On September 6, 2019, the EPA published a proposed amendment to what is commonly referred to as the Plywood or Kiln MACT. This proposed amendment does not address lumber kiln emission standards. EPA has stated that the lumber kiln emission and work practice standards will be addressed in a later proposed amendment.

This proposed amendment to 40 CFR 63, Subpart DDDD: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plywood and Composite Wood Products (PCWP) is based on the completion of the residual risk and technology review. The review has found that no revisions are necessary to the current controls in the original rule. The rule does propose removal of the startup, shutdown, and malfunctions plans as EPA has deemed this to be sufficiently addressed in the work practice standards of the regulation, as well as by the Clean Air Act (CAA).

The proposed rule is open to comments until October 21, 2019. All submissions must include Docket ID No. EPA-HQ-OAR-2016-0243-0034. The EPA encourages that comments be submitted through the Federal eRulemaking Portal located at https://www.regulations.gov/.

If you need help identifying how this proposed rule change will affect your facility or need assistance with providing comments to the EPA, please contact us at (770) 263-6330 or cti@conversiontechnology.com.

The Emission Inventory for Georgia facilities is due to the Georgia Environmental Protection Division (GAEPD) by June 30, 2019. This is for the mandatory reporting of facility emissions that occurred in calendar year 2018. This is part of the US Environmental Protection Agency’s (USEPA) National Emissions Inventory (NEI). The NEI is developed during three-year cycle reporting periods, where all Title V (or Part 70) permitted sources will be required to report at least every third year. The other two years only comprise larger sources with greater emission potentials. The 2017 emission inventory required all Title V sources to report. The 2018 inventory due this year, and the 2019 inventory that will be due in 2020, is for the larger Title V sources only. Continue reading “Air Emission Inventory Due End of June”

Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the Environmental Protection Agency (EPA) or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random and infrequent.

Continue reading “Staying in Compliance with Air Quality Regulations”

Changes to EPA “Once In Always In” Policy for MACT Rules

On January 25th 2018, the EPA released a guidance memo reversing the “Once in Always in” (OIAI) policy regarding the classification of major source facilities subject to MACT (Maximum Achievable Control Technology) standards. A major source is defined as any facility which emits at least 10 tons of any Hazardous Air Pollutant (HAP), or 25 tons of any combination of HAPs. This policy, which has been in place since 1995, stated that any major source that becomes subject to a MACT rule must stay in compliance with that rule permanently, even if the facility finds a way to drop emissions below major source thresholds. Continue reading “Federal, State, and Local Changes to Air Permitting Requirements”

The US EPA mailed the ICR by registered mail to 391 facilities in the PCWP industry that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering National Emission Standards for Hazardous Air Pollutants (NESHAP) applicability.

 Recipients are asked to complete the ICR by February 9, 2018.

Continue reading “The EPA Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) Was Mailed by the EPA and is Due February 9, 2018”

The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), for the “Plywood Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Risk  and Technology Review (RTR)” (Kiln MACT) to the office of Management and Budget (OMB) for preview and approval.

This Kiln MACT applies to every sawmill that is a Major Source or Synthetic Minor Source for Hazardous Air Pollutants (HAP).

The ICR will be sent to all known operators of PCWP facilities that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering NESHAP applicability. The information collection seeks to collect facility-level information (e.g. facility name, location, contact information, and process unit details), emissions information, compliance data, control information, and descriptions of technological innovations.

The EPA will either establish an emission limit or work practices in order to minimize emissions for process units included in the PCWP MACT source category. Capturing, controlling, and the measurements of kiln emissions is not feasible. Installing emissions capture and add-on control equipment for VOC/HAP removal have not been identified. It is therefore predicted that facilities will choose to use work practice requirements in lieu of emission limits.

The purpose of work practices is to minimize HAP emissions. For most kiln schedules, the HAP emissions increase near the end of the drying cycle when the wood reaches its final moisture content. HAP emissions increase as the moisture content decreases.

If you operate a lumber kiln, you will need to develop a plan for minimizing HAP emissions from the lumber kiln(s) by minimizing the annual average variability in dried lumber moisture content. Plans must be required to be submitted to the appropriate regulatory agency with your Notice of Compliance Status and you will need to maintain appropriate records of compliance with the work practices.

Changes in kiln operating temperatures can significantly affect mill operations and drying capacity. Lower kiln temperatures result in longer drying times. This is a production and capacity issue for mills. A mill operating four lumber kilns at full capacity at 225OF would have to add two more lumber kilns to dry the same amount of lumber at 180OF. To overcome the potential Kiln MACT limitation, facilities will need to prepare a compliance work practice plan that minimizes emissions with the least affect to drying production.

Shortly Major Source and Synthetic Minor Source of HAPs will receive an ICR survey. You will have 120 days after ICR mailout to submit it. CTI is experienced in this area in assisting many lumber mills in the permitting process that includes most of the information requested in the survey. CTI also has assisted facilities with ICR for other regulations in the past.

Upon receipt of the ICR, feel free to contact us for a proposal to assist you to prepare it. If you have any questions or need additional information, please contact us.

The US Environmental Protection Agency (EPA) has proposed to issue an Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as the “PCWP MACT” or “Kiln MACT”. This is an important update for those in the lumber industry, as lumber drying kilns are one of the sources regulated under the standard. While the PCWP NESHAP covers many types of process units, this discussion will be primarily focused on the standard’s effect on sawmills operating lumber drying kilns.

 What is the history of the rule? Continue reading “EPA Proposes Collection of Information for “Kiln MACT””

On July 29, 2016, the U.S. Court of Appeals for the D.C. Circuit ruled on the lawsuits over EPA’s Boiler MACT (40 CFR Part 63, Subpart DDDDD) and Boiler GACT (40 CFR Part 63, Subpart JJJJJJ) regulations. The lawsuit was the consolidation of multiple suits from industry and environmental groups. The split of the suits from industry versus environmental groups was stated by the court to be approximately 50/50. In summary, the court rejected all the industry petitions and granted some of the petitions from environmental groups. The most significant aspects of this ruling pertain to vacating portions of the standard and remanding additional portions of the standard to EPA to provide further explanation.

Under the Boiler MACT regulation, boilers are divided into subcategories based on the type of fuel utilized and the configuration of the combustion unit. Continue reading “Court Rules on Lawsuit over EPA’s Boiler MACT Regulation”

By Joshua Haar, EIT

The US EPA has revised the National Ambient Air Quality Standards (NAAQS) for ground level ozone. This will impact new and existing industrial facilities in some locations.

Background

The NAAQS were implemented as part of the Clean Air Act in the 1970’s to protect public health from a variety of pollutants, including particulates, carbon monoxide, and ozone, among others. The ozone NAAQS were instituted to limit the health effects (e.g. reduced lung function and pulmonary inflammation) caused by ground level ozone in the atmosphere; effects that primarily impact children, older adults, and people with asthma or other lung diseases. While ozone in the stratosphere helps block harmful radiation from reaching the surface of the earth, ozone at ground level is harmful. Specifically, it is not easily removed by our upper respiratory tract and is absorbed in our lungs, where it can cause narrowing of airways and decrease lung function. Continue reading “New Primary and Secondary Ozone NAAQS Requirements”

Boiler Area Source applies to a boiler in a facility with actual emissions of Hazardous Air  Pollutants (HAP) less than 10 tons per year of any single HAP or less than 25 tons per year of all HAPs combined. EPA allows Boiler Area Source facilities the use of Generally Available Control Technologies (GACT) or management practices to reduce emissions of hazardous air pollutant (as compared to Boiler MACT facilities explained later requiring stricter practices). If your facility is an Area Source, you should have submitted the Initial Notification Report and Notification of Compliance Status to the State and US EPA by May 31, 2013. Continue reading “Meeting Compliance Schedule and Requirements for Boiler MACT”