U.S. EPA Revises NESHAP Requirements for the Pulp and Paper Industry

This article is available as a podcast episode on ALL4’s Air Quality Insider

On October 11, 2017, U.S. EPA finalized the long-awaited revisions to 40 CFR Part 63, Subpart MM (National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills).  Publication of the final rule officially completes U.S. EPA’s required Risk and Technology Review (RTR) for the “Pulp and Paper Combustion Sources” source category, which had been under a consent decree to complete by October 1, 2017.

The Clean Air Act (CAA) requires U.S. EPA to revisit and review previously promulgated 40 CFR Part 63 emission standards no less often than every eight years, taking into account developments in practices, processes, and control technologies that could result in significant additional reductions of Hazardous Air Pollutants (HAP).  For those of you within the pulp and paper industry, you’ll likely recall the great Pulp and Paper Information Collection Request (ICR) of 2011 that informed U.S. EPA during their RTR of this rule; I’m told the survivors here at ALL4 were given commemorative shirts.

The revisions to Subpart MM became effective upon their October 11, 2017 publication within the Federal Register.  The following is a high-level summary of U.S. EPA’s revisions to the rule:

• The opacity monitoring allowance for all recovery furnaces equipped with electrostatic precipitators (ESPs) has been revised from 6% to 2%.
• The opacity monitoring allowance for all lime kilns equipped with ESPs has been revised from 6% to 3%.
• A new requirement for recovery furnaces and lime kilns equipped with ESPs to maintain proper operation of the ESP Automatic Voltage Control (AVC) has been added.
• A new requirement to maintain proper operation of the ESP AVC and wet scrubber parameter monitoring for emissions units equipped with an ESP followed by a wet scrubber has been added.
• Alternative monitoring, specifically, scrubber fan amperage, has been added as an alternative to pressure drop measurement, for smelt dissolving tank dynamic scrubbers operating at ambient pressure and low-pressure entrainment scrubbers on smelt dissolving tanks where the fan speed does not vary.
• The startup, shutdown, and malfunction (SSM) exemption has been eliminated.
• A new requirement for facilities to conduct periodic air emissions performance testing has been added, with the first of the tests to be conducted within three years of the effective date of the revised standards, and thereafter no longer than five years following the previous performance test.
• Procedures for establishing operating limits based on data recorded by Continuous Parametric Monitoring Systems (CPMS), including the frequency for recording parameters and the averaging period for reducing the recorded readings, have been added.
• The frequency for submitting excess emissions reports has been reduced from quarterly to semi-annually in conjunction with requiring electronic reporting of excess emissions (in the future, as reporting forms are tested and become available).
• New requirements have been added for facilities to submit electronic copies of performance test reports.
• New requirements have been added for facilities to submit initial notifications and Notifications of Compliance Status (NOCS) electronically.
• Various other technical and editorial corrections have been made.

New sources are required to comply with the revised standards by October 11, 2017, or upon startup, whichever is later.  Existing sources are obligated to comply with the revised standards within two years (i.e., by October 11, 2019), with the exception of the first periodic performance test, which must be completed by October 13, 2020 and submitted via U.S. EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) within 60 days of completing the test. Please be advised that quarterly excess emissions reporting requirements still apply until one year after a Subpart MM excess emissions reporting form appears in CEDRI; CEDRI is not yet equipped to receive Subpart MM reports.

With the clock already ticking, existing sources should take steps now to determine what system adjustments need to be made to demonstrate compliance with the revised requirements by October 11, 2019, including adjustments to data acquisition systems (DAS) to include startup and shutdown periods and the revised opacity monitoring allowances, to transition to electronic excess emissions reporting, and to comply with revised monitoring requirements. At first glance these revisions seem straightforward, but the incorporation of new secondary monitoring parameters into existing reporting systems can in certain instances be complicated and costly business.

Need help determining how the October 11, 2017 Subpart MM amendments will affect your mill?  Please contact your friendly, local ALL4 team for support!