Alternative VOC Ract for a Wood Products Plant in a Response to Title 1 of the Clean Air Act and the California FIP, 1996 Environmental Conference Proceedings

A proposed Federal Implementation Plan (FIP) for the Sacramento ozone nonattainment area was issued by the Environmental Protection Agency (EPA) on February 14, 1994. Part of the proposed FIP was a reasonably available control technology (RACT) rule that would have imposed additional volatile organic compound (VOC) emission control at a medium-density fiberboard (MDF) plant in Rocklin, California. As part of ongoing permitting related to the generation of emission reduction credits, the facility had committed to additional particulate matter controls on fiber dryers and a wood-tired boiler, as well as a packed tower scrubber on the MDF press vents for formaldehyde control. These equipment control VOC emissions as well. The initial EPA proposed rule indicated that regenerative thermal oxidation (RTO) technology would represent RACT for the VOC. In response, the facility proposed an alternative VOC RACT. The basis for this alternative proposal relied on supplemental information regarding the VOC emission control effectiveness of the equipment that was installed, a reevaluation of the emission baseline used by the EPA in the analysis supporting their initial proposal reevaluation of the economic data for the resulting control alternatives, and consideration of the average level of VOC emissions control actually achieved at other U.S. MDF plants. The analysis concluded that the current equipment being installed would achieve substantial VOC emission reduction, and represented RACT. However, recent source testing results of the installed equipment indicates that the anticipated level of VOC control is not being achieved and necessary controls to meet RACT is currently being considered.