EPA Finalizes the Residual Risk and Technology Review for Pulp and Paper

Posted on September 17, 2012

On September 11, EPA finalized changes to NESHAP Subpart S where they determined the proposed increased collection and treatment requirements were not cost effective and hence they did not change them.  For industry this is great news however the remainder of the changes are not so great as follows:

Repeat air emissions performance testing is required ever 5 years for sources complying with kraft, soda and semi-chemical pulping vent gases, sulfite pulping processes, and bleaching systems.  The first repeat air emissions performance testing is due September 7, 2015.  Repeat testing is not required for knotter systems with emissions less than 0.1 lb/ODTP, screen systems with emissions less than 0.2 lb/ODTP, and combined knotter and screen system with emissions less than 0.3 lb/ODTP.  Repeat testing is not required for decker systems using fresh water or white water containing less than 400 ppmw methanol.
Continuous monitoring parameters and ranges that were set from the initial performance testing will be reset as a result of this repeat air emissions performance testing.  Sources that have not completed testing in a while need to begin planning for these changes, especially sources that operate without much margin above the limit.
Added four additional test methods for methanol that can be used as follows:

Method 18 of Part 60, appendix A-6
Method 320 of Part 63, appendix A
ASTM D6420-99
ASTM D6348-03

Incorporated general duty to minimize emissions.
Added reporting and record keeping requirements for malfunctions.
Added an affirmative defense section that can be used to avoid civil penalties for violations.  Violations occur when excess emissions exceed 1 % of operating time for low volume high concentration (LVHC) system, 4 % for high volume low concentration (HVLC) system and 10 % for stripper systems.  All criteria have to be met to assert an affirmative defense.  The question each facility should have is do they have robust enough systems in place that meet all the criteria because that is the expectation.
EPA claims that they are making reporting easier by the following electronic reporting changes but we will let you be the judge:

Performance tests are to be submitted using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through Central Data Exchange (CDX) in the file format from EPA’s Electronic Reporting Tool (ERT).

However, if the report contains confidential business information (CBI) then submit on compact disk instead.
If the performance test methods are not listed in the ERT then submit a paper copy.

Continuous Emission Monitoring (CEM) relative accuracy test audits are to be submitted using CEDRI through CDX in file format from ERT.

However, performance evaluations of monitoring systems with no corresponding RATA pollutants in the ERT are to submit a paper copy.

EPA is deferring changes to the excess emission allowance for LVHC and HVLC until later.  This is a big deal because the allowances may decrease making it more difficult to avoid a violation.

For additional information on how Environmental 360 can help with your air compliance needs, please contact Dell Majure at Dell.Majure@environmental360.com
Source: E360 Old Site

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