Plywood and Composite Wood Products (PCWP)
NESHAP Summary
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4. What Operating Requirements Are in the Final Rule?
 The operating requirements in the PCWP MACT final rule apply
to add-on control systems used to comply with the final rule
and to process units meeting the final production-based compliance
options or emissions averaging provisions without an add-on
control device (e.g., debit-generating process units). For
incineration-based control devices and biofilters, the final
rule specifies that the source must either monitor operating
parameters or use a THC continuous emission monitoring system
(CEMS) to demonstrate continuous compliance. The final operating
requirements are summarized below:
If the source operates a thermal oxidizer, such as a regenerative thermal oxidizer
(RTO), you must maintain the firebox temperature at a level that is greater than
or equal to the minimum temperature established during the performance test.
If the source operates a combustion unit that accepts process exhaust into the
flame zone, they are exempt from the testing and monitoring requirements described
above for thermal oxidizers.
If
the source operates a catalytic oxidizer, such as a regenerative catalytic oxidizer
(RCO) or thermal catalytic oxidizer (TCO), you must maintain the average catalytic
oxidizer temperature at or above the minimum temperature established during the
performance test. The source must also check the activity level of a representative
sample of the catalyst at least every 12 months.
 If the source operates a biofilter, they must maintain the average biofilter
bed temperature
within the range developed during the initial performance test or during qualifying
previous performance tests using the required test methods. If the source uses
values from previous performance tests to establish the operating parameter
ranges, they must certify that the biofilter and associated process unit(s)
have not been modified subsequent to the date of the performance tests.
If the source operates an add-on control system not listed in today’s
final rule, they must establish operating parameters to be monitored and parameter
values that represent the operating requirements during the performance test,
subject to prior written approval by their regulatory agency.
If the source operates a process unit that meets the production-based compliance
options or a process unit that generates debits in an emissions average without
an add-on control device, they must maintain on a daily basis the process unit
controlling operating parameter(s) within the ranges established during the
performance test corresponding to the representative operating conditions identified
during the performance test.
As
an alternative to monitoring the operating parameters specified above for thermal
oxidizers, catalytic oxidizers, biofilters, other control devices, and process
units that meet compliance options without add-on control systems, the source
may monitor THC concentration in the outlet stack with a THC CEMS. If the source
selects this option, they must maintain the outlet THC concentration below
the maximum concentration established during the performance test. The source
may choose to subtract methane from the THC concentration measured by the CEMS
if they wish to do so.
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