From:
Woock,
Steve
[
mailto:
steve.
woock@
weyerhaeuser.
com]
Sent:
Friday,
July
30,
2004
7:
36
PM
To:
'
nizich.
greg@
epa.
gov'
Cc:
'
kissell.
mary@
epa.
gov';
'
kphanks@
rti.
org'
Subject:
PCWP
NESHAP/
MACT
Question
re:
Scheduled
start­
ups/
shutdowns
Greg­
We
understand
that
EPA
is
working
on
the
technical
amendments
to
the
PCWP
rule
and
wanted
to
bring
a
point
of
confusion
to
your
consideration.
Reviewing
the
PCWP
rule
requirements
at
63.2250
(
a)
has
lead
several
people
to
question
if
only
scheduled
shutdowns
and
startups,
but
not
unscheduled
shutdowns
and
startups,
are
exempt
from
the
rule
requirements.
The
pertinent
paragraph
is
copied
below.
The
first
sentence
indicates
shutdown
and
startup
periods
are
exempt
from
the
identified
rule
elements.
However,
the
second
sentence
refers
specifically
to
scheduled
shutdowns
and
startups.
It
is
clear
from
EPA's
response
to
comments
document
(
for
comments
2.8.3.2
and
2.8.3.5),
that
EPA
makes
the
second
reference
to
shutdowns
and
startups
using
the
modifier
"
scheduled,"
to
emphasize
the
need
to
minimize
the
duration
of
these
specific
events.
However,
a
plain
reading
of
the
rule
language
is
not
that
clear.

As
an
example
of
the
confusion,
I've
attached
the
draft
summary
of
the
rule
requirements
from
Tom
Link's
implementation
materials
group.
The
entry
for
63.2250,
as
it
summarizes
the
rule,
states
the
exemption
for
shutdowns
and
startups
apply
only
during
scheduled
events.
See
63.2250
on
the
attached
document.

We'd
like
to
suggest
a
simple
revision
to
the
second
and
third
sentences
to
make
the
meaning
clear.
This
is
given
in
the
second
version
of
the
paragraph
below.

Current
version:
§
63.2250
What
are
the
general
requirements?
(
a)
You
must
be
in
compliance
with
the
compliance
options,
operating
requirements,
and
the
work
practice
requirements
in
this
subpart
at
all
times,
except
during
periods
of
process
unit
or
control
device
startup,
shutdown,
and
malfunction;
prior
to
process
unit
initial
startup;
and
during
the
routine
control
device
maintenance
exemption
specified
in
§
63.2251.
The
compliance
options,
operating
requirements,
and
work
practice
requirements
do
not
apply
during
times
when
the
process
unit(
s)
subject
to
the
compliance
options,
operating
requirements,
and
work
practice
requirements
are
not
operating,
or
during
scheduled
startup
and
shutdown
periods,
and
during
malfunctions.
These
startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary
for
these
events.

Suggested
clarification:
(
Square
brackets
denote
words
to
delete;
ALL
CAPS
denote
an
addition)

§
63.2250
What
are
the
general
requirements?
(
a)...
The
compliance
options,
operating
requirements,
and
work
practice
requirements
do
not
apply
during
times
when
the
process
unit(
s)
subject
to
the
compliance
options,
operating
requirements,
and
work
practice
requirements
are
not
operating,
or
during
[
scheduled]
startup
and
shutdown
periods,
and
during
malfunctions.
[
These]
SCHEDULED
startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary
for
these
events.

I'll
follow
this
up
with
a
call
to
discuss.
Thank
you
for
your
time.

Regards,
Steve
Woock
Stephen
E.
Woock
Federal
Regulatory
Affairs
Manager,
Weyerhaeuser
PO
Box
1391,
New
Bern,
NC
28563­
1391
steve.
woock@
weyerhaeuser.
com
ph
252­
633­
7351
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Plywood
and
Composite
Wood
Products
(
June
4,
2004)

Section
Section
Title
Content
Date
of
Requirements*

What
This
Subpart
Covers
63.2230
What
is
the
purpose
of
this
subpart?
Subpart
establishes
requirements
for
hazardous
air
pollutants
(
HAP)

emitted
from
plywood
and
composite
wood
products
(
PCWP)

manufacturing
sources.

63.2231
Does
this
subpart
apply
to
me?
Applies
to
you
if:

(
a)
You
own
or
operate
PCWP
manufacturing
source
(
described
in
this
section);
and
(
b)
The
PCWP
source
is
a
major
source
of
HAP.

­
You
are
exempt
if
the
Environmental
Protection
Agency
(
EPA)

determines
you
are
part
of
the
low­
risk
subcategory
of
PCWP
manufacturing
facilities,
as
specified
in
appendix
B
of
the
rule.

63.2232
What
parts
of
my
plant
does
this
subpart
cover?
Applies
to
new,
reconstructed,
or
existing
affected
sources.
"
Affected
source"
is
described
as
the
collection
of
dryers,
blenders,
formers,

presses,
board
coolers,
and
other
process
units
associated
with
PCWP
manufacturing.

63.2233
When
do
I
have
to
comply
with
this
subpart?
New
or
Reconstructed
Sources:

­
If
initial
startup
of
affected
source
is
before
60
days
after
the
publication
date
of
the
rule,
you
must
comply
no
later
than
60
days
after
the
publication
date
of
the
rule.

­
If
initial
startup
of
affected
source
is
after
60
days
after
the
publication
date
of
the
rule,
you
must
comply
upon
initial
startup.

Existing
Sources:
No
later
than
the
date
38
months
after
the
publication
date
of
the
rule.

Area
Sources
that
Become
Major
Sources:
Must
comply
with
this
subpart
by
the
date
38
months
after
the
effective
date
of
the
rule
or
upon
initial
startup
as
a
major
source,
whichever
is
later.

Compliance
Options,
Operating
Requirements,
and
Work
Practice
Requirements
63.2240
What
are
the
compliance
options
and
operating
requirements
and
how
must
I
meet
them?
Meet
one
of
the
following
compliance
options
for
each
process
unit::

­
Production­
Based
Compliance
Options
(
PBCO):
Total
HAP
lb/
thousand
square
feet
(
MSF)
or
oven­
dried
tons
2
(
ODT)
specified
by
process
unit
in
Tables
1A
and
Table
2,

respectively.
Add­
on
controls
cannot
be
used
to
meet
the
PBCO.

­
Add­
On
Control
System
Options
(
Table
1.
B.):

­
reduce
emissions
of
total
HAP,
measured
as
THC
(
as
carbon),
by
90
percent;
or
­
limit
total
HAP
emissions,
measured
as
THC
(
as
carbon),

to
20
ppmv,
dry;

­
reduce
methanol
emissions
by
90
percent;
or
­
limit
methanol
emissions
to
less
than
or
equal
to
1
ppmvd
if
uncontrolled
emissions
are
greater
than
or
equal
to
10
ppmvd;
or
­
reduce
formaldehyde
emission
by
90
percent;
or
­
reduce
formaldehyde
emissions
by
90
percent
or
limit
to
less
than
or
equal
to
1
ppmvd
if
uncontrolled
emissions
are
greater
than
or
equal
to
10
ppmvd.

If
you
choose
to
comply
with
the
regulation
by
using
one
of
the
above­
mentioned
add­
on
control
system
options,
you
must
have
a
capture
device
that
either
meets
the
definition
of
wood
products
enclosure
in
§
63.2292
or
achieves
a
capture
efficiency
of
greater
than
or
equal
to
95
percent.

­
Emissions
Averaging
Option:
Existing
(
not
new)
sources
have
the
option
of
complying
by
emissions
averaging
among
process
units.

Formulas
and
restrictions
for
emissions
averaging
presented.

Operating
requirements
that
correspond
to
the
compliance
option
are
specified
in
Table
2.
3
63.2241
What
are
the
work
practice
requirements
and
how
must
I
meet
them?
­
You
must
meet
the
work
requirements
specified
for
existing
or
new
process
units
(
i.
e.,
dry
rotary
dryers,
hardwood
veneer
dryers,
softwood
veneer
dryers,
veneer
redryers,
Group
1
miscellaneous
coating
operations)
in
Table
3
of
the
rule;
or
you
may
apply
for
permission
to
use
alternative
work
practices,
as
provided
in
§
63.6(
g)
of
the
General
Provisions.

­
If
you
have
a
dry
rotary
dryer,
you
may
choose
to
designate
your
dry
rotary
dryer
as
a
green
rotary
dryer
and
meet
the
more
stringent
compliance
options
and
operating
requirements
for
green
rotary
dryers
instead
of
the
work
practices
for
dry
rotary
dryers.

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

General
Compliance
Requirements
63.2250
What
are
the
general
requirements?
­
You
must
be
in
compliance
at
all
times,
with
the
exception
of
periods
of
SSM;
prior
to
process
unit
initial
start
up;
and
during
the
routine
control
device
maintenance
exemption
(
RCDME).

­
You
must
operate
and
maintain
your
affected
source
according
to
§
63.6(
e)(
1)(
i)
of
the
General
Provisions.

­
You
must
develop
and
implement
a
written
SSMP
according
to
§
63.6(
e)(
3)
of
the
General
Provisions.

­
Requirements
do
not
apply
during
times
when
the
process
unit(
s)
are
not
operating,
during
scheduled
startup/
shutdowns,
or
malfunctions.

Startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary.

Shutoff
of
direct­
fired
burners
resulting
from
partial
and
full
production
stoppages
of
direct­
fired
softwood
veneer
dryers
or
overtemperature
events
shall
be
deemed
shutdowns
and
not
malfunctions.

Lighting
or
re­
lighting
any
one
or
all
gas
burners
in
direct­
fired
softwood
veneer
dryers
shall
be
deemed
startups
and
not
malfunctions.
4
63.2251
What
are
the
requirements
for
the
routine
control
device
maintenance
exemption?
­
You
may
request
and
justify
a
routine
control
device
maintenance
exemption
for
events
such
as
control
device
bakeouts,
washouts,
media
replacement,
and
replacement
of
corroded
parts.
The
exemption
must
not
exceed
operating
up
time
percentages
specified
for
differing
process
units
in
paragraphs
(
b)(
1)
and
(
b)(
2)
of
this
section
(
3
percent
and
0.5
percent,
respectively).

­
If
the
request
is
approved,
it
must
be
incorporated
by
reference
in
and
attached
to
the
affected
source's
title
V
permit.

­
The
compliance
options
and
operating
requirements
do
not
apply
during
times
when
control
device
maintenance
covered
under
your
approved
routine
control
device
maintenance
exemption
is
performed.

Startup
and
shutdown
periods
must
not
exceed
the
minimum
amount
of
time
necessary.
Emissions
must
be
minimized
to
the
greatest
extent
possible
during
these
times.

­
Startup
and
shutdown
of
emission
control
systems
must
be
scheduled
during
times
when
process
equipment
is
shut
down.

Initial
Compliance
Requirements
63.2260
How
do
I
demonstrate
initial
compliance
with
the
compliance
options,
operating
requirements,

and
work
practice
requirements?
­
You
must
conduct
performance
tests
and
establish
site­
specific
operating
requirements
to
demonstrate
compliance
for
your
source,
as
specified
in
Tables
2
and
4
of
the
rule.

­
You
must
demonstrate
initial
compliance,
as
specified
in
Tables
5
and
6
of
the
rule.

­
You
must
submit
the
Notification
of
Compliance
Status
containing
the
initial
compliance
demonstration
results.

63.2261
By
what
date
must
I
conduct
performance
tests
or
other
initial
compliance
demonstrations?
­
Performance
tests
must
be
conducted
upon
initial
startup
or
no
later
than
180
calendar
days
after
the
compliance
date
that
is
specified
for
your
source
in
§
63.2233
and
according
to
the
requirements
in
§
63.7(
a)(
2),
whichever
is
later.

­
Initial
compliance
demonstrations
that
do
not
require
performance
tests
must
be
conducted
upon
initial
startup
or
no
later
than
30
calendar
days
after
the
compliance
date
that
is
specified
for
you
source
in
§
63.2233,
whichever
is
later.
5
63.2262
How
do
I
conduct
performance
tests
and
establish
operating
requirements?
­
You
must
conduct
each
performance
test
in
accordance
with
§
63.7(
e)(
1)
and
as
specified
in
this
section,
and
according
to
the
methods
specified
in
Table
4
of
the
rule.

­
You
must
not
conduct
performance
tests
during
periods
of
SSM,
as
specified
in
§
63.7(
e)(
1).

­
You
must
test
under
representative
operating
conditions
and
explain
why
the
conditions
are
representative
in
your
performance
test.

­
With
the
exception
of
capture
efficiency
testing,
you
must
conduct
at
least
3
separate
test
runs
lasting
at
least
one
hour
each.

Paragraph
descriptors/
titles
follow:

(
b)
Periods
when
performance
tests
must
be
conducted.

(
c)
Number
of
test
runs.

(
d)
Location
of
sampling
sites.

(
e)
Collection
of
monitoring
data.

(
f)
Collection
of
production
data.

(
g)
Nondetect
data.

(
h)
Calculation
of
percent
reduction
across
a
control
system.

(
i)
Calculation
of
mass
per
unit
production.

(
j)
Thickness
basis
conversion.

(
k)
Establishing
thermal
oxidizer
operating
requirements.

(
l)
Establishing
catalytic
oxidizer
operating
requirements.

(
m)
Establishing
biofilter
operating
requirements.

(
n)
Establishing
operating
requirements
for
process
units
meeting
compliance
options
without
a
control
device.

(
o)
Establishing
operating
requirements
using
THC
CEMS.
6
63.2263
Initial
compliance
demonstration
for
a
dry
rotary
dryer.
Must
demonstrate
that
dryer
processes
furnish
with
an
inlet
moisture
content
of
less
than
or
equal
to
30
percent
(
by
weight,
dry
basis)
and
operates
with
a
dryer
inlet
temperature
of
less
than
or
equal
to
600
degrees
F.

­
Must
designate
and
clearly
identify
each
dryer.

­
You
must
record
the
inlet
furnish
moisture
content
(
dry
basis)
and
inlet
dryer
operating
temperature
for
a
minimum
of
30
days.

­
You
must
submit
the
highest
recorded
24­
hour
average
inlet
furnish
moisture
content
and
the
highest
recorded
24­
hour
average
dryer
inlet
temperature
with
your
certified
Notification
of
Compliance
Status
report.

­
You
must
submit
a
signed
statement
by
a
responsible
official
that
certifies
with
truth,
accuracy,
and
completeness
that
the
dry
rotary
dryer
will
dry
furnish
with
a
maximum
inlet
moisture
content
less
than
or
equal
to
30
percent
(
by
weight,
dry
basis)
and
will
operate
with
a
maximum
inlet
temperature
of
less
than
or
equal
to
600
degrees
F
in
the
future
with
your
Notification
of
Compliance
Status
report.

63.2264
Initial
compliance
demonstration
for
a
hardwood
veneer
dryer.
­
You
must
record
the
annual
volume
percentage
of
softwood
veneer
species
processed
in
the
dryer
using
the
equation
provided.

­
You
must
designate
and
clearly
identify
each
dryer.

­
You
must
submit
the
annual
volume
percentage
of
species
dried
in
the
dryer
based
on
dryer
production
for
12
months
prior
to
the
compliance
date
specified
for
your
source.

­
If
you
did
not
dry
softwood
species
in
the
dryer
during
the
12
months
prior
to
the
compliance
date,
then
you
need
only
submit
a
statement
saying
so.

­
You
must
submit
a
signed
statement
by
a
responsible
official
that
certifies
with
truth,
accuracy,
and
completeness
that
the
veneer
dryer
will
be
used
to
process
less
than
30
volume
percent
softwood
species
in
the
future
with
your
Notification
of
Compliance
Status..

63.2265
Initial
compliance
demonstration
for
a
softwood
veneer
dryer.
­
You
must
develop
a
plan
for
review
and
approval
for
minimizing
fugitive
emissions
from
the
veneer
dryer
heated
zones,
and
must
submit
the
plan
with
your
Notification
of
Compliance
Status
report.
7
63.2266
Initial
compliance
demonstration
for
a
veneer
redryer.
­
You
must
record
the
inlet
moisture
content
of
the
veneer
processed
in
the
redryer
for
a
minimum
of
30
days.

­
You
must
designate
and
clearly
identify
each
redryer.

­
You
must
submit
the
highest
recorded
24­
hour
average
inlet
veneer
moisture
content.

­
You
must
submit
a
signed
statement
by
a
responsible
official
that
certifies
with
truth,
accuracy,
and
completeness
that
your
redryer
will
dry
veneer
with
a
moisture
content
less
than
25
percent
(
by
weight,

dry
basis)
in
the
future
with
your
Notification
of
Compliance
Status
report.

63.2267
Initial
compliance
demonstration
for
a
reconstituted
wood
product
press
or
board
cooler.
­
You
must
either
use
a
wood
products
enclosure,
or
measure
the
capture
efficiency
of
the
capture
device
for
the
press
or
board
cooler
(
new
sources
only)
using
Methods
204
and
204A
through
204F
of
40
CFR
part
51,
appendix
M
(
as
appropriate)
or
using
the
alternative
tracer
gas
method
contained
in
appendix
A
of
the
rule.

­
You
must
submit
documentation
that
the
enclosure
meets
the
press
enclosure
design
criteria,
or
the
results
of
the
capture
efficiency
verification
with
your
Notification
of
Compliance
Status
report.

63.2268
Initial
compliance
demonstration
for
a
wet
control
device.
­
If
you
use
a
reference
control
device
as
the
sole
means
of
reducing
HAP
emissions,
you
must
develop
and
implement
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
emissions
reductions
are
obtained.

­
The
plan
must
be
submitted
with
your
Notification
of
Compliance
Status
report.

63.2269
What
are
my
monitoring
installation,
operation,
and
maintenance
requirements?
­
You
must
install,
operate,
and
maintain
each
continuous
parameter
monitoring
system
(
CPMS)
as
specified
in
this
section.
Specifications
are
provided
for
temperature
monitors,
wood
moisture
monitors,
and
continuous
emissions
monitoring
systems
(
CEMS).

Continuous
Compliance
Requirements
63.2270
How
do
I
monitor
and
collect
data
to
demonstrate
continuous
compliance?
­
You
must
conduct
all
monitoring
in
continuous
operation
at
all
times
that
the
process
unit
is
operating,
except
during
monitor
malfunctions,

associated
repairs,
and
required
QA
or
control
activities.

­
You
may
not
use
the
following
in
data
averages:
(
1)
data
recorded
during
monitoring
malfunctions,
associated
repairs,
out­
of­
control
periods,
and
required
quality
assurance
or
control
activities;
(
2)
data
during
periods
of
startup,
shutdown,
and
malfunction;
or
(
3)
data
recorded
during
periods
covered
by
a
routine
control
device
maintenance
exemption.

­
You
must
use
all
data
collected
during
all
other
periods
in
assessing
8
compliance.

­
You
must
determine
the
3­
hour
or
24­
hour
block
averages
of
all
recorded
readings
(
excluding
data
exceptions
cited
in
this
section).

­
You
must
have
at
least
75
percent
of
the
required
recorded
readings
for
an
averaging
period,
based
on
valid
data
(
excluding
data
exceptions
cited
in
this
section)..

63.2271
How
do
I
demonstrate
continuous
compliance
with
the
compliance
options,
operating
requirements,

and
work
practice
requirements?
­
You
must
demonstrate
continuous
compliance
with
the
compliance
options,
operating
requirements,
and
work
practice
requirements
in
§
§
63.2240
and
63.2241
according
to
the
methods
specified
in
Tables
7
and
8.

­
You
must
report
each
instance
in
which
you
did
not
meet
each
compliance
option,
operating
requirement,
and
work
practice
requirement.

­
During
periods
of
SSM,
you
must
operate
in
accordance
with
your
SSMP
­
Deviations
that
occur
during
a
period
of
startup,
shutdown
and
malfunction
or
by
any
approved
routine
control
device
maintenance
exemption
are
not
violations
if
you
can
demonstrate
that
you
were
operating
in
accordance
with
your
startup,
shutdown,
and
malfunction
plan
or
with
your
approved
routine
control
device
maintenance
exemption,
respectively.

Notifications,
Reports,
and
Records
63.2280
What
notifications
must
I
submit
and
when?
You
must
submit
all
of
the
notifications
in
§
§
63.7(
b)
and
(
c),
63.8(
e),

(
f)(
4)
and
(
f)(
6),
63.9(
b)
through
(
e),
and
(
g)
and
(
h)
of
the
General
Provisions:

Initial
Notification:
no
later
than
120
calendar
days
after
the
effective
date
(
60
days
after
publication
in
the
Federal
Register)
of
the
subpart
or
after
initial
startup,
whichever
is
later.

Notification
of
Intent
to
Conduct
a
Performance
Test:
at
least
60
calendar
days
before
the
performance
test
is
scheduled
to
begin.

Notification
of
Compliance
Status:

no
performance
test
­
before
the
close
of
business
on
the
30th
calendar
day
following
the
completion
of
the
initial
compliance
demonstration.

performance
test
­
must
submit
notification
with
performance
test
results,
before
the
close
of
business
on
the
60th
calendar
day
following
the
completion
of
the
performance
test
Request
for
a
Routine
Control
Device
Maintenance
Exemption
­
no
later
than
30
days
before
compliance
date.

Application
for
Approval
of
Emissions
Averaging
Plan
­
no
later
than
1
year
before
the
compliance
date
or
no
later
than
1
year
before
9
the
date
you
would
begin
using
an
emissions
average,
whichever
is
later.
Other
Notifications
(
modifications
or
replacement
of
control
system,
shutdown
of
process
unit
(
included
in
emissions
averaging
plan),
change
of
continuous
monitoring
parameter(
s))
­
must
notify
Administrator
within
30
days
before
action
taken.

63.2281
What
reports
must
I
submit
and
when?
You
must
submit
each
report
in
Table
9
of
the
rule,
by
the
following
dates:

First
Compliance
Report
(
Semi­
annual)
­
as
specified
in
Table
9,

covering
a
period
of
at
least
6
mos,
but
less
than
12
mos
(
ending
June
30
or
December
31st)
­
postmarked
or
delivered
no
later
than
July
31st
or
January
31st,
respectively.

Subsequent
Compliance
Reports
(
Semi­
annual)
­
no
later
than
July
31st
or
January
31st,
respectively.

Paragraphs
(
c)
through
(
g)
of
this
section
specify
what
is
to
be
contained
in
your
compliance
reports.

63.2282
What
records
must
I
keep?
You
must
keep
the
following
records:

­
A
copy
of
each
notification
and
report
submitted
in
compliance
with
the
rule.

­
Records
required
under
§
63.6(
e)(
3)(
iii)
through
(
v)
(
related
to
SSM)
of
the
General
Provisions.

­
Records
relating
to
control
device
maintenance
and
documentation
of
your
approved
routine
control
device
maintenance
exemption
(
if
applicable)

­
Records
of
performance
tests
and
evaluations.

­
Records
specified
for
each
CEMS
­
If
you
operate
a
catalytic
oxidizer,
you
must
keep
records
of
annual
catalyst
activity
checks
and
subsequent
corrective
actions
­
If
you
comply
with
the
emissions
averaging
compliance
option,

records
of
emission
debit
and
credit
calculations
must
be
kept.

63.2283
In
what
form
and
how
long
must
I
keep
my
records?
You
must
maintain
you
records
in
a
form
suitable
and
readily
available
for
expeditious
review.

Each
record
must
be
maintained
for
a
period
of
5
years
on­
site
following
the
date
of
each
occurrence,
measurement,
maintenance,

corrective
action,
report,
or
record.
Records
are
to
be
maintained
onsite
for
2
years
after
each
recording
and
can
be
maintained
off­
site
for
the
remaining
3
years.

Other
Requirements
and
Information
10
63.2290
What
parts
of
the
General
Provisions
apply
to
me?
You
are
required
to
comply
with
the
parts
of
the
General
Provisions
in
§
§
63.1
through
63.13,
as
specified
in
Table
10.

63.2291
Who
implements
and
enforces
this
subpart?
­
This
subpart
can
be
implemented
and
enforced
by
the
U.
S.
EPA
or
a
delegated
authority,
such
as
your
State,
local,
or
tribal
agency.

­
Approval
of
alternatives
to
the
compliance
options,
operating
requirements,
and
work
practice
requirements
can
only
be
obtained
from
the
U.
S.
EPA
(
such
approval
is
not
delegated).

­
Approval
for
major
alternatives
to
the
rule's
test
methods,

monitoring,
and/
or
recordkeeping
and
reporting
can
only
be
obtained
from
the
U.
S.
EPA
(
such
approval
is
not
delegated).

­
Approval
for
eligibility
for
the
low­
risk
subcategory
developed
according
to
appendix
B
of
rule
can
only
be
obtained
by
the
U.
S.
EPA
(
such
approval
is
not
delegated).

63.2292
What
definitions
apply
to
this
subpart?
The
following
terms
are
defined:

Affected
Source
Agricultural
fiber
Biofilter
Capture
device
Capture
efficiency
Catalytic
oxidizer
Combustion
unit
Control
device
Control
system
or
add­
on
control
system
Conveyor
strand
dryer
Conveyor
strand
dryer
zone
Deviation
Dryer
heated
zones
Dry
rotary
dryer
Dry
forming
Fiber
Fiberboard
Fiberboard
mat
dryer
Flame
zone
Furnish
Glue­
laminated
beam
Green
rotary
dryer
Group
1
miscellaneous
coating
operations
Hardboard
Hardboard
oven
Hardwood
Hardwood
veneer
dryer
11
Kiln­
dried
lumber
Laminated
strand
lumber
Laminated
veneer
lumber
Lumber
kiln
Medium
density
fiberboard
Method
detection
limit
Miscellaneous
coating
operations
MSF
Nondetect
data
Non­
HAP
coating
Oriented
strandboard
Oven­
dried
tons
Partial
wood
products
enclosure
Particle
Particleboard
Plywood
and
composite
wood
products
manufacturing
facility
Plywood
Press
perdryer
Pressurized
refiner
Primary
tube
dryer
Process
unit
Reconstituted
wood
product
board
cooler
Reconstituted
wood
product
press
Representative
operating
conditions
Resin
Responsible
official
Rotary
strand
dryer
Secondary
tube
dryer
Softwood
Softwood
veneer
dryer
Startup
Startup,
initial
Startup,
shutdown,
and
malfunction
plan
Strand
Temporary
total
enclosure
Thermal
oxidizer
Total
hazardous
air
pollutant
emissions
Tube
dryer
Veneer
Veneer
redryer
Wet
control
device
12
Wet
forming
Wood
I­
joists
Wood
products
enclosure
Work
practice
requirement
1­
hour
period
Tables
Table
1A
Production­
Based
Compliance
Options
Contains
production­
based
compliance
options
for
fiberboard
mat
dryer
heated
zones
(
at
new
sources
only),
green
rotary
dryers,

hardboard
ovens,
press
predryers
(
at
new
sources
only),
pressurized
refiners,
primary
tube
dryers,
secondary
tube
dryers,
reconstituted
wood
product
board
coolers
(
at
new
sources
only),
reconstituted
wood
product
presses,
softwood
veneer
dryer
heated
zones,
and
rotary
strand
dryers.
The
production­
based
compliance
options
are
on
a
total
HAP
basis.
Total
HAP,
as
defined
in
§
63.2292,
means
for
the
purposes
of
this
subpart,
the
sum
of
the
emissions
of
the
following
six
compounds:

acetaldehyde,
acrolein,
formaldehyde,
methanol,
phenol,
and
propionaldehyde.

Table
1B
Add­
On
Control
Systems
Compliance
Options
Contains
six
compliance
options
by
using
an
emissions
control
system
for
fiberboard
mat
dryer
heated
zones
(
at
new
sources
only),
green
rotary
dryers,
hardboard
ovens,
press
predryers,
pressurized
refiners,

primary
and
secondary
tube
dryers,
reconstituted
wood
product
board
coolers,
reconstituted
wood
product
presses,
softwood
veneer
dryer
heated
zones,
rotary
strand
dryers,
conveyor
strand
dryer
zone
one
(
at
existing
sources),
and
conveyor
strand
dryer
zones
one
and
two
(
at
new
sources)..

Table
2
Operating
Requirements
Contains
operating
requirements
for
operation
of
a
thermal
oxidizer;

catalytic
oxidizer;
biofilter;
control
devices
other
than
those
mentioned;
and
for
a
process
unit
that
meets
a
compliance
option
in
Table
1A
or
debit­
generating
process
unit..

Table
3
Work
Practice
Requirements
Contains
work
practice
requirements
for
dry
rotary
dryers;
hardwood
veneer
dryers;
softwood
veneer
dryers;
veneer
redryers;
and
Group
1
miscellaneous
coating
operations.

Table
4
Requirements
for
Performance
Tests
Contains
performance
test
requirements.
Specifies
emissions
test
methods
and
procedures
for
determining
capture
efficiency
for
presses
and
board
coolers.
13
Table
5
Performance
Testing
and
Initial
Compliance
Demonstrations
for
the
Compliance
Options
and
Operating
Requirements
Describes
how
to
demonstrate
initial
compliance
with
the
compliance
options
and
operating
requirements.

Table
6
Initial
Compliance
Demonstrations
for
Work
Practice
Requirements
Contains
initial
compliance
demonstrations
for
work
practice
requirements.

Table
7
Continuous
Compliance
With
the
Compliance
Options
and
Operating
Requirements
Contains
requirements
for
demonstrating
continuous
compliance
with
compliance
options
and
operating
requirements.

Table
8
Continuous
Compliance
With
the
Work
Practice
Requirements
Contains
requirements
for
demonstrating
continuous
compliance
with
work
practice
requirements.

Table
9
Requirements
for
Reports
Contains
requirements
for
reports.

Table
10
Applicability
of
General
Provisions
to
Subpart
DDDD
Contains
applicability
of
the
General
Provisions
to
this
rule.

Appendices
Appendix
A
Alternative
Procedure
to
Determine
Capture
Efficiency
From
Enclosures
Around
Hot
Presses
in
the
Plywood
and
Composite
Wood
Products
Industry
Using
Sulfur
Hexafluoride
Tracer
Gas
Contains
an
alternative
procedure
to
determine
capture
efficiency
of
a
hot
press
enclosure
in
the
PCWP
industry
using
sulfur
hexafluoride
tracer
gas.

Appendix
B
Methodology
and
Criteria
for
Demonstrating
That
an
Affected
Source
is
Part
of
the
Low­
risk
Subcategory
of
Plywood
and
Composite
Wood
Products
Manufacturing
Facilities
Provides
the
methodology
and
criteria
for
demonstrating
that
your
affected
source
is
part
of
the
low­
risk
subcategory
of
plywood
and
composite
wood
products
manufacturing
facilities.
You
can
do
this
by
using
either
a
look­
up
table
analysis
(
based
on
the
look­
up
tables
included
in
the
appendix)
or
using
a
site­
specific
risk
assessment
performed
according
to
criteria
specified
in
this
appendix.

*
Date
of
requirements
will
be
filled
in
once
the
rule
is
published
in
the
Federal
Register.
This
summary
is
not
meant
to
replace
the
published
regulation
titled
"
National
Emission
Standard
for
Hazardous
Air
Pollutants
(
NESHAP):
Plywood
and
Composite
Wood
14
Products
NESHAP"
(
XX
FR
XXXXX).
This
summary
is
merely
an
outline
of
the
content
of
the
regulation
and
does
not
cover
all
parts
of
the
regulation.
