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EPA Issues Direct Final Rule to Amend the Wool Fiberglass Manufacturing NESHAP

In the July 27, 2017 Federal Register the Environmental Protection Agency (EPA) published both a direct final rule and proposed rule amending 40 CFR 63 Subpart NNN, National Emission Standards for Hazardous Air Pollutants for Wool Fiberglass Manufacturing. EPA believes the direct final rule is noncontroversial and will not receive significant adverse comment. However, if EPA does receive significant adverse comment, the direct final rule will be withdrawn and move forward with the proposed rule. The proposed changes provides affected sources a 1-year extension, to comply with the emission limits for flame attenuation lines. The deadline would be extended until July 31, 2018. The direct final rule will be effective October 25, 2017, unless a public hearing is requested by August 3, 2017 or significant adverse comments are submitted by August 28, 2017. The EPA has proposed extending the compliance deadline for sources regulated under 40 CFR 63 Subpart NNN, National Emission Standards for Hazardous Air Pollutants for Wool Fiberglass Manufacturing to comply with the emission limits for flame attenuation lines. The deadline will be extended for one year, through July 31, 2018. EPA believes this extension is noncontroversial, and has therefore issued a direct final rule. If EPA receives a request for a public hearing by August 3, 2017 or receives significant adverse comments by August 28, 2017, the direct final rule will be withdrawn, and EPA will proceed with the concurrently issued proposed rule. EPA has proposed this extension of the compliance deadline in response to two recent issues. EPA wishes to review revised data and additional process data to determine whether any actions are necessary. First, a company that manufactures wool fiberglass notified EPA that the data the company collected in 2011 for the Wool Fiberglass Residual Risk and Technology Review (RTR) contained methodology errors, which resulted in errors in the final stack test emission results submitted to EPA. EPA used this data to help develop the current emission limits for formaldehyde, methanol, and phenol emitted from the bonding and curing process on flame attenuation lines. The company has since provided revised test results. Second, the company also informed EPA that some of their flame attenuation lines manufacture a product by extruding extremely thin glass fibers at a very low pull rate through a fiber forming process. This process is subject to the flame attenuation line emission limits, which are expressed in pounds of pollutant per ton of glass pulled. The company asked EPA to consider alternative emission limits for processes equivalent to pounds per ton limits, but expressed as a concentration (pounds of pollutant per dry standard cubic foot) or as hourly production (pounds of pollutant per hour).  

Sources:

EPA, Direct Final Rule, National Emission Standards for Hazardous Air Pollutants for Wool Fiberglass Manufacturing; Flame Attenuation Lines, 82 FR 34858, July 27, 2017 EPA, Proposed Rule, National Emission Standards for Hazardous Air Pollutants for Wool Fiberglass Manufacturing; Flame Attenuation Lines, 82 FR 34910, July 27, 2017

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