Under a new EPA proposal, pulp and paper mills subject to the Agency’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) will not need to undertake new compliance measures as a result of the Agency’s residual risk review. However, the EPA believes developments in this sector warrant revisions to the existing opacity requirements. Several other amendments to monitoring, testing, and reporting provisions are also being proposed.
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Clean Air Act (CAA) Section 112(f)(2) directs the EPA to a conduct a residual risk review 8 years after issuance of a NESHAP to determine if the existing provisions are protective of human health with an ample margin of safety. Also, CAA Section 112(d)(6) instructs the Agency to determine if pollution control technology for a NESHAP source category has improved. Should the reviews indicate that existing regulations are inadequately protective of human health or out of step with current pollution control technologies, the Agency must initiate rulemaking to close the gaps.
108 facilities
Pulp and paper facilities that are major sources of hazardous air pollutants (HAPs) are subject to two NESHAPs, one for noncombustion processes (40 CFR Part 63, Subpart S) and one chemical recovery combustion occurring at kraft, soda, sulfite, and stand-alone semichemical pulp mills (40 CFR Part 63, Subpart MM). The current proposal addresses only Subpart MM, which the Agency says covers 97 kraft pulp mills, 1 soda pulp mill, 3 sulfite pulp mills, and 7 stand-alone semichemical pulp mills.
Residual risk
Subpart MM was originally issued in 2001 and amended in 2003. Based on its residual risk review, the Agency states that HAP emissions, primarily regulated as particulate matter (PM), from this source category are low for all populations (e.g., inhalation cancer risks are less than 4 in 1 million for all populations, and noncancer hazard indices are less than 1). Also, the Agency conducted an environmental risk screening that found there is no adverse environmental effect as a result of HAP emissions from Subpart MM facilities. As a result, no amendments to address risks to human health or the environment are proposed.
Technology
However, in its technology review, the EPA says it found evidence that supports changes to Subpart MM’s PM opacity regulations. The current PM opacity limits are 35 percent opacity for existing recovery furnaces and 20 percent opacity for existing lime kilns, new lime kilns, and new recovery furnaces. Subpart MM also contains an opacity monitoring allowance for existing sources where 6 percent of the 6-minute opacity averages during a quarter (excluding periods of start-up, shutdown, and malfunction (SSM) and periods when the facility is not operating) may exceed the 35 percent recovery furnace or 20 percent lime kiln opacity limits without being considered a violation.
The Agency now says that it has found that existing recovery furnace operating practices support reducing the existing source opacity limit from 35 percent to 20 percent and revising the monitoring allowance for the 20 percent opacity limit from 6 percent to 2 percent. Additional evidence shows that developments in existing lime kiln operating practices support revising the monitoring allowance from 6 percent to 1 percent for opacity, says the EPA. Therefore, the EPA is proposing amendments in line with those findings.
The EPA estimates that the proposed changes to the opacity limits and monitoring allowances will reduce PM emissions by approximately 235 tons per year (tpy) and fine particle (PM-2.5) emissions by approximately 112 tpy.
Other proposed revisions
The proposal would also require parameter monitoring for processes equipped with electrostatic precipitators (ESPs), clarify monitoring for combined ESP/wet scrubber controls, provide alternative monitoring for smelt dissolving tank (SDT) wet scrubbers, require periodic air emissions performance testing once every 5 years, eliminate the SSM exemption, and require mills to submit electronic copies of compliance reports, which include performance test reports.
AF&PA’s statement
In a statement, the American Forest & Paper Association (AF&PA) said it welcomed EPA’s finding that the 2001 NESHAP protects public health.
“That’s a positive testament to our industry’s investments and commitment to air quality and sustainability,” said the AF&PA. “Pulp mills have invested over $1.5 billion in state-of-the-art controls to reduce emissions, and these technologies remain the best available.”
The AF&PA added that it has concerns about EPA’s proposed changes to the opacity provisions and will elaborate in its formal comments on the proposal.
EPA’s proposal was published in the December 30, 2016, FR.