The U.S. Environmental Protection Agency has been working through several required Risk and Technology Reviews (RTRs) of National Emission Standards for Hazardous Air Pollutants (NESHAP). One of the latest RTRs to be finalized is the PCWP NESHAP. This rule is promulgated in 40 CFR Part 63, Subpart DDDD, and covers wood products plants that are major sources of hazardous air pollutants (HAPs). The original rule was finalized in 2004, reconsidered and revised in 2006, and revised due to a court decision in 2007. The latest revisions to the rule were signed on June 8, 2020 and have not yet been published in the Federal Register. The U.S. EPA determined that risk from PCWP facility air emissions is acceptable and that public health is protected by the current NESHAP with an ample margin of safety. However, there were several revisions and clarifications made to the PCWP NESHAP requirements. The most significant revision concerning the repeating of emissions testing is discussed below. Other revisions to note include adjustments to the non-HAP coating definition, the temperature sensor validation requirements, and excess emissions reporting.
The U.S. EPA finalized a requirement to perform repeat emissions testing within three years of promulgation of the final rule or within 60 months of the previous test, whichever is later. The test report must be entered into the online Electronic Reporting Tool (ERT). The final rule clarifies that repeat testing is not required for press capture efficiency if the capture device is maintained and operated consistent with its design and operation during the previous capture efficiency demonstration (see new footnote to Table 7). The U.S. EPA also revised Tables 2 and 7 to indicate an annual Regenerative Catalytic Oxidizer (RCO) catalyst check is not required during a calendar year when a performance test is conducted. The final rule also allows for an additional variability margin to be added to the bio-filter temperature operating range developed during testing. A Notification of Compliance Status (NOCS) is required following the repeat testing.
If your facility is subject to the PCWP NESHAP, review the final rule to determine how the revisions affect your plant or contact Acro Technologies, Inc. for compliance assistance or to schedule repeat emissions testing.
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