CC-98-050: Applicability of Subpart Kb NSPS to Pulp Mill Storage Tanks

Attached is a letter recently received by AF&PA from EPA’s Office of Enforcement and Compliance Assurance regarding the applicability of the Subpart Kb New Source Performance Standard (NSPS) to tanks containing volatile organic liquids. EPA concluded the Subpart Kb NSPS do not apply to tanks that are “flow-through process tanks” because they are not used to store liquids.