Kraft Pulp Mill NSPS (40 CFR Part 60 Subpart BBa) Has Been Finalized!
Posted: April 11th, 2014Author: All4 Staff
U.S. EPA has finalized their review of the Kraft Pulp Mill NSPS, codified at 40 CFR Part 60 Subpart BBa. The final rule was published in the Federal Register on April 4, 2014. The rule applies to affected facilities at Kraft pulp mills for which construction, modification, or reconstruction commences after May 23, 2013. No other affected facilities have been identified by the new rule and the new rule does not replace Subpart BB which continues to apply to affected facilities constructed, modified, or reconstructed after the original Subpart BB applicability date September 24, 1976 but prior to the applicability date of Subpart BBa. The new rule only applies to the following affected facilities at Kraft pulp mills.
- Digester system
- Brownstock washer system
- Multiple-effect evaporator system
- Recovery furnace
- Smelt dissolving tank
- Lime kiln; and
- Condensate stripper system
The rule focuses on particulate matter (PM) and total reduced sulfur (TRS). The emission limits are in terms of filterable PM; however, the rule requires a condensable PM performance test when conducting the initial and repeat performance testing for filterable PM. The condensable PM test must be conducted using Method 202 of Appendix M of 40 CFR Part 51. Table 1 summarizes the PM emission limits of Subpart BBa.
The TRS Emission Standards are summarized in Table 2 below.
The final rule contains the affirmative defense language that we’ve seen in many other new and revised regulations. Also in line with other previous rule revisions is the removal of startup, shutdown, and malfunction (SSM) exemptions. The rule states that the emission standards apply at all times.
As expected, there is an initial and repeat performance testing requirement for PM and TRS. The repeat testing will be required every five (5) years. The performance test reports must be submitted using the U.S. EPA’s Electronic Reporting Tool (ERT). Subpart BBa requires semiannual reporting of excess emissions.
The proposed rule was not consistent with Subpart S language. The final rule has incorporated language consistent with 40 CFR Part 63 Subpart S in regards to requirements for closed-vent collection systems to correct this. U.S. EPA also provided clarity regarding how excess emissions are defined. Excess emissions are defined in §60.284(d) and (e) of the new rule along with specified averaging times (e.g. 12-hour block averages for TRS, 3-hour block average for combustion temperature, and % allowable for venting). The original Subpart BB rules do not give this level of clarification.
When evaluating projects around your Kraft pulp mill, be sure to review this new rule to determine its potential applicability to your project. This regulation is already effective as of April 4th and applies to units that commenced construction, reconstruction, or modification after May 23, 2013.