On August 13, EPA published the final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the plywood and composite panel industries. This rule, otherwise known as the Risk and Technology Review (RTR), was required to be completed by EPA eight years after the initial promulgation of the original plywood NESHAP standard in 2004. Subsequently, a court-imposed schedule was imposed on EPA to comply with the statutory obligation. The final rule is identical to the proposed rule EPA published on September 6, 2019.
As reported in the June 11 edition of @the edge, the final rule:
- Does not change any of the emission limits
- Requires emission testing every five years, verses a required initial test, to improve performance of control technologies, other than for biofilters (which are already required to be tested every two years)
- Clarifies that the standards are applicable during periods of startup, shutdown and malfunction
- Incorporates work practices for certain startup and shutdown events based on site-specific procedures
- Requires electronic reporting of performance test results and semiannual reports.