FACT SHEET
Final Amendments to Air Toxics Standards for Cellulose Products
Manufacturing
ACTION
•	On March 11, 2020, the US. Environmental Protection Agency (EPA) finalized
amendments to the 2002 Cellulose Products Manufacturing National Emission
Standards for Hazardous Air Pollutants (NESHAP).
•	The Cellulose Products Manufacturing NESHAP applies to two source
categories - Cellulose Ethers Production and Miscellaneous Viscose
Processes, which currently include cellophane, cellulose food casings and
cellulosic sponges.
•	Following a residual risk and technology review conducted under the Clean
Air Act (CAA), EPA is finalizing:
o The elimination of the startup, shutdown and malfunction exemption;
o Periodic air emissions performance testing once every five years for facilities
using non-recovery add-on controls to demonstrate compliance with the
standards;
o A requirement for facilities to submit electronic copies of compliance
reports, including performance tests; and
o Provisions for more flexible monitoring requirements.
•	This action applies to emissions units including process vents, storage vessels,
equipment components, wastewater and liquid streams in open systems.
RESIDUAL RISK ASSESSMENT
•	The CAA requires EPA to assess the risk remaining after application of the final
air toxics standards. This is known as a residual risk assessment.
•	Based on the completed risk assessment, available health information and
associated uncertainties, EPA determined risks from cellulose products
manufacturing to be acceptable and provide an ample margin of safety to
protect public health.
•	The maximum individual cancer risk for inhalation is estimated to be 80-in-l
million for the Cellulose Ethers Production source category and less than 1-in-l
million for the Miscellaneous Viscose Processes source category.
o For both source categories, the chronic hazard index and acute hazard
quotient are below 1.
TECHNOLOGY REVIEW
•	The CAA also requires EPA to assess, review and revise the air toxics standards as
necessary, taking into account developments in practices, processes and control
1

-------
technologies since the standards were first issued.
•	The technology assessment for cellulose products manufacturing did not identify
any technological developments to reduce emissions of air toxics.
BACKGROUND
•	The CAA requires EPA to regulate hazardous air pollutants, also known as air toxics,
from categories of industrial facilities in two phases.
•	The first phase is "technology-based," where EPA develops standards for controlling
the emissions of air toxics from sources in an industry group (or "source category").
These maximum achievable control technology (MACT) standards are based on
emissions levels that are already being achieved by the best-controlled and lower-
emitting sources in an industry.
•	Within eight years of setting MACT standards, the CAA directs EPA to assess the
remaining health risks from each source category to determine whether the MACT
standards protect public health with an ample margin of safety and protect against
adverse environmental effects. This second phase is a "risk-based" approach called
residual risk. Here, EPA must determine whether more health-protective standards
are necessary.
•	Also, every eight years after setting MACT standards, the CAA requires that EPA
review and revise the standards, if necessary, to account for improvements in air
pollution controls and/or prevention.
FOR MORE INFORMATION
•	To download a copy of the final rule notice, go to EPA's website at
https://www.epa.gov/stationary-sources-air-pollution/cellulose-products-
manufacturing-national-emission-standards.
•	Today's action notice and other background information are also available either
electronically at https://www.regulations.gov/. EPA's electronic public docket and
comment system, or in hardcopy at the EPA Docket Center's Public Reading Room.
o The Public Reading Room is located at the EPA Headquarters library, room number
3334 in the EPA WJC West Building, 1301 Constitution Avenue, NW, Washington, DC.
Hours of operation are 8:30 a.m. to 4:30 p.m., eastern standard time, Monday
through Friday, excluding federal holidays,
o Visitors are required to show photographic identification, pass through a metal
detector and sign the EPA visitor log. All visitor materials will be processed through an
X-ray machine as well. Visitors will be provided a badge that must be visible at all
times.
o Materials for this final action can be accessed using Docket ID No. EPA-HQ-OAR-2018-
0415.
•	For further technical information about the rule, contact Dr. Kelley Spence at the
EPA's Office of Air Quality Planning and Standards, at (919) 541-3158 or at
spence.kelley@epa.gov.
2

-------