Tuesday, July 6, 2010

Review of Pulp - Paper Industry NESHAP and NSPS

EPA's Office of Air Quality Planning and Standards (OAQPS) has initiated an integrated NESHAP Risk and Technology Review for Pulp and Paper Industry and Chemical Recovery Combustion Sources, and a NSPS review for Kraft Pulp Mills. Section 112(f)(2) of the Clean Air Act directs EPA to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards, and to determine if additional standards are needed to reduce residual risks, to be completed 8 years after promulgation. Section 112(d)(6) of the CAA requires EPA to review and revise the MACT standards, as necessary, taking into account developments in practices, processes and control technologies, to be done at least every 8 years.

The NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (Subpart MM) was promulgated in 2001 and has not been reviewed. Similarly, the NESHAP for the Pulp and Paper Industry (Subpart S) was promulgated in 1998 and also has not been reviewed. Section 111(b)(1)(B) of the Clean Air Act mandates that EPA review and, if appropriate, revise existing NSPS at least every 8 years. The Kraft Pulp Mill NSPS was promulgated in 1978 and is in need of review. This NSPS component of the review will include evaluating existing emission limits for particulate matter, total reduced sulfur, and opacity and evaluating the appropriateness of developing emission limits for other pollutants such as sulfur oxides, nitrogen oxide, and carbon dioxide.

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