control
PCWP
press
emissions)
are
the
only
two
types
of
add­
on
APCDs
that
consistently
and
continuously
reduced
HAP
emissions.
The
performance
data
for
the
incineration­
based
controls
and
biofilters
showed
methanol
and
formaldehyde
emissions
reductions
equal
to
or
greater
than
90
percent,
except
in
those
cases
where
the
pollutant
loadings
of
the
emission
stream
entering
the
control
systems
were
very
low.
The
performance
data
for
THC
showed
that
incineration­
based
control
systems
achieved
THC
emissions
reductions
equal
to
or
greater
than
90
percent.
The
average
THC
emissions
reductions
achieved
with
biofilters
was
about
80
percent.
However,
biofilters
achieved
HAP
emissions
reductions
equal
to
or
greater
than
90
percent.
Both
incineration­
based
controls
and
biofilters
achieved
identical
formaldehyde
and
methanol
emissions
reductions.

We
ranked
the
process
units
within
each
process
unit
group
according
to
the
HAP
control
devices
that
were
applied.
We
based
the
MACT
floor
for
new
sources
on
the
highest
ranked
process
unit
(
i.
e.,
the
best­
controlled
similar
source).
When
we
ranked
the
process
units,
we
treated
process
units
equipped
with
any
type
of
incineration­
based
control
system
or
biofilters
as
being
equivalent
with
respect
to
their
potential
to
reduce
HAP
emissions.
We
ranked
the
process
units
by
control
device
rather
than
actual
unit­
specific
emissions
reductions
because
we
have
limited
inlet/
outlet
data
on
which
to
calculate
control
efficiency
(
i.
e.,
inlet/
outlet
data
are
not
available
for
many
of
the
controlled
process
units).
As
discussed
in
responses
to
comment
2.3.2.1,
we
believe
that
ranking
process
units
based
on
actual
emissions
reduction
(
as
opposed
to
ranking
by
APCD
type)
is
not
feasible
and
is
unnecessary
for
the
PCWP
source
category.

We
acknowledge
that
some
incineration­
based
controls
and
biofilters
can
achieve
greater
than
90
percent
reduction
in
formaldehyde,
methanol,
or
THC
during
a
single
performance
test
or
a
test
run
within
a
performance
test.
However,
we
also
recognize
that
the
percent
reduction
achieved
varies
according
to
pollutant
inlet
concentration,
a
factor
that
is
not
directly
controllable
2­
91
from
a
process
or
control
device
standpoint.
Other
unknown
factors
may
also
cause
variability
in
control
system
performance.
In
addition,
there
is
variability
related
to
emission
measurements.

For
example,
we
have
THC
percent
reduction
data
for
an
RTO
used
to
control
emissions
from
three
tube
dryers
and
a
press
at
an
MDF
plant
for
two
emission
tests
conducted
at
different
times.

In
1996,
the
RTO
achieved
92.7
percent
reduction
of
THC,
and
in
1998
the
same
RTO
achieved
98.9
percent
reduction
of
THC.
In
addition,
we
have
emissions
test
data
for
the
same
process
unit
and
control
system
for
multiple
years,
and
these
data
show
different
emission
factors,

indicating
that
variability
is
inherent
within
each
process
unit
and
control
system
combination.

Thus,
we
estimate
that
the
best
MACT
technology
achieves
90
percent
HAP
reductions
when
variations
in
operations
and
measurements
are
considered.

As
stated
previously,
no
technology
is
currently
available
that
achieves
a
greater
reduction
in
emissions
than
incineration­
based
controls
or
biofilters.
Therefore,
no
beyond­
the­
floor
control
options
were
considered
for
process
unit
groups
at
new
sources
with
MACT
floors
based
on
incineration­
based
control
or
biofiltration.
We
considered
beyond­
the­
floor
measures
including
pollution
prevention
and
incineration­
based
controls
for
other
process
units
at
new
sources.
Our
data
do
not
show
that
any
emission
reduction
is
achieved
through
use
of
potential
pollution
prevention
measures
(
e.
g.,
using
direct­
versus
indirect­
fired
dryers,
using
a
certain
fuel
to
direct
fire
dryers,
etc.)
that
may
be
technically
feasible
for
application
at
new
sources.
Therefore,
our
beyond­
the­
floor
analysis
focused
on
add­
on
controls.
Like
in
our
beyond­
the­
floor
analysis
for
existing
sources,
we
concluded
that
the
costs
of
beyond­
the­
floor
control
measures
for
process
units
at
new
sources
are
not
justified
by
the
environmental
benefits.
13
2.5
AIR
POLLUTION
CONTROL
DEVICES
2.5.1
General
2.5.1.1
Comment:
Commenter
IV­
D­
08
pointed
out
that
if
EPA
wishes
"
to
encourage
private
industry
investment
in
emissions
reduction,
you
must
consider
providing
safe
assurances
that
controls
installed
will
remain
acceptable."
The
commenter
noted
that
a
WESP,
considered
to
represent
"
best
available
control
technology
(
BACT)"
in
1997,
was
voluntarily
installed
on
a
veneer
dryer
at
one
facility
at
a
cost
of
$
1.5
million.
For
the
PCWP
NESHAP,
EPA
is
requiring
that
RTOs
be
installed
on
dryers
instead.
The
commenter
contended
that
companies
now
will
2­
92
think
twice
about
installing
voluntary
controls
for
fear
of
installing
the
"
wrong"
control
technology.

Response:
Major
stationary
sources
subject
to
PSD
must
conduct
an
analysis
to
ensure
the
application
of
BACT.
During
each
BACT
analysis,
which
is
done
on
a
case­
by­
case
basis,
the
reviewing
authority
evaluates
the
energy,
environmental,
economic
and
other
costs
associated
with
each
alternative
technology,
and
the
benefit
of
reduced
emissions
(
e.
g.,
criteria
pollutants,

VOC)
that
the
technology
would
bring.
The
final
PCWP
rule
is
based
on
MACT
for
HAP
emissions;
therefore,
decisions
on
control
levels
and
compliance
demonstrations
are
based
on
HAP
reductions.
The
MACT
for
veneer
dryers
was
determined
to
be
the
emission
reduction
achievable
with
incineration­
based
control.
We
note
that
MACT
for
veneer
dryers
was
established
at
the
MACT
floor
control
level,
which
does
not
consider
costs.
While
many
of
the
PCWP
provisions
for
HAP
may
be
used
to
comply
with
PSD,
the
PCWP
provisions
are
not
universally
applicable.
In
cases
where
one
rule
is
more
stringent
than
the
other,
you
must
comply
with
both
rules.

We
acknowledge
that
many
veneer
dryers
have
been
equipped
with
WESPs
or
wet
scrubbers
to
reduce
blue
haze.
These
wet
control
devices
are
effective
at
reducing
blue
haze
and
PM
emissions,
but
are
not
reliable
technologies
for
reducing
gaseous
HAP
emissions.
While
WESP
and
wet
scrubbers
may
absorb
some
water­
soluble
HAP,
these
same
HAP
will
eventually
be
re­
emitted
as
the
recirculating
WESP
or
scrubber
water
and
becomes
saturated
with
these
pollutants.
We
note
that
facilities
may
use
any
control
technology
to
meet
the
MACT
standards
provided
that
the
technology
meets
the
compliance
options.
Facilities
choosing
to
use
a
WESP
to
meet
the
MACT
standards
may
petition
the
Administrator
for
approval
of
site­
specific
operating
requirements
that
can
be
used
to
demonstrate
continuous
compliance.
Alternatively,
facilities
using
WESP
may
use
a
THC
continuous
emissions
monitoring
system
(
CEMS)
to
show
that
the
THC
concentration
in
the
WESP
exhaust
remains
below
the
minimum
concentration
established
during
the
performance
test.
Facilities
using
wet
control
devices
also
must
submit
with
their
Notification
of
Compliance
Status,
a
plan
for
review
and
approval
to
address
how
organic
HAP
captured
in
the
wastewater
from
the
wet
control
device
is
contained
or
destroyed
to
minimize
rerelease
to
the
atmosphere
such
that
the
desired
emission
reduction
is
achieved.
2­
93
2.5.2
Definition
of
control
device
2.5.2.1
Comment:
Two
commenters
(
IV­
D­
03
and
IV­
D­
27)
requested
that
scrubbers
be
added
to
the
definition
of
"
control
device."
Commenter
IV­
D­
27
also
requested
that
adsorbers
and
scrubbers
be
added
to
the
definition
and
that
condensers
be
omitted.
Based
on
the
commenters'
recommendations,
the
definition
of
control
device
would
be
modified
as
follows
(
suggested
additions
are
in
italics
and
suggested
deletions
are
in
strikeout
format):

Control
device
means
any
equipment
that
reduces
the
quantity
of
a
hazardous
air
pollutant
that
is
emitted
to
the
air.
The
device
may
destroy
the
hazardous
air
pollutant
or
secure
the
hazardous
air
pollutant
for
subsequent
recovery.
Control
devices
include,
but
are
not
limited
to,
thermal
or
catalytic
oxidizers,
combustion
units
that
incinerate
process
exhausts,
biofilters,
absorbers,
adsorbers,
and
scrubbers
and
condensers.

Response:
We
disagree
with
the
commenters
that
the
proposed
definition
of
"
control
device"
should
be
changed.
In
the
proposed
PCWP
rule
we
intentionally
left
absorbers
(
e.
g.,
wet
scrubbers)
out
of
the
list
of
potential
control
devices
because
these
technologies
generally
are
not
reliable
for
reducing
HAP
emissions.
These
wet
systems
may
achieve
short­
term
reductions
in
THC
or
gaseous
HAP
emissions;
however,
the
HAP
and
THC
control
efficiency
data,
which
range
from
slightly
positive
to
negative
values,
indicate
that
the
ability
of
these
wet
systems
to
absorb
water­
soluble
compounds
(
such
as
formaldehyde)
diminishes
as
the
recirculating
scrubbing
liquid
becomes
saturated
with
these
compounds.
2
We
wished
to
limit
the
examples
included
in
the
definition
of
"
control
device"
to
those
devices
for
which
we
have
data
to
demonstrate
that
they
are
effective
in
reducing
HAP
emissions
from
PCWP
facilities.
However,
we
note
that
the
definition
includes
the
phrase
"
but
not
limited
to,"
so
the
definition
does
not
exclude
other
types
of
controls.
We
are
aware
that
new
technologies
(
some
of
which
may
be
adsorption­
based
or
absorption­
based)
may
be
developed
that
effectively
reduce
HAP
emissions
from
PCWP
sources.

The
definition
of
"
control
device"
does
not
prevent
their
development
or
use.

Facilities
using
wet
scrubbers
or
WESPs
to
meet
the
add­
on
APCD
or
emissions
averaging
compliance
options
can
petition
the
Administrator
for
approval
of
site­
specific
operating
requirements
to
be
used
in
demonstrating
continuous
compliance.
Alternatively,

facilities
using
a
wet
scrubber
or
WESP
may
use
a
THC
CEMS
to
show
that
the
THC
concentration
in
the
APCD
exhaust
remains
below
the
minimum
concentration
established
during
the
performance
test.
In
addition,
facilities
using
wet
control
devices
(
e.
g.,
wet
scrubber
or
2­
94
WESP)
as
the
sole
means
of
reducing
HAP
emissions
must
submit
with
their
Notification
of
Compliance
Status
a
plan
for
review
and
approval
to
address
how
organic
HAP
captured
in
the
wastewater
from
the
wet
control
device
is
contained
or
destroyed
to
minimize
re­
release
to
the
atmosphere
such
that
the
desired
emission
reduction
is
achieved.
Because
wet
scrubbers
and
WESPs
are
add­
on
APCDs
and
have
variable
effects
on
HAP
emissions,
the
final
rule
specifies
that
sources
cannot
use
add­
on
control
systems
or
wet
control
devices
to
meet
the
PBCO.

Facilities
demonstrating
compliance
with
the
PBCO
for
process
units
equipped
with
any
wet
control
device
that
effects
HAP
emissions
must
test
prior
to
the
wet
control
device.
We
added
the
following
definition
of
"
wet
control
device"
to
the
final
rule
to
clarify
that
these
add­
on
technologies
cannot
be
used
to
meet
the
PBCO:

Wet
control
device
means
any
equipment
that
uses
water
as
a
means
of
collecting
an
air
pollutant.
Wet
control
devices
include
scrubbers,
wet
electrostatic
precipitators,
and
electrified
filter
beds.
Wet
control
devices
do
not
include
biofilters
or
other
equipment
that
destroys
or
degrades
hazardous
air
pollutants.

2.5.2.2
Comment:
Commenter
IV­
D­
55
requested
changes
to
the
definition
of
"
control
system"
so
that
facilities
with
certain
types
of
add­
on
control
devices
could
still
comply
using
the
PBELs.
The
commenter
specifically
requested
that
the
definition
of
an
"
add­
on
control
system"

exclude
those
"
control
systems"
that
are
designed
for
the
primary
purposes
of
capturing
and
using
alternative
sources
of
fuel
and
preventing
potential
storm
water
impacts.
The
commenter
described
a
"
steam
collapse
system"
that
condenses
steam
from
the
particleboard
press
exhaust
and
then
routes
the
condensate
to
an
onsite
wastewater
treatment
system.
The
remaining
noncondensed
gases
exiting
the
steam
collapse
system
are
then
routed
to
an
onsite
boiler
where
they
are
combusted
as
supplemental
fuel.
The
heating
value
of
the
gases
was
reported
to
be
700
BTU
per
standard
cubic
foot.
The
commenter
noted
that
both
the
steam
collapse
system
and
the
boiler
reduce
HAP
emissions,
and
thus
meet
the
proposed
definition
of
control
device,
which
means
that
the
mills
would
have
to
demonstrate
compliance
using
the
either
the
add­
on
control
system
compliance
options
or
emissions
averaging.
The
commenter
further
noted
that
the
add­
on
control
system
compliance
options
would
require
the
installation
of
a
PTE,
which
the
commenter
believes
would
result
in
negligible
emission
reductions
and
would
cause
operational
difficulties
as
well
as
a
fire
hazard.
For
these
reasons,
the
commenter
recommended
that
the
definition
of
an
2­
95
"
add­
on
control
device"
be
adjusted
to
refer
only
to
those
capture
and
control
devices
for
which
the
removal
of
HAP
is
the
primary
goal.

Response:
The
definition
of
"
control
system
or
add­
on
control
system"
refers
to
the
combination
of
capture
and
control
devices
used
to
reduce
HAP.
The
commenter's
concern
relates
to
the
definition
of
"
control
device."
The
definition
of
"
control
device"
in
the
final
PCWP
rule
includes
condensers
and
combustion
units
that
incinerate
process
exhausts.
For
purposes
of
MACT
standard
development,
the
reason
a
control
device
was
installed
is
immaterial.
All
control
devices
or
techniques
that
reduce
HAP
emissions
are
considered
when
setting
MACT
standards.

The
PBCOs
were
developed
and
included
in
the
PCWP
rule
for
inherently
low­
emitting
process
units
or
process
units
with
pollution
prevention,
not
for
process
units
with
add­
on
control
devices
(
see
Section
2.6.3
for
more
details
on
the
development
of
the
PBCOs).
Emissions
data
for
the
outlet
of
APCD
(
including
wet
control
devices)
were
not
used
in
developing
the
PBCOs.
The
control
system
described
by
the
commenter
is
an
add­
on
control
system
which
cannot
be
used
to
comply
with
the
PBCO
(
unless
emissions
measured
prior
to
the
steam
collapse
system
meet
the
PBCO,
indicating
that
the
press
is
a
low­
emitting
press
without
add­
on
control).
Even
though
the
PBCO
is
not
an
available
compliance
option
for
the
outlet
of
the
commenter's
control
system,

there
are
six
add­
on
control
device
compliance
options
plus
emissions
averaging
in
the
final
PCWP
rule.
We
disagree
that
an
enclosure
around
the
press
would
result
in
operational
problems
and
fire
hazard;
enclosures
have
been
successfully
installed
around
particleboard
presses.
The
final
PCWP
rule
defines
design
criteria
for
wood
products
enclosures,
and
also
allows
for
partial
enclosures
as
long
as
the
overall
emission
reduction
is
achieved.
Wood
products
enclosures,
as
defined
in
the
final
rule,
are
assumed
to
achieve
100
percent
capture;
however,
partial
wood
products
enclosures
must
be
tested
to
determine
capture
efficiency.
To
determine
the
percent
reduction
associated
with
the
commenter's
control
system,
testing
would
likely
need
to
be
conducted
prior
to
the
steam
collapse
system
and
after
the
boiler.
Additional
information
on
incineration
of
process
exhausts
is
provided
in
Section
2.7.12.

2.5.3
Regenerative
thermal
and
catalytic
oxidizers
2.5.3.1
Comment:
Commenters
IV­
D­
34,
IV­
D­
35,
IV­
D­
47,
and
IV­
D­
50
requested
that
EPA
reevaluate
the
benefits
of
RTO
and
RCO
control
devices.
The
commenters
contended
that
many
of
these
units
currently
in
use
are
not
meeting
their
design
destruction
efficiency.
2­
96
Commenters
IV­
D­
34
and
IV­
D­
35
argued
that
EPA
did
not
take
in
to
account
the
lack
of
industry
experience
with
incineration­
based
control
technologies
when
proposing
the
rule
and
suggested
that
EPA
re­
evaluate
these
technologies
in
light
of
recent
experience
to
ensure
that
the
units
are
truly
capable
of
meeting
the
emissions
requirements.
Commenter
IV­
D­
50
further
argued
that
RTOs
and
RCOs
are
unable
to
satisfactorily
treat
press
emissions
that
have
low
concentrations
of
VOCs.

Response:
We
disagree
that
the
PCWP
industry
does
not
have
experience
with
RTOs
and
RCOs.
Responses
to
our
PCWP
general
survey
conducted
in
1998
indicated
that
there
were
90
of
these
types
of
control
devices
in
use
on
various
PCWP
process
units.
10
Several
additional
RTOs
and
RCOs
have
been
installed
on
PCWP
processes
since
the
1998
survey.
18,19
Our
data
show
that
RTOs
and
RCOs
in
the
PCWP
industry
routinely
achieve
90
percent
HAP
reduction
efficiency
regardless
of
whether
these
controls
are
installed
on
presses,
dryers,
or
a
combination
of
PCWP
process
units.
20
We
note
that
we
have
not
established
standards
more
stringent
than
90
percent
reduction
to
account
for
units
that
may
not
meet
their
design
destruction
efficiency;
we
believe
that
90
percent
reduction
represents
the
level
of
control
that
is
continuously
achieved
accounting
for
inherent
variability
over
time.

2.5.4
Biofilters
2.5.4.1
Comment:
Commenter
IV­
D­
27
requested
that
the
proposed
definition
of
biofilter
be
modified
so
that
rotating
biological
disk
biofilters
will
meet
the
definition
of
biofilter.
The
suggested
changes
to
the
definition
are
as
follows
(
additions
are
in
italics
and
deletions
are
in
strikeout
format):

Biofilter
means
an
enclosed
control
system
such
as
a
tank
or
series
of
tanks
with
a
fixed
roof
that
are
filled
with
contact
emissions
with
a
solid
media
(
such
as
bark)
and
use
microbiological
activity
to
transform
organic
pollutants
in
a
process
exhaust
stream
to
innocuous
compounds
such
as
carbon
dioxide,
water,
and
inorganic
salts.
Wastewater
treatment
systems
such
as
aeration
lagoons
or
activated
sludge
systems
are
not
considered
to
be
biofilters.

Response:
We
agree
with
the
suggested
change
and
have
modified
the
definition
of
biofilter
in
the
final
rule
as
requested.

2.5.4.2
Comment:
Commenters
IV­
D­
34,
IV­
D­
35,
and
IV­
D­
47
stated
that
more
investigation
into
biofilters
is
needed
before
they
are
considered
a
viable
alternative.
These
2­
97
commenters
contended
that
the
large
space
requirements
associated
with
biofilters
would
preclude
their
use
at
many
PCWP
facilities,
because
many
of
these
facilities
lack
sufficient
open
property
on
which
to
site
a
biofilter.

Response:
Facilities
are
free
to
choose
whatever
control
technology
works
best
for
their
facility
(
provided
that
the
technology
meets
the
compliance
options)
based
on
site­
specific
concerns
such
as
the
process
unit
to
be
controlled
and
available
space.
Biofilters
are
a
viable
alternative
for
some
facilities.
Biofilters
have
been
used
successfully
to
control
press
emissions,

and
our
data
show
that
biofilters
can
achieve
HAP
reductions
of
90
percent
or
greater.
Biofilters
are
available
in
different
designs
including
some
modular
designs
which
may
be
easier
to
retrofit
at
facilities
with
less
available
space.
Nevertheless,
we
acknowledge
that
some
facilities
simply
do
not
have
the
space
to
install
a
biofliter
and
therefore
must
use
a
control
technology
with
a
smaller
footprint
(
e.
g.,
RTO,
RCO,
or
incineration
in
an
onsite
combustion
unit).

2.5.5
Availability
of
APCDs
2.5.5.1
Comment:
Commenters
IV­
D­
19,
IV­
D­
27,
and
IV­
D­
48
requested
that
the
deadline
for
existing
sources
to
come
into
compliance
with
the
PCWP
rule
be
extended.

Commenter
IV­
D­
27
recommended
that
sources
installing
incineration­
based
equipment
or
equivalent
emissions
control
technology
be
granted
a
one­
year
extension
because
of
the
limited
availability
of
qualified
and
financially
viable
vendors
for
add­
on
control
systems.
The
commenter
contended
that
most
affected
PCWP
plants
will
choose
to
install
RTOs
rather
than
RCOs
or
biofilters
because
RTOs
can
be
used
in
more
situations
and
applications
than
an
RCO
or
biofilter.

The
commenter
also
noted
that
the
use
of
a
process
combustion
unit
as
an
incineration­
based
control
device
would
be
limited
by
the
amount
of
airflow
that
can
be
controlled
and
by
safety
concerns.

Commenter
IV­
D­
27
stated
that
there
are
four
main
challenges
facing
the
PCWP
industry
under
a
three­
year
compliance
schedule.
First,
a
large
majority
of
the
companies
that
provide
RTOs,
RCOs,
and
biofilters
to
the
wood
products
industry
are
relatively
new,
small
businesses
with
relatively
low
capitalization.
Because
less
than
a
handful
of
vendors
have
capitalization
substantial
enough
both
to
support
installation
and
to
honor
their
warranties
and
guarantees,
there
will
be
numerous
facilities
competing
for
a
limited
number
of
experienced
contractors
in
order
to
meet
the
standards
at
the
same
time.
Commenter
IV­
D­
48
agreed,
noting
that
both
PCWP
2­
98
facilities
and
equipment
suppliers
dislike
the
short
three­
year
time
period
to
perform
initial
compliance
testing,
select
and
install
control
equipment
if
needed,
and
perform
post­
compliance
testing.
Because
of
this
schedule,
facilities
may
be
unable
to
install
equipment
from
their
first
choice
of
supplier
and
may
have
to
resort
to
second,
third,
or
fourth
choices.
Second,
there
are
a
limited
number
of
fabricators
that
the
vendors
can
choose
as
subcontractors,
and
they
are
usually
small
businesses.
Third,
there
are
several
MACT
standards
scheduled
to
be
released
over
the
next
year,
and
any
that
require
incineration­
based
add­
on
controls
will
further
increase
the
demand
on
the
limited
resources
of
the
vendors
and
fabricators.
Fourth,
the
typical
biofilter
vendor
only
has
one
or
two
installed
systems
and
will
propose
a
newer,
often
untested
version.
As
a
result,

biofilter
vendors
provide
even
more
compliance
and
cost
risks
then
the
RTO/
RCO
vendors.

Commenter
IV­
D­
27
also
noted
that
"
over
two­
thirds"
of
the
vendors
who
installed
the
RTOs
and
RCOs
included
in
the
MACT
floor
determination
have
gone
bankrupt
in
the
past
four
years.

Commenter
IV­
D­
27
provided
a
summary
of
problems
experienced
by
a
PCWP
company
that
recently
contracted
with
a
vendor
to
fabricate
and
install
multiple
RTOs/
RCOs.
In
this
situation,
the
vendor
declared
bankruptcy
after
only
one
RCO
was
installed,
forcing
the
PCWP
company
to
negotiate
contracts
with
each
subcontractor
directly
to
complete
the
construction
and
installation
of
the
remaining
RTOs.
The
PCWP
company
also
lost
the
money
that
had
been
prepaid
to
the
vendor.
In
addition,
the
RCO
"
barely
met"
the
required
THC
destruction
efficiency
and
has
had
ongoing
problems
meeting
opacity
limits.
For
the
reasons
stated
above,
the
commenter
requested
that
the
compliance
deadline
either
be
extended
by
one
year
or
that
a
staggered
compliance
schedule
for
the
sources
affected
by
the
standards
be
implemented.
The
commenter
suggested
that
individual
companies
be
granted
the
option
to
comply
within
2,
3,
4,
or
5
years,
as
long
as
the
average
compliance
duration
does
not
exceed
four
years.
The
commenter
stated
that
a
staggered
compliance
schedule
would
smooth
out
demand;
enhance
the
economic
viability
of
the
vendor
segment;
eliminate
the
need
to
make
case­
by­
case
extension
determinations;
and
provide
efficient,
effective,
and
reliable
compliance
options
for
the
industry.

The
commenter
also
argued
that
sources
choosing
pollution
prevention
should
be
granted
an
extension
to
the
compliance
schedule
to
provide
the
time
needed
for
the
development
and
implementation
of
these
innovative
approaches.
The
commenter
noted
that
add­
on
controls
have
multiple
environmental
disbenefits,
including
significant
increases
in
energy
use
and
greenhouse
2­
99
gas
emissions,
so
pollution
prevention
should
be
encouraged
whenever
possible.
The
commenter
agreed
that
pollution
prevention
options
are
not
widely
used
by
the
PCWP
industry
but
noted
that
the
industry
has
placed
a
priority
on
developing
pollution
prevention
techniques.
Because
pollution
prevention
projects
are
more
complex,
more
time
consuming,
and
potentially
more
capital
intensive
than
simply
installing
add­
on
controls,
the
commenter
contended
that
more
compliance
time
would
be
necessary.
However,
with
a
three­
year
compliance
deadline,
the
commenter
stated
that
only
the
add­
on
control
system
approach
is
viable
on
a
widespread
basis.

The
commenter
suggested
adding
four
years
to
the
compliance
deadline,
for
a
total
of
seven
years,
to
address
the
challenges
with
implementing
pollution
prevention
options.
The
commenter
suggested
that
EPA
could
require
facilities
that
implement
this
approach
to
declare
their
commitment
to
do
so
within
two
years
after
promulgation
of
the
rule
and
provide
annual
progress
reports
to
identify
progress
towards
those
goals.

Commenter
IV­
D­
19
supported
Commenter
IV­
D­
27'
s
recommendation
for
a
one­
year
extension
for
plants
installing
incineration­
based
control
and
the
three­
year
extension
for
plants
choosing
pollution
prevention.
Commenter
IV­
D­
19
also
recommended
that
any
facility
choosing
a
control
technology
that
does
not
require
natural
gas
be
granted
a
one­
year
compliance
extension.
To
qualify
for
the
last
option,
a
facility
would
have
to
demonstrate
that
transporting
either
natural
gas
or
propane
to
the
site
would
be
technically
and/
or
economically
impractical.

Response:
Section
112(
i)(
3)
of
the
CAA
states
that
"(
A)
After
the
effective
date
of
any
emissions
standard,
...
in
the
case
of
an
existing
source,
the
Administrator
shall
establish
a
compliance
date
or
dates
for
each
category
or
subcategory
of
existing
sources,
which
shall
provide
for
compliance
as
expeditiously
as
practicable,
but
in
no
event
later
than
3
years
after
the
effective
date
of
such
standard,
except
as
provided
in
subparagraph
(
B)...
"(
B)
The
Administrator
(
or
a
State
with
a
program
approved
under
title
V)
may
issue
a
permit
that
grants
an
extension
permitting
an
existing
source
up
to
1
additional
year
to
comply
with
standards
under
subsection
(
d)
if
such
additional
period
is
necessary
for
the
installation
of
controls."

Thus,
we
are
allowing
the
full
length
of
time
permitted
by
the
CAA
(
i.
e.,
three
years
as
opposed
to
a
shorter
time
frame)
for
compliance
with
the
PCWP
rule.
At
this
point,
based
on
available
information,
we
disagree
that
a
compliance
extension
is
needed
for
installation
of
APCD
or
for
implementation
of
pollution
prevention
measures.
The
three­
year
compliance
date
for
the
final
rule
is
projected
in
2007
(
assuming
publication
of
the
final
rule
in
2004).
As
of
April
2000,
we
2­
100
estimated
that
26
percent
of
facilities
were
already
using
the
control
technologies
needed
to
meet
the
final
PCWP
rule.
In
addition,
many
facilities
have
installed
controls
since
April
2000.
The
final
PCWP
rule
contains
various
compliance
options,
some
of
which
will
reduce
the
number
or
size
of
controls
needed
to
meet
the
rule
(
e.
g.,
PBCOs,
emissions
averaging).
In
addition,
different
types
of
add­
on
APCDs
can
be
used
to
meet
the
final
rule
(
e.
g.,
RTO,
RCO,
incineration
of
process
exhaust
in
an
onsite
combustion
unit,
biofilter).

Even
conservatively
assuming
that
incineration­
based
controls
are
selected
by
all
facilities
for
compliance
with
the
PCWP
rule,
we
are
not
convinced
that
there
are
not
enough
vendors
to
handle
the
remaining
demand
for
incineration­
based
control
devices
during
the
three
years
following
promulgation
of
the
PCWP
rule.
A
review
of
journal
articles
and
Internet
webpages
revealed
at
least
10
incineration­
based
control
device
vendors
currently
in
operation
that
have
experience
installing
controls
at
PWCP
facilities
and
that
appear
to
be
capable
of
handling
multiple
installation
requests
simultaneously.
Six
other
companies
have
experience
with
the
industry,
but
it
is
unclear
if
they
have
the
ability
to
handle
the
same
number
of
simultaneous
orders
as
the
10
top­
quality
vendors.
About
12
additional
companies
have
experience
manufacturing
and
installing
incineration­
based
controls,
but
they
do
not
have
experience
with
the
PCWP
industry.

Eleven
different
vendors
were
responsible
for
installing
the
89
incineration­
based
control
devices
listed
in
the
MACT
survey
results.
Four
of
these
eleven
vendors
have
gone
out
of
business
in
the
last
few
years,
but
all
of
them
have
been
purchased
or
otherwise
acquired
by
another
company.

Three
of
the
vendors
were
acquired
by
two
of
the
10
top­
quality
vendors
mentioned
above.
The
fourth
vendor
was
recently
purchased
by
an
environmental
technology
company
with
experience
in
pollution
control
for
the
pulp
and
paper
industry
and
is
now
considered
one
of
the
six
smallercapacity
vendors.
A
fifth
company
which
installed
four
of
the
RTOs
reported
in
the
PCWP
survey,
is
still
operating,
but
the
company
appears
to
be
focusing
on
mist
eliminators
and
scrubbers.

The
available
information
does
not
support
the
commenter's
claim
that
two­
thirds
of
the
vendors
responsible
for
installations
considered
in
the
MACT
floor
determination
have
gone
bankrupt
in
the
past
four
years.
Four
of
11
vendors
of
incineration­
based
control
devices
reported
in
the
MACT
survey
responses
have
gone
out
of
business.
These
four
vendors
represented
69
percent
of
the
installations
that
were
reported
in
the
MACT
survey
and
considered
2­
101
in
determining
the
MACT
floor,
which
may
have
been
the
basis
for
the
commenter's
claim.

However,
since
all
of
the
vendors
that
closed
are
now
back
in
business,
the
number
of
bankrupt
vendors
is
no
longer
relevant.
Although
four
APCD
vendors
may
no
longer
operate
as
independent
companies,
their
products
and
designs
are
still
available,
and
they
have
become
part
of
larger
corporations,
which
will
increase
their
stability.
As
a
result,
there
appear
to
be
enough
vendors
to
handle
all
of
the
orders
for
incineration­
based
control
devices.
21
Facilities
concerned
about
having
their
first
choice
supplier
should
submit
their
equipment
contracts
early
in
the
threeyear
compliance
time
frame.
In
any
event,
individual
sources
will
be
able,
consistent
with
the
language
of
section
112(
i)(
3)(
B),
to
present
their
own
claims
of
need
for
additional
time
to
install
controls
to
permitting
authorities.

We
further
disagree
that
control
technologies
that
do
not
use
natural
gas
require
a
one­
year
extension.
Facilities
can
use
any
control
technology
that
meets
the
standards
based
on
their
site­
specific
needs.
Control
technologies
(
including
those
that
use
natural
gas
and
those
that
do
not)
are
available
for
installation
within
the
three­
year
compliance
time
frame,
and
therefore,
it
is
not
necessary
to
extend
the
compliance
date.

We
wish
to
encourage
pollution
prevention,
as
evident
from
our
inclusion
of
PBCOs
in
the
PCWP
rule.
We
acknowledge
that
there
are
significant
challenges
in
implementing
pollution
prevention
measures,
and
that
currently
there
are
no
widespread
HAP
pollution
prevention
measures
used
in
the
PCWP
industry.
It
is
not
known
if
an
additional
four
years
of
research
would
identify
pollution
prevention
measures.
We
do
not
wish
to
allow
facilities
up
to
four
years
after
the
compliance
date
to
ponder
potential
pollution
prevention
measures,
only
to
then
decide
after
four
years
to
install
an
add­
on
APCD.
Moreover,
section
112(
i)(
3)
provides
no
authority
for
such
a
lengthy
compliance
extension
solely
due
to
the
wish
to
explore
currently
unidentified
and
un­
demonstrated
pollution
prevention
measures.
Even
if
it
were
allowed
under
the
CAA,
we
disagree
that
a
four­
year
extension
of
the
compliance
date
is
appropriate
in
this
rulemaking,
since
as
reflected
in
our
MACT
floor
determinations,
it
does
not
appear
that
there
are
any
pollution
prevention
measures
that
could
be
universally
applied
across
the
industry.

While
we
believe
that
the
need
for
a
blanket
compliance
extension
is
not
necessary
for
most
facilities,
we
note
that
section
112(
i)(
3)(
B)
allows
facilities
to
petition
permitting
authorities
for
a
case­
by­
case
extension
of
the
compliance
date
of
up
to
one
year
if
such
an
extension
is
2­
102
necessary
for
installation
of
controls.
Thus,
facilities
facing
exceptional
difficulty
obtaining
the
technology
necessary
to
comply
with
the
final
rule
have
an
avenue
for
obtaining
a
compliance
extension
based
on
their
site­
specific
circumstances,
which
could
include
the
adoption
of
demonstrated
pollution
prevention
measures
that
achieve
MACT
levels
of
performance
but
that
cannot
be
implemented
by
the
3­
year
compliance
date.

2.6
COMPLIANCE
OPTIONS
2.6.1
Multiple
compliance
options
2.6.1.1
Comment:
Commenter
IV­
D­
45
pointed
out
that
although
EPA
has
presented
several
compliance
options,
there
are
so
many
restrictions
on
each
one
that
many
facilities
may
only
have
one
choice
for
compliance.
The
commenter
asserted
that
a
facility
without
add­
on
controls
cannot
choose
the
emissions
averaging
compliance
option,
and
that
a
facility
with
add­
on
controls
cannot
choose
the
PBCO.

Commenter
IV­
D­
03
questioned
whether
or
not
it
would
be
possible
under
current
regulations
to
apply
different
compliance
options
to
process
units
with
multiple
emission
points.

The
commenter
specifically
referred
to
multistage
tube
dryers,
which
have
multiple
emission
points
but
are
defined
as
one
process
unit
under
the
proposed
rule.

Response:
We
disagree
with
the
commenter's
assertion
that
there
are
too
many
restrictions
on
the
compliance
options
and
maintain
that
the
final
PCWP
rule
provides
maximum
compliance
flexibility
for
PCWP
sources
subject
to
this
NESHAP.
The
proposal
preamble
states
in
63.2240
that
"
You
cannot
use
multiple
compliance
options
for
a
single
process
unit.
(
For
example,
you
cannot
use
a
production­
based
compliance
option
for
one
vent
of
a
veneer
dryer
and
an
add­
on
control
system
compliance
option
for
another
vent
on
the
same
veneer
dryer.
You
must
use
either
the
production­
based
compliance
option
or
an
add­
on
control
system
compliance
option
for
the
entire
dryer.)"
However,
this
restriction
does
not
apply
to
the
PCWP
facility
as
a
whole,
such
that
PCWP
facilities
have
the
flexibility
of
complying
with
different
options
for
different
process
units.
For
example,
a
PCWP
facility
may
choose
to
comply
with
a
PBCO
for
one
of
their
presses,
comply
with
an
add­
on
control
systems
option
for
one
dryer,
and
include
another
dryer
in
an
emissions
averaging
plan
with
a
blender
(
e.
g.,
control
blender
emissions
and
apply
no
controls
to
the
dryer
emissions,
or
undercontrol
emissions
from
both
units.).
Also,
the
2­
103
final
rule
has
modified
language
in
§
63.2240
to
clarify
that
the
restriction
regarding
application
of
multiple
compliance
options
does
not
apply
to
individual
process
units
complying
solely
with
the
add­
on
control
system
compliance
options
(
see
response
to
comment
No.
2.6.2.1)]

Regarding
other
restrictions
noted
by
the
commenter,
the
emissions
averaging
provisions
require
that
credit­
generating
sources
be
equipped
with
add­
on
controls
because
determining
the
actual
emission
reduction
from
pollution
prevention
techniques
can
be
very
difficult
and
contentious,
and
other
compliance
options
are
available
to
accommodate
pollution
prevention
techniques
(
i.
e.,
PBCOs).
We
also
note
that
debit­
generating
sources
may
be
uncontrolled
or
under
controlled
process
units
in
an
emissions
averaging
plan.
Thus,
emissions
averaging
plans
will
include
a
mix
of
controlled,
uncontrolled,
and
undercontrolled
process
units.
Regarding
the
restrictions
on
the
use
of
PBCOs,
we
developed
these
options
specifically
to
address
the
need
for
compliance
alternatives
for
the
future
development
of
pollution
prevention
techniques.
The
use
of
the
PBCOs
is
not
allowed
for
process
units
equipped
with
add­
on
controls.
We
also
note
that
sources
equipped
with
add­
on
control
systems
have
six
compliance
options
available
to
them
in
addition
to
the
option
of
being
part
of
an
emissions
averaging
plan.
(
See
also
responses
to
comments
2.6.3.2
and
2.6.4.5.)

Regarding
application
of
multiple
compliance
options
to
multistage
tube
dryers,
we
note
that,
unlike
the
proposed
rule,
the
final
rule
distinguishes
between
primary
and
secondary
tube
dryers
(
see
response
to
comment
2.1.2.2).
Therefore,
a
PCWP
facility
may
select
different
compliance
options
for
the
primary
and
secondary
tube
dryers.

2.6.2
Add­
on
control
systems
compliance
options
2.6.2.1
Comment:
Commenter
IV­
D­
19
supported
multiple
compliance
options
for
addon
control
systems
because
of
the
flexibility.
However,
another
commenter
(
IV­
D­
04)
argued
that
the
use
of
multiple
compliance
options
for
add­
on
control
systems
will
make
it
difficult
to
determine
if
a
facility
is
actually
in
compliance.
The
commenter
pointed
out
that,
according
to
the
preamble,
if
a
facility
tested
for
two
options
but
passed
only
one,
they
would
still
be
in
compliance.
However,
if
a
facility
chose
to
only
test
for
one
option
and
then
failed
that
test,
it
is
unclear
if
EPA
would
consider
that
facility
to
be
in
violation
or
if
another
test
could
be
run
for
a
different
option.
The
commenter
stated
that
in
that
situation,
they
would
contend
that
there
had
been
a
violation
of
the
standard,
and
any
retesting
to
determine
compliance
with
a
different
option
2­
104
would
not
reverse
the
initial
violation.
Therefore,
the
commenter
requested
that
EPA
clarify
that
the
option
to
use
the
"
most
beneficial"
results
of
two
or
more
test
methods
applies
only
when
these
tests
are
conducted
during
a
single
performance
test.
According
to
the
commenter,
any
facility
that
chose
to
use
only
one
test
method
during
the
compliance
test
would
have
to
accept
the
results
of
that
test.

Commenters
IV­
D­
27
and
IV­
D­
21
argued
that
a
facility
should
be
able
to
switch
between
the
six
add­
on
control
options
as
needed
to
maintain
compliance.
To
illustrate
the
necessity
of
the
ability
to
switch
from
one
add­
on
control
option
to
another,
the
commenters
provided
an
example
whereby
the
operator
of
a
veneer
dryer
might
want
to
demonstrate
compliance
with
the
90
percent
THC
reduction
option
(
option
1)
under
certain
operating
conditions
and
with
the
20
ppmv
THC
option
(
option
2)
under
other
operating
conditions.
Commenter
IV­
D­
21
also
noted
that
production
starts,
stops,
and
minor
malfunctions
are
common
at
PCWP
facilities,
and
most
of
them
do
not
affect
the
performance
of
the
air
pollution
control
device.
However,
frequent
SSM
events
resulting
in
a
low
concentration
to
the
inlet
of
the
control
device
could
affect
a
facility's
ability
to
comply
with
the
percent
reduction
option.
In
this
case,
the
commenter
stated
that
the
freedom
to
switch
compliance
options
would
be
valuable.
For
these
reasons,
the
commenters
requested
that
EPA
explicitly
state
in
the
PCWP
rule
that
"
a
facility
only
need
comply
with
any
one
of
the
six
options
at
any
one
time,
and
that
it
can
change
between
them
as
needed
to
fit
process
operating
conditions."

Response:
The
proposed
rule
states
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,
and
that
at
any
point
in
time
for
purposes
of
assessing
compliance,
the
given
compliance
option
will
have
been
pre­
selected
and
reflected
as
applicable
in
the
sources
permit.

In
fact,
in
discussions
with
industry
representatives
prior
to
proposal,
they
expressed
concern
that
2­
105
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
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
sources
permit
(
e.
g.,
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
average
RTO
temperature
during
a
three­
run
test)

would
then
be
set
as
the
operating
limit
in
the
permit
for
that
source.
In
this
example,
if
the
RTO
operating
temperature
drops
below
the
operating
limit,
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
commenter
IV­
D­
04
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
with
the
commenter
that,
if
a
facility
selects
multiple
options
under
the
compliance
options
for
add­
on
control
systems,
then
they
should
be
required
to
conduct
all
necessary
testing
associated
with
compliance
with
the
selected
options.
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
2­
106
a
single
time
frame.
For
example,
if
the
source
wishes
to
include
options
1,
3,
and
5
in
their
permit,
then
they
must
perform
inlet
and
outlet
testing
for
THC,
methanol,
and
formaldehyde
anytime
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
all
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
preestablished
as
applicable
at
a
later
date.

Because
different
States
may
wish
to
implement
the
final
rule
differently,
the
final
rule
does
not
specify
that
States
must
allow
compliance
with
all
6
options
"
at
any
given
time,"
and
therefore,
the
specifics
of
compliance
demonstrations
and
permit
conditions
for
facilities
that
can
meet
multiple
options
for
add­
on
control
systems
will
be
left
to
the
State
agencies.
However,
as
mentioned
in
the
response
to
the
previous
comment
(
No.
2.6.1.1),
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
§
63.2440
of
the
final
rule
has
been
modified
as
follows
(
deletions
in
strikeout,
additions
in
italics):

"...
You
cannot
use
multiple
compliance
options
combine
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
dryer.]"

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
the
potential
for
PCWP
facilities
to
be
able
to
include
multiple
compliance
options
for
add­
on
control
systems
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
2­
107
the
six
options
for
add­
on
control
systems.
Therefore,
the
final
rule
does
not
prevent
sources
from
establishing
multiple
compliance
options
for
add­
on
control
systems
in
their
permits.

2.6.2.2
Comment:
Commenters
IV­
D­
21
and
IV­
D­
27
stated
that,
if
switching
between
the
six
add­
on
control
system
compliance
options
is
not
allowed,
then
EPA
must
allow
a
long
compliance
averaging
time.
The
commenters
noted
that
the
proposed
rule
does
not
specify
any
compliance
averaging
period
for
the
add­
on
control
systems
compliance
options.
The
commenters
contended
that,
even
if
a
facility
follows
all
of
the
guidelines
to
ensure
continuous
compliance,
there
will
probably
be
short
periods
of
time
in
which
the
inlet
to
the
control
device
has
a
low
HAP
concentration
and
the
facility
does
not
meet
the
requirement
of
the
compliance
option,
although
they
may
meet
the
requirements
of
the
"
Indicators
of
Performance"
section
of
the
rule.
The
commenters
stated
that,
if
EPA
chooses
not
to
incorporate
a
long
compliance
averaging
period,
then
the
add­
on
control
system
compliance
options
should
only
apply
for
initial
certification
testing,
and
thereafter,
the
operating
requirements
should
apply.
To
demonstrate
the
necessity
for
the
one­
week
averaging
period,
commenter
IV­
D­
27
noted
that
a
rotary
dryer
that
normally
meets
the
90
percent
THC
removal
condition
may
have
compliance
problems
when
dryer
production
is
reduced
because
of
problems
elsewhere
on
the
production
line.
The
commenter
explained
that
the
generation
rate
of
HAP
emissions
from
rotary
dryers
is
a
strong
function
of
the
dryer
inlet
temperature.
The
inlet
temperature
is
a
function
of
the
production
rate.

The
concentration
of
HAP
in
the
dryer
exhausts
are
doubly
affected
by
reduced
production
rates
because
the
air
flow
normally
remains
constant
while
the
lbs/
unit
production
decreases
with
the
lower
inlet
temperature.
The
commenter
stated
that,
during
periods
of
low
production,
the
facility
may
be
unable
to
meet
any
of
the
options
for
add­
on
control
devices,
and
thus
could
be
found
in
violation
of
the
standards.

Commenter
IV­
D­
27
stated
that
an
averaging
period
needs
to
be
specified
to
allow
a
manager
to
certify
continuous
compliance
through
a
range
of
operating
conditions.
The
commenter
contended
that
the
averaging
period
should
be
no
shorter
than
one
week
to
accommodate
extended
periods
of
operation
where
emission
concentrations
from
the
process
are
low.
The
commenter
stated
that
the
data
used
to
establish
the
floor
only
included
process
units
operating
at
maximum
capacity
and
did
not
reflect
the
full
operating
range
of
the
processes
being
tested.
The
commenter
also
pointed
out
that
"
at
a
very
minimum,
a
24­
hour
averaging
period
is
2­
108
needed
to
recover
from
a
three­
hour
period
with
very
low
inlet
emissions
to
the
control
device.
If
there
is
more
than
one
period
of
low
inlet
concentrations,
then
a
longer
averaging
period
is
needed."

Response:
We
disagree
with
the
commenters'
request
to
extend
the
averaging
period
for
compliance
testing
and
operating
parameter
monitoring.
The
"
averaging
period"
for
the
initial
performance
test
is
three
hours
because
the
rule
requires
a
minimum
of
three
one­
hour
test
runs,

and
the
average
of
these
three
runs
is
used
to
determine
compliance.
Like
the
proposed
rule,
the
final
rule
requires
an
initial
performance
test,
and
during
that
initial
compliance
test,
the
average
value
of
the
operating
parameter
(
e.
g.,
temperature)
is
set
as
the
operating
limit.
Because
the
performance
test
is
based
on
the
average
of
three
one­
hour
test
runs,
the
operating
limit
value
is
also
based
on
a
three­
hour
average.
As
noted
in
the
response
to
the
previous
comment,
sources
may
conduct
multiple
performance
tests
in
order
to
establish
an
operating
limit
that
provides
them
with
the
most
operating
flexibility.
Following
the
initial
compliance
test(
s),
the
facility
is
required
to
comply
with
the
operating
parameter
limit.
No
additional
performance
testing
is
required.

However,
if
the
facility
expects
to
be
operating
under
different
conditions,
such
that
maintaining
the
APCD
at
or
above
the
minimum
temperature
would
not
ensure
compliance
with
the
chosen
compliance
option,
then
the
facility
can
conduct
additional
testing
under
the
different
operating
conditions
to
demonstrate
compliance
with
a
different
compliance
option
and
a
different
operating
parameter
limit
that
can
be
met
under
the
alternate
operating
conditions.
In
such
cases,
the
facility
would
need
to
be
able
to
document
when
the
source
is
operating
under
each
set
of
conditions
and
maintain
separate
records
for
each
operating
scenario.
We
also
note
that
option
2
under
the
compliance
options
for
add­
on
controls
systems
(
i.
e.,
limit
APCD
outlet
emissions
of
THC
to
20
ppmvd)
can
be
used
to
address
situations
where
the
inlet
emissions
are
very
low
because
there
are
no
minimum
inlet
THC
concentration
requirements
for
this
control
option.

Because
the
performance
tests
are
based
on
a
three­
hour
average
and
facilities
are
allowed
to
establish
different
operating
parameter
limits
under
different
operating
scenarios,
the
final
rule
retains
the
three­
hour
averaging
period
for
operating
parameter
limits.
(
See
also
responses
to
related
comments
on
compliance
averaging
periods
in
Section
2.7.)

2.6.2.3
Comment:
Commenters
IV­
D­
03,
IV­
D­
19,
IV­
D­
21,
and
IV­
D­
27
noted
the
apparent
redundancy
between
options
3
and
4
and
options
5
and
6
in
Table
1B
to
Subpart
DDDD
2­
109
of
the
proposed
rule
(
Add­
on
Control
System
Compliance
Options).
Commenters
IV­
D­
21
and
IV­
D­
27
stated
that
the
preamble
to
the
proposed
rule
implies
that
EPA
did
not
intend
for
these
options
to
be
redundant,
especially
for
streams
with
low
HAP
concentrations.
The
proposed
preamble
stated,
"[
i]
n
general,
applying
an
incineration­
based
MACT
control
system
to
a
process
unit
that
emits
high
concentrations
of
HAP
and
THC
will
result
in
a
greater
percentage
of
emissions
reductions
than
if
that
same
incineration­
based
MACT
control
system
was
applied
to
a
process
unit
that
emits
lower
concentrations
of
HAP
and
THC."
The
commenters
noted
that
only
options
3
and
5
actually
state
that
they
require
90
percent
reduction
of
methanol
and
formaldehyde,
but
because
options
4
and
6
require
an
inlet
concentration
of
greater
than
10
ppm
and
an
outlet
concentration
of
less
than
1
ppm
of
the
controlled
HAP,
all
four
of
them
technically
require
90
percent
destruction.
Therefore,
the
commenters
argued
that
the
rule
is
contradictory
in
that
it
recognizes
that
streams
with
low
concentrations
are
difficult
to
treat
but
still
requires
a
high
level
of
control
for
those
streams.

To
address
the
redundancy,
the
commenters
suggested
that
options
4
and
6
be
modified
to
allow
lower
control
efficiencies
for
methanol
and
formaldehyde.
Commenter
IV­
D­
27
provided
a
scatter
plot
of
pollutant
removal
efficiency
data
versus
inlet
concentration
for
methanol
and
formaldehyde
emissions
treated
with
RTOs/
RCOs
to
show
that
some
RTOs/
RCOs
achieved
less
than
a
90
percent
reduction
of
methanol
and
formaldehyde
when
the
inlet
concentration
of
these
pollutants
was
below
10
ppm.
The
commenter
also
provided
RTO/
RCO
inlet
and
outlet
concentration
data
for
methanol
and
formaldehyde.
The
inlet
data
ranged
from
approximately
1
ppm
to
50
ppm,
and
the
outlet
data
ranged
from
less
than
1
ppm
to
approximately
6
ppm.

Commenter
IV­
D­
27
stated
that,
based
on
these
data,
most
RTOs
are
capable
of
achieving
an
outlet
formaldehyde
concentration
less
than
2
ppm
when
the
inlet
concentration
is
less
than
10
ppm
and
less
than
1
ppm
methanol
when
the
inlet
concentration
of
methanol
is
less
than
10
ppm.

The
commenter
also
stated
that
RCOs
are
only
capable
of
meeting
less
than
3
ppm
formaldehyde
in
the
outlet,
regardless
of
the
inlet
concentration.
The
commenter
acknowledged
EPA's
concerns
about
circumvention
of
the
rule
by
sources
that
would
install
controls
that
had
little
or
no
effect
on
HAP
emissions
if
the
rule
did
not
contain
minimum
concentration
requirements
at
the
control
device
inlet
for
options
4
and
6.
The
commenters
recommended
that
the
minimum
concentration
requirements
be
retained,
but
at
a
lower
value
greater
than
or
equal
to
the
outlet
2­
110
limit.
Specifically,
the
commenters
recommended
the
following
modification
to
the
wording
in
Table
1B
to
Subpart
DDDD,
Add­
on
Control
Systems
Compliance
Options:

(
4)
Limit
methanol
emissions
to
less
than
or
equal
to
1
ppmvd,
rounded
to
the
nearest
single
significant
digit,
if
uncontrolled
methanol
emissions
entering
the
control
device
are
greater
than
1
ppm.
***
(
6)
Limit
formaldehyde
emissions
to
less
than
or
equal
to
2
ppmvd,
rounded
to
the
nearest
single
significant
digit,
if
uncontrolled
methanol
emissions
entering
the
control
device
are
greater
than
2
ppm.

The
commenter
further
noted
that
if
a
facility
has
emissions
above
the
applicability
limit
for
either
methanol
or
formaldehyde
but
below
for
the
other,
it
should
be
required
to
treat
the
HAP
that
is
above
the
limit.
If
the
emissions
levels
are
both
below
the
limit,
then
the
facility
can
probably
meet
the
requirements
for
the
applicable
PBCO.

Response:
In
other
rules,
we
have
historically
addressed
control
device
performance
issues
at
varying
concentrations
by
offering
two
control
options
 
one
in
the
form
of
a
percent
reduction
and
the
other
in
the
form
of
a
maximum
outlet
concentration
level
 
with
the
idea
that
well­
controlled
sources
could
meet
one
or
the
other,
but
not
always
both.
Due
to
the
variability
in
PCWP
emissions
and
relatively
dilute
streams,
three
"
percent
reduction"
options
and
three
"
outlet
concentration"
options
were
provided
in
the
proposed
rule.
The
predominant
pollutant
emitted
from
PCWP
sources
is
THC;
however,
options
for
the
two
predominant
HAP,
methanol
and
formaldehyde,
were
added
for
those
sources
that
emitted
these
HAP
in
quantities
sufficient
to
serve
as
a
total
HAP
surrogate
for
determining
control
device
performance.
We
elected
not
to
require
testing
for
total
HAP
because
the
two
MACT
technologies
in
use
(
incineration
and
biofiltration)
are
effective
in
reducing
emissions
of
all
six
of
the
pollutants
that
comprise
"
total
HAP"
as
defined
in
the
rule,
such
that
a
single
(
predominant)
HAP
emitted
from
a
given
source
would
be
a
good
surrogate
for
determining
the
control
device
performance.

We
disagree
with
the
commenter's
assertion
that
options
4
and
6
are
redundant
to
options
3
and
5
and
that
the
inlet
concentration
restrictions
in
options
4
and
6
should
be
lowered.
First,

we
established
the
10
ppmvd
minimum
inlet
concentration
for
options
4
and
6
to
avoid
having
a
source
base
compliance
on
a
pollutant
that
was
not
present
in
sufficient
quantities
and
to
avoid
the
use
of
control
devices
that
have
little
or
no
ability
to
consistently
reduce
HAP
emissions.
Many
NESHAP
require
sources
to
base
compliance
on
the
primary
pollutant
to
minimize
measurement­
2­
111
related
issues
such
as
concentrations
near
method
detection
limits
and
rounding
of
emissions
data
into
compliant
ranges.
We
believe
that
compliance
with
a
NESHAP
should
not
be
based
on
a
pollutant
that
is
only
present
in
quantities
close
to
the
detection
limit.
We
also
note
that
the
control
efficiencies
are
determined
based
on
mass
of
pollutant
at
the
control
device
inlet
and
outlet,
not
the
concentration,
and
thus,
a
control
device
with
an
inlet
pollutant
concentration
of
10
ppmvd
coupled
with
an
outlet
concentration
of
1
ppmvd
does
not
necessarily
correspond
to
a
90
percent
reduction
in
emissions.
Second,
if
inlet
and
outlet
requirements
are
set
at
the
same
values
(
e.
g.,
1
ppm)
as
suggested
by
the
commenters,
no
emissions
reduction
would
be
required,
and
ineffective
or
poorly
operating
emission
control
devices
could
be
used
to
comply
with
the
standards.
We
note
that
data
supplied
by
the
PCWP
industry
show
that
the
flow
rate
at
the
outlet
of
the
control
device
can
be
more
than
35
percent
higher
than
the
inlet
flow
rate,
which
creates
a
dilution
effect
on
the
outlet
pollutant
concentration.
11
Thus,
the
combination
of
lowered
minimum
inlet
concentration
requirements,
dilution
effects,
and
beneficial
rounding
to
the
"
nearest
significant
digit"
would
render
control
options
4
and
6
equivalent
to
"
no
control."
Third,
we
note
that
there
are
six
compliance
options
for
sources
equipped
with
add­
on
controls
(
in
addition
to
emissions
averaging),
and
a
review
of
the
available
data
show
that
every
RTO,
RCO
and
biofilter
could
meet
at
least
one
of
these
six
options,
with
some
RTOs
meeting
five
of
the
six
options.
20,22
The
available
data
also
show
that
some
RTOs
with
inlet
methanol
or
formaldehyde
emissions
less
than
10
ppmvd
can
achieve
90
percent
reduction
in
emissions.
20,22
We
further
note
that
sources
are
only
required
to
meet
one
of
the
six
options
for
add­
on
controls,
and
thus,
a
facility
that
is
unable
to
use
options
4
and/
or
6
due
to
low
inlet
concentrations
still
has
at
least
four
compliance
options
available
to
them.
For
these
reasons,
we
retained
the
six
proposed
compliance
options
for
add­
on
control
systems
in
the
final
rule.

2.6.3
Production­
based
compliance
options
(
PBCO)

2.6.3.1
Comment:
Commenters
IV­
D­
19,
IV­
D­
27,
and
IV­
D­
56
stated
that
facilities
should
be
allowed
to
neglect
nondetect
HAP
measurements
for
PBCO
calculations.
Commenters
IV­
D­
19
and
IV­
D­
27
stated
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.
These
two
commenters
also
noted
that
the
detection
levels
measured
in
the
field
by
the
NCASI
IM/
CAN/
WP­
99.01
generally
range
between
0.35
ppm
and
1
ppm,
and
the
results
of
the
Fourier
transform
infrared
(
FTIR)
2­
112
methods
average
about
1
ppm.
Because
these
detection
levels
are
higher
than
the
levels
achieved
in
the
lab,
the
one­
half
detection
levels
that
plants
must
use
in
their
calculations
are
higher
than
the
theoretical
values
used
to
set
the
limits.
The
commenter
provided
a
sample
calculation
to
demonstrate
the
effect
that
the
detection
level
has
on
the
compliance
calculation.
Commenter
IVD
56
noted
that
only
10
percent
of
the
one­
half
nondetect
level
was
used
to
establish
the
PBCO
limits,
but
facilities
must
add
the
full
amount
of
the
one­
half
level
in
emissions
calculations.

Commenters
IV­
D­
19
and
IV­
D­
27
suggested
that
if
EPA
does
not
agree
to
allow
facilities
to
neglect
nondetect
HAP
data
altogether,
then
EPA
should
at
least
allow
facilities
to
multiply
the
detection
level
by
0.05
to
achieve
a
value
that
is
10
percent
of
the
one­
half
detection
limit
level.

Response:
The
PBCO
was
established
to
allow
for
the
future
development
of
pollution
prevention
alternatives
and
to
avoid
the
installation
of
add­
on
control
systems
on
inherently
lowemitting
sources
that
achieve
MACT
level
performance
through
pollution
prevention
After
reviewing
the
total
HAP
data
used
to
establish
the
PBCO
limits,
we
decided
to
allow
sources
to
treat
nondetect
measurements
for
an
individual
HAP
as
zero
for
the
sole
purpose
of
determining
compliance
with
the
PBCO,
if
the
following
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.
23
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.
24
We
included
the
second
condition
to
ensure
that
the
source
is
truly
low­
emitting,
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
addon
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
result,
the
PBCO
limit
for
reconstituted
wood
product
2­
113
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.

2.6.3.2
Comment:
Commenter
IV­
D­
23
supported
the
inclusion
of
the
PBCO
in
the
rule
as
pollution
prevention
compliance
options,
noting
that
pollution
prevention
is
"
always
preferred
over
pollution
control."
Commenters
IV­
D­
19
and
IV­
D­
27
also
approved
of
the
inclusion
of
a
PBCO,
but
suggested
that
facilities
be
allowed
to
use
add­
on
control
methods
to
achieve
PBCO
limits
to
make
the
PBCO
a
better
P2
method.
Commenters
IV­
D­
28
and
IV­
D­
43
concurred.

Commenters
IV­
D­
19
and
IV­
D­
27
provided
rationale
to
support
their
recommendation.

First,
both
commenters
stated
that
allowing
add­
on
controls
is
consistent
with
the
development
of
the
PBCO
for
the
PCWP
rule.
According
to
the
commenters,
the
high
costs,

secondary
emissions
and
energy
requirements
associated
with
the
use
of
add­
on
controls,

combined
with
the
low
toxicity
and
concentration
of
the
regulated
HAP
prompted
EPA
to
include
an
option
based
on
P2
as
an
alternative
to
mandatory
use
of
add­
on
controls.
Commenter
IV­
D­

27
quoted
the
following
text
from
the
document
Development
of
Production­
Based
Emission
Limits
for
Plywood
and
Composite
Wood
Products
Process
Units
(
Docket
#
II­
B­
32,
hereafter
referred
to
as
the
PBCO
memo),
"[
t]
he
emission
limits
should
not
be
set
so
low
that
already
wellcontrolled
process
units
could
not
meet
the
limits;
and
conversely,
the
limits
should
not
be
set
so
high
that
uncontrolled
process
units
could
easily
meet
the
limits."
The
commenter
interpreted
that
text
to
mean
that
EPA
intended
that
these
PBCO
limits
would
be
applicable
to
process
units
with
add­
on
controls
in
place
and
that
uncontrolled
units
would
have
to
apply
"
significant
measures"
to
meet
the
limits.
The
commenter
asserted
that
the
referenced
document
did
not
place
any
restrictions
on
the
methodology
by
which
PBCO
limits
would
be
met.

Second,
the
commenter
contended
that
including
add­
on
controls
in
the
PBCO
is
consistent
with
other
MACT
rules
and
P2
approaches.
According
to
the
commenter,
numerous
recent
NESHAP,
including
Printing
and
Publishing
Industry;
Leather
Finishing
Operations;
Amino
and
Phenolic
Resins
Production;
Wood
Building
Products
Surface
Coating
Operations
(
proposed);
Printing,
Coating,
and
Dying
of
Fabrics
(
proposed);
Large
Appliances
Surface
Coating
Operations
(
proposed);
Paper
and
Other
Web
Coating;
and
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations,
allow
emissions
limits
to
be
reached
using
add­
on
controls,
P2
techniques,
or
a
combination
of
both.
Similarly,
the
Wool
Fiberglass
Manufacturing
2­
114
NESHAP
does
not
specify
how
a
facility
must
meet
the
production­
based
emission
limits.
The
commenter
stated
that
there
is
"
no
legal
or
policy
basis
to
impose
restrictions
on
the
use
of
PBCO
in
the
PCWP
MACT
that
were
not
deemed
necessary
in
any
of
these
other
MACT
standards."

Third,
the
commenter
contended
that
allowing
add­
on
control
methods
supports
those
facilities
trying
to
achieve
compliance
through
P2
methods.
The
commenter
noted
that
the
PBCO
memo
states
that,
if
add­
on
controls
were
used
to
achieve
PBCO
limits,
then
the
industry
would
have
no
incentive
for
developing
P2
techniques.
However,
the
commenter
disagreed
and
suggested
that
EPA
view
add­
on
controls
from
a
"
continuous
compliance"
perspective.

According
to
the
commenter,
the
selective
use
of
a
MACT­
level
add­
on
control
is
a
legitimate
P2
technique
to
compensate
for
a
minor
emission
reduction
shortfall
of
a
process
P2
strategy
or
to
provide
a
compliance
safety
margin
for
a
similar
P2
strategy
whose
ability
to
deliver
continuously
certifiable
compliance
might
be
threatened
by
such
things
as
seasonal
variability
of
raw
materials.

The
commenter
contended
that
such
an
approach
would
provide
the
necessary
incentive
for
sources
to
invest
in
innovative
P2
techniques
by
providing
protection
against
noncompliance
action
during
the
technology
development
process.
