1
­­­­­
Forwarded
by
DonaldF
Anderson/
DC/
USEPA/
US
on
12/
18/
03
09:
15
­­­­­

DonaldF
Anderson
To:
"
Hunt,
Tim"
<
Tim_
Hunt@
afandpa.
org>
cc:
"
Schwartz,
Jerry"
<
Jerry_
Schwartz@
afandpa.
org>
Subject:
Re:
Plywood
MACT
and
zero
discharge(
Document
link:
DonaldF
Anderson)
12/
18/
03
09:
17
Tim
­

I
got
the
file.
We
will
consider
the
suggestions
in
the
file.
Happy
holidays,

Don
"
Hunt,
Tim"
<
Tim_
Hunt@
afandpa.
org>
To:
DonaldF
Anderson/
DC/
USEPA/
US@
EPA
cc:
"
Schwartz,
Jerry"
<
Jerry_
Schwartz@
afandpa.
org>
Subject:
Plywood
MACT
and
zero
discharge
12/
17/
03
17:
09
Don,

Here
are
the
clarifications
on
the
zero
discharge
issue
for
Plywood
MACT
that
Jerry
promised
earlier
this
month.
They
are
pretty
self
explanatory
with
actual
rule
language
working
from
the
original
proposal
and
explanations
for
the
changes.
If
you
would
like
to
talk
about
them
at
all,
let
us
know.
I
am
out
after
Monday
for
the
rest
of
the
year,
so
it
might
need
to
happen
after
the
first
of
the
year.
If
everything
is
OK,
it
would
be
good
to
know
that
as
well.

Thanks
in
advance
for
your
help.

Happy
Holidays.

<<
zero
discharge
final
rule
language
12­
17­
03.
DOC>>

Timothy
Hunt
Senior
Director,
Air
Quality
Programs
American
Forest
and
Paper
Association
Suite
800
1111
19th
St.,
NW
Washington,
DC
20036
phone:
202­
463­
2588
fax:
202­
463­
2423
Tim_
Hunt@
afandpa.
org
(
See
attached
file:
zero
discharge
final
rule
language
12­
17­
03.
DOC)
2
Replacement
for
existing
40
CFR
§
429.11(
c)
(
AF&
PA
additions
to
EPA
1/
9/
03
preamble
shown
in
italics):

The
term
"
process
wastewater"
specifically
excludes
non­
contact
cooling
water,
material
storage
yard
runoff
(
either
raw
material
or
processed
wood
storage),
boiler
blowdown,
and
wastewater
from
air
pollution
control
devices
installed
or
used
by
facilities
in
subparts
B,
C,
D,
and
M
of
this
part
to
comply
with
the
proposed
or
final
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.
An
air
pollution
control
device
installed
or
used
to
comply
with
the
proposed
or
final
PCWP
NESHAP
is
a
device
that
reduces
the
amount
of
a
hazardous
air
pollutant
emitted
into
the
air
(
including
any
appurtenant
equipment
needed
to
capture
or
transport
exhaust
gases
containing
hazardous
air
pollutants
to
such
a
device),
the
operation
of
which
is
necessary
to
reduce
emissions
of
hazardous
air
pollutants
below
the
emission
limitations
set
forth
in
the
PCWP
NESHAP,
or
below
the
level
at
which
those
emissions
are
not
subject
to
the
emission
limitations
set
forth
in
the
PCWP
NESHAP.

Possible
Preamble
Language:

As
discussed
in
the
preamble
to
the
proposed
PCWP
MACT
rule,
EPA
has
considered
industry's
request
that
EPA
amend
the
effluent
guidelines
applicable
to
many
PCWP
facilities
and
contained
in
40
CFR
part
429.
Those
effluent
guidelines
for
a
number
of
subcategories
prohibit
the
discharge
of
process
wastewater
pollutants
into
navigable
waters
of
the
United
States.
Certain
types
of
wastewaters
are
excluded
from
this
discharge
prohibition,
but
wastewater
from
operation
and
maintenance
of
air
pollution
control
equipment
is
not
mentioned
in
the
exclusions.
Industry
argued
that
compliance
with
the
PCWP
MACT
rule
could
generate
substantial
quantities
of
wastewater
that
were
never
contemplated
by
EPA
when
EPA
determined
that
the
zero
discharge
of
process
wastewater
effluent
guidelines
were
achievable
with
Best
Available
Technology.
EPA
has
confirmed
that
operation
and
maintenance
of
the
types
of
emission
control
devices
on
which
the
PCWP
standards
are
based
could
result
in
the
generation
of
significant
quantities
of
wastewater
beyond
those
considered
by
EPA
when
it
determined
that
elimination
of
the
discharge
of
process
wastewater
pollutants
was
practicable.
Thus,
EPA
is
today
amending
the
effluent
guidelines
to
exclude
from
the
definition
of
"
process
wastewater"
those
wastewaters
generated
by
operation
and
maintenance
of
technology
to
meet
the
PCWP
NESHAP.

Equipment
that
reduces
emissions
to
meet
the
limitations
on
hazardous
air
pollutant
emissions
in
the
proposed
or
final
PCWP
NESHAP
is
covered
by
this
exclusion.
So
is
equipment
needed
to
reduce
or
maintain
HAP
emissions
below
3
applicability
thresholds,
or
to
allow
the
source
to
qualify
for
a
risk­
based
alternative
to
specified
HAP
emission
limitations.
An
"
air
pollution
control
device"
is
any
equipment
that
reduces
the
quantity
of
a
hazardous
pollutant
that
is
emitted
to
the
air,
and
it
also
includes
any
equipment
that
captures
or
transports
HAP
emissions
to
a
device
for
destruction
or
recovery.
Some
examples
of
the
types
of
equipment
that,
if
used
to
comply
with
the
PCWP
NESHAP,
would
have
wastewater
exempted
from
the
discharge
prohibition
in
the
effluent
guidelines
are
RTOs,
TCOs,
and
other
types
of
thermal
destruction
devices;
boilers
or
other
combustion
units
used
to
burn
process
exhaust
gases;
biofilters;
condensers;
and
the
hoods,
vents,
and
ductwork
that
captures
exhaust
gases
containing
hazardous
air
pollutants
and
transports
it
to
a
control
device,
including
particulate
removal
equipment,
such
as
a
wet
electrostatic
precipitator,
that
is
operated
as
part
of
a
thermal
oxidation
system
to
reducing
the
particulate
loading
on
the
thermal
oxidation
device.

In
the
absence
of
applicable
effluent
guidelines,
the
discharge
of
wastewater
to
waters
of
the
United
States
from
the
operation
and
maintenance
of
pollution
control
equipment
covered
by
this
exclusion
would
be
subject
to
discharge
allowances
in
individual
NPDES
permits.
The
actual
discharge
allowances
would
be
determined
initially
on
a
case­
by­
case
basis
by
NPDES
permitting
authorities
using
their
best
professional
judgment
(
see
40
CFR
§
125.3).
EPA
will
consider,
through
the
CWA
section
304(
m)
planning
process,
whether
it
is
appropriate
to
revise
part
429
at
a
later
time
in
order
to
establish
category­
or
subcategory­
specific
effluent
limitations
and
standards
for
such
air
pollution
control
wastewater
discharges.
Wastewater
from
operation
and
maintenance
of
air
pollution
control
equipment
used
to
comply
with
the
PCWP
NESHAP
at
wet
process
hardboard
mills,
40
C.
F.
R.
part
429
subpart
E,
will
continue
to
be
subject
to
the
discharge
allowances
in
the
effluent
limitations
guidelines
contained
in
that
subpart.

AF&
PA
Explanation
AF&
PA
does
not
believe
that
listing
particular
types
of
air
pollution
control
equipment
in
the
regulation
is
necessary
or
advisable
for
several
reasons.
Most
importantly,
any
list
may
result
in
permit
writers
deciding
that
other
types
of
equipment
not
listed
should
not
be
subject
to
the
exclusion
from
zero
discharge,
which
could
obstruct
the
use
of
innovative
technologies
to
comply
with
the
PCWP
NESHAP.
Instead
of
listing
specific
equipment,
we
have
used
descriptive
terminology
similar
to
the
definitions
of
"
control
system"
and
"
control
device"
in
the
proposed
PCWP
NESHAP.

It
was
suggested
that
the
exclusion
should
apply
only
to
subparts
C
(
Plywood),
D
(
Dry
Process
Hardboard),
and
M
(
Particleboard).
AF&
PA
understands
the
logic
of
not
extending
the
exclusion
to
subpart
E
(
Wet
Process
Hardboard)
(
although
for
new
wet
process
hardboard
mills,
which
are
subject
to
a
zero
discharge
NSPS,
special
efforts
will
4
have
to
be
taken
in
designing
the
mill
to
allow
use
of
the
air
pollution
control
equipment
wastewater
within
the
confines
of
a
zero
discharge
requirement).
Subparts
F
through
L
and
N
through
P
apply
to
operations
not
subject
to
the
PCWP
MACT
standards,
so
the
exclusion
should
not
apply
to
them,
either.
Subpart
B
(
Veneer)
appears
to
be
subject
to
MACT
standards
for
veneer
dryers,
however.
Thus,
veneer
mills
will
encounter
the
same
kinds
of
increased
wastewater
loading
from
the
MACT
controls
on
their
veneer
dryers
that
facilities
in
other
subcategories,
such
as
plywood
mills,
will
face.
AF&
PA
is
not
aware
of
any
reason
for
treating
veneer
mills
differently;
they
should
be
part
of
the
exclusion
for
air
pollution
control
wastewaters,
also.

AF&
PA
has
inserted
language
to
clarify
that
the
exclusion
from
zero
discharge
for
air
pollution
control
wastewaters
applies
to
equipment
used
to
reduce
HAP
emissions
below
applicable
thresholds
for
requirements
to
meet
specific
emission
limits.
If
the
final
rule
includes,
as
we
anticipate,
an
option
for
a
mill
to
demonstrate
eligibility
for
sitespecific
delisting
based
on
risk,
then
equipment
employed
by
the
mill
to
get
below
that
risk
threshold
is
just
as
much
a
consequence
of
new,
unanticipated
CAA
requirements
as
is
equipment
used
to
meet
production­
based
limits
or
percent
reduction
requirements.
