8. How Does a Source Demonstrate Continuous Compliance With the Final Rule?
The continuous compliance requirements in the PCWP MACT rule
vary with the different types of compliance options.
Production-Based Compliance Options (PBCO) If
the source complies with the PBCO, then they must monitor
and/or record the controlling operating parameter(s) identified
as affecting total HAP emissions from the process unit(s)
in the performance test. For each parameter, the source must
use the monitoring methods, monitoring frequencies, and averaging
times (for continuously monitored parameters not to exceed
24 hours) specified in their performance test and Notification
of Compliance Status. For each operating parameter, the source
must maintain on a daily basis the parameter at or above
the minimum, at or below the maximum, or within the range
(whichever applies) established during the performance test.
Instead of monitoring process operating parameters, the
source may operate a continuous
emission monitoring system (CEMS) for monitoring total
hydrocarbon (THC) concentration to demonstrate compliance
with the operating equirements in today’s final rule.
If the source chooses to operate a THC CEMS in lieu of
a continuous parameter monitoring systems (CPMS), they
must demonstrate continuous compliance, as described below.
Add-On Control System Compliance Options
For add-on control systems, the source must install a CPMS
to monitor the temperature or install a CEMS to monitor
THC concentration to demonstrate compliance with the operating
requirements in the final rule. If the source operates
a CPMS, they must have at least 75 percent of the required
recorded readings for each 3-hour or 24-hour block averaging
period to calculate the data averages. The source must
operate the CPMS at all times the process unit is operating.
The source must also conduct proper maintenance of the
CPMS and maintain an inventory of necessary parts for routine
repairs of the CPMS. Using the data collected with the
CPMS, the source must calculate and record the average
values of each operating parameter according to the specified
averaging times.
Thermal Oxidizer Firebox Diagram
For thermal oxidizers, the source must continuously maintain
the 3-hour block average firebox temperature at or above
the minimum temperature established during the performance
test. For catalytic oxidizers, the source must continuously
maintain the 3-hour block average catalytic oxidizer temperature
at or above the minimum value 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 and take any necessary corrective action to ensure
that the catalyst is performing within its design range.
For biofilters, the source must continuously maintain
the 24-hour block average biofilter bed temperature within
the operating range they establish during the performance
test. The source must also conduct a repeat performance
test using the applicable method(s) within 2 years following
the previous performance test and within 180 days after
each replacement of any portion of the biofilter bed with
a different media or each replacement of more than 50 percent
(by volume) of the biofilter bed media with the same type
of media.
If
the source chooses to operate a CEMS for monitoring THC
concentration instead of operating a CPMS, they must install,
operate, and maintain the CEMS
according to Performance Specification 8 in 40 CFR part
60, appendix B. The source must also comply with the CEMS
data quality assurance requirements in Procedure 1 of appendix
F of 40 CFR part 60. The source must conduct
a performance evaluation of the CEMS according to 40
CFR 63.8 and Performance Specification 8. The
CEMS must complete a minimum of one cycle of operation
(sampling, analyzing, and data recording) for each successive
15-minute period. Using the data collected with the CEMS,
the source must calculate and record the 3-hour block average
THC concentration for thermal or catalytic oxidizers. For
biofilters, the source must calculate and record the 24-hour
block average THC concentration. The source must continuously
monitor and maintain the 24-hour block average THC concentration
at or below the maximum established during the performance
test. The source may use a CEMS that subtracts methane
from the measured THC concentration if they wish to do
so.
If the source complies with the PCWP MACT rule using
an add-on control system, they may request a routine control
device maintenance exemption from their regulating agency.
The source's request for a routine control device maintenance
exemption must document the need for routine maintenance
on the control device and the time required to accomplish
the maintenance, describe the maintenance activities and
the frequency of these activities, explain why the maintenance
cannot be accomplished during process shutdowns, describe
how they plan to make reasonable efforts to minimize emissions
during these maintenance activities, and provide any other
documentation required by their regulating agency. If the
source's request for the routine control device maintenance
exemption is approved by the their regulating agency, it
must be incorporated into their title V permit.
The compliance options and operating requirements would
not apply during times when control device maintenance
covered under the source's approved routine control device
maintenance exemption
is performed. The routine control device maintenance exemption
may not exceed 3 percent of annual operating uptime for
each green rotary dryer, tube dryer, rotary strand dryer,
or pressurized refiner controlled. The routine control
device maintenance exemption is limited to 0.5 percent
of the annual operating uptime for each softwood veneer
dryer, reconstituted wood product press, reconstituted
wood product board cooler, hardboard oven, press predryer,
conveyor strand dryer, or fiberboard mat dryer controlled.
If the source's control device is used to control a combination
of equipment with different downtime allowances (e.g.,
a tube dryer and a press), then the highest (i.e., 3 percent)
downtime allowance applies.
Emissions Averaging Compliance Option
To demonstrate continuous compliance with the emissions
averaging provisions, the source must continuously comply
with the applicable operating requirements for add-on control
systems (described above). The source also must maintain
records of their operating hours for each process unit
included in the EAP. For each semiannual compliance period,
the source must demonstrate that the actual mass removal
(AMR) equals or exceeds the required mass removal (RMR)
using their initial (or most recent) total HAP measurements
for debit-generating units, initial (or most recent) performance
test results for credit-generating units, and the operating
hours recorded for the semiannual compliance period.
Work Practice Requirements To demonstrate continuous compliance with the work practice
requirements for dry rotary dryers and veneer redryers,
the source must operate all dry rotary dryers and veneer
redryers so that they continuously meet the definitions
of these process units in the PCWP MACT rule. For dry rotary
dryers, the source must continuously monitor and maintain
the inlet furnish moisture content at or below 30 percent
and the
inlet dryer operating temperature at or below 600[deg]F.
The source must also calibrate the moisture monitor based
on the procedures specified by the moisture monitor manufacturer
at least once per semiannual compliance period to verify
the readings from the moisture meter. For veneer redryers,
the source must continuously monitor and maintain the inlet
veneer moisture content at or below 25 percent.
To demonstrate continuous compliance with the work practice
requirements for softwood veneer dryers, the source must
follow the procedures in their operating plan for minimizing
fugitive emissions from the green end and heated zones
of the veneer dryer and maintain records documenting that
they have followed their plan. For hardwood veneer dryers,
the source must continue to process less than 30 percent
softwood veneer by volume and maintain records on veneer
dryer production.
To demonstrate continuous compliance with the work practice
requirements for group 1 miscellaneous coating operations,
the source must keep records showing that they continue
to use non-HAP coatings as defined in the final rule.
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If
the source complies with the PBCO, then they must monitor
and/or record the controlling operating parameter(s) identified
as affecting total HAP emissions from the process unit(s)
in the performance test. For each parameter, the source must
use the monitoring methods, monitoring frequencies, and averaging
times (for continuously monitored parameters not to exceed
24 hours) specified in their performance test and Notification
of Compliance Status. For each operating parameter, the source
must maintain on a daily basis the parameter at or above
the minimum, at or below the maximum, or within the range
(whichever applies) established during the performance test.
If
the source chooses to operate a CEMS for monitoring THC
concentration instead of operating a CPMS, they must install,
operate, and maintain the 
The compliance options and operating requirements would
not apply during times when control device maintenance
covered under the source's approved routine control device
maintenance exemption
is performed. The routine control device maintenance exemption
may not exceed 3 percent of annual operating uptime for
each green rotary dryer, tube dryer, rotary strand dryer,
or pressurized refiner controlled. The routine control
device maintenance exemption is limited to 0.5 percent
of the annual operating uptime for each softwood veneer
dryer, reconstituted wood product press, reconstituted
wood product board cooler, hardboard oven, press predryer,
conveyor strand dryer, or fiberboard mat dryer controlled.
If the source's control device is used to control a combination
of equipment with different downtime allowances (e.g.,
a tube dryer and a press), then the highest (i.e., 3 percent)
downtime allowance applies. 
To demonstrate continuous compliance with the work practice
requirements for dry rotary dryers and veneer redryers,
the source must operate all dry rotary dryers and veneer
redryers so that they continuously meet the definitions
of these process units in the PCWP MACT rule. For dry rotary
dryers, the source must continuously monitor and maintain
the inlet furnish moisture content at or below 30 percent
and the
inlet dryer operating temperature at or below 600[deg]F.
The source must also calibrate the moisture monitor based
on the procedures specified by the moisture monitor manufacturer
at least once per semiannual compliance period to verify
the readings from the moisture meter. For veneer redryers,
the source must continuously monitor and maintain the inlet
veneer moisture content at or below 25 percent.