EPA-450/2-76-014-a
 STANDARDS SUPPORT
 AND ENVIRONMENTAL
  IMPACT STATEMENT
        VOLUME 1:
 PROPOSED STANDARDS
   OF PERFORMANCE
FOR KRAFT PULP MILLS
     Emission Standards and Engineering Division
    U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Waste Management
     Office of Air Quality Planning and Standards
     Research Triangle Park, North Carolina 27711

           September 1976

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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air and
Waste Management, Environmental Protection Agency, and approved for publica-
tion.  Mention of company or product names does not constitute endorsement
by EPA.  Copies are available free of charge to Federal employees, current
contractors and grantees, and non-profit organizations--as supplies permit--
from the Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711; or may be obtained,
for a fee, from the National Technical .Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.

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                                 Draft

                         Standards Support and
                     Environmental Impact Statement

                           Kraft Pulp Mills

                    Type of Action:  Administrative

                              Prepared by
Director, Emission Standards and Engineering Division          (Date)
Environmental Protection Agency
Research Triangle Park, N. C.  27711

                              Approved by
Assistant Administrator                                        (Date)
Office of Air and Waste Management
Environmental Protection Agency
401 M Street, S.W.
Washington, D. (/.  20460
Additional copies may be obtained at:

Public Information Center (PM-215)
Environmental Protection Agency
Washington,  D. C.  20460

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                               INTRODUCTION
     Standards of performance under section 111 of the Clean Air Act are proposed
following a detailed investigation of air pollution control methods available
to the affected industry and the impact of their costs on the industry.  This
document summarizes the information obtained from such a study of the kraft
pulping industry.  Its purpose is to explain in detail the background and
basis of the proposed standards and to facilitate analysis of the proposed
standards by interested persons, including those who may not be familiar with
the many technical aspects of the industry.  To obtain additional copies of
this document or the Federal Register notice of proposed standards, write to
Public Information Center  (PM-215), Environmental Protection Agency, Washington, D. C.
20460  (specify Standard Support  and  Environmental  Impact Statement:  Standards
of Performance for Kraft Pulp Mills,  Volume  I).
AUTHORITY FOR THE STANDARDS
     Standards of performance for new stationary sources  are developed under
section 111  of the Clean Air Act (42  USC 1857c-6),  as  amended in 1970.   Section 111
requires the establishment of standards of performance for new stationary
sources of air pollution which ". .  .may contribute significantly to air
pollution which causes  or  contributes to the endangerment of nublic health
or welfare."  The Act requires that standards  of performance for such sources
reflect ".  . .the degree of emission  limitation achievable through the aoolication

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of the best system of emission reduction which (taking into account the  cost
of achieving such reduction) the Administrator determines has  been adequately
demonstrated."  The standards apply only to stationary sources,  the construction
or modification of which commences after regulations are-proposed by publication
in the Federal Register.
    Section 111 prescribes three steps to follow in establishing standards  of
performance.
    1.  The Administrator must identify those categories of stationary sources
        for which standards of performance will ultimately be promulgated by
        listing them in the Federal Register.
    2.  The regulations applicable to a category so listed must be proposed
        by publication in the Federal Register within 120 daj(S of its listing.
        This proposal provides interested persons an opportunity for comment.
    3.  Within SO days after the proposal, the Administrator must promulgate
        standards with any alterations he deems appropriate.
      Standards of performance, by  themselves,  do not  guarantee  protection of
 health or welfare; that is,  they  are  not  designed  to  achieve  any  specific
 air quality levels.  Rather,  they  are designed to  reflect  best  demonstrated
 technology  (takinq into account costs)  for the affected  sources.  The overriding
 purpose of  the collective body of  standards  is to  maintain  existing  air quality
 and to orevent" new pollution  problems  from developing.
      Previous  legal  challenges to  standards  of performance  have resulted in
                        1  ?
 several court  decisions  '    of importance in  developing  future  standards.   In
 those cases,  the principal  issues  were whether EPA:   (1) made reasoned decisions
 and fully explained  the basis of  the  standards,  (2) made available to interested
 parties the information on which  the  standards were based,  and  (3) adequately
 considered  significant comments from  interested parties.

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    Among other things, the court decisions established: (1) that preparation of
environmental impact statements is not necessary for standards developed under
section 111 of the Clean Air Act because, under that section, EPA must consider
any counter-productive environmental effects of a standard in determining what
system of control is "best;" (2) in considering costs it is not necessary to
provide a cost-benefit analysis; (3) EPA is not required to justify standards
that require different levels of control in different industries unless such
different standards may be unfairly discriminatory; and (4) it is sufficient
for EPA to show that a standard can be achieved rather than that it has been
achieved by existing sources.
    Promulgation of standards of performance does not prevent State or local
agencies from adopting more stringent emission limitations for the same sources.
On the contrary, section 116 of the Act (42 USC 1857-D-l) makes clear that States
and other political subdivisions may enact more restrictive standards.
Furthermore, for heavily polluted areas, more stringent standards may be required
under section 110 of the Act (42 USC 1857c-5) in order to attain or maintain
national ambient air quality standards prescribed under section 109 (42 USC 1857c-4),
Finally, section 116 makes clear that a State may not adopt or enforce less
stringent new source standards than those adooted by EPA under section 111.
     Although standards of performance are normally structured in terms of
numerical emission limits where feasible,!'  alternative approaches
are sometimes necessary.  In some cases nhysical measurement of emissions from
    —'"'Standards of performance,1  .  .  .  refers to the degree of emission control
which can be achieved through process changes, operation changes, direct emission
control, or other methods.  The Secretary [Administrator] should not make a
technical judgment as to how the standard should be implemented.  He should
determine the achievable limits and let the owner or operator determine the most
economical technique to apply."  Senate Report 91-1196.
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 a new source may be impractical or exorbitantly expensive.  For example,
 emissions of hydrocarbons from storage vessels for petroleum liquids are
 greatest during tank filling.  The nature of the emissions (high
 concentrations for short periods during filling and low concentrations for
 longer oeriods during storage) and the configuration of storage tanks make
 direct emission measurement impractical,,  Therefore, a more practical
 approach to standards of oerformance for storage vessels has been equioment
 soecification.
 SELECTION OF CATEGORIES OF STATIONARY SOURCES
    Section 111 directs the Administrator to publish and from time to time revise
a list of categories of sources for which standards of performance are to be
proposed.  A category is to be selected ". .- .  if [the Administrator] determines
it may contribute significantly to air pollution which causes or contributes to
the endangerment of public health or welfare."
    Since passage of the Clean Air Amendments of 1970, considerable attention
has been given to the development of a system for assigning priorities to various
source categories.  In brief, the approach that has evolved is as follows.  Snsciflc
areas of interest are identified by considering the broad strategy of the Agency
for imolementing the Clean Air Act.  Often, these "areas" are actually pollutants
which are primarily emitted by stationary sources.   Source categories which emit
these pollutants are then evaluated and ranked  by a process involving such
factors as (1) the level  of emission control  (if any) already required by
State regulations; (2)  estimated levels of control  that might result from
standards of performance  for the source category; (3) projections of growth
and replacement of existing facilities for the  source category;  and (4)  the
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estimated incremental  amount of air pollution that could be  orevented,  in a pre-
selected future year,  by standards of performance for the source category.   An
estimate is then made  of the time required to develop a standard.   In some
cases, it may not be feasible to develop a standard immediately for a source
category with a high priority.  This might occur because a program of research
and development is needed to develop control  techniques or because techniques
for sampling and measuring emissions may require refinement.  The schedule  of
 activities must also  consider differences  in the time  required  to  complete  the
 necessary investigation for different source categories.  Substantially  more
 time may be necessary,  for example, if a number of pollutants must be  investigated
 in a single source category.  Further, even  late in the development process the
 schedule for completion of a standard may  change.   For example, inability  to
 obtain emission data  from well-controlled  sources  in time to pursue the  development
 process in a systematic fashion mav force  a  channe in  schedulino.
      Selection of the source category leads  to  another major decision:   determination
 of the tynes of facilities within the source category  to which  the standard will
 apply.  A source category often has several  facilities that cause  air  pollution.
 Emissions from some of these facilities  may  be  insignificant or very expensive
 to control.  An investigation of economics may  show that, within  the costs  that
 an owner could reasonably afford, air pollution control  is  better  served by applying
 standards to the more severe pollution problems.   For  this  reason  (or  perhaps
 because there may be  no adequately demonstrated system for  controlling emissions
 from certain facilities), standards often  do not apnly to all  sources  within
 a category.  For similar reasons, the standards may not aoply  to  all air
 pollutants emitted by such sources.  Consequently, although a  source category
 may be selected to be covered by a standard  of  performance, not all  pollutants
 or facilities within  that source category  may be covered by the standards.
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PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
     Congress mandated that sources regulated under section 111  of the Clean
Air Act be required to utilize the best system of air pollution  control
(considering costs) that has been adequately demonstrated at the time of their
design and construction.  In so doing, Congress sought to:
     1.  Maintain existing Shigh-quality air,
     2.  Prevent new air pollution oroblems, and
     3.  Ensure uniform national standards for new facilities.
     Standards of performance, therefore, must (1) realistically reflect
best demonstrated control practice; (2) adequately consider the  cost of
such control; (3) be applicable to existing sources that are modified as well
as new installations; and (4) meet these conditions for all variations of
operating conditions being considered anywhere in the country.
     The objective of a nrogram for development of standards is  to identify
the best system of emission reduction which "has been adequately demonstrated
(considering cost)."  The legislative history of section 111 and the court
decisions referred to earlier make clear that the Administrator's judgment
of  vhat is adequately demonstrated is not limited to systems that are in
actual routine use.  Consequently, the search may include a technical assess-
ment of control systems which have been adequately demonstrated  but for v/hich
there is limited operational exoerience.  In most cases, determination of
the "degree of emission limitation achievable" is based on results of tests
of emissions from existing sources.  This has required worldwide investigation
and measurement of emissions from control systems.  Other countries with heavily
populated, industrialized areas have sometimes develooed more effective systems
of control than those used in the United States.
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     Since the best demonstrated systems of emission reduction may not be in
widespread use, the data base upon which standards are developed may be
somewhat limited.  Test data on existing well-controlled sources are
obvious starting points in developing emission limits for new sources.
However, since the control  of existing sources generally  represents  retrofft
technology or was originally designed to meet an  existing 'State  or  local  regulation,
new sources may be able to  meet more stringent emission standards.   Accordingly,
other information must be considered and judgment is  necessarily involved in
setting proposed standards.
    Since passage of the Clean Air Amendments of  1970, a  process for the  development
of a standard has evolved.   In general, it  follows the guidelines below.
    1.   Emissions from existing well-controlled sources are measured.
    2.   Data on emissions from such sources are assessed  with consideration
        of such factors as:  (a) the representativeness of  the source  tested
        (feedstock, operation, size, age, etc.);  (b)  the  age and maintenance  of
        the control equipment tested (and possible degradation in the  efficiency
        of control of similar new equipment even  with good  maintenance procedures);
        (c) the design uncertainties for the type of  control equipment being
        considered; and (d) the degree of uncertainty that  new sources will  be
        able to achieve similar levels of control.
    3.  During development of the standards, information from pilot and
        prototype  installations, guarantees by vendors of control equipment,
        contracted (but not yet constructed) projects, foreign technology, and
        published  literature are considered, especially for sources where
        "emerging" technology appears significant.
    4.  Where possible, standards are develooed which permit the use of
        more than  one  control technique or licensed process.
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     5.  Where possible, standards are developed to  encourage  (or at  least  permit!
         the use of process modifications or new processes  as  a method  of control
         rather than "add-on" systems of air pollution  control
     6.  Where possible, standards are develooed to  permit  use of systems caoable of
         controlling more than one pollutant (for example,  a scrubber can
         remove both gaseous and oarticulate matter  emissions, whereas  an
         electrostatic precipitator is specific to particulate matter).
     7,  Where aonropriate, standards for visible emissions are developed in
         conjunction with concentration/mass emission standards.   The opacity
         standard is established at a level  which will  require proper operation
         and maintenance of the emission control system installed to  meet the
         concentration/mass standard on a day-to-day basis, but not require the
         installation of a control system more efficient or expensive than  that
         required by the concentration/mass  standard.  In some cases, however,
         it is not nossible to develoo concentration/mass standards,  such as  with
         fugitive sources of emissions.  In  these cases, only  opacity standards
         may be developed to limit emissions.
CONSIDERATION OF COSTS
     Section 111 of the Clean Air Act requires that  cost be considered  in developing
standards of performance.  This requires an  assessment of the  oossible  economic
effects of implementing various levels of control technology in new plants  within
a given industry.  The first step in this analysis requires the generation  of
estimates of installed capital costs and annual oneratinq costs for various
demonstrated control systems, each control system alternative  having  a  different
overall control capability.  The final step  in the analysis is to determine the
economic impact of the various control alternatives  upon a  new plant  in the industry.
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The fundamental  question to be addressed is whether or not a new plant would be
constructed if a certain level of control costs would be incurred.   Other issues
that are analyzed are the effects of control costs upon product prices and product
supplies, and producer profitability.
     The economic impact upon an industry of a proposed standard is usually
 addressed both  in absolute terms and by comparison with the control  costs that
 would be incurred as a result of compliance with typical  existing  State control
 regulations. This incremental  approach is taken since a  new plant would be
 required to comply with State regulations in the absence  of a Federal standard of
 performance. This approach requires a detailed analysis  of the impact upon the
 industry resulting from the cost differential that exists between  a standard
 of performance  and the typical  State standard.
      The costs  for control of air pollutants are not the only costs considered.
 Total environmental costs for control of water pollutants as well  as air pollutants
 are analyzed wherever possible.
      A  thorough  study  of  the profitability  and  price-settinc] mechanisms of the
   industry is essential to the analysis  so that  an accurate estimate of potential
   adverse economic  impacts can be made.   It  is also essential to know the capital
   requirements placed on plants  intfie absence of Federal standards of performance
   so that the additional capital requirements necessitated by these standards can
   be  placed  in  the  proper  perspective.   Finally,  it  is  necessary to  recognize  any
   constraints on  capital availability within an  industry  as  this factor  also influences
   the ability of  new plants  to  generate  the  capital  required  for installation  of
   the additional  control equipment  needed to meet  the  standards of performance.

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CONSIDERATION OF ENVIRONMENTAL IMPACTS



     Section 102(2)(c)  of the National Environmental  Policy Act (NEPA)  of 1969



(PL 91-190) renuires Federal  agencies to orenare detailed environmental  statements-



on proposals for legislation  and other major Federal  actions significantly



affecting the quality of the  human environment.   The  objective of NEPA  is to



build into the decision-making nrocess of Federal anencies a careful  consideration



of all environmental asnects  of nronosed actions.



     As mentioned earlier, in a number of lenal  challenges to standards  of



performance for various industries, the Federal  Courts of Anneals have  held



that environmental impact statements need not be prepared by the Agencv  for



proposed actions under section 111 of the Clean  Air Act.   Essentially,  the Federal



Courts of Anneals have determined that "...the best system of emission  reduction,"



"...require(s) the Administrator to take into account counter-productive environ-



mental effects of a proposed  standard, as well as economic costs to the  industry...



On this basis, therefore, the Courts "...established  a narrow exemption  from


                                               1 2
NEPA for EPA determinations under section 111.  '



     In addition to these judicial determinations, the Energy Sunnly and



Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically



exempted proposed actions under the Clean Air Act from NEPA renuirements.



According to section 7(c)(l), "No action taken under  the  Clean Air Act



shall be deemed a major Federal action significantly  affecting the quality



of the human environment within the meaning of the National Environmental



Policy Act of 1969."



     The Agency has concluded, however, that the preparation of environmental



imoact statements could have  beneficial effects  on certain regulatory actions.



Consequently, while not legally reouired to do so by  section 102(2){c)  of NEPA,




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environmental  impact statements  will  be  orenared  for various  regulatory  actions,
including standards of performance developed under section  111  of  the Clean
Air Act.  This voluntary nreoaration  of  environmental  imnact  statements, however,
in no way legally subjects the Agency to NEPA requirements.
     To implement this policy, therefore, a  separate section  is included in
this document which is devoted solely to an  analysis of the potential environ-
mental impacts associated with the nronosed  standards.   Both  adverse and beneficial
impacts in such areas as air and water pollution, increased solid  waste  disposal,
and increased energy consumotion are  identified and discussed.
IMPACT ON EXISTING SOURCES
     Standards of performance may affect an  existing source in  either of two
ways.  Section 111 of the Act defines a  new  source as "any  stationary
source, the construction or modification of  which is commenced  after the
regulations are proposed."  Consequently, if an existing source is modified
after oronosal of the-standards, with a  subseouent increase in  air pollution,
it is subject to standards of performance.  [Amendments to  the  general  provisions
of-Subpart A of 40 CFR Part 60 to clarify the meaning of the  term  modification
were promulgated in the FEDERAL  REGISTER  on  December 16, 1975 (40 FR 58416).]
     Secondly, promulgation of a standard of performance requires States to
establish standards of performance for existing sources in  the  same industry
under section lll(d) of the Act if the standard for new sources limits  emissions
of a pollutant for which air guality  criteria have not been issued under section 108
or which has not been listed as a hazardous  pollutant under section 112.  If a
State does not act, EPA must establish such  standards.   [General provisions
outlining procedures for control of existing sources under  section 111(d)  have
been promulgated on November 17, 1975 as Suboart  B of 40 CFR  Part  60 (40 FR 53340).]
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REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level  of air noTlution control  achievable  by any
industry may improve with technological  advances.   Accordingly,  section 111  of the
Act provides that the Administrator may revise such standards from time to time.
Although standards proposed and promulgated by EPA under section 111 are designed
to require installation of the  "... best system of emission reduction .  . . (taking
into account the cost).  . ." the standards will be reviewed periodically,   Revisions
will be proposed and promulgated as necessary to assure that the standards continue
to reflect the best systems that become available in the future.  Such revisions
will not be  retroactive  but will apply to stationary sources constructed or
modified after proposal  of the  revised standards.
STANDARDS  OF PERFORMANCE  FOR TOTAL  REDUCED SULFUR COMPOUNDS
     The proposed standards Include limitations on emissions of total  reduced
sulfur  (TRS) compounds.   Since  air  quality criteria have not been issued for
TRS compounds and TRS  compounds have not been listed as hazardous air pollutants,
the promulgation, of TRS  standards for kraft puln mills will require States to
establish  standards of performance  for TRS from existing kraft pulo mills
under section lll(d) of  the Act.
     Hydrogen sulfide, methyl mercaptans, dimethyl sulfide, and dimethyl disulfide,
taken as a group, are  called TRS.   The most noticeable characteristic  of TRS
is its  highly odorous  nature.   Public opinion surveys often identify malodors
as the  air pollutant that is most apparent and of greatest personal concern
                  o
to the  individual.   A recent national task group evaluating air pollution research
goals indicated  that odors are  of considerable concern to the average  person.^
This group also  concluded that  odors should be considered undesirable  air pollutants,
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whether or not they are linked to long-term health effects,  simply  because  they
constitute an annoyance to people,
    Numerous cases of individuals obtaining legal  redress  because of damages
suffered from the presence of odors have occurred.   The effects which  resulted
in compensations for damaqes include loss of sleep, loss of  appetite, nausea,
vomiting, and curtailment of the use or enjoyment  of property.
    The Administrator's decision to control TRS emissions  under federal  standards
was based on the following:
    1.  There are no national ambient air quality  standards  for TRS to
        provide protection against the effects  of  TRS.
    2.  Although many states have adopted TRS control regulations,  major sources
        of TRS emissions exist in several states with no TRS regulations.
    3.  A uniform national standard of performance for new sources  would
        discourage movement of major TRS emitters  to states  with no TRS
        regulations.
    4.  Kraft pulp mills, one of the major sources of TRS  emissions, are commonly
        located near major waterways that comprise borders between  states.  The
        potential for interstate conflict concerning control of emissions  from
        such mills has prompted Federal investigations in  the past.
    The Administrator concluded that TRS should be regulated under  section  111
of the Act for the following reasons:
    1.  In contrast with the problems presented by the six pollutants for
        which national ambient air quality standards have  been promulgate^,
        the TRS problem is highly localized initie  vicinity of major point  sources
        and is not complicated by the presence  of numerous area sources.
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         Promulgating a national  ambient air  quality  standard  for TRS
         under section 109 would  require states  to  submit  implementation
         plans to attain and maintain  such  standards.   Because of the
         complex problems involved in  relating emissions to  ambient  levels,
         most plans would be based on  the application of best  demonstrated
         control technology to a  few major  sources  of TRS.   The same
         result can be accomplished more directly and efficiently through
         the promulgation of standards of performance.
     2.   Adopting national standards of performance would  be more comoatible
         with existing state regulations than adopting ambient air quality
         standards.  Most state regulations are  expressed  in terms of  source
         standards rather than ambient air  standards.
REFERENCES
1.  Portland Cement Association vs.  Ruckelshaus,  486 F.  2nd 375 (D.C.  Cir.
    1973).
2.  Essex Chemical  Corp. vs. Ruckelshaus, 486 F 2nd 427  (D.C.  Cir.  1973).
3.  Sullivan, R.J., Preliminary Air Pollution Survey of  OdorousCompounds.
    Department of Health, Education, and  Welfare, Raleigh, North Carolina  -
    APTD 69-42, October 1969.
4.  Peckham, B.W.,  "Odors, Visibility and Art:  Some Aspects of Air Pollution
    Damage."  Presented at:  Seminar on the  Economics of Air and Water Pollution.
    Water Resources Research Center, Virginia Polytechnic  Institute.   Blacksbury,
    Virginia, April 1969, 29 oages.
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                        TABLE OF CONTENTS

                                                                Page

 INTRODUCTION  .....  	v

 LIST OF  FIGURES.  .  .  „	xxii

 LIST OF  TABLES	xxiv

 CHAPTER  1.  SUMMARY.	1-1

         1.1   PROPOSED STANDARDS	1-1

         1.2   ENVIRONMENTAL  IMPACT	1-5

         1.3   INFLATION  IMPACT	1-8

         1.4   CAPACITY AND COST IMPACT	,...,,.. .1-8

CHAPTER 2.  THE KRAFT PULPING INDUSTRY	2-1

        2.1  INTRODUCTION	2-1

        2.2  DESCRIPTION OF THE KRAFT PULPING PROCESS AND
             AFFECTED FACILITIES	2-5

        REFERENCES	 ; . .2-18

CHAPTER 3.  SUMMARY OF THE PROCEDURE FOR THE DEVELOPMENT OF
            THE PROPOSED STANDARDS	3-1

        3.1  LITERATURE REVIEW  AND  INDUSTRIAL CONTACTS	3-1

        3.2  PLANT INSPECTIONS	3-2

        3.3  SAMPLING AND ANALYTICAL TECHNIQUES	3-2

        3.4  EMISSION MEASUREMENT PROGRAM	3-3

        REFERENCES	3-5

CHAPTER 4.  EMISSION CONTROL TECHNOLOGY	4-1

        4.1  PARTICULATE CONTROL	4-1

        4.2  TRS CONTROL	 .4-11

        4.3  ALTERNATIVE CONTROL  SYSTEMS	4-20

        REFERENCES	4-24
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CHAPTER 5.  MODIFICATION AND RECONSTRUCTION	5-1

        5.1  CONVERSION OF A DIRECT-CONTACT FURNACE TO AN
             INDIRECT-CONTACT SYSTEM	5-3

        5.2  CONVERSION OF A LIME KILN FROM BURNING NATURAL
             GAS TO BURNING OIL	5-4

        5.3  ADDING AN ADDITIONAL STAGE OF WASHERS TO AN
             EXISTING BROWN STOCK WASHER SYSTEM	5-4

CHAPTER 6.  EMISSION DATA TO SUBSTANTIATE THE PROPOSED
            STANDARDS	6-1

        6.1  PARTICULATE EMISSIONS	6-1

        6.2  TRS EMISSIONS	6-26

        REFERENCES	6-51

CHAPTER 7.  ENVIRONMENTAL IMPACT	7-1

        7.1  AIR POLLUTION IMPACT   	7-3

        7.2  WATER POLLUTION IMPACT	7-15

        7.3  SOLID WASTE IMPACT	7~16

        7.4  NOISE AND RADIATION IMPACT	7-17

        7.5  ENERGY IMPACT	7-17

        7.6  OTHER ENVIRONMENTAL CONCERNS	7-20

        REFERENCES	7_25

CHAPTER 8.  ECONOMIC IMPACT	8-1

        8.1  INDUSTRY CHARACTERIZATION	8-2

        8.2  CONTROL COSTS AND COST EFFECTIVENESS	8-19

        8.3  OTHER COST CONSIDERATIONS	8-65

        8.4  POTENTIAL ECONOMIC (INCLUDING SOCIAL AND
             INFLATIONARY) IMPACT 	8-66

        REFERENCES	8-74
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                                                               Page

CHAPTER 9.  RATIONALE FOR THE PROPOSED STANDARDS	9-1

        9.1  SELECTION OF SOURCE FOR CONTROL	9-1

        9.2  SELECTION OF POLLUTANTS AND AFFECTED FACILITIES. .9-8

        9.3  SELECTION OF BEST SYSTEM OF EMISSION REDUCTION
             CONSIDERING COSTS	9-13

        9.4  SELECTION OF THE FORMAT OF THE PROPOSED
             STANDARDS	9-29

        9.5  SELECTION OF THE EMISSION LIMITS	9-32

        9.6  VISIBLE EMISSION STANDARDS	9-45

        9.7  MODIFICATION AND RECONSTRUCTION CONSIDERATIONS . .9-49

        9.8  SELECTION OF MONITORING REQUIREMENTS	9-51

        9.9  SELECTION OF PERFORMANCE TEST METHODS	9-58

        REFERENCES	9-60

APPENDIX A  EVOLUTION OF THE PROPOSED STANDARDS 	A-l

APPENDIX B  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS. . . .8-1

APPENDIX C  EMISSION SOURCE TEST DATA 	C-l

APPENDIX D  EMISSION MEASUREMENT	D-l

APPENDIX E  MILL CHARACTERISTICS	E-l

ABSTRACT AND TECHNICAL REPORT DATA	F-l
                                 xxi

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                            LIST OF FIGURES
                                                                Page
2-1   Kraft Pulping Process	2-6
2-2   Direct-Contact (Conventional) Recovery Furnace System
      with Black Liquor Oxidation	2-11
2-3   Indirect-Contact Recovery Furnace System	2-13
6-1   Particulate Concentrations in Control Systems Exhaust
      from Kraft Recovery Furnaces	6-2
6-2   Percent Opacity vs. Particulate Concentration for
      Recovery Furnace Emissions	6-13
6-3   Particulate Emissions in Control System Exhaust From
      Smelt Dissolving Tanks Used in the Kraft Pulping
      Industry	6-14
6-4   Particulate Concentrations in Control System Exhaust
      From Lime Kilns Used in the Kraft Pulping Industry .  .  .  .6-21
6-5   TRS Concentration From Incinerator Burning
      Noncondensables	6-28
6-6   TRS Emissions from Recovery Furnace Systems Averaged
      for Periods of Four Hours	6-31
6-7   TRS Emissions from Direct-Contact Recovery Furnace
      Systems with Black Liquor Oxidation (Furnace A),
      Operator Data	6-32
6-8   TRS Emissions From Indirect-Contact Recovery Furnace
      (Furnace B), Operator Data	6-34
6-9   TRS Emissions From Indirect-Contact Recovery Furnace
      (Furnace H), Operator Data	6-35
6-10  TRS Emissions From Indirect-Contact Recovery Furnace
      (Furnace K), Operator Data	6-36
6-11  TRS Mass Emission Rate From Smelt Dissolving Tank D.  .  .  .6-38
6-12  TRS Mass Emission Rate From Smelt Dissolving Tank E.  .  .  .6-41
6-13  Total Reduced Sulfur (TRS) Concentrations in Control
      System Exhaust From Lime Kilns Used in the Kraft Pulping
      Industry	6-42
                                 xxi i

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                                                               Page

6-14  TRS Emissions From Lime Kiln System Not Utilizing
      Caustic Scrubbing (Lime Kiln D, EPA Data)	6-43

6-15  TRS Emissions From Lime Kiln System Utilizing
      Caustic Scrubbing (Lime Kiln E, EPA Data)	6-45

6-16  TRS Emissions From Lime Kiln System Utilizing
      Caustic Scrubbing (Lime Kiln E, Operator Data) 	 6-46

6-17  TRS Emissions From Lime Kiln System Not Utilizing
      Caustic Scrubbing (Lime Kiln K, EPA Data)	6-48

6-18  TRS Emissions From Lime Kiln System Not Utilizing
      Caustic Scrubbing (Lime Kiln 0, Operator Data) 	 6-49

7-1   Typical Plant Layout (1000-ton-per-day kraft pulp
      mill)	7-7

8-1   Wood, Total Kraft, and Bleached and Unbleached Kraft
      Pulp Consumption	8-8

8-2   Consumption of Various Kraft Pulp Grades 	 8-9

8-3   Disposable Income and Kraft Pulp; Wood Pulp; and Paper
      and Board Consumption	8-11
                               xxiii

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                           LIST OF TABLES
                                                                 Page
1-1   Summary of Proposed Standards and Monitoring
      Requirements	1-2
1-2   Matrix of Environmental and Economic Impacts of the
      Alternative Standards	1-6
4-1   Participate Emissions from Various Recovery Furnace
      Control Systems	4-4
4-2   Particulate Emissions from Various Smelt Dissolving Tank
      Control Systems	4-12
4-3   Particulate Emissions from Various Lime Kiln Control
      Systems	4-13
4-4   Summary of Present State Control Standards for Kraft
      Pulp Mills	4-21
6-1   Recovery Furnace D; Summary of Visible Emissions	6-5
6-2   Recovery Furnace J'; Summary of Visible Emissions	6-7
6-3   Recovery Furnace J"; Summary of Visible Emissions	6-8
6-4   Recovery Furnace L; Summary of Visible Emissions	6-11
6-5   Smelt Dissolving Tank D; Summary of Visible Emissions .  .  .6-16
6-6   Smelt Dissolving Tank F; Summary of Visible Emissions .  .  -6-18
6-7   Smelt Dissolving Tank 6; Summary of Visible Emissions .  .  .6-19
6-8   Lime Kiln LI; Summary of Visible Emissions	6-24
6-9   Lime Kiln L2; Summary of Visible Emissions	6-25
6-10  TRS Emissions from Smelt Dissolving Tanks Used in the
      Kraft Pulping Industry	6-40
7-1   Secondary Environmental Impacts of Individual Control
      Techniques	7-2
7-2   Emission Reduction Under Alternative Control Techniques  .  .'7-4
7-3   Primary Impact of the Alternative Control Systems on
      Mass Emissions	7-6
                              xxlv

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                                                                    Page
7-4   Estimated Impact of Kraft Pulp Mill Emissions Assuming
      the Occurrence of Aerodynamic Downwash	7-9
7-5   Estimated Impact of Kraft Pulp Mill Emissions Under
      Non-Downwash Assumption 	 7-11
7-6   Energy Impact	7-18
7-7   Environmental Impact, of No Standard	7-23
8-1   Summary of Industry Statistics (Firms)	8-4
8-2   Summary of Industry Statistics (by State) 	 8-6
8-3   Pulp, Paper, and Paperboard Production	8-12
8-4   Prices of Kraft Pulp	8-17
8-5   Control Costs for Direct Contact Recovery Furnaces	8-22
8-6   Incremental  Control Costs for Direct Contact Recovery
      Furnaces	8-24
8-7   Control Costs for Indirect Contact Recovery Furnaces	8-26
8-8   Incremental  Control Costs for Indirect Contact Recovery
      Furnaces	8-27
8-9   Control Costs for Smelt Tank Control Systems	8-28
8-10  Incremental  Control Costs for the Smelt Dissolving Tank . .  . 8-30
8-11  Control Costs for Lime Kilns	8-32
8-12  Incremental  Control Costs for Lime Kilns	8-33
8-13  Control Costs for the Digester and the Multiple-Effect
      Evaporators	8-35
8-14  Control Costs for the Brown Stock Washers 	 8-37
8-15  Black Liquor Oxidation Costs	8-39
8-16  Incremental  Control Costs for Black Liquor Oxidation
      Over State Requirements 	 8-41
8-17  Incranental  Costs for Indirect Contact Recovery Furnace
      Over Typical State Control Requirements 	 8-44
8-18  Control Costs for Incineration of Black Liquor Oxidation
      System Off-gases in Recovery Furnace	8-45
                                  xxv

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                                                               Page
8-19  Control Costs for Lime Kilns	8-48
8-20  Incremental Control Costs for Alternative Control
      Systems 2 through 5 Above State Requirements (Lime
      Kilns)	8-49
8-21  Control Costs for the Condensate StHpper	8-51
8-22  Comparison of Alternative Control Systems	8-52
8-23  Summary of Incremental Costs Above State Regulatory
      Requirements per Affected Facility for Designated
      Alternative Controls	8-54
8-24  Summary of Aggregate Incremental Costs for Alternative
      Control Systems for Direct Contact Recovery Furnace
      Designs	8-55
8-25  Cost Effectiveness for 1000 TPD Mill (Direct Contact
      Recovery Furnace)	8-57
8-26  Control Cost Requirements for Digester Modifications. .  .8-60
8-27  Control Cost Requirements for Brown Stock Washer
      Modifications	8-62
8-28  Incremental Control Costs for Indirect Contact
      Recovery Furnaces Over SIP Requirements	8-63
8-29  Cost Requirements for Modifications to Lime Kiln
      Scrubber	8-64
8-30  Absolute and Relative Incremental Control Cests
      for New Plants	8-67
8-31  Simulated Return on Investment Impact: Grass Roots
      New Plants	8-70
8-32  Simulgated Return on Investment Impact: Modifications
      at Existing Plants	8-72
9-1   Effects of Hydrogen Sulfide	9-4
9-2   Comparison of the Alternative Control  Systems  for the
      Lime Kiln Systems	9-21
9-3   Lime Kiln E - Distribution of TRS Data	9-40
9-4   Lime Kiln E - Distribution of TRS Data	9-41
                                xxvi

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                          1.  SUMMARY
1.1  PROPOSED STANDARDS
     Standards of oerformance for new and modified kraft pulp mills
are beinq pronosed under the authority of section 111  of the Clean
Air Act.  Emissions from these sources that will  be controlled
are narticulate matter and total  reduced sulfur (TRS).  Precedinq
the act of prooosal has been the  Administrator's  determination that
emissions from kraft pulo mills contribute to the endanqerment of nublic
health or welfare.  In accordance with section 117 of the Act, nrooosal
of the standards was nreceded by  consultation with aporonriate
advisory committees, independent  exnerts, industry representatives,
and Federal departments and agencies.
     The oroposed standards limit emissions of particulate matter
from three affected facilities:  the recovery furnace, the smelt
dissolving tank, and the lime kiln.   These three  facilities account
for virtually all of the particulate matter emissions from a kraft pulp mill
Emissions of TRS are to be limited from eight affected facilities:
the digester system, the brown stock washers, the multinle effect
evaporators, the black liquor oxidation system, the recovery furnace,
the smelt dissolvinq tank, the lime kiln, and the condensate strinner
system.  These eight facilities account for virtually all of the odorous
emissions of TRS from a kraft oulp mill.  A summary of the proposed
standards and monitoring requirements is presented in Table 1-1.
                                1-1

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                               Table 1-1,  Summary of Proposed Standards-;jnd Monitor^np Requirements

1.

2.

3.

4.
5.


6.

7.
8.

Recovery Furnace
System
Lime Kiln

Smelt. Tank

Brown Stock
Washer System
Black Liquor
Oxidation
System
Condensate
Stripping
System
Digester System
Multiple-Effect
Evaporator
System
Total Reduced
ppm1 Ib/T ADP
52

52

5

52
52


52

52
5

0.15

0.025

0.025

0.01
0.01


0.01

0.01
0.01

Sulfur
g/kg ADP
0.075

0.0125

0.01252

0.005
0.005


0.005

0.005
0.005

Parti cul ate Matter
gr/dscf g/dscm Ib/T ADP g/kg ADP Opacity
0.044 O.I2 2.0 1.0 35

0.067 gas 0.15? gas 0.55 0.0275 None
0.13 oil 0.30 oil .1.07 0.535 None
0.052 0.119 0.3 0.152 None

N ' 4 >
I* * J > - I-UII1--I 	 — -. «.«!,,_. 	 	 	 _p
NC - \



»J C y


n c i

H c . . •+


Monitoring Requirements
Opacity, TRS and 02

TRS, 02, scrubber pressura
drop, fluid supply pressure
Scrubber pressure drop and
fluid supply pressure
TRS,3 firebox temperaturs
TRS, firebox temperature


•^
TRS,0 firebox temperature

TRS,° firebox temperature.
TRS,- firebox tenperature

1.   By volume dry  basis  4 hr average.
2.   Indicates units  of recommended  standard.
3.   In most instances  separate  monitoring will  not  be  required  since  these  sources will  be oxidized 1n the Hroe kiln or recovery furnace.
    If they are oxidized in  separate  incineration or power bDilers only the temperature ;will be monitored.
4.   No Standard.

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     The digester system, the brown stock washer system, the black
liquor oxidation system, the multiple-effect evaporator system, and
the condensate stripper system are sources only of TRS emissions and
constitute approximately 25 percent of the potential  emissions from
the  average kraft pulp mill.  The noncondensable gas  streams from
these facilities can be controlled through incineration in the recovery
furnace, lime kiln, or separate incinerator.  The demonstrated emission
level attainable by incineration is less than 5 ppm.   The proposed
standards for these facilities therefore limit concentrations of TRS
to 5 ppm by volume (dry basis) on a four-hour average.
     The recovery furnace, the smelt dissolving tank, and the lime
kiln are sources of both TRS and oarticulate emissions.  The proposed
standard limits TRS emissions from the furnace to 5 ppm by volume
(dry basis)  on a four-hour average and particulate emissions to 0.10 q/dscm
(Q044 qr/dscf).  The ass stream must be corrected to 8 volume
percent oxygen when the actual concentration exceeds  8 nercent.  In
addition, the opacity of the exhaust stream must not  exceed 35 percent.
     The nrooosed standards for the smelt dissolving  tank have been
developed in terms of a mass-per-unit-of-production basis.  This is
for the purpose of preventing circumvention by dilution due to the
large amount of process air present.  The proposed TRS standard limits
emissions to 0.0125 g/Kg ADP (0.025 Ib/T ADP); the particulate standard
is proposed  as 0.15 g/Kg ADP (0.30 Ib/T ADP).
                                1-3

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     The proposed standards for the lime kiln limit the concentration
of the TRS to 5 ppm by volume (dry basis) on a four-hour average.   When
burning natural gas as fuel, the proposed particulate standard is
0.15 g/dscm (0.067 gr/dscf); when burning fuel oil, the proposed
standard is 0.30 g/dscm (0.13 gr/dscf).   For both the TRS and
particulate standards, the gas stream must be corrected to 10 volume
percent when the actual oxygen concentration exceeds 10 percent.
                                 1-4

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1.2  ENVIRONMENTAL IMPACT
     The beneficial  and adverse environmental  and economic impacts
associated with the  proposed standards and with the various control
system alternatives  that were considered are presented  in  this  section.
The impacts are discussed in detail in chapter 7, Environmental
Effects, and chapter 8, Economic Impact.  A matrix summarizing
these impacts is included in Table 1-2.  Appendix B contains a  cross
reference between this document and the Agency's guidelines for
Environmental Impact Statements.
     Alternative number 1 is the baseline system upon which the
impacts associated with the other alternatives can be measured.
Alternatives 2, 3, 4, and 5 are systems which are combinations
of the potential best demonstrated control technologies, considering
costs.  These five systems are described in chapter 4,  Emission
Control Technology.
     The impacts on air quality due to reductions in TRS and
particulate emissions are beneficially large for alternatives
2, 3, 4, and 5.  The impact on water supply and treatment for
the same alternatives is adverse but small.  This impact is
due to the requirement of scrubbers on the smelt dissolving
tank and the lime kiln.  An adverse solid waste impact may be
caused by the addition of an electrostatic precipitator to the
lime kiln control system under alternatives 4 and 5.  The
impact, however, is considered to be small.  Energy impacts
will be associated with each of the alternative standards.
Comparing the impacts against system number 1 shows that  a
 small  adverse  energy  impact  is  associated  with  alternatives 2  and  3,
                               1-5

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   Table 1-2.  MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS OF THE ALTERNATIVE STANDARDS
\
Alternative
No. 1
Alternative
No. 2
Alternative
No. 3
Alternative
No. 4
Alternative
No. 5
Delayed
Standards
No
Standards
Air
Impact
0
+4
+4
+4
+4
-3
-3
Water
Impact
0
-2
-2
-2
-2
+2
+2
Solid
Waste
Impact
0
0
0
-2
n
+2
+2
Energy
Impact
0
-2
-2
-3
-3
+3
+3
Noise and
Radiation
Impacts
0
0
0
0
0
0
0
Economic
Impact
0
-1
-1
-1
-1
+1
+1
Inflationary
Impact
0
0
0
0
0
0
0
Key:   + Beneficial  Impact
      - Adverse Impact
0 No impact
1 Negligible Impact
2 Small Impact
3 Moderate Impact
4 Large Impact

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and a moderate adverse impact is associated with alternatives 4
and 5.  The additional impact assigned to systems 4 and 5 is due
to the higher electrical  operating requirements on an ESP and
the fuel penalty of the separate incineration unit required when
an ESP is used.  Impacts  on noise levels due to the use of any
of the alternative control systems have not been quantified.  It is
reasonable to assume that any impacts, if they are actually present,
are negligible.  There are no known radiation impacts associated with
any of the alternatives under consideration.  The economic impacts
associated with the alternatives have been judged to be negligible.
     Two additional regulatory alternatives have also been considered:
the impact of delayed standards and the impact of no standards.  In
both cases the adverse impact on air quality would be moderate to
large, since the new and modified facilities that would otherwise
fall under the proposed standards would be allowed to emit TRS and
particulate matter at existing rates.  Other impacts due to these
alternatives are small positive impacts on water and solid waste,
a moderate positive impact on energy, and a negligible positive
economic impact.
                                1-7

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1.3  INFLATION IMPACT
     The costs associated with the proposed standards for new and
modified facilities at kraft pulp mills have been judged not to be of
such magnitude to require an analysis of the inflationary impact.
Screening criteria have been developed by EPA to be used in the impact
analysis.  These criteria have been outlined in an Agency publication
and include:
     (1)  National annualized cost of compliance.
     (2)  Total added production cost in relation to sales nrice.
     (3)  Net national energy consumption increase.
     (4)  Added demands or decreased supn'lies of selected materials.
Should any of the guideline values listed under these criteria be
exceeded, a full inflationary impact assessment is required.

1.4  CAPACITY AND COST IMPACT
     TPie proposed standards- will  impact an estimated 17 million tons- of
kraft pulpinq capacity by 1981.   About one third of the capacity will be
affected as a result of expansion of existing mill  capacity.   TRe remainder
of the capacity will  Be affected By replacement of depreciated designated
fact Ifties.
     TRfi total investment costs by  1981 are projected to be
approximately $104 mill ton.   The fifth year annuallzed  costs,  including
depreciation and fnterest, are estimated at approximately $33  million.
About one third of these costs will be incurred by mills expanding capacity;
the remainder by mills replacing depreciated  designated facilities.

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               2.  THE KRAFT PULPING INDUSTRY
2.1  INTRODUCTION
     Currently there are about 120 kraft oulp mills located in 28
States throughout the United States.  The areas of greatest density
are the Southeast, the Northwest, and the Northeast, in descending
order.  A list of all kraft pulp mills currently operating in the
United States is included in Appendix E.
     The main product; of the kraft pulping industry is wood cellulose
orpulp.  Nearly  all  of trie  32,342,000 tons of  kraft pulp  produced
in 1974 was used to make paper,  linerboard and  similar products.  The
December 1975 market value of semi-bleached kraft pulp was about
350 dollars per ton.  Plant size ranqes from about 180 to 2550 tons of
pulp  per day with an averane pulp production  per mill  of about 770
tons  per day.
     During 1973 about 210,000 people were employed by the industry
in integrated pulp  and paper mills  and  non-integrated pulp mills.
Total wages were about $2,100,000,000.  Approximately 70  percent
of the  pulp produced in the United  States is produced by  the  kraft
process.
     Due to the  rapid growth rate of the industry, kraft  mills are
a particularly attractive source category for new source  performance
standards  (NSPS).   Between  1956  and 1975 the growth rate  of the
industry was 5.5 percent per year.  It  is projected that  kraft pulp
production will  increase at. a rate  of 2.5 percent per year between
1975 and 1978.   However, it, is also projected that the industry
will return to a higher growth rate by  1980.
                               2-\

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     Kraft pulp mills can be significant sources of odorous gases and
particulate emissions.  These odors are offensive and sometimes
carry twenty miles downwind of a mill, subjecting an entire town
to foul odors from a single poorly controlled mill.  Because of
the large areas affected, kraft pulp mills have prompted interstate
abatement activities and have caused international problems.  The
State of Vermont sued the State of New York and International  Paper
Company over the emissions from the pulp mill at Ticonderoga,
New York.  The United States Supreme Court involved EPA as a friend
of the Court for the purpose of supplying technical information,
although EPA did not have NSPS or standards on retrofitting existing
sources.  Other border areas where kraft pulp mills have stimulated
EPA activity in the past include Lewiston, Idaho - Clarkston, Washington;
International Falls, Minnesota - Fort Frances, Ontario;  Fernandina
Beach, Florida-St. Mary's, Georgia; and Luke, Maryland- Keyser,
West Virginia.
     Gaseous emissions from kraft mills are principally hydrogen
sulfide, methyl mercaptan, dimethyl sulfide, dimethyl  disulfide,
and sulfur dioxide.  The particulate emissions are largely sodium
sulfate from the recovery furnace, smelt tank, and lime kiln,  as
well as calcium compounds from the lime kiln.
     Hydrogen sulfide and organic sulfides, when taken  as a group,
are called total reduced sulfur (TRS).   They are extremely odorous,
and can be detected at concentrations of a few parts per billion.
Significant sources of TRS in a kraft pulp mill  which  are candidates
for new source performance standards are the recovery  furnace
                              2-2

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system, lime kiln, smelt dissolving tank, digester system, multiple-
effect evaporator system, black liquor oxidation system, brown
stock washer system, and condensate stripping system.
     In an Agency-sponsored study, completed in 1973,  it was  estimated
that the average United States mill emits approximately 4.8 pounds
of TRS per ton of air-dried pulp (1b TRS/T ADP) produced.1  National
annual TRS emissions from kraft pulp mills using this  emission
factor and the total pulp produced in 1974 are about 77,600 tons.
The typical state standard for the states that have TRS standards
is 1.3 Ibs TRS/T ADP.   A well  controlled mill  emits only 0.25
Ib TRS/T ADP.   Compared to a typical  state standard, this is
an emission reduction  of 81  percent;  and compared to the average
mill  in the United States, it is a reduction of 95 percent.
     Significant sources of parti oil ate emissions which  are candidates
for new source performance standards are  the  recovery  furnace system,
lime kiln, and smelt dissolving tank.  Bark and  power  boilers are
not presently included but will be considered with  other boilers
under a separate new source performance standard.   Development of
standards of performance forparticulate matter will significantly
reduce emissions over present control levels.  Only a  limited number
of recovery furnaces have installed highly efficient control systems.
Many new furances that are designed to reduce odors by  eliminating
the direct-contact evaporator have created collection  problems for
electrostatic precipitators.  Elimination of  the  direct-contact
evaporator increases the  particulate loading  to  the ESP and changes
the physical characteristics of the dust.  However, properly designed
                                2-3

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precipitators have been shown to be able to solve this problem.   One
domestic mill has successfully used an ESP to control  particulate
emissions from the lime kiln.  There has been little additional
effort by the industry to solve the problems sometimes encountered
with the use of a precipitator or to install more efficient lime
kiln collectors.  The average United States mill emits about 5.5
pounds of particulate per ton of air-dried pulp and this is also
representative of the typical state standard.  A well  controlled
mill emits only 2.8 Ib/T ADP.  National emissions of particulates
from kraft pulp mills are about 89,000 tons per year and would be
reduced by about 49 percent if the best systems of emission reduction
were applied to recovery furnaces, lime kilns, and smelt dissolving
tanks.
     Kraft pulp mills are also sources of S0£, NOX, and CO emissions.
The recovery furnace is the major source of S02.  The lime kiln
and bark or power boilers have also been identified as sources
of S02-  Bark or power boilers are not covered by the proposed
standards and may be covered under a separate industry category.
EPA tests on two recovery furnaces and three lime kilns show
emission levels of S02 of about 3.9 Ib/T ADP (about 70 ppm) and
0.3 Ib/T ADP (about 30 pprn) respectively.  Standards for control
of S02 emissions from recovery furnaces and lime kilns are not
being proposed since the best demonstrated control techniques,
considering costs, has not been identified for these facilities.
     Recovery furnaces and lime kilns are also sources of CO
and NO .  CO emissions were measured by EPA on two recovery furnaces
and showed levels of about 2.5 Ib/T ADP (about 100 ppm).  CO
emissions from lime kilns average about 10 Ib/T ADP.  Presently
                               2-4

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 there are no state regulations specific for control of CO emissions
 from kraft mill recovery furnaces or lime kilns.  Standards for
 CO emissions from these two affected facilities are not being
 proposed since no control  techniques have been  demonstrated in the
 kraft pulpinq industry.
      EPA tests on two recovery furnaces showed NOX levels of
 about 1.9 Ib/T ADP (about 50 ppm).  No data are available on
 NO  emissions from lime kilns at kraft pulp mills.  However,
   A
 EPA tests on three lime kilns used in the lime industry indicated
 NOX emissions of about 200 ppm.  Presently there are no state
 regulations for control of NOX emissions from recovery furnaces
 or lime kilns at kraft pulp mills.  NOX standards are not being
 proposed because there is no available emission control technology
 for NOX which has been demonstrated for these facilities.
 2.2  DESCRIPTION OF THE KRAFT PULPING PROCESS AND AFFECTED FACILITIES
 2.2,1  General Description
    The process for producing kraft pulp from wood is shown in Figure 2-1.
In the process, wood chips are cooked (digested) at an elevated temperature
and pressure in "white liquor", a water solution of sodium sulfide (Na2S)
and sodium hydroxide (NaOH).  The white liquor chemically dissolves lignin
(the material that bonds the cellulose fibers together ) from the wood.  The
remaining cellulose (pulp) is filtered from the spent cooking liquor, washed
with water, and made into paper.
    The balance of the process is designed to recover both cooking chemicals
and heat.   Spent cooking liquor and the pulp wash water are combined to
form a weak black liquor which is concentrated in multiple-effect evaporators
to  about 65 percent solids,  and then fired in a recovery furnace.   There
                                2-5

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Q_
_l

Q-
o
o
                              T
                      Noncondensables
                                                                  T
                                                               Vent Gases
          	 Wood	:

         -White Liquor-*
          (NaOH + Na2S)
                           DIGESTER
                           SYSTEM
Condensate


   	Pulp
                 Exhaust Gas
                         RECOVERY
                         FURNACE
                         SYSTEM
                    BROWN STOCK
                       (PULP)
                        WASHERS
                                                                                Pulp
                                                                            «-Water
                                                     Weak Black Liquor->-
                                                Vent Gases           Noncbndensables
                                                       T    Condensate—^'
                                                I
                                                1BLACK
                                                ^LIQUOR
                                        Heavy   'OXIDATION
                                        black   'TANK
                                                (OPTIONAL)
                           Smelt
                        (Na2C03+Na2S)
                                     f-.

                                     Air
               ilater—>
                                  Vent1 Gases
                         SMELT-
                         DISSOLVING
                         TANK
                           MULTIPLE
                           EFFECT
                           EVAPORATOR
                           SYSTEM
                                                                    Vent Gases
                                                       CONDENSATE
                                                       STRIPPER
                                                                      To treatment pond—»

                                                                             Exhaust  Gases
                          Green Liquor
        f  White
        I— Lin
            Liquor
          (recycle  to
          digester)
CAUS'
FICIZING
FANK
€ 	 Li
                                               Calcium
                                               carbonate
                                               mud
                           Figure 2-1.   Kraft pulping process

                                           2-6

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are'two main types of recovery furnace systems in use in the industry:
the direct-contact evaporator system and the newer indirect-contact
or "low odor," system.   When the conventional  direct-contact
system is employed, oxidation of the concentrated black liquor
prior to combustion in  the recovery furnace is required to minimize
TRS emissions.   Combustion of the wood lignin dissolved in the
black liquor provides heat for generating process steam and
converting sodium sulfate (NagStty) to NagS.  To make up for chemicals
lost in the operating cycle, salt cake (sodium sulfate) is usually
added to the concentrated black liquor before it is sprayed into the
furnace.
     The smelt, consisting of sodium carbonate (NaoCOo) and sodium
sulfide, is dissolved in water to from green liquor which is trans-
ferred to a causticizing tank where quicklime (CaO) is added to
convert the sodium carbonate to sodium hydroxide.  Formation of
the sodium hydroxide completes the regeneration of white liquor,
which is returned to the digester.  A calcium carbonate mud precipitates
from the causticizing tank and is calcined in a kiln to regenerate
quicklime.   The condensate streams from the digester system and multiple-
effect evaporator system usually contains dissolved TRS gases.
These gases may be removed from the stream prior to discharge with
a condensate stripping  system using either air or steam in a stripping
column.
2.2.2  Digester System
     Wodd chips are digested at about 170 to 175°C at pressure ranging  from
100 to 135 pounds per square inch gauge (psig).   Gases formed during digestion
                                     2-7

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are vented in order to maintain the proper cooking pressure within the unit.
At some mills these gases are first cooled to condense and recover turpentine
before venting.  The condenser cooling water recovers the heat and may he
used in some other process.   At the end of the  cooking cycle,  contents  of
the digester are transferred to an atmospheric  tank usually referred to as
a blow tank.  Steam and other gases that flash  from the blow tank are piped
to a condenser to permit heat recovery.  The noncondensable gases from the
relief system and the blow tank vent may contain TRS concentrations  as  high
              n
as 26,000 ppm.   Both streams are sometimes referred to as digester  "non-
condensables".  Uncontrolled TRS emissions from a typical digester system
(lonn tons/day) average about; 60 Ib/hr (1.5 Ib/T ADP) at a concentration of
         i)
9500 ppm.   Operating variables that have been  shown to affect TRS emissions
from digester systems are the black liquor recycle rate, cook duration,
cooking liquor sulfidity (percentage of sodium  sulfide to total alkali,
Na2S and NaOH, in white liquor), and residual alkali level.  Presently
five states require incineration of the digester noncondensables.
2.2.3  Brown Stock Washer System
     Pulp from the digesters is washed countercurrently with water in
several sequential stages.  On leaving each stage, the pulp is dried on
a vacuum filter, with the water draining into filtrate tanks.   Some
washer systems are hooded to collect the vapors steaming off the open
washers.  TRS emissions from a washer system average about 0.1 Ib/T ADP
(5-37 ppm) in the hood vent gas and about 0.2 Ib/T ADP (240-600 ppm)
in the filtrate tank (under) vent.'
     Brown stock washer TRS emissions have been shown to be affected by
the wash water source, water temperature, degree of agitation and turbu-
lence in filtrate tank, and blow tank pulp consistency.3  Presently one
                                2-8

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 state  requires  incineration of the gases from the brown stock washer
 system.*
 2.2.4   Black  Liquor Oxidation Tank
     Black  liquor  oxidation is designed to decrease the emission
 from the  direct-contact evaporator by producing a negligible
 sodium sulfide  concentration in the black liquor.  Black liquor
 oxidation is  the practice of oxidizing the sodium sulfide to
 sodium thiosulfate or  a higher oxidation state in either weak or
 strong black  liquor, using either oxygen or air.  As previously
 mentioned,  sodium  sulfide that is present in the black liquor
will react with SO- and COo in the recovery furnace gases  to produce hydrogen
sulfide.  In these mills which oxidize black liquor,  air is  most often used.
Sparging  reactors, packed towers, and bubble tray columns  have been used in
single or  multiple stages to provide intimate contact between the liquor
and air.  During the process the air strips out some reduced sulfur compounds
from the  liquor.   TRS emissions are orincioally dimethyl sulfide and dimethyl
disulfide and generally are emitted in the range of 0.08 to 0.13 Ib/T ADP  (about
35 optn)?  Oxidation systems that use only oxygen have the advantage of emitting
virtually no off-gases because the total gas stream reacts in the sparge system.
    Black liquor oxidation system TRS concentrations are affected by the
sulfide content, residence time in system and temperature of the black liquor.
'Presently there are no state regulations controlling the TRS emissions from
black  liquor oxidation systems.
 2.2.5   Multiple-Effect Evaoorat.nr Sv<;tpm
    Spent cooking  liquor from the digester is combined with the pulp washer
discharge to form  weak (dilute) black liquor.  Multiple-effect evaporators
are utilized to concentrate the weak black liquor'from 12-18 percent
                                 ? 9

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 solids  to 40-55 percent solids.  Concentration of the black liquor Is
 necessary to  facilitate combustion  of  the  dissolved  organic material  in
 the  recovery  furnace.  During  the concentration, all of the gases are routed
 through a condenser.  The noncondensable gases consist of air drawn in
 through system leaks and reduced sulfur compounds that were either in the
 dilute  black  liquor or formed  during the evaporation process.  TRS emissions
 from the multiple-effect evaporators can be as high as 44,000 ppm.   Uncontrolled
 TRS  emissions from a typical evaporator system (1000 tons of pulp/day) average
 about 42 Ib/hr (1.0 Ib/T ADP)  at a  concentration of 6800 ppm.*5
    The type of condenser used can influence the TRS concentrations.   Certain
 types of condensers (e.g. barometric) allow the noncondensable gases  and
 the  condensate to mix»  resulting in a limited quantity of hydrogen sulfide
 (H2S) and methyl  mercaptan gases to be dissolved in the water.  This  reduces
 the TRS concentration from the system but  increases the sulfide level  in the
 condensate.  Sulfidity and pH of the weak  black liquor also tend to have an
 effect  on the TRS concentration from the multiple-effect evaporators.
     Presently five states  require  incineration of the  noncondensables from
the multiple effect evaoorators.
 2.2.6  Recovery Furnace System
      In the recovery furnace, concentrated black liquor is burned to produce
 a smelt of sodium carbonate and sodium sulfide that is used to reconstitute
 cooking liquor.   Steam is produced as a by-nroduct.
      There are two main t.yoes of recovery  furnace systems in use in the
 industry.  The first type enrol oys a direct-contact evaoorator to provide
 the final stage of evaporation for the black liquor; this type is called
 a conventional or direct-contact system, and is shown in Figure 2-2.   The
                                 2-10

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ro
i
 Air
 Smelt
                                                                                                           Exhaust
                                                                                                         AGas
                                                                                                         i
                                                                           DEVICE
                                                                                       Vent
                                                                                       Gases
                                          DIRECT CONTACT
                                          UlKtUI LUIMIrttl
                                            EVAPORATOR
500/ SnliH«
BLACK LIQUOR
  OXIDATION
    TANK
                                                                                       «-,
                                          CTAfi/
                                          b'ALK
                                                                                               Black Liquor
            Figure  2-2. Direct Contact (Conventional) Recovery  Furnace  System  With  Black Liquor Oxidation

-------
second type of recovery furnace employs an indirect-contact, direct-fired,
or a "low odor" system and is shown in Figure 2-3.  About 75 oercent of the
new furnaces that have been installed in the last 5 years are of the
indirect-contact design.
    The particulate levels from a recovery furnace prior to  a direct contact
evaporator or control  device normally range from 8 to 12 gr/dscf (200 to 450
Ib/T ADP).  A direct contact evaporator acts as  a participate control
device and reduce the particulate enission f^om  a furnace system by about
50 percent.  The particulate emissions from uncontrolled recovery furnace
systems presently in operation average about 3.81 gr/dscf (180 Ib/T ADP).'
The particulate matter emitted from the recovery furnace consists of sodium
sulfate and sodium carbonate and may contain small amounts of sodium chloride.
Sodium chloride will be present if the pulpwood  has been stored in saline
water or if the make-up chemicals contain chloride impurities.
     TRS emissions from this facility mav originate in either the furnace
or in the direct-contact evaporators and may be  as high as several  hundred
parts ner million (pom) or as low as 1 r>nm when  controlled by careful furnace
          O
operation.    Recovery furnace emissions are affected by the quantity and
distribution of combustion air, rate of solids  (concentrated black liquor)
feed, spray pattern and droplet size of the liquor fed, turbulence in
the oxidation zone, and smelt bed disturbance.   The effect of these variables
on TRS emissions  has been shown to be independent of the oresence or
absence of a direct contact evaporator.   TRS emissions from the direct-
contact evanorator depend largely on the concentration of sodium sulfide
in the black liquor.  Acidic gases, such as carbon dioxide and sulfur dioxide,
in the flue gas react with sodium sulfide in the black liquor to form
hydrogen sulfide  gas.
                               2-12

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PO
I
   Air
   Smelt

r— !~ NX-




RECOVERY FURNACE
/
> 1
i











Combustion gas ^

i
i






'. i v ;
"~ ;
-' [
N :
— "" •_' . *
i
! 	 — !


^- T~/:i*~l 65% Solids
~ s- 	 ^:
i
t 	 — >




INDIRECT

CONTACT
EVAPORATOR






C ~t O/
i 57%

1

I —
PARTICULATE j 	
CONTROL I j 1
npvirF i ''
i

1
I
i j





• 	 »!
Exhaust
• Gas


















STACK ;


                           Figure 2-3.  Indirect contact recovery furnace system.

-------
     Four commercially available processes eliminate the direct-contact
evaporator to avoid this source of emissions.   In these systems, the furnace
flue gases never directly contact the black liquor and hydrogen sulfide
cannot be formed in the evaporator.
     Of the 12 states which presently regulate kraft mill TRS emissions,
the typical TRS standard for existing recovery furnaces is 17.5 ppm (0.5
Ib/T ADP).  There are 12 states that haye a particulate standard
specifically for kraft recovery furnaces.  Typically, the state
standards are about 4 Ib/T ADP (0.085 gr/SDCF).  The most stringent
is 2.75 Ibs/T ADP (0.058 gr/SDCF).9
2.2.7   Smelt  Dissolving  Tank
    The smelt dissolver  is a large tank located below the recovery furnace
hearth.   In it, molten smelt  (sodium  carbonate and  sodium sulfide) th*fe
accumulates on the floor of the recovery furnace is dissolved in water to
form green liquor.  The  tank is equipped with an agitator to assist
dissolution,  and a steam or liquid shatterjet system to break up the
smelt  stream  before it enters the solution.  Contact of the molten
smelt  with the water causes the evolution of large  volumes of steam,
which  must be vented.
     Particulate matter  (finely divided smelt) is entrained in the vapor
that leaves the tank.  Uncontrolled emissions from  a typical smelt
dissolving tank (1000 tons of pulp/day) may be as hinh as 380 Ib/hr
(8.0 Ib/T ADP).1
     Because  of the presence of a small percentage  of reduced sulfur
compounds in  the smelt,  some odorous materials escape the tank with
the flashed steam.  TRS  concentrations may be as high as about 800 ppm
                                2-14

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and as ">ow as non-detectable.     Several factors have been shown
to affect the TRS emissions from this facility.  Among these
that affect the emissions from the tank are the sulfide content
of the primary water in the tank itself, the turbulence of the
dissolving water, and the sulfide content of the smelt entering
the tank.  It is also possible that TRS-contaminated gases can
flow from the smelt pour spout of the recovery furnace and be
emitted from the smelt tank.  TRS can also be generated from the
particulate scrubber.  Factors that affect the generation of TRS
from this unit are pR and sulftde content of trie water and the
sulfide content of the collected particulate.
     Presently ten states have regulations to control the particulate
emissions from smelt dissolving tanks.   These regulations are
typically 0.5 Ib/T ADP (0.087  gr/SDCF).   No state has a TRS regula-
tion specifically for smelt dissolving  tanks.
2.2.8  Lime Kiln
     The lime kiln is an essential element of the closed-loop system that
converts the green liquor solution of sodium carbonate and sodium sulfide
to white liquor.  The kiln calcines the lime mud (calcium carbonate which
precipitates from the causticizer) to produce calcium oxide  (quicklime, CaO)
for recausticizinq the green liquor.  The lime sludge typically enters as a
55 to 60 percent solid-water slurry.
    The  kraft pulping  industry  typically  uses  large  rotary kilns that are
capable  of  producing 40  to  400  tons  per day  of quicklime.  Fluidized bed
calciners are presently  being used at four pulp mills but their production
rate at  this time is under  150  tons/day.  These fluidized bed calciners only
produce  about one percent  of  the total  quicklime produced  in the kraft
          1?
industry.

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     The lime kilns used in the industry differ from those used in the lime
manufacturing industry in that the'calcium carbonate is  qenerallv fed as
a mud (sludge), containing 40 to 45 percent water instead of as a solid
(limestone).  This mud contains a small  percentage of sodium sulfide which
affects the size distribution and composition of the particulate in the
exhaust gases.  This sodium.sulfide is not present in the limestone used  in
the lime industry.  Dry collectors, such as electrostatic precipitators,  and bag-
houses, are used extensively in the lime manufacturing industry but presently
only one kraft pulp mill uses a dry collector  (electrostatic precipitator).
    TRS emissions  can originate in the lime kiln proper and in the kiln
scrubber which is  normally  installed to control particulate emissions.  TRS
emissions oriqinatinq in the lime kilns are affected by several factors:   the
oxyqen  content of  the exhaust stream, the  kiln length-to-diameter ratio, the
sulfide content of the lime mud, the cold-end  exit gas temperature, and the
practice of simultaneously  burninq the sulfur-bearing materials contained
in  the  lime mud (e.g. green liquor dregs;  the  impurities  resulting from
clarifying the green liquor).'-*
     Operating variables which govern the  contribution of TRS emissions
from the particulate control device are the residual sulfide content
of  scrubber make-up water (depending on the source of the water), the
recirculation rate within the scrubber, the pH of the scrubbing solution,
and the sulfide content of the particulate collected.  Depending on
these factors, the particulate control device may contribute as much
as  100 ppm (0.5 Ib/T ADP) to the kiln exhaust.13
                                2-16

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    Lime kiln participate emissions  consist  principally  of  sodium  salts,


calcium carbonate, and  calcium oxide.   The  sodium salt  emissions  results


primarily from sodium compounds that are retained  in  the mud  because  of


less efficient or incomplete washing.  Therefore,  the particulate  emissions


are affected by the efficiency of the mud washing  system (higher than normal


sodium levels in mud result in higher particulate  emissions).   The calcium


particles result from entrainment, and therefore the  emissions are affected by


the gas velocity and turbulence in the kiln.  Uncontrolled  particulate


emissions from a typical  lime kiln (1000 ton of pulp/day) are about 3300


Ib/hr (80 Ib/T ADP) at a concentration of 9.7 gr/sdcf.1


     Presently only three states have TRS regulations specifically for lime


kilns.  These standards are typically 40 pnm (0.2  Ib/T ADP),  and the  most


stringent is 10 ppm.  Twelve states  have oarticulate  standards snecifically


for kraft mill lime kilns.  Typically, these standards are  about  1.0  Ib/T


ADP (0.12 gr/dscf), and the most stringent is 0.5  Ib/T ADP  (0.061  gr/dscf).8

2.2.9   Condensate  Stripping System

     When digester and multiole-effect evaporator off-gases are condensed,


some TRS gases  are partially  dissolved in the condensate.  Prior to being


discharged  to the  water treatment ponds, the TRS compounds  can!be strioped


from  the digester  and evaporator condensate with either steam or air in a


stripping column.   Uncontrolled TRS emissions from a condensate striooer


are estimated to  be about  2 Ib/T ADP  (5000  ppm).    Currently only one state

                                                                    a
requires incineration  of  gases  from the  condensate stripping system.
                                     2-17

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                          References
 1.  AtmosphericEmissions from the Pulp and Paper Manufacturing
     Industry, EPA-450/1-73-002, September 1973, (Also published
     as a NCASI Technical Bulletin No. 69, February 1974).
 2.  Reference No. 1, Table 3, p. 15.
 3.  Factors Affecting Emission of Odorous Sulfur .Compounds From
     Miscellaneous Kraft Process Sources; NCASI Technical Bulletin
     No. 60, March 1972.
 4.  Hovey, Harry H.  Jr., New York State Department of Environmental
     Conservation, April 5, 1974, letter to Mr. Jean J.  Schueneman, EPA.
 5.  Reference No. 1, Table 20, p. 46.
 6.  Reference No. 1, Table 7, p. 20.
 7.  Reference No. 1, pages 34-37.
 8.  Factors Affecting Reduced Sulfur Emissions from the Kraft Recovery
     Furnace and Direct Contact Evaporator, NCASI Technical Bulletin
     No. 44, December 1969.
 9.  Analysis of Final State Implementation Plans - Rules and Regulation,
     U.S.  Environmental Protection Agency, Research Triangle Park, N.C.,
     July 1972.
10.  Reference No. 1, pages 48-50.
11.  Reference No. 1, Tables 26 and A-3.
12.  Dorr-Oliver Fluosolids System for Lime Mud Returning in Connection
     with Recausticizing in Kraft Mills, Dorr-Oliver Reprint No.  7353.
13.  Suggested Procedures for the Conduct of Lime Kiln Studies to Define
     Emissions of Reduced Sulfur through Control of Kiln and Scrubber
     Operating Variables, NCASI Special Report No.  70-71, January 1971.
14.  Air Emission Control Program for Hoerner Maldorf Corporation Mill
     Expansion Missoula. Montana; submitted by Hoerner Waldorf Corpnration
     to Montana State, March 12, 1974.
                                 2-18

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       3.  SUMMARY OF THE PROCEDURE FOR THE DEVELOPMENT
                   OF THE PROPOSED STANDARDS
3.1  LITERATURE REVIEH AND INDUSTRIAL CONTACTS
     Information initially used in the develonment of the nrooosed
standards of performance for the kraft pulping industry was obtained
from two studies nerformed bv research and engineering comnanies
                      1  p
under contract; to EPA. '   These studies provide information on
trends in the kraft pulnina industry, industry statistics, economics,
processes and emissions, and emission control  technology and nrocedures.
     A more recent study has provided further information used in
the develonment of the nronosed standards.  This study was a joint
program by the National  Council of the Paper Industry for Air and
Stream Improvement (NCASI) and EPA, and was primarily concerned with
emissions and control techniques used in the kraft pulping industry.
The studv utilized a survey of the industry (nerformed with questionnaires),
special studies reported in NCASI Technical Bulletins, other literature
sources, and a field sampling nroqram conducted by EPA.  The study
provided information on control techniques and range of emissions for
                                                                  o
each of the operations involved in the chemical nulninq processes.
     During the standards develonment nroqram additional literature
was also obtained and reviewed, and information was obtained from four
State and local air pollution control  agencies and from manufacturers
of process equipment and emission control enuinment.  Meetings were
held with representatives of the industry and the NCASI to obtain
additional information useful in the development of standards.
                                3-1

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3.2  PLANT INSPECTIONS
     EPA engineers visited 26 kraft pulp mills to identify those
mills which appeared to utilize the best systems of emission reduction
on any of the affected facilities to which the proposed standards
apply.  Durinq these visits, information and data were obtained on
each of the affected facilities.  The well-controlled facilities
that were tested were chosen on the basis of the type of control
device used, its ooerating conditions, available data on emissions,
and the feasibility of conducting tests.
3.3  SAMPLING AND ANALYTICAL TECHNIQUES
3.3.1  Particulate Sampling
     EPA Reference Method 5 was used to gather the data used to
support the proposed particulate standards for the recovery furnace,
the smelt dissolving tank, and the lime kiln.  The provisions of this
method were originally published in the Federal Register on December 23,
1971 (36 FR 24877).  Minor revisions of the method have been published
since then.
     The method provides detailed sampling methodology and equipment
specifications.  The method also provides specific procedures ;for
the measurement of moisture content and volume of gas sampled, and
permits continuous assurance of isokinetic sampling.
     EPA Reference Method 2 is used to measure gas flow which is
required to calculate the mass emission rate.  Since the proposed
particulate standard for the smelt dissolving tank limits the mass
emission rate rather than the concentration, an accurate measure of
the flow rate is required.
                               3-2

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3.3.2  TRS Sampling and Analysis
     Since no method for measurement of total reduced sulfur had
been standardized at the inception of the kraft mill  program, it
was necessary to develop an effective and reliable method.   Several
methods were surveyed through literature reviews, contact with
industry personnel, and review of previous research and evaluation
of analytical techniques by EPA.
     The methods surveyed fell into four main categories:  colorimetry,
direct spectrophotometry, coulometry, and gas chromotography.  The
gas chromotography and flame photometric detector {GC/FPD)  was
considered to be the most promising and was selected for field
evaluation.
     As a result of the field exoerience of testing TRS compounds
at kraft mills, Method 16, "Semicontinuous Determination of
Sulfur Emissions at Stationary Sources," was prepared
for determining compliance with the proposed standards.  This
method requires the use of the GC/FPD system developed during the
test program.  Design specifications for the required dilution system,
calibration technique, and instrumentation that was considered necessary
to insure accuracy, precision, and reliability are specified.
3.4  EMISSION MEASUREMENT PROGRAM
     EPA performed emissions measurements at 12 domestic kraft pulp
mills.  Included are particulate tests on five recovery furnaces, four
smelt dissolving tanks, and four lime kilns; and TRS tests  on three
recovery furnaces, two smelt dissolving tanks, three lime kilns, and
one incinerator for noncondensable gases from multiple effect
evaporator systems and digester systems.
                                    3-3

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3.4.1  Particulate Test Program
     Of the recovery furnaces tested for nartlculates, two were direct
fired tynes and three had direct contact evanorators.  At least one
complete sootblowing cycle was included within each sampling neriod.
During tests, the control system and furnace operation were monitored
to detect process upsets or abnormal operation which would affect the
test results.  Three or more individual test runs were made for each
furnace.
     During  the  four snelt  tank tests, the control  system  and the
recovery furnace operation  were monitored to  detect  process uosets
or  abnormal  operation which might affect the  test  results.  The
furnace operation was monitored because the flow of  smelt to the
dissolving tank  cannot  be monitored directly  and the  best indication
of  a normal  smelt flow  rate is normal  operation of the recovery
furnace.  Three  or more  individual  test runs  were  made for each
smelt dissolving tank.
     Durinq  the  four lime kiln tests,  both the control system  and the
lime kiln operations were monitored to detect process upsets or
abnormal operation which miqht affect  the test results.   On three
kilns, three test runs  were conducted  on each tyoe of fuel  (gas
and oil) used  in the kiln,  totalling  six test runs for each kiln.
Three test runs were made on the fourth kiln  which only burns
natural gas.
     Opacity measurements were also taken during the particulate
testing whenever possible and were  usually  conducted over the
length  of  the  particulate tests.  All  readings were  taken in
accordance with  EPA  Reference Method  9 technigues.  Visible emissions
                                 3-4

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readings were recorded on four recovery furnace stacks during the
particulate test runs.  Readings were also attempted to be made on
three smelt dissolving tanks and one lime kiln.  Although some data
were recorded, it was determined that due to the presence of steam
plumes, the readings did not support the setting of a visible emissions
standard for the smelt dissolving tank or the lime kiln.
3,*.2  TRSTest Program
     Tests were conducted on three recovery furnaces  (one indirect
contact  furnace and  two with a  direct  contact evaporator), two smelt
dissolving tanks, three lime kilns, and the one incinerator for
noncondensables.  During thesfc  tests,  the control system and the
operation of the respective facilities were monitored to detect
process  upsets or abnormal operation which might affect the test results.
Three  to six individual test runs were made during each of these tests.
The duration of each test run was four hours.
 NOTE:   A chronological  history  of the  development  and evolution
 of the proposed  standards which includes  all  significant  plant
 visits,  meetings, and project milestones  is described  in
 Appendix A,  Evolution of the  Proposed  Standards.
                          References
1.  Control  ofAtmospheric  Emissions in the  Hood Pulping Industry,
    Environmental  Engineering,  Inc.; and  J.  E.  Sirrine Company,
    Contract No.  CPA 22-69-18r» March 15,  1970,
2.  Background Information for Establishment of National Standards  of
    Performance for New SourceT:Pulp  and Paper Industry, (Draft Copy),
    Environmental  Ing1neeHng,  Inc., Contract No.  CPA 70-042, Task  Order
    No. 2, March  15, 1971.
3.  Atmospheric Emissions from the  Pulp and  Paper Manufacturing Industry,
    EPA-450/1-73-002, September  1973, (also  published by NCASI  as Technical
    Bulletin No.  69, February  1974).
                                 3-5

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               4.   EMISSION  CONTROL TECHNOLOGY
     The  alternative methods  of emission  control  applicable to each
 affected  facility  at kraft puln mills  are presented  in  this chapter.
 Where  available, emission data obtained from  the  joint  study
 conducted by  EPA and NCASI are also presented.    These  data
 illustrate the range of  control levels that have  been applied to
 affected  facilities at the domestic mills studied.   Alternative
 emission  control systems, combinations of the best control techniques,
 which  are considered as  likely candidates for the best  system
 of emission reduction, considering costs, are summarized.
 4.1  PARTICULATE CONTROL
 4.1.1   Recovery  Furnace
     Nearly all  recovery furnaces employ  electrostatic  nrecipitators
 as their  primary oarticulate control devices.   The degree of control
 provided, however,  varies among the individual  units.   Design
 efficiencies  range  from  about 90 percent  on older precipitators
 to above  99.5 percent on recent installations.
     Until recently, almost  all recovery  furnace  systems  incorporated
 a direct  contact evaporator.  Although the purpose of the evaporator
 is to  concentrate  black  liquor, it may also scrub particulate
 matter from the gas stream.   Depending on the type of direct-contact
 evaporator used, up to 50% of the participate may be removed.
     Most direct  contact evanorators  are the cascade  type, in  which
the furnace gases pass  over a trough  filled  with black  liquor,  which
is scooped un  by  a  rotating  paddle  wheel  and then cascades through the
gas stream.  Some mills  use  cyclones  or Venturis as  the  direct  contact
                                 4-1

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evaporator.   In these installations,  the black liquor serves  as  the par-
ticulate scrubbing liquid.   Sometimes two Venturis are used in series
to increase  particulate collection, and in that case an electrostatic
precipitator may not be required.
     On some recovery furnaces scrubbers have been installed  down-
stream from  precipitators.   In the United States this practice
has been confined to upgrading existing units.  In Sweden, the
purpose of the backup scrubber has been to increase the heat
recovery from the furnace gases.   The scrubbers used are low
energy sprays.  Such scrubbers can effectively reduce the "snowing"
(the emission of large white particles resembling snowflakes) from
inefficient  precipitators,  but are probably ineffective against  the small
particles that escape from a well  designed and operated precipitator.
The principal cause of snowing is  the electrode rapping done  to
dislodge collected material  from collecting electrodes.  Because
salt cake particles tend to be light  and fluffy, some of it is
re-entrained in the gas stream and can escape the precipitator.
The re-entrainment problem can be  intensified if the gas flow through
the precipitator is improperly distributed.  A second cause of
snowing is electrical sparking.  When excessive sparking occurs,
the basic collecting action of the precipitator is momentarily lost,
and puffs of salt cake particles  can  escape.  Overloading the
precipitator by sootblowing or abnormal furnace operation can also
cause snowing.
                                4-2

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      Emission levels observed from various control  systems are
 shown in Table 4.1.  For each system there is a wide range of emissions.
                                                                3
 This table is based on data reported in a questionnaire survey.
 The emission ranges are due to the variance in collection efficiency
 and design of the control systems.
      In a meeting with EPA on March 7,  1975,  the kraft pulping
 industry expressed concern that even with diligent  maintenance the
 proposed particulate standard of 0.10 g/dscm (0.044 gr/dscf)  for
 kraft recovery furnaces could not be achieved over  the life of an
 electrostatic precipitator (ESP).  The  industry has little confidence
 that precipitator performance will meet design expectations.   In
 support of their contention, case histories of precipitator performance
 were provided to EPA by individual companies.  These cases are concerned
 with units that do not achieve design performance,  with problems
 encountered during the fine turning of units in bringing them up to
 performance, and with the amount of maintenance required to maintain
 the performance of a precipitator.  The industry feels that the
 performance of precipitator should be allowed to deteriorate until a
 sufficient amount of maintenance is necessary to justify shuting.  down
 the unit and performing the maintenance.
     Weyerhauser Co., American Can Co.,  Brunswick Pulp and Paper Co.,
and Buckeye Cellulose all reported problems in the application of
electrostatic precipitators for control  of particulate emissions  from
kraft recovery furnaces.
                    4
     Weyerhauser Co.  stated that their last three precipitator
installations on indirect contact system recovery furnaces have not
                                 4-3

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                  Table  4.1.   PARTICULATE  EMISSIONS  FROM VARIOUS RECOVERY FURNACE CONTROL SYSTEHS

Number of
Control system Units averaged
Preci pita tor 87
Venturi 10
Precipitator & feackup
scrubber Combination
Precipitator only 7
Back-up scrubber 7

(a) (b) (c)
Emissions; Ib/T ADP Emissions; gr/dscf Emissions;q/dscm
Range Median Range Median Range Median
1-95 14 0.02-2.0 0.3 0.05-4.5 0.69
14-115 45 0.3-2.4 1.0 0.69-5.49 2.29

6-88 23 0.1-1.9 0.5 0.229-4.35 1.14
2-13 4 0.04-0.3 0.08 0.09-0.69 0.18
(a)   Reference  1,  pages  34-35
(b)   Calculated from  emissions  in  Ib/T ADP  on  the  basis  of  1.0  gr/dscf  = 47.3  Ib/T ADP.
(c)   Calculated from  emissions  in  gr/dscf on the basis of 1.0 gr/dscf = 2.288  g/dscm.

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met the level of the proposed standard even though the design basis of
99.5 percent should have been adequate.  Extensive efforts have been
made to bring the units into compliance and to overcome corrosion
problems.  One unit has been totally rebuilt at an estimated cost  of
0.5 million dollars and a second unit ts currently facing the same
situation.  The rebuilding of the second unit is expected to exceed the
original costs.  A third precipitator has been plagued by excessive
wire breakage since startup.  Weyerhauser reports that the manufacturer
of the unit blames this problem on poor flue gas distribution at the
inlet.  Based on their experiences with three different manufacturers,
Weyerhauser contends that the state of the art is not now adequate to
meet a level of 0.10 g/dscm,
     American Can Co.   has experienced similar problems.  The first
indirect contact evaporator system was installed at their Halsey,  Oregon
mill in 1969.  American Can reported that during the period August 1,  1973,
to March 1, 1974, it was necessary for American Can to notify the  State
Agency about 70 times that they were exceeding the particulate standard
of 4 Ib/ton due to a malfunction of the precipitator.  Late in 1973
American Can spent approximately $50,000 for mechanical improvements on
the precipitator.  American Can stated that the maintenance of a
precipitator on a kraft recovery furnace is a continuous ordeal for
any kraft mill.  Planned maintenance outages are necessary and it  is
difficult to predict when unplanned situations could occur.  Routine
maintenance expenses are also quite high.
     Brunswick Pulp and Paper Co.  reports that shortly after start-up
                                4-5

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of their unit at Brunswick,  Georgia, they were forced to replace the
electric rappers on the collecting plates with pneumatic rappers.
The original rappers did not produce sufficient rapping intensity to
clear the plates of collected saltcake.  It also became apparent after
start-up that the scraper saltcake removal system had inadequate
capacity.  Other problems causing abnormal precipftator operation have
resulted from troubles with electrical controls, broken wires and
numerous instances of problems with liquor lines which began to fat!
during 1974.  In all, there were 519 hours in 1974 during which
abnormal operation was experienced requiring the process of cutting
out one-half of the precipitator.  Brunswick Pulp and Paper also
experienced additional internal problems due to plugging of turning
vanes and distribution plates, which caused channeling of the gas
flow and reduced the precipitator effectiveness.  Inaccessibility of
the turning vanes requires cooling down the precipitator for maintenance.
Clean out is now scheduled at least semi-annually.  The best remedy
thus far suggested involves the application of rappers to the turning
vanes.
     Brunswick will personnel further stated that even a recently
designed and installed high efficiency precipitator is subject to
malfunction on an average of one day per week.  These malfunctions can
periodically occur more frequently.  Therefore, they state ft is
important to recognize that abnormal operation can and does occur, and
that allowance for unavoidable abnormal operation should be made in the
proposed standards.
                                4-6

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     At the meeting between EPA and kraft pulp mill industry
representatives on March 7, 1975, representatives of Buckeye Cellulose
stated that the particulate emissions from their No. 2 recovery furnace,
which was tested by EPA, increased fay almost 10 times over a one-year
period.  Data obtained in February 1974 showed levels of 0.007 gr/dscf;
data obtained in February 1975 showed levels of 0.06 gr/dscf.  Buckeye
attributed the increase to wire breakage within the precipitator.
                                     7 8
     Three precipitator manufacturers '  were visited by EPA personnel
to obtain their opinion concerning the kraft industry's position with
regard to ESP performance on recovery furnaces.  All three manufacturers
stated that with a reasonable amount of maintenance electrostatic
precipitators can achieve 0.10g/dscm over the life of the unit.
The manufacturers feel that some of the problems encountered by the
industry were due to underdesign of the units or operation under
conditions for which they were not designed.  At a recent TAPPI conference,
one vendor representative stated that if the precipitators had been
adequately sized in the design that they would have been non-competitive
with other bidders.^  Most units being sold presently have design
outlet loadings of 0.01 grain/acf (about 0.02 grain/dscf) for both
conventional and low-odor units.   They further stated that the
performance problems with precipitators on indirect contact system
furnaces are now recognized and that new basic parameters for both
sizing and design have been established.
     Since the characteristics of the particulate matter and the gases
are reasonably constant from mill to mill, the problems encountered are
with air distribution and patterns to minimize re-entrainment.
Application of precipitators to the kraft industry is more demanding
than in other industries.   The dust collected in the fcraft industry,
                                 4-7

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especially from indirect contact systems, is more corrosive and
sticky than that encountered in other industries.  More intense
rapping is required to remove the dust from the collecting surfaces.
The manufacturers feel that some design changes are needed to improve
the precipitator's ruggedness and extra maintenance will  be required.
     Concerning the problem of gradual deterioration of precipitator
performance, the manufacturers were most emphatic in stating that
a properly maintained precipitator should not deteriorate over the
expected life of the unit.   Problems encountered are usually due to
operating the equipment at conditions for which it was not designed
(i.e., higher gas volumes,  higher inlet loadings, or lower inlet
temperatures).  For preventing corrosion, the manufacturers install
insulation or heated shells to maintain the gas temperature through
the precipitator.  Corrosion resulting from low inlet temperature
(below the acid dew point-280°F), frequent start-ups and  shutdowns
of the^recovery furnace, or due to an ambient corrosive atmosphere
is not dependent on the design of the unit.
     The viewpoint of the manufacturers on the wire breakage encountered
by the kraft industry is that wire breakage generally occurs soon
after start-up, with a lessening in frequency as operating time
increases.  A precipitator is generally capable of losing 5 to 10
percent of the wires without a noticeable effect on the performance.
One manufacturer believes that the rash of wire breakage  reported
are due to increased rapping intensity to improve performance.
                             4-8

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This problem is most noticeable with indirect-contact furnaces that



generate a stickier dust which is more difficult to remove from



the collection surfaces.  Some operators have replaced the original



electric rapping system with more efficient high energy air vibrators.



A maximum pressure at which these air vibrators should be operated



will be recommended by the manufacturers.



     A new design has been reported by one manufacturer which


                                                                 24
minimizes wire breakage and maintains high collection efficiency.



This design involves supporting the wires in a frame with fasteners



every five feet.  High energy rapping is possible with less loss



of wires.  They feel that this is a more dependable design than the



weighted wire design typical of precipitators used in the kraft



pulping industry today.



     St. Regis' Tacoma, Washington mill currently uses a precipitator



with this design.  EPA tested this precipitator and reported particu-



late emissions below 0.02 g/dscm.25  Additional data supplied by the



state control agency show that the monthly particulate tests have been less

                                                                 q

than 0.10 g/dscm since the unit started operation in August 1973.



The main problems that have been encountered were one broken wire,



burned out motors or bearings, and plugging of salt cake hoppers.



The manufacturer estimates that approximately 240 man-hours of maintenance



will be required per year on this type of unit.



     A survey was conducted by an Air Pollution Control Association



Committee on the maintenance requirements of precipitators.    The



purpose of the survey was to establish the degree of satisfaction



of the user with the equipment from an operational and a maintenance





                               4-9

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viewpoint.  This survey indicated that, although there is obviously
room for improvement on the part of precipitator manufacturers, the
majority of the users are satisfied with the performance (73.5 percent
satisfied) and maintenance (55 percent satisfied) of precipitators used
in the wood oulpinq industry.  These values are consistent with values
from other industries (cement and utility).
     On the basis of the industry and vendor data and comments,
EPA has concluded that the application of electrostatic precfpitators
for control of particulate emissions from both direct-contact and
indirect-contact recovery furnace systems is a feasible and proven
application.  The level of the proposed standard, 0.10 g/dscm, has
been demonstrated on presently operating systems of both types.
Provided the original design was adequate and a reasonable amount
of maintenance is performed, the performance of the precipitator
should not significantly deteriorate.  Unusual conditions may,
however, exist at some mills which may reouire more maintenance
or create a greater corrosion problem.
4.1.2  Smelt Dissolving Tanks
     The gases from most smelt dissolving tanks are vented through demister
pads, fine wire mesh screens, about one foot thick.  Demister pads are
basically low energy scrubbers with collection efficiencies of about
80 percent.   Droplets condensing from the gas collect on the screen,
and are backflushed with water sprays to the dissolving tank.  Several
dissolving tanks are equipped with more efficient water scrubbers,
such as low pressure drop Venturis (6-8 inches of water), packed towers,
and cyclones with water sprays.   Efficiencies of these systems are
about 95 percent.   A few mills combine the dissolving tank gases with
the recovery furnace gases, sending both streams to an electrostatic
precipitator.                     4-19

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     Emission data reported for 29 dissolving tanks range from 0.05 to
2.38 Ib/T ADP (equivalent to about 0.009-0.4 gr/dscf)  with a median
of 1.0 Ib/T ADP12 (equivalent to about 0.17 gr/dscf).   Available data
reported in a questionnaire survey comparing the efficiencies of
various scrubber systems are shown in Table 4.2.
4.1.3  Lime Kiln
     Nearly all  lime kilns are controlled with venturi scrubbers,
with pressure drops ranging from 10 to 25 inches of water.  These
systems provide collection efficiencies of up to about 99 percent.
Impingement scrubbers, with wetted baffles and water sprays, are
used less frequently.  The impingement scrubbers have  pressure drops
of 5-6 inches of water and provide collection efficiencies of only
about 90 percent.
     Electrostatic precipitators are found on some lime kilns operating
in Sweden.  Design efficiencies of these systems are about 99 percent.
One United States mill has retrofitted a precipitator  to serve three
existing kilns.
     Particulate emissions from lime kiln scrubbers range widely,
depending on operating conditions—especially the scrubber pressure
drop.  Available data for 66 scrubbers show a range of 0.08 to
43 Ib/T ADP, with a median of 2.7 Ib/T ADP.13  Available data reported
in a questionnaire survey comparing the performance of the different
control devices are shown in Table 4.3.
4.2  TRS CONTROL
4.2.1  Digester and Multiple-Effect Evaporator Systems
     TRS emissions from the digester and multiple-effect evaporators
will be considered together, since their emissions are normally combined

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                       Table  4.2.   PARTICULATE  EMISSIONS  FROM  VARIOUS
                              SMELT DISSOLVING  TANK CONTROL  SYSTEMS

Collection afficie
Control System %
Demister pad 72




i
77
78
90
93
71
Demister pad plus 96
ncy(a)
Ib/T ADP^a
0.052
0.15
0.63
2.3
1.2
1.58
0.41
Emission rate
] g/kg ADP(b
0.03
0.08
0.32
1.15
0.60
0.79
0.21

* gr/dscf^
0.009
0.03
0.1
0.4
0.2
0.3
0.07
  shower
Demister pad plus
  packed tower
Packed tower
92

98
1.20

0.05
0.60
0.03
0.2
0.009
(a)  Reference 3
(b)  Calculated from emissions in Ib/T ADP on the basis of 1.0 Ib/T  ADP  =  0.5  g/kg  ADP.
(c)  Calculated from emissions in Ib/T ADP on the basis of 1.0 gr/dscf = 5.76  Ib/T  ADP.
                                             4-12

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                           Table  4.3.  PARTICIPATE  EMISSIONS  FROM VARIOUS LIME  KILN CONTROL SYSTEMS
I
_J

Impingement scrubber^
Outlet Outlet^ Outlet^
gr/dscf g/dscm ib/T ADP
0.46
0.43
0.58
1.05
0.88
1.56
0.53

1.05
0.98
1.33
2.40
2.01
3.57
1.21

3.78
3.53
4.77
8.63
7.23
12.8
4.36

Venturi scrubbers'9 Electrostatic Precipitator'1"^
Outlet Outlet^ Outlet^ Outlet Outlet^ 0_utlet^
gr/dscf g/dscm Ib/T ADP gr/dscf g/dscm ' Ib/T ADP
0.16
1.00
0.23
0.13
0.12
0.14
0.38
0.37
0.37
2.29
0.53
0.30
0.27
0.32
0.87
0.85
1.32 0.029 0.066
8.22 0.088 0.201
1.89 Ava. 0.058 0.134
1.07
0.99
1.15
3.12
3.04
Q.24
0.73
0.48





   Avg.    0.78
1.79
6.44
0.32
0.73
'2.60
          (a)   Reference  1,  Table  27
          (b)   Computed on the  basis:  1  gr/dscf  =  2.288  g/dscm
          (c)   Reference  15
          (d)   Computed on the  basis:  1  gr/dscf  =  8.22 Ib/T ADP

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for treatment.  The noncondensable gases from these facilities are often
vented directly to the atmosphere.  For odor control an increasing
number of mills presently burn the gases, most often in the lime kiln.
Special gas-fired incinerators are also used, either as backup for
the kiln when it is down, or as the regular control unit.
     The blow gases from batch digesters come in strong bursts that may
exceed the capacity of the lime kiln.  Special gas handling equipment
has been developed to smooth out the gas flows,^ and is in use at many
presently operating mills.  Adjustable volume gas holders, with movable
diaphragms or floating tops, receive the gas surges, and bleed a small
steady stream to the kiln.  Although the noncondensable gases form
explosive mixtures in air, possible explosion hazards have been
effectively minimized by the development of gas holding systems,
flame arresters, rupture disks, and flame-out controls.  Incineration
of these gases in existing process equipment such as the lime kiln
is particularly attractive since no additional fuel is required to
achieve effective emission control.
     Scrubbers are used at a few mills to reduce TRS emissions.  White
liquor, the usual scrubbing medium, is effective for removing hydrogen
sulfide and methyl mercaptan, but not dimethyl sulfide or dimethyl
disulfide.  At least 3 mills scrub the noncondensable gases prior to
incineration in order to recover sulfur, condense steam, and remove
turpentine vapors and mist, lessening the explosion hazards.
     Combustion of noncondensable gases in a lime kiln or gas-fired
incinerator provides nearly complete destruction of TRS compounds.  During
an EPA test on an incinerator burning noncondensables from digesters and
multiple-effect evaporators, the unburned TRS residuals were less than

                               4-14

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 5 ppm  (about 0.01 Ib/T ADP).  Scrubber efficiencies are much lower
 because only hydrogen sulfide and methyl mercaptan react with the
 alkaline medium.  The composition of noncondensables is highly
 variable, but on the average, hydrogen sulfide and methyl mercaptan
 comprise about half the TRS compounds.    Alkaline scrubber efficiencies,
 therefore, will be roughly 50 percent and TRS emissions will be about
 1 Ib/T ADP.
 4.2.2  Brown Stock  (nulo) Washing System
    Nearly all  kraft mills vent the pulp washing system gases directly to the
 atmosphere.  At least four mills in the United States and Canada, and several in
 Sweden, utilize the gases as combustion air in a recovery furnace.
     The gas volume from the washer drums is large, about 150 CFM/TPD.^  It
 may be reduced by enclosing the drums with tight hoods.  Use as combustion
 air in a recovery furnace or power boiler is the most likely control
 alternative.
     The gases vented from the filtrate tank have considerably less volume,
 about 6 CFM/TPD.  ' This stream can be incinerated in a lime kiln, or blended
 with the hood vent gas and burned in a recovery furnace.  Combustion of the
 gases from these filtrate tanks would not result in any significant
 increase in fuel requirements.
    Incineration is  the only control  method  known to  be practiced.  As
discussed in Chapter 6, TRS  combustion residuals  are  very low,  less  than
about 5 ppm (0.01  Ib/T ADP).

 4.2.3  Black Liquor Oxidation Systems
    The vent gases from black liquor oxidation (BLO)  systems are emitted directly
 to the atmosphere.  Presently there  are no control  techniques being  practiced to
 reduce TRS levels in these vent gases, but technology for eliminating these vent
 gases completely has been demonstrated.

-------
     There are apparently no technical  or economic reasons to prevent controlling
BLO systems by using the vent gases as  combustion air in the recovery furnace.
Incineration has proved highly effective at some mills in controlling similar
streams such as at the vent gases from  pulp washing systems, the nonconden-
sable gases from digesters and multiple-effect evaporators, and the vent
gases from condensate strippers.   Incineration in the recovery furnace
or power boiler is the most likely control alternative for this facility
since no significant fuel penalties will result.  Condensers may be required
to reduce moisture content before burning, especially if the moist washer
gases are burned in the same furnace.
     The use of molecular oxygen  instead of air in oxidation systems is
considered an alternative control system.  At least two mills in the
United States now oxidize black liquor  by pumping oxygen directly into
the black liquor lines.  There are no vent gases from this closed system.
The economic feasibility of such  a system will depend largely on the
price and availability of oxygen.
     Based on data from incinerator systems burning similar gases, TRS
combustion residuals from control of BLO vent gases are estimated to
be less than 5 ppm (0.01 Ib/T ADP).  Enclosed oxygen systems have no
TRS emissions.
4.2.4  Recovery Furnace System
     The TRS emissions from the recovery furnace are controlled by maintaining
proper process conditions.  The most important operating variables whose
control are required for minimum  TRS emissions are black liquor firing
rate, available oxygen for combustion,  air-to-solids ratio, and the ratio
of primary to secondary and tertiary air. '
                                4-16

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     There are two general  process  designs thatureduce TRS emissions
that normally result from a direct-contact evaporator:  the direct-
contact system with black liquor oxidation and the indirect-contact
system.  In the direct-contact system, final  concentration is accomplished
by bringing the recovery furnace combustion gases into direct contact
with the black liquor.  The reactions between the combustion gases
and black liquor that normally generate hydrogen sulfide, however, are
inhibited by oxidizing the black liquor before it enters the direct-
contact evaporator.  In the indirect-contact system, direct contact
between furnace gases and black liquor is eliminated, and hydrogen
sulfide is prevented from forming.
     Variations of both furnace systems are found in practice.   In the direct
 contact system, the black  liquor is  sometimes oxidized before  being  concentrated
 in the multiple-effect evaporators  (weak black liquor oxidation), sometimes
 following evaporation (strong black  liquor oxidation), and sometimes both.  A1r
 is the normal  oxidizing agent, but molecular oxygen is also  used  when a supply
 is on  hand.   Air sparging  reactors are the most common units,  but packed  towers
 and bubble tray towers are also found.   The  various indirect contact systems are
 called Direct Fired (Babcock  and Wilcox Co.), Large Economizer, Laminaire Heater,
 and Air Contact Evaporation (last  three by Combustion Engineering Inc.).
     TRS emissions  from direct contact  systems  depend  on  the  design and operation
of the recovery furnace and the oxidation  system.   A  survey  of 32 recovery furnace
systems where  black  liquor oxidation was  not  used shows TRS  emissions ranging
from 35 to 1300 ppm  (1.5 to 62 Ib/T  ADP)  with  a  median of 5.9  Ib/T ADP.18
A  survey  of  17  units  utilizing black liquor oxidation  indicates a broad TRS
emission  range  of  0,2  to 25.9  Ib/T ADP with a median value of 3.7 Ib/T ADP.19
As mentioned previously, blr.ck liquor  oxidation  is  not effective  in
reducing  TRS emissions  from the furnace  proper.  The  effectiveness of black
liquor oxidation on  preventing TRS emissions  resulting  from  thr- direct contact

-------
evaporator Is dependent on how the oxidation system is designed and
operated.  TRS emissions from indirect-contact systems are usually
confined to a narrow range of about 0.03 to 0.3 Ib/T ADP (1 to 11 ppm).
     One control system that has recently been demonstrated on pilot
plant scale and is currently being applied to a full-scale furnace
removes TRS from the recovery furnace gas stream and reportedly results
in emission levels comparable with black liquor oxidation - direct-contact
evaporator furnace systems and the indirect-contact furnace system.
This system utilizes a low pressure drop cross flow caustic scrubber
with activated carbon as a catalyst.  EPA has not tested this control
system because it has only recently been developed and applied.  This
may represent another viable alternate for controlling TRS from
the recovery furnace.
4.2.5  Smelt Dissolving Tank
    There are no special TRS control devices for smelt dissolving tanks.  TRS
emissions are governed by process conditions, and the principal option available
is the choice of water.  Clean water, low in dissolved sulfides, is preferable,
although low emissions are possible with nearly any process stream.20
    TRS emissions from dissolving tanks are normally low and average about 0.01
gfkg ADP (0.02 Ib/T ADP).21
4.2.6  Lime Kiln
     TRS emissions from lime kilns  can be emitted from two sources within
the installation:  the lime kiln itself and the particulate control
device (e.g. scrubbers).  The TRS emissions from the lime kiln installation
are controlled by maintaining proper process conditions.  The most
important parameters that were identified in a recent study by the NCASI.22
                              A -18

-------
are the temperature at the cold end point of exhaust discharge,  the oxygen
content of the gases leaving the kiln, the sulfide content of the lime
mud fed to the kiln, and the pH and sulfide content of the scrubbing water.
     Further reduction of the TRS concentration in the emissions from this
facility can be accomplished by the addition of a caustic solution to the
scrubbing water.  Maintenance of the process controls is also required
with this technique.  The effectiveness of caustic scrubbing is  limited
to absorbing only hydrogen sulfide and methyl mercaptan.  TRS emissions
from lime kilns, however, are principally hydrogen sulfide; therefore,
the combination of process control and caustic scrubbing can be very
effective in the control of TRS.
    TRS  emissions  from  lime  kilns  range from about 0.02 to 4.0 Ib/T ADP, with
an  average of about 0.8 Ib/T ADP,23

 4.2.7  Condensate  Strippers
    In at least three United States mills, dissolved sulfides and other volatile
compounds are stripped  from  the digester and evaporator condensates prior to
discharge.  At  two mills, the  gases discharged from the stripper column are
 burned  in a  lime kiln.   One stripper  uses  air; the  other  uses steam as
 the stripping  agent.  The other mill  burns  the gases  from an air  stripper
 in  a  separate  incinerator.   There are no  alternative  control techniques
 for the  off-gases  presently practiced.
      TRS emissions  in the stripper gases  following  incineration are  estimated
to  be less than 0.01 Ib/T ADP  (5  ppm).
                                 4-19

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4.3  ALTERNATIVE CONTROL SYSTEMS



     The alternative control systems that are considered the best



combinations of the control techniques previously discussed are



presented in this section.  The analyses of environmental effects



in chapter 7 and of economic: impact in chapter 8 will examine



the imnacts associated with the alternative emission control



systems.  Since there are multiple facilities and several



alternatives for control of many of the processes, not all



the possible systems are presented.  Only the systems that are



judged to be representative of the best systems, considering costs,



are considered.  Alternative standards are not discussed in this



section.  The rationale for the selection of the best system of



emission reduction considering costs is presented in chapter 9.



     Alternative number 1 represents a control system based on the



average level of state standards that would apply to a new kraft



pulp mill in the absence of new source performance standards.



A summary of the present state control standards specific to



kraft pulp mills is presented in Table 4.4.  The control techniques



required to meet these levels are:



     -  Recovery furnace -•  !v'\">0' F^P for participate  control plus



        a sinnle sta
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                          TABLE  4.4.   Sunmary  of  Present State  Control Standards
                                               for  Kraft  Pulp  Mills
   Affected
   Facility

Participates

Recovery furnace

Smelt dissolving tank

Lime kiln

TRS

Recovery furnace

Smelt dissolving tank

Lime kiln

Digester system


Multiple-effect evaporator
 system

Black liguor oxidation tank

Brown stock washers


Condensate  strippers
Number of States
With Existing Standards
12
10
12
12
None
3
5
5
None
1
Typical
Control
Standard
4 Ib/T ADP
0.5 Ib/T ADP
1.0 Ib/T ADP
17.5 ppm
-
40 ppm
Incineration of
non-combustibles
Incineration of
non-combustibles
-
Incineration of
Most Stringent
Standard
2.75 Ib/T ADP
0.5 Ib/T ADP
0.5 Ib/T ADP
1 ppm
-
10 ppm
r-»

-
-
_
 gases

Incineration of
 gases

-------
     - Brown Stock Washer Systems - No control
     - Black Liquor Oxidation System - No control
     - Condensate Stripper System - Incineration
     Alternative number 2 consists of the following control  techniques:
     Recovery furnace - 99.9% ESP plus nrocess  control;
       black liquor oxidation or non-contact evaporation
     Smelt Dissolving Tank - Scrubber plus use  of clean
       water (process control)
     Lime Kiln - 30-inch venturi scrubber with  caustic addition
       to scrubber water plus process controls
     Digester Systems - Incineration
     Multiple-Effect Evaporators - Incineration
     Brown Stock Washers - Incineration
     Black Liquor Oxidation System - Incineration
     Condensate Stripner System - Incineration
     Alternative number 3 is identical to system 2 except that
caustic is not added to the scrubber water on the lime kiln
control system.  TRS emissions from the lime kiln are increased
as a result of this change.
     Alternative number 4 is identical to system number  3 except that
the venturi scrubber used for control of particulate emissions from
the lime kiln is replaced with a high efficiency electrostatic
orecipitator.  TRS emissions from the kiln are  controlled by the
use of good process control.
                              A-22

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     Alternative number 5 is a composite system based on
alternatives 2 and 4.   Both a caustic scrubber and an ESP
are used for the simultaneous control of TRS and particulate
emissions from the lime kiln.  Although this system has not been
demonstrated, it is assumed that it is technically possible to
apply.
                             4-23

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                   References  for Chapter  4
 1.   Atmospheric Emissions  from  the  Pulp and  Paper Manufacturing
     Industry.  EPA-450/1-73-002,  September 1973,  (also  published
     by NCASI  as Technical  Bulletin  No. 69, February  1974).
 2.   Malarkey,  E.J.  and  C.  Rudosky,  "What  Can Be  Done About  Recovery
     Boiler Snowing?", Paper Trade Journal, July  14,  1969.
 3.   Reference  1, pp.  34-37.
 4.   Letter from David Nicholson  of  the Weyerhaeuser  Company to
     Don Goodwin of EPA  dated  May 2,  1975.
 5.   Letter from John  Cuthbertson of the American Can Company to
     Don Goodwin of EPA  dated  March  19, 1975.
 6.   Letter from Andrew  Ryfun  of Brunswick Pulp & Paper Company
     to Don Goodwin of EPA  dated  March  19, 1975.
 7.   Eddinger,  James A., EPA,  Trip Report  "Koppers Company at
     Baltimore, Maryland, and  Research  Cottrell at Bound Brook,
     New Jersey," August 25, 1975,
 8.   Eddinger,  James A., EPA,  Trip Report  "Wheelabrator Frye at
     Pittsburgh, Pennsylvania,"  August  25, 1975.
 9.   Monthly Reports to  the Washington  State  Department of Ecology,
     August 1973 to April 1975.
10.   The Wet Scrubber  Newsletter, May 31,  1975, No.  11, page 6.
11.   Electrostatic Precipitator  Maintenance Survey,  Robert L. Bump,
     TC-1 Committee of APCA, Paper 75-15.5.
12.   Reference  1, Table  A-2.
13.   Reference  1, Table  A-4.
14.   National  Council  of the Paper Industry for Air  and Stream
     Improvement, Inc.  (NCASI),  Current Practices in  Thermal Oxidation
     of Non-Condensable  Gasesinthe KraftIndustry,  Technical
     Bulletin No. 34,  November 1967.
15.   Reference  1, Tables 3, 5, and 7.
16.   NCASI, Factors Affecting  Emissions of Odorous Reduced Sulfur
     Compounds  from MiscellaneousKraft Process Sources, Technical
     Bulletin No. 60,  March 1972.
                               . -24

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17.  NCASI, Factors Affecting Reduced Sulfur Emissions from the
     Kraft Recovery Furnace and Direct Contact Evaporator, Technical
     Bulletin No. 44, December 1969.

18.  Reference 1, Table 14.

19.  Reference 1, Table 15.

20.  Reference 1, Table 25.

21.  Reference 1, Table 25.

22.  NCASI, Suggested Procedures for the Conduct of Lime Kiln Studies
     to Define Emissions of Reduced Sulfur Through Control of Kiln
     and Scrubber Operating Variables, NCASI Special Report No. 71-01,
     January 1971.

23.  Reference 1, Table A-5.

9A.  Engelbrecht, H.L., "New Precipitator Design Licks Recovery
     Emission Problems," TAPPI,  55(a), September 1975.

25.  Air Pollution Emission Test 74-KPF1-15 (Recovery Furnace K),
     June 1974.
                               4-25

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             5.  MODIFICATION AND RECONSTRUCTION
     The proposed standards apply to all affected facilities
constructed or modified after the date of proposal of the proposed
standards.  Provisions applying to modification and reconstruction
were originally published in the Federal Register on December 23, 1971.
Clarifying amendments were proposed in the Federal Register on
October 15, 1974 (39 FR 36946), and final regulations were promulgated
in the Federal Register on December 16, 1975 (40 FR 58416).
     Modification is defined as "any physical change in, or change
in the method of operation of, an existing facility which increases
the amount of any air pollutant (to which a standard applies) emitted
into the atmosphere by that facility or which results in the
emission of any air pollutant (to which a standard applies) into
the atmosphere not previously emitted."  Reconstruction occurs
when components of an existing facility are replaced to such an
extent that:
     (1)  The fixed capital cost of the new components
          exceeds 50 percent of the fixed capital cost
          that would be required to construct a comparable
          entirely new facility, and
     (2)  It is technologically and economically feasible
          to meet the applicable standards,
     There are certain circumstances  under which an increase  in
emissions does not result in a  modification.   If a  capital
                                5-1

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expenditure, that is less than the most recent annual asset guide-
line repair allowance published by the Internal Revenue Service
(Publication 534), is made to increase capacity at an existing facility
and also results in an increase in emissions to the atmosphere of a
regulated pollutant, a modification is not considered to have occurred.
Other cases under which an increase in emissions does not constitute
a modification occurs when the increase is caused by an increase in
capacity throughput or a change in the type of fuel being used when
these changes do not involve a change in the original design of the
facility.  Additionally, if an increase in emissions has occurred.
which could be considered a modification, the amount of increased
emissions, in Kg per hour, may be traded off by reducing emissions
of the same pollutant from another facility within the same kraft pulp
mill, as long as it can be shown that the total emissions of that
pollutant from the mill has not increased.  This is referred to as the
"bubble concept".
       The purpose of this chapter is to identify potential
  modifications and reconstructions of affected facilities,
  and any exemptions or special allowances covering changes in
  existing facilities that should be considered.  Exemptions from
  the regulations may be based on availability of technology and
  economic considerations;
       The following physical  changes and changes in the method of
  operation of kraft pulp mills were considered:
       (1)  Conversion of a direct-contact furnace system
            to an indirect-contact system;
                                5-2

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     (2)  Conversion of a lime kiln from burning natural qas
          to burning oil;
     (3)  Adding an additional stage of washers to an existing
          brown stock washer system.
5.1  CONVERSION OF A DIRECT-CONTACT FURNACE SYSTEM TO A NON-CONTACT
     SYSTEM
     Occasionally, an existing recovery furnace will be changed
by replacing the direct-contact evaporator with a steam-heated
indirect-contact evaporator.  The main purpose for this change
is to reduce TRS emissions from the recovery furnace system.
The new indirect-contact evaporator, however, becomes a part
of the multiple-effect evaporator system, causing a possible
increase in TRS mass emissions from this affected facility.
Since the conversion of a direct-contact furnace system to a
non-contact system will reduce TRS emissions, the bubble concept
may be applied to account for the possible increased TRS emissions
from the evaporators.   If the original system employed black liquor
oxidation, it is possible that this step would be removed from
operation.  Should this occur, a further reduction in TRS emissions
 would take place.  This reduction could be applied to the bubble
concept in the trade off of emissions.
     This change would also possibly result in an increase of
particulate emissions  from the furnace.  Without the direct-contact
evaporator, inlet particulate loadings to the precipitator will
increase.  To account  for this increase in emissions, the
collection efficiency  of the existing ESP must be upgraded to
meet the requirements  of the proposed new source performance
                              5-3

-------
standards or the emissions must be traded off under the bubble
concept by a reduction of particulate emissions elsewhere
in the mill.  The costs associated with upgrading the precipitator
have been analyzed and are presented in Table 8-28 of the Economic
Impact chapter.  The annual costs for this conversion is r.hout ^.41
dollars per ton for both a r>in ton-por-day and a 1000 ton-per day mill.
5.2  CONVERSION OF A LIME KILN FROM BURNING NATURAL GAS TO BURNING OIL
     An existing lime kiln that burns natural gas may be
converted to burn fuel oil.  This change in fuel would cause an
increase in particulate emissions from the facility.  If the kiln
was not originally designed to burn oil as an alternative fuel,
the change in fuels would constitute a modification.
     The maximum impact would occur if the entire existing scrubber
system were replaced to control the increased particulate emissions.
Additional TRS control would not be required in this case; therefore,
there would be no need for the addition of caustic to the scrubbing
solution.  The cost requirements for this modification are summarized
in Table 8-29.  The annual costs for the new control system range
from 0.20 dollars per ton for a 1000-ton-per-day mill to 0.33 dollars
per ton for a 250-ton-per-day mill.
5.3  ADDING AN ADDITIONAL STAGE OF WASHERS TO AN EXISTING BROWN
     STOCK WASHER SYSTEM
      An additional stage of brown stock washer may be added
 to an existing line of washers in order to improve washing
 efficiency.  It is expected that this change will  usually take
 the form of adding a fourth stage.   Emission of TRS may increase
 as a result of this  change, subjecting this  facility to the
 provisions  of §60.14.
                              5-4

-------
     The costs for this modification were analyzed for two cases:
(1) major retrofit of ventilating system plus incineration of
TRS emissions in an existing recovery furnaee, and (2) major
retrofit of ventilating system plus incineration of the TRS
emissions in a separate incineration system.  The cost estimates
for these two cases are summarized  in  Table  8-27  for  250,  500,  and
1000 ton per day mills.   The worst  case,  that involving use  of
a separate incinerator, requires  an annual cost of as  high as
3.84 dollars per ton for a 250-ton-per-day mill.
                               5-5

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      6.  EMISSION DATA TO SUBSTANTIATE THE PROPOSED STANDARDS

     Emission data nresented in this section are the results of tests
conducted by EPA at 12 kraft pulp mills.  These data represent 11 TRS
tests and 19 particulate tests performed on the various facilities
affected by the proposed standards.  Eight emission tests were
performed on seven recovery furnaces for particulate or TRS; five
smelt dissolving tanks were tested; eight tests were performed
on seven lime kilns; and four tests were run on four different
miscellaneous sources for TRS.  Opacity readings were taken during
particulate tests on four stacks at three recovery furnaces, during
tests on three smelt dissolving tank stacks, and during two tests
on one lime kiln.  The visible emissions readings on the recovery
furnace stacks totalled 5514 minutes (919 six-minute averages).
The total for the smelt dissolving tank is 206 minutes and 15
seconds; the total for the lime kiln is 682 minutes and 30 seconds.
The results of these emissions tests are used to substantiate the
proposed standards.  Additional data that were obtained from various
kraft mills, state air nollution control agencies, and other
sources are also presented where pertinent.
6.1  PARTICULATE EMISSIONS
6.1.1  Recovery Furnace
     Five recovery furnaces were tested by EPA.  Three of the furnaces
had direct-contact evaporators; the other two furnaces were indirect-
contact (no direct-contact evaporator) type furnaces.  The particulate
emissions for the furnaces tested are shown in Figure 6-1.  Data
                               6-1

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                 Figure 6-1

Participate Concentrations in Control  Systems
    Exhaust from Kraft Recovery Furnaces

0.26
0.24
0.22
0.20 •
KEY
EPA Other _OJ1Q
o P Maximum Data Point
i ' n
H-H rM-i Average
1 1 ' i i
I'M — n riQQ
v b Minimum Data Point u 0.14
QJ ~~^.
4-1 CD
| 0.12
.,—"
4->
£ 0.10

0.08

0,06
0.04
0.02

0
FURHACE
-0.066
O :
Ji ,, -0.055
Proposed NSPS Level 	 	 Q Q44
b
e
^i_4 -0.033
1 i
q P -0.022
1 i !
' 1 i
10 l& ' f ^
'' ' JH
ifr 5 Data q * ill -0.011
•*' /Points t— * ^T
X i V9
D J'l J'2 J"l J"2 Kl K2 LI L2
Furnace Type DC 1C 1C 1C 1C 1C 1C DC DC 1C - I




Gr/DSCF








nd
f.n
Control Equip- P* P P P P P P P P DC - Dir
P -E$e
Test Report 3,4 6-6-7-8-
Reference Preci
st
pi
                    6-2

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obtained from the operators of mills with several of the furnaces
tested by EPA are also presented in Figure 6-1 for comparison
purposes.  Visible emission data for the furnaces tested are
presented in Tables 6-1 to 6-4.
     In addition, EPA contacted several vendors and operators in
response to comments on long-term precipitator performance on
recovery furnaces.  The conclusions of this investigation, discussed
in detail in section 4.1.1, is that with proper design and maintenance
a well operated precipitator can control particulate emissions from
recovery furnaces to below the level of the proposed standard of
0.10 g/dscm.
Furnace D
     Furnace D, which uses a direct-contact evaporator, is designed
for an equivalent pulp production rate of 602 tons per day.  Furnace D
was operating at 90 to 95 percent of design capacity during the EPA
testing.  This furnace was tested twice by EPA,3>4 in tests conducted
about one year apart.  Three runs were performed during each test.
The particulate emissions from this facility are controlled by a
wet-bottom electrostatic precipitator.  Information supplied by the
operator indicate that this electrostatic precipitator has an operating
collection efficiency of 99.5 percent and a collection surface area-
to-gas volume ratio of 346 (sq. ft/1000 acfm).  The first set of EPA
tests were inconclusive because results indicated abnormal conditions
were existing during the test due to either a control device or furnace
malfunction or to improper testing.  This conclusion is supported
by company data obtained over a 17-month period which indicated an
                               6-3

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average emission rate of 0.128 g/dscm (0.056 gr/dscf).   During the
second set of EPA tests, D on Figure 6-1, the emissions ranged
from 0.061 to 0.083 and averaged 0.075 g/dscm (0.033 gr/dscf),
corrected to 8 volume percent oxygen.  Oxygen levels in the exhaust
gases during these tests ranged between 9.8 and 10.6 percent.
Visible emission data, Table 6-1, were also obtained during the
second set of tests.   The span of the six-minute average opacity
readings was 0 to 29.2  with an average of about 16.3 percent.
Furnace J
     Furnace J, which does not have a direct-contact evaporator,
is designed for an equivalent pulp production rate of 1100 tons per
day.  This furnace was tested by EPA while it was operating at
design capacity.  The participate emissions are controlled by  a dry-
bottom electrostatic  precipitator which has a design collection
efficiency of 99.8 percent arid has a collection surface area-to-
gas volume ratio of 383 sq.  ft/1000 acfm.  The precipitator has
two separate identical chambers in parallel; each chamber has  five
electrical fields.  The exhaust gases from each chamber exit through
separate stacks.  Both stacks* were simultaneously tested for a total
of six test runs on each stack.
     The emissions from the one half (J1) ranged from 0.023 to 0.041
g/dscm  with an average of ^.029 g/dscm (0.013 gr/dscf).   Oxygen
levels in the exhaust were less than 8 percent by volume.   The
emissions from the other half (J") ranged from 0.117 to 0.133  g/dscm
and averaged 0.124 g/dscm (0.054'gr/dscf).
                               6-4

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                                       Table  6-1
                          Summary of Visible  Emissions for
                                 Recovery Furnace D
Date:  Nov.  1-2, 1973
Type of Plant: Kraft Pulp Mill
Type of Discharge:  Stack
Location of  Discharge:  Recovery  Furnace
Height of Point of Discharge:  250 ft.
Description  of Background:

Description  of Sky:

Wind Direction: Not  Available
Color of Plume:
Interference of Steam Plume:
Duration of  Observation:    11/1  - 19 min.
                          Distance from Observer to Discharge  Point:
                          Height of Observation Point: 220 ft.
                          Direction of Observer from Discharge Point:
        30  ft.
                          Wind Velocity:  Not Available
                          Detached Plume:
mi/hr
                   15 sec.
                          11/2  - 22 min., lj[ sec.
                                4T min., 30 sec.
          Summary  of Data:   (Normalized to  a 3.0 m  stack diameter):

          Run
No. of 6-Minute
   Averages
           1
           2
        4
        3
Range of
Averages
14.2 - 29.2
0
- 11.1
Average
Opacity (%)
24.1
6.0
Parti cul ate
Concentration
g/dscm(gr/dscf)
0.07 (0.031)
0.05 (0.021)
                                            6-5

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     Visible emission data were also recorded during the participate
tests and indicate that the average opacity from precipitator J',
Table 6.2, and J", Table 6.3, was  less than 8 and 45 percent,
respectively.
     Data J'2 and J"2 (two tests) obtained from the operator
indicate that the participate emissions from precipitator J' and J"
range from 0.037 to 0.041 g/dscm and from 0.087 to 0.137 g/dscms
respectively.
     Since the precipitators (J1 and J") are physically separated,
have the same design and operating parameters, and handle approximately
half of the exhaust flow from the furnace, the only difference
between the two precipitators was the maintenance received.
The turning vanes and air distribution plates on precipitator J'
were cleaned one month prior to the EPA tests.  The air distribution
plates on precipitator J" were cleaned about three months prior to
EPA's testing but the turning vanes had not been cleaned since the
precipitator went into operation (about 17 months prior to EPA
tests).  The operator felt  that the reason for the poorer collection
efficiency on the one half (J") was due to the turning vanes and air
distribution plates being caked which resulted in improper air
patterns through the precipitator.  The manufacturer also stated
that improper air distribution through a precipitator resulting
from buildup on the turning vanes can reduce the collection efficiency
of the precipitator. "  At the time of the test, there were no
cleaning mechanisms such as rappers on these turning vanes to keep
                               6-6

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                                          Table  6-2

                           Summary of  Visible  Emissions  for
                                   Recovery Furnace J'
Date:  Jan.  22-25, 1974
Type of Plant:   Kraft Pulp Mill
Type of Discharge: Stack                          Distance  from Observer to Discharge Point:  30 ft.
Location of Discharge: Recovery  Furnace #5         Height  of Observation Point:  240 ft.
Height of Point  of Discharge:  250 ft.              Direction of Observer from Discharge  Point: S.W.
Description of Background: Sky and frequent plumes from other  stacks
Description  of Sky:  Clear to partly cloudy
                S-SE
                White
Wind Direction:
Color of Plume:
Interference of Steam Plume:  No
Duration of Observation:  15  hrs.,  58 minutes
Wind Velocity:  0-15
Detached Plume:  No
                                                                                   mi/hr
          Summary of Data:   (Normalized to a  3.0 m stack diameter):
                                                                                    Particulate
Run
1A
B
2A
B
3A
B
4A
B
5A
B
6A
B
No. of 6-Minute Range of Averaqe
Averages Averaaes npaHty" (*)
27
27
20
28
20
27
20
20
20
17
20
0.7-8.2
1.1-15.2
0-1.3
'1-2.0
0-3.2
no readinys taken
0-0
0.3
0-10.0
0-3.2
0-0
0.5
2.2
7.r,
0.5
0.5
2.5
U
0
4.1
0.8
0
0.5
' u i u i ^ u i u i*vi
Concentration
g/dscm(gr/dscf)
0.02 (0.011)
0.04 (0.018)
0.03 (0.013)
0.02 (0.010)
0.02 (0.010)
0.03 (0.014)
                                            6-7

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                                        Table  6-3

                          Summary of  Visible Emissions for
                                 Recovery Furnace J"
Date:  Jan.  22-25, 1974

Type of Plant:  Kraft Pulp Mill

Type of Discharge: Stack

Location of Discharge:  Recovery Furnace #5

Height of Point of Discharge:  250  ft.
                                                 Distance from Observer to Discharge Point:   30 ft.
                                                 Height of Observation Point: 240 ft.
                                                 Direction of Observer from Discharge Point:  S.W.
Description of Background:  Sky and frequent plumes  from other stacks
Description of Sky:  Clear to  partly cloudy
Wind Direction: S-SE
Color of  Plume:  White
Interference of Steam Plume:    No

Duration  of Observation:   14  hrs., 18 minutes
                                                 Wind Velocity:   0-15
                                                 Detached Plume:   No
rni/hr
          Summary of Data  (Normalized to a  3.0 m stack diameter)
          Run

          1A
           B

          2A
           B

          3A
          4A
           B

          5A
           B

          6A
           B
                      No. of 6-Minute
                         Averages	

                             27
                             27

                             20
                             28

                             18
                             18

                             15
                             20

                             14
                             19

                             18
                             20
i.U III iLdtK. Ql
Range of
Averages
20.3-40.5
15.8-39.0
18.0-50.0
29.4-49.4
15.5-42.2
12.4-30.8
25.7-46.8
20.1-42.9
23.8-46.4
23.8-41.0
40.6-51.5
26.6-48.6
ameter;
Average
Opacity (%}
28.4
30.8
38.8
40.3
30.5
22.1
40.0
34.2
36.9
34.2
45.4
35.1
Particulate
Concentration
g/dscm (qr/dscf)
0.13 (0.058)
0.12 (0.055)
0.12 (0.053)
0.13 (0.057)
0.12 (0.052)
0.12 (0.053)
                                            6-8

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them clean.  The manufacturer stated that rappers could be installed
to keep the turning vanes free of buildup.  A certain amount of
engineering work would be necessary to determine the number and
location of the rappers in order to keep the turning vanes cleaned
                            ?fi
during continuous operation.
Furnace K
     Furnace K, which does not have a direct-contact evaporator,
is designed for an equivalent pulp production rate of 863 tons per
day.  The participate emissions from Furnace K are controlled by a
dry-bottom electrostatic precipitator with a design efficiency of
99.5 percent and a surface area-to-volume ratio of 441 (sq. ft/1000 acfm),
but during the testing by EPA the ratio was 570 (sq. ft/1000 acfm)
due to the furnace operating  at, 74 percent of design capacity.  This
ratio of 570 is much hi'iher than the normal surface-to-volume ratio
encountered in this industry.   Five test runs were conducted on
Furnace K by EPA.   The participate emissions ranged from 0.006 to 0.008
g/dscm with an average of 0.007 q/dscm (0.0031 gr/dscf), corrected
to eight volume percent oxygen.  Oxygen levels were about 10 percent
during the EPA testing.
     Monthly data (K2) obtained over a period of seven months
from the state agency show that the particulate emissions range
from 0.003 to 0.055 g/dscm.
     Weather conditions existing during the EPA tests did not permit
opacity observations on Furnace K.
Furnace L
     Furnace L is designed for an equivalent pulp production rate
of 550 tons per day.  The furnace has a direct-contact evaporator.
                               6-9

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The particulate emissions from Furnace L are controlled by an
electrostatic precipitator with a design collection efficiency
of 99.5 percent.  This precipitator has a design collection surface
area-to-gas volume ratio of 402 (sq. ft/1000 acfm).  Six test runs
                                      Q
were performed on this furnace by EPA.   Furnace L was operating at
16 percent above design capacity during the testing.  The emissions
(LI) from these tests ranged between 0.028 and 0.037 g/dscm and
averaged 0.032 g/dscm (0.014 gr/dscf).
     Data (L2) obtained over a period of two months (7 tests) from
the company show that the paniculate emissions ranged between
0.011 and 0.053 g/dscm.
     Visible emission measurements, Table 6.4, made during the EPA
tests indicate that the average opacity of the plume from Furnace L
is less than 6 percent.  The six-minute averages ranged from 4.4 to
8.7 percent opacity.   The stack gas opacity peaked at regular
intervals during the tests.  These small  increases in opacity were
observed to coincide with cleaning of the induced draft fan.  This
fan is blown with steam at approximately twelve-minute intervals.
Furnace I
                                     5
     Furnace I was also tested by EPA  but the data are not
presented in Figure 6.1.   This furnace has a direct-contact evaporator
and is designed for an equivalent pulp production rate of 900 tons per
day.  During the testing, the furnace was operating at about 78 percent
of design capacity.  The particulate emissions are controlled by an elec-
trostatic precipitator with design collection efficiency of 98.8 percent.
                                6-10

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                                        Table 6-4
                           Summary  of Visible Emissions  for
                                  Recovery Furnace L
Date:  May 7-10,  13,  14, 1974
Type of Plant:   Kraft Pulp M111
Type of Discharge: Stack
Location of Discharge:  Recovery Furnace #2
Height of Point  of Discharge:  220 ft.
Description of Background:  Sky-Clouds

Description of Sky:  Sunny, partly cloudy

Wind Direction:  Variable
Color of Plume:  White
Interference of  Steam Plume:
Durat1on of Observation:  23 hrs., 51 minutes

          Surrmary  of Data
Distance from  Observer to Discharge Point:  850  ft.
Height of Observation Point: Ground
Direction of Observer from Discharge Point:  East
Wind Velocity:   0-15
Detached Plume:
mi/hr
                                                                                     Particulate
Run
1A
B
2A
B
3A
B
4A
B
5A
B
6A
B
No. of 6-Minute
Averages
36
39
38
36
31
16
38
30
43
30
45
40
Range of
Averages
4.4-6.8
4.4-8.7
4.4-6.3
4.4-5.5
4.4-6.5
4.4-6.5
4.4-6.3
4.4-6.3
4.4-6.3
4.4-6.3
4.4-6.8
4.4-6.3
Average
Opacity (%)
5.3
5.1
4.9
4.7
5.0
4.7
4.9
4.7
4.9
4.8
5.0
4.9
Concentration
9/dscm (gr/dscf)
0.03 (0.014)
0.03 (0.012)
0.03 (0.013)
0.03 (0.012)
0.04 (0.016)
0.03 (0.015)
                                             6-11

-------
The emissions from Furnace I ranged from 0.215 to 0.295 n/dscm and averaged
0.262 g/dscm (0.115 gr/dscf) over three test runs.  No visible
emission readings were taken during this test.  Oxygen levels in
the exhaust during the testing were about 7 percent.
     All three test runs were conducted during sootblowing.  Soot-
blowing oh this furnace is not continuous as is commonly practiced
but is performed once a shift, or less often.  Each soot blowing
cycle takes about three hours which is the approximate duration
the sampling probe was in the stack.  Therefore, this data represents
a maximum or peak emission.  The other four furnaces tested, however,
have continuous, sequentially repeated sootblowinq.
Visible Emissions
     A total of 919 six-minute averages were taken during the
particulate tests on furnaces D, J1, J", and L.  The particulate
concentration during each test run was plotted versus the six-minute
average opacities recorded during the same period.  By plotting a
least squares fit line on these data points, a correlation
between particulate concentration in g/dscm and the plume opacity
can be made.  The 95 percent confidence limit, based on the
standard deviations of each test run, was also determined and plotted
along with the average.  The results of this study are shown in
Figure 6-2.  All opacity data were normalized to a 3.0 meter stack
diameter for these calculations.
6.1.2  Smelt Dissolving Tanks
     Four smelt dissolving tanks were tested by EPA.  The data from
these tests are presented in Figure 6-3.  Monthly data obtained from
                                6-12

-------
      60 n
            Figure 6-2.  Percent Opacity vs. Participate Concentration for Recovery  Furnace Emissions
                                      (All data normalized to a 3.0 meter stack diameter)
      50-
                                                                                   X
                                                                              *  A
                                                                                 X
                                                                                        +95% Confidence Limit
I

C*J
D_
o
      40-
      30-
      20-
     10-
 0.02
(.010)
                                     0.04
                                    (.020)
                                          0.07
                                         (.030)
 0.09
(.040)
 0.11
(.050)
                                                                                           Average
                                                                                          KEY

                                                                                   •  AVERAGE LEVEL

                                                                                   A  95% LEVEL
_— r .
  0.13
 (.060)
 0.16
(.070)
                                  PARTICULATE CONCENTRATION - g/dscm (gr/dscf)

-------
                                         Figure  6-3

                       Particulate Emissions in Control System Exhaust
               From Smelt Dissolving Tanks Used In The Kraft Pulping Industry
      0.25
0.20  -
c
o
in
in
LJJQ
s~

O-
      0.15
      0.10
                       Key
              EPA  Other
               c   w   Maximum Data Point
                     (t
                        Average

                        Minimum Data Point
   0.5
                       Proposed NSPS  Level
                                                                        0
                                                                        0
Jo.,
                                                                          _ _  - 0.3


                                                                        ii
                                                                        d
                                                                         - 0.2
                                                         d
                                                         8

0.05
0
Smelt Di
Control
Test Ret
Referer
! i
i >
c $ !
i e
^

b
\ i i ii
ssolving Tank D E Fl F2 61 62
Equipment C C PT PT PT PT
)ort in 11 12 - 13
                                                                               .J  o
                                                                     PT-Packed Tower

                                                                     C-Cyclonic  Scrubber
                                          6-14

-------
a state agency on two of the smelt tanks are also presented.  Visible
emissions data for the smelt dissolving tanks tested are shown
in Tables 6*5 to 6-7.  Visible emissions are normally difficult to
obtain from smelt dissolving tanks due to the interfering steam
usually present in the plume.  The data that were taken are considered
to be questionable and do not constitute a sufficient data base upon
which to base an opacity standard.
Smelt Dissolving Tank D
     Particulate emissions from smelt dissolving tank D are cofttrolled
by a wet fan scrubber.  Demister pads are also installed to aid the
scrubber.  Three'test runs were performed by EPA on this facility.
The measured emissions ranged from 0.048 to 0.088 g/kg ADP and
averaged 0.072 g/kg ADP (0.143 Ib/T ADP).
     Visible emission data, Table 6.5, obtained during  the  EPA test
indicate that the opacity of the residual plume from this smelt tank
is zero percent.  Smelt Tank D associated recovery furnace  operates
at an equivalent pulp production rate of 570 tons per day.
SmeltDissolving Tank E
     The particulate emissions from smelt dissolving tank E are
controlled by a wet scrubber which is basically a wet fan cyclone.
The particulate emissions during the EPA test runs ranged from
0.048 to 0.053  g/kg ADP and  averaged 0.05 g/kg ADP  (0.1  Ib/T  ADP).11
     It was not possible  to  obtain meaningful data on the visible
emissions from  this smelt dissolving tank since the plume mixed with
plumes from other facilities in the mill.
     The associated recovery furnace at  this mill was operating
at an equivalent pulp production rate of 770 tons per day during
the test.
                                6-15

-------
                                         Table  6-5
                           Summary of Visible Emissions for
                                 Smelt Dissolving Tank D
Date:  Oct.  1-2,  1973
Type of Plant:   Kraft Pulp Mill
Type of Discharge: Stack
Location of Discharge: Smelt Dissolving Tank
Height of Point  of Discharge:  250 ft.
Description of Background:  Clouds or  Blue Sky

Description of Sky:  dear to partly cloudy

Wind Direction:   SW
Color of Plume:   White
Interference of  Steam Plume:  Yes
Duration of Observation:  74 min., 45  sec.
       Distance from Observer to Discharge Poin.t:   40 ft.
       Height of Observation Point:   240 ft.
       Direction of Observer from Discharge Point:   East
       Wind Velocity: 10
       Detached Plume: No
m1/hr
                  Summary of Data:
                  Observation
                        1
                        2
                        3
                        4
                        5
                        6
                        7
                        8
                        9
                       10
                       11
                       12
6-Minute Average Opacity  (%)
               0
               0
               0
               0
               0
               0
               0
               0
               0
               0
               0
               0
                                              6-16

-------
Smelt Dissolving Tank F
     The particulate emissions from smelt dissolving tank F are
controlled by a packed scrubber tower.  Three test runs on this
facility were performed by EPA.    The emissions (Fl) ranged
from 0.098 to 0.114 g/kg ADP and averaged 0.105 g/kg ADP (0.209
Ib/T ADP).
     Visible emission data, Table  6-6, obtained during the EPA
tests indicate that the opacity of the residual plume from smelt
tank F is less than 10 percent.
     Data (F2) obtained from the state agency over a period of ten
months show that the particulate emissions ranged from 0.040 to 0.240 g/kg
ADP and averaged 0.101 g/kg ADP (0.202 Ib/T ADP).  Smelt tank F
associated recovery furnace operates at an equivalent pulp production
rate of 450 tons per day.
Smelt Dissolving Tank G
     Particulate emissions from smelt dissolving tank G are also
controlled by a packed scrubber tower.  Four test runs were
                                 13
conducted on smelt tank G by EPA.     The emissions (Gl) during
these tests ranged from 0.078 to 0.215 g/kg ADP and averaged
0.135 g/kg ADP (0.27 Ib/T ADP).
     Visible emissions data, Table 6-7, obtained during these
tests show that the opacity of the residual plume averages below
10 percent.
     Data (G2) obtained from the state agency over a period of
ten months ranged from 0.065 to 0.200 g/kg ADP and averaged
0.106 g/kg ADP (0.212 Ib/T ADP).
                                6-17

-------
                                          Table 6-6
                            Summary of  Visible  Emissions  for
                                  Smelt  Dissolving Tank  F
Date:   Oct.  9, 1973
Type of Plant:  Kraft Pulp Mill
Type of Discharge: Stack
Location of  Discharge:  Smelt Dissolving Tank
Height of Point of Discharge:   125 ft.
Description  of Background:

Description  of Sky:   Hazy and partly cloudy

Wind Direction:  West
Color of Plume:  White
Interference of Steam Plume:  yes
Duration of Observation:  56  m1n., 30 sec.

                    Summary of Data:

                    Observation

                          1

                          2

                          3

                          4

                          5

                          6

                          7

                          8

                          9

                         10
     Distance from Observer to Discharge Point:  750 ft.
     Height of Observation Point:   125  ft.
     Direction of Observer from Discharge Point: South
     Wind Velocity:   5
     Detached Plume:  No
mi/hr
6-Minute Average Opacity
              1.9

              2.3
              1.2

              0.8

              1.0
              0.6

              0.0


              0.4
              0.0
                                             6-18

-------
                                       Table 6-7

                          Summary of Visible Emissions  for
                                Smelt Dissolving  Tank G

Date:  Oct.  16 & 18, 1973
Type of Plant:  Kraft Pulp Mill
Type of Discharge: Stack                          Distance from Observer  to Discharge Point:  50 ft.
Location of "Discharge: Smelt Dissolving Tank #3    Height of Observation Point: 140 ft.
Height of Point of Discharge:  150 ft.              Direction of Observer from Discharge Point: W-SW
Description of Background: Hazy  sky

Description of Sky:  Sunny, partly cloudy

Wind Direction:  West                             Wind Velocity: 0-10                mi/hr
Color of Plume:  White                            Detached Plume:  No
Interference of Steam Plume:   Yes
Duration of Observation: 75 minutes


           Summary  of Data:

                       No.  of  6-Minute          Range of           Average
           Run            Averages	         Averages          Opacity  (%)

            12                    0.0                 0

            2                10                  0.8-2.5              1.9
                                             6-19

-------
     The recovery furnace associated with smelt tank G operates
at an equivalent pulp production rate of 300 tons per day.
6.1.3  Lime Kilns
     Particulate data obtained on four lime kilns tested by EPA are
presented in Figure 6-4.  Data obtained by the mills and state
agencies are also presented.  The particulate emissions from each
lime kiln are controlled by a venturi scrubber.  Visible emissions
were recorded during two tests on Kiln L.  Normally it is difficult
to take opacity readings at lime kilns due to steam interference
at the stack.  The six-minute opacity averages are presented, but
are not considered to be a sufficient base upon which to base a
visible emissions standard.
Lime Kiln D
     Particulate emissions from lime kiln D ranged between 0.142
and 0.343 and averaged 0.228 g/dscm (0.10 gr/dscf) during the
EPA tests.     Oxygen levels in the exhaust stream following the
scrubber were less than 10 percent by volume.  These data are the
results of three test runs conducted while the kiln was burning
natural gas.  The operating pressure drop of the venturi scrubber
during these tests was 22-25 inches, water gauge.  Weather conditions
existing during the EPA tests did not permit ooacity observations
to be recorded.
     This kiln operates at an equivalent pulp production rate of
about 570 tons per day.
     These data are not representative of the best emission control
level for particulate emissions from lime kilns, and therefore
do not substantiate the proposed standards.
                                6-20

-------
                       Figure 6-4
       Particulate Concentrations in Control System
Exhaust from Lime Kilns Used in the Kraft Pulping  Industry
U.DU



0.55


0.50

]P
I I
i 1
I i
4-H
H
1 1
to

^
0.35


• g 0.30
-M
(O
.|j
c

<_> t/i
a
 CD
g 0.20
•i —
•M
fd
O.
0.15



0.10




0,05


0
_


. P
1 1
1 1
. i
^•i^ i
1 1



»




Q
| j


!! H
" M
M I! ^.
1 1
1 1 ^
W R
1 1 i
1 1 i
1 1 TI
!! *
U

i i i i i
KEY

EPA Other
p p Maximum Data Point
Mil
}yp« i-j-yi Average
n M
W b1 Minimum Data Point
N
0.26



0.24


0.22

\


Proposed NSPS Level

0.14

(oil-fired) j
J 0.12
1


0
f/'J
Q
- 0.10 a
o
€) i
!' !
I ! i
I -i O.Q8

Proposed NSP? ,' ', j
Level ^T 1
^\ '


,, (.gas -fired) , ', -j 0.06
M 1 | i
P '' . j
f| I ft j
•;i 4ri -I 0.04
i i ui
i . ^
_, 1 1

3 " ,

i
i i __.' it i



0.02


n
Lime Kiln 1(1 K2 K3 LI L2 L3 ! ' "' Nl N2 ,, ,, . .
Control! Equipment VVVVVV VV v-*en^n
Fuei Type Used 6NN2NN 6 N ., ^c>fUDDei
flest Report Reference 16,17 16,17 18 18 20 20 N-Natural
                                                                 2-No.2 fuel; oil
                                                                 6-No.6 fuel oil
                             6-21

-------
Lime Kiln K
     Lime kiln K was tested by EPA while burning both natural gas
and No. 6 oil.16
     The emissions (Kl) during the three test runs while burning
No. 6 oil ranged between 0.233 and 0.286 g/dscm and averaged 0.258 g/dscm
(0.121 gr/dscf), corrected to 10 volume percent oxygen.  The
operating pressure drop of the venturi scrubber during three
tests was 31.0 to 33.0 inches of water.  The oxygen levels in
the exhaust stream following the scrubber during these
tests were about 11 percent by volume.
     The emission (K2) during the two test runs while burning
natural gas ranged between 0.092 and 0.149 g/dscm and averaged
0.121 g/dscm (0.053 gr/dscf), corrected to 10 volume percent
oxygen.  The operating pressure drop of the venturi scrubber during
these tests was 26.5 to 31.0 inches of water gauge.  Oxygen levels
in the exhaust stream following the scrubber during these test runs
were about 11 percent by volume.
     It was impossible to obtain meaningful data on the visible
emissions from this lime kiln since the plume mixed with the plume
from the adjoining lime kiln.
     Data on particulate emissions (K3) obtained from the state agency
over a period of seven months ranged from 0.032 to 0.167 g/dscm and averaged 0
0.107 g/dscm (0.047 gr/dscf).
     Lime kiln K operates at an equivalent pulp production rate of
320 tons per day.
                                6-22

-------
Lime Kiln L
     Lime kiln L was also tested by EPA on both types of fuel (natural
gas and No. 2 oil) used in this kilnJS  Three test runs were performed
on each fuel.  The emissions (LI) during the fuel oil tests ranged
between 0.515 and 0.597 g/dscm and averaged 0.548 g/dscm (0.24 gr/dscf).
These high particulate levels are concluded to be the results of
incomplete combustion of the oil.  The operator indicated that they
were experiencing difficulties in maintaining the kiln temperatures
over any period of time when burning fuel oil.  Thus, the operator
only burns oil when there is no other alternative.
     The emissions (L2) during the natural gas tests ranged between
0.048 and 0.076 g/dscm and averaged 0.061 g/dscm (0.027 gr/dscf).
The operating pressure drop of the venturi scrubber during these
tests was 15-18 inches of water.  The oxygen content of the exhaust
was about three percent during these tests.
     The visible emission data indicated that the opacity of the
residual plume from lime kiln L during the fuel oil tests, Table 6-8,
and natural gas tests, Table 6-9, was less than 25 and 10 percent,
respectively.
     Data (L3) obtained from the operator over a period of three
months (11 tests) show that the emissions ranged from 0.039 to 0.151
g/dscm and averaged 0.093 g/dscm (0.04 gr/dscf).  These tests were
conducted while the lime kiln was burning natural gas.  This lime
kiln operates at an equivalent pulp production rate of about
500 tons per day.
                                6-23

-------
                                        Table  6-8
                           Summary of  Visible Emissions  for
                                     Lime Kiln LI
Date:  April 30-May 1,  1974
Type of  Plant:  Kraft Pulp Mill
Type of  Discharge:  Stack
Location of Discharge:  Liine Kiln #3 (Gas-Fired)
Height of Point of Discharge:  100 ft.
Description of Background:  Blue sky
Distance from Observer to Discharge Point:  200 ft.
Height of Observation Point:  Ground
Direction of Observer from Discharge Point: North
Description of Sky:  Clear
Wind Direction:  Northwest
Color of  Plume:  White
Interference of Steam Plume:  Yes
Duration  of Observation:  5 hrs., 36 1/2 minutes
Wind Velocity:  0-18
Detached Plume: No
mi/hr
   Summary of  Data:
            No.  of 6-Minute       Range of         Average
   Run          Averages            Averages      Opacity (%)
   1A              21               5.0-5.8             5.0
    B              23               5.0-5.0             5.0
   2A              20               5.0-5.0             5.0
    BO                  -
   3A              16               5.0-5.0             5.0
    B               1                 5.0               5.0
                                Comment
                      steam interference
                      steam interference
                                            6-24

-------
                                          Table 6-9
                            Summary of  Visible Emissions for
                                       Lime Kiln  L2
Date: May 2-3, 1974
Type of  Plant:  Kraft Pulp Mill
Type of  Discharge:   Stack
Location of Discharge: Lime Kiln #3 (Oil-Fired)
Height of Point of Discharge:  100  ft.
Description of Background:  Sky  and clouds
Distance from Observer  to Discharge Point:  500 ft.
Height  of Observation Point:  Ground
Direction of Observer from Discharge Point: Northwest
Description of Sky:   Partly cloudy
Wind Direction:  Southwest
Color of Plume:  White
Interference of Steam Plume:  Yes
Duration of Observation:   5 hrs,,  46 minutes
Wind Velocity:  5-15
Detached Plume: No
mi/hr
     Summary of  Data:
              No.  of 6-Minute       Range of          Average
     Run          Averages            Averages        Opacity (%)
     4A              13                5.0-9.8             6.0
      BO                   -                 -
     5A              21                5.6-14.2           10.5
      BO                   -                 -
     6A              22               10.0-15.0           12.1
      BO                   -
                                Comment
                         steam interference
                         steam interference
                          steam interference
                                             6-25

-------
Lime Kiln N
     Lime kiln N was also tested by EPA on both types of fuel used
(natural gas and No. 6 fuel oil).20  Three test runs were performed
using each fuel.  The emissions during the tests when No. 6 fuel
oil was burned ranged between 0.07 and 0.22 g/dscm and averaged 0.165
g/dscm (0.072 gr/dscf).
     The emissions (N2) during the natural gas tests ranged between
0.08 and 0.11 g/dscm and averaged 0.095 g/dscm (0.041 gr/dscf).  The
operating pressure drop of the venturi scrubber during these tests
was about 18 inches of water.
     It was impossible to obtain meaningful visible emission data
during the particulate test since the plume mixed with the plume
from the other lime kiln.
Effect of Fuel on Lime Kiln Particulate Emissions
     Testing was performed on more than one type of fuel on several
of the lime kilns, since the results of the testing on lime kiln K
indicated that the controlled emissions depended on the type of
fuel used.  The difference in the controlled particulate levels
when using No. 6 oil and natural gas seems to be the result of
the added particulates produced by inefficient combustion of No. 6
oil.  The black color observed on the sampling filters supports
this conclusion.
6.2  TRS EMISSIONS
6.2.1  Digesters and Multiple-Effect Evaporators
     At least 23 U.S. mills incinerate noncondensable gases from digesters
and multiple-effect evaporators in lime kilns.^7  TRS remaining from
                                 6-26

-------
incomplete combustion of the noncondensables is difficult to
distinguish from TRS normally emitted by the lime kiln.   To
determine TRS emission levels that can be achieved by combustion,
EPA measured emissions at a plant that combines noncondensable
gases from a continuous digester and multiple-effect evaporator
and burns them in a separate incinerator.^
     The inlet and outlet streams of the incinerator were monitored
for TRS by gas chromatography.   The inlet stream, which  included
premixed combustion air, was found to contain trace amounts of
S02 and more than 1,000 parts per million TRS.   (Precise TRS measure-
ments of the inlet stream could not be made because the  high levels
saturated the photometric detector,)  The results of four test runs
on the outlet stream, presented in Figure 6-5,  indicate  that the
TRS levels were less than 5 ppm.  The TRS test  results (four-hour
averages) ranged between 0.5 and 3 ppm and averaged 1.5  ppm
(dry gas basis).
     During the tests, the incinerator was handling a combination
flow rate of abour 2800 scfm of noncondensable  gases from the
digester system and multiple-effect evaporator  system.  The
continuous digester was producing about 670 tons of pulp per day.
The incinerator was operating at 1000°F (measured) with  a retention
time for the gases of at least 0.5 seconds (calculated).   Natural
gas was fired in the incinerator at an estimated rate of 195 scfm.
     In a batch digestion system, TRS emission  levels from an
incinerator may peak during a blow of a digester due to  the large
surges of gas to the incinerating device.  However, these peaks
                               6-27

-------
                                                      Figure 6-b

                               TRS Concentration From Incinerator Burning  Noncondensables
24
         10
IV
a
      in
      tO
      en
      o
      >
     Q.
     Q.
     4J
     C
     cu
     u
9 l\
\ A
Q '; ' tr\ ,*,
\
\
\
6 :
r
\
^
5 i 	 \ Proonsprl NSPS
4 •
Key
o - Run No.l
o - Run No, 2
A - Run No. 3
O - Run No ,4
Noncondensable qas flow-2800 SCFM
Incinerator TemD.-1000°F
Fuel Type-Natural Gas
Fuel Flow-195 SCFM

                              >
0
iP-""
1
, , Q- 	 O 	
2345
l^G^
6
Sam
                                                                    en"-'     — •-!§- .l_n8_. _
                                                                                    10
      11
12
13
                                                     Sample Number
                                                        4 hours —

-------
can effectively be avoided by preventing these large surges
of gas by using either large spherical tanks equipped with a
movable nonporous diaphragm or conventional gas holders.
6.2.2  Brown Stock Washing System
     Vent; gases from the brown stock washers are used as combustion
air in recovery furnaces at three mills (two in U.S.).  One of
these mills has more than 4 years of on-line experience.  The
company reports that initial problems with corrosion of equipment
have been eliminated and that no significant operating problems
have appeared.
     Incineration of brown stock washer gases in the furnace appears
to have little effect on the TRS emissions from the recovery furnace.
The results of tests by EPA on furnace B, Figure 6-6, show that
when the gases from the brown stock washers are incinerated in the
furnace, the TRS emissions are less than 5 ppm.
6.2.3  Black Liquor Oxidation Tanks
     All mills currently vent the gases from black liquor oxidation
|BLO) tanks to the atmosphere.  Since the volume of the vent gases
from BLO tanks are large (10 to 50 CFM/TPD), it is anticipated that
the gases will be used as combustion air with the brown stock
washer gases in the recovery furnace.  The gases will be fired
into the furnace with the combustion air.  This control technique
is considered feasible if the entrained water in the BLO gases is
removed by using condensers.  >29
                              6-29

-------
 6.2.4   Recovery  Furnaces
     TRS emissions from three  recovery  furnaces were measured by EPA.
 The  results of these EPA  tests  are  presented  in RJgure  6-6.  These
 data are four-hour averages.   The emissions were monitored simultaneously
 with a  gas chromatograph  and a  coulometric titrator.  Continuous
 monitoring data  obtained  by operators and reported  to state  control
 agencies on two  recovery  furnaces are also reported in  Figures 6-7
 and  6-8.  These  TRS data  are daily  averages  and are not used to
substantiate  the  proposed  standard.   They are included to give  an
indication  of long term emission control performance.
 Furnace A
     Furnace A,  which  has a direct-contact evaporator,  employs a
 black liquor oxidation system  to control its  TRS emissions.  The
 recovery furnace is designed for an equivalent pulp production
 rate of 657 tons per day  and was operating near design  capacity
 during  the EPA testing.   Furnace A  was  tested over  a  six-day
 period  by EPAJ   Simultaneous  analyses  by gas chromatography,
 the  reference test method, and an EPA coulometric titrator were
 consistently in  agreement and  showed TRS levels less  than 5  ppm
 on a four-hour average.   Daily average  TRS emissions  from Furnace A
 obtained froi the mill operator are presented in Figure 6-7.  These
 data were obtained over a period of 15  months by the  operator with
 a coulometric titrator.
 Furnace B
     Furnace B TRS emissions are controlled  by maintaining proper
 furnace operation for  TRS combustion and eliminating  the direct-
 contract evaporator from  the black  liquor concentrating system.
                                6-30

-------
 CO
 (O
(O
05
TJ
O
CL
CL
O
01
u
CO
oc
Oi
O)
tO

(U
                               Figure 6-6

                       TRS Emissions From Recovery Furnace
                  Systems  Averaged For Periods  Of Four Hours
10  i
   L

   P
                             Key
                  O Company Coulometric Titrator

                  • EPA Coulometric Titrator

                  A EPA Gas Chromatograph
                     Proposed MSPS
      L
      VA
      Furnace A
      (Direct Contact)
                                  Furnace B
                                  (Direct Fired)
                                                             O
                                                         Furnace D
                                                         (Direct Contact)
   0.1!
Test Report
  Reference
         June 72
            1
                                    July 72
                                   6-31
Nov. 72
   3

-------
                       Figure  6-7.     TRS EMISSIONS FROM DIRECT  CONTACT RECOVERY  FURNACE SYSTEMS

                                       WITH BLACK LIQUOR OXIDATION (FURNACE A),  OPERATOR DATA37
CTi
I

GJ
        11.
        10 -
       in
       •r—
       I/I
       1/1
       »6
J3



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       c
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       4->
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       QJ
       ° O
       c 3
       o

"
-
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A
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1
3 ppm)


\l

A
/ ^
j



, /
• Maximum Da
D 95% Confid
o Minimum Da
A 	
'\
I
    Month
No. of Daily

Averages

         d	

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 <-



22
                      en
                      3
Ct.     4->
QJ     U
(/>     O
                                                 O
                                                 (U
                                                 a
                                                            o     T-            *,     C.
                                               "0     
-------
Noncondensable gases from the brown stock v/ashers are Incinerated
in this recovery furnace.  Furnace B is designed for an equivalent
pulp production rate of 300 tons per day; during the EPA testing,
the furnace was operating at a pulp production rate of about 345 tons
per day, 15 percent above the rated capacity.  Emission measurements
were also made over a 7-day period by EPA.  Simultaneous analyses
by gas chromatography, and EPA coulometric titrator and the operator's
coulometric titrator consistently agreed.  The results of the EPA
tests showed four-hour average TRS emissions less than 1 ppm.^  TRS
emissions from Furnace B obtained from the operator are presented
in Figure 6-8.  These data were obtained over a 26-month period
by the operator with a coulometric titrator.  These daily averages
are not as stringent as the proposed four-hour average standard.
The data are presented as an indication of long-term performance
of this facility.
Furnace D
     Furnace D was tested over a 5-day period by EPA.   The TRS
emissions from Furnace D, which has a direct-contact evaporator,
are controlled by employing a black liquor oxidation system and
maintaining proper furnace operation for TRS combustion.  Four
out of five analyses by gas chromatography indicated TRS levels
less than 5 ppm.  The data are presented in Figure 6-6.
Furnace H
     Furnace H, which does not have a direct-contact evaporator,
was not tested by EPA.  Continuous monitoring data (daily averages)
was obtained from the local control agency for a period of 8 months.29
                                6-33

-------
                              Figure 6-8.  TIBS  Emissions From Indirect  Contact Furnace35
                                               System (Furnace B) Operator  Data
           Proposed  riSPS
  in
  rB
  1C
  O
  >
  £5



  Q
  c

  C
  
                                    o
                                     o
                                     ai
                                    Q
                                  O
                                  f-
                                  to
                      ! 972
0>
c
3


1973
         r—  •  CT
                                                                cu
                                                                     U
                                                                     0
                             >
                             o
          U
          01
         O
c
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                                             0)
          Ul
          S-!
          US
                                                                                                             1974
s_
Q.

«C
                                      O!
                                      C
           29   22   27    31   20—19
                             27   3V   30   30   30   31
               30-27-  31   30- -26 .. .2&	27
                                                                                                                    30    31  :30

-------
                                                           Fiqure 6-9

                  TRS Emissions from  Indirect  Contact Recovery Furnaces (Furnace H), Operator
io
xn
       en
       (O
       OJ
      ' Q.
       O.
       
-------
f   S
°J
01   >>
                                                              Figure 6-10

                        TRS Emissions  from Indirect  Contact Recovery Furnace  (Furnace K), Operator Data35
           10  I    "	   *  (32)
     i/i


     S                   •       \

     ^     7             ;"J
     "0                   / \
     '-'':Xir°3H§	,
     I              /          \               \


            4  -     '                   /       ^

     J             '             '.     ''          \

     «      -3       /               \               \

     +J '     ^  ~   /                H'
     CT
     OJ           /
     O           '
     C      ?     ,
     O      <-  _  /


     oo
     o:         '-
            5                  '                                                 '                              i
                                              \                                ,                              !
           0  ; , __  ..    _	 i  		i     	  j_		 j_         |   	  	j	j_ 	  	j

  Month      Aug.      Sept.     Oct.       Nov.       Dec.      Jan.       Feb.     March     April     May

              <                       1973      •              >< 	-1974—              >

  No. of      29         29       31         30        28       29        26         31          30        31

  Daily Avgs.

-------
These data, Figure 6-9, show that the TRS emissions can be maintained
below 5 ppm.  Furnace H operates at an equivalent pulp production
rate of about 200 tons per day.  These daily averages are not as
stringent as the proposed four-hour average standard.  The data are
presented as an indication of long-term performance of this facility.
Furnace K
     Furnace K, which does not have a direct-contact evaporator,
was not tested for TRS by EPA.  Continuous monitoring data was
obtained from the local control agency for a period of 10 months.
These data, presented in Figure 6-10, indicate that the TRS emissions
can be maintained below 5 ppm on a daily average.  Since daily
averages are not as stringent as four-hour averages, these data
do not actually support the proposed standards.   They do, however,
indicate long-term performance, and are included for this reason.
6.2.5  Smelt Dissolving Tank
     Two smelt dissolving tanks were tested by EPA for TRS emissions
using a gas chromatograph for 3 days.  The TRS emissions from these
smelt dissolving tanks (D and E) are presented in Figures 6-11 and 6--12.
The EPA results are four-hour averaqes.
Smelt Dissolving Tank D
     The TRS emissions from smelt tank D were under 0.008 g/kg ADP (0.016
Ib/T ADP or 6.9 to 8.8 ppm) during the three-day test period.10  The
data are presented in  Finure  C-ll. This smelt dissolving tank also
employs a wet fan type scrubber to control its TRS emissions.  Weak
wash liquor (water from lime mud washers) is used as the scrubbing
solution in this scrubber.

                               6-37

-------
                                                         Figure 6-11

                                   TRS Mass Emission Rate  From Smelt  Dissolving Tank D
    0.0175
            o
    0.0150  L.'
Q.

<  0.0125
en
 (/)


J 0.0100

 en
 i/)
•r—
 E
LU


£ 0.0075
                                                       Key

                                                       o -  Run  No.  1


                                                       D    Run  No.  2


                                                       A  Run No.  3
                                                     Proposed
                             P
  0.0050  -
  0.0025
                                          D-.
                                                                    \
                                                                    \^ . '

                                                                    " \
                                                           9    10



                                                       Sample Number

                                                         4 hours
                                                                                                                 0.035
                                                                                                                 0.030
                                                                                                        	-... 0.025
                                                                                                                      Q.
                                                                                                                      O
                                                                                                                0.020
                                                                                                       D-      0.015
                                                                                                               0.010
                                                                                                             -0.005
12    13    14    15     16
                                                                                                              I


                                                                                                             17

-------
Smelt Dissolving TankE
     The TRS emissions from smelt tank E were under 0.004 q/kg ADP
(0.0079 Ib/T ADP or 1.8 to 2.8 ppm) during the three-day test period,
The data are presented in Figure 6-12.  This smelt dissolving tank employs
a wet fan type scrubber to control its TRS emissions.  Fresh water
is used as the scrubbing solution in the scrubber.
Add it i pna 1 Tes t Data
     A special study, conducted by NCASI personnel in 1970 and 1971,
                                                            -3Q
measured TRS emissions from numerous smelt dissolving tanks.    The
reduced sulfur contributions from 20 smelt tank vents are also
summarized and reported in Table 6-10.  This table shows that 15
smelt tanks, tested by NCASI, had TRS levels less than 0.013 g/kg ADP
(0.025 Ib/T ADP or 7 ppm).  Table 6-10 also lists the control device
and scrubbing solution for each smelt dissolving tank tested.  Based
on this information, the most effective control device for TRS
emissions is a wet scrubber using fresh water.
6.2.6  Lime Kilns
     Three lime kilns were tested for TRS emissions by EPA, and the
data is summarized in Figure 6-13.  TRS emissions were monitored
with a gas chromatograph.  These data are four-hour averages.  Continuous
monitoring data (daily averages) obtained on one of these lime
kilns are also reported in Figure 6-13.
Lime Kiln D
     The TRS emissions from lime kiln D during the EPA tests ranged
                                               14
between 2.8 and 24.1 ppm and averaged 9.8 ppm.    These data, Figure 6-14,
are the results of six four-hour runs.  TRS emissions from  kiln D
are controlled by maintaining good process controls.  The cold-end
                             6-39

-------
  F.PA
           Results
                                           Table G-IO

                        TRS Emissions From Snelt Dissolving Tanks
                           Used In The Kraft Pulping Industry
                         TRS

Mil 1

E
D
NCASJ_St
II
III




IV



V



VI


vn
VIII

IX
X


XI
XII





__
n / 1 -i i /' 1 ">
9/K() /"-'•
0.004
O.OOC
cdy Re"','l ts
0.005
0.06


0.005

-------
                                                   Figure 6-12

                              TRS Mass Emission Rate  From Smelt Dissolving Tank E
   0.0175;
   0.0150-
                                                   Key
                                                  L
                 Run No. 1

                 Run No. 2


                 Run No. 3
                                                                                                                0.035
0.030
Q  0.0125-
<-C        :

.

-------
                   Figure 6-13

Total Reduced Sulfur (TRS) Concentrations in Control
  System Exhaust From Lime Kilns Used In The Kraft
                   Pulping Industry


35




30


25



C
o
•i —
2 20
c
0) E
O Q-
C Q-
o
0
CO
^ 15



10



5

0
0(40)
Key i !
EPA Other i 1
~ M P Maximum Data Point ii
1 1 ' ! . II
ji_U| ji-Lj Average ' '
i i i t i
fj o Minimum Data Point h
1 '
1 •
1 :
1!
1 1
1 i
II
1!
.0 "
11 1 1 1
>, I'
11
H I'
II H
Ii I)
i i
1 i

*4 1 1
I! '
Ii "
h • n
Ji ,,
! 1
M II
' '1 ' *'
R Hr1 e • ^
j I , . ' • .1
ii i ? i i . . i
" M ' i , i
' i" Proposed ^SPS f ; M '
•H £ 1) : 1 i '
ii ' ' '
6 Data Points ; ! ' :
fi ^ i r .. . H '
Hr^T ^ I I T
Lime Kiln El E2 D K ' 0
Control Method C C P P PC- Process
Controls
Test Report 15 14 17 - Caustic
Reference 6-42" Addition
                                                      P -_ Process
                                                        " Controls Only

-------
                                                   Figure 6-14


             TRS Emission From Lime Kiln System Not Utilizing Caustic Scrubbing (Lime Kiln D;  EPA Data
,14
50 rr
10
•r-
-Q
CO Aft
 i

j^, f™^ ;
to
E
Gi-
n-

Key
O Run No.
j • Run No.
1 A Run No.
i
; • Run No.
j a Run No.
I
A Run No.









1
2
3

4
5

6


*




ro
s-
o>
u
o
o
UO
cc:
     20  -
     10  _
                                                                                 I,
                                                                                 I
                                                                                      A
                                                   •
                                                   /
                                                                                13    14    15    16
                                                Sample  Number


                                               — 4  hours	

-------
temperature is maintained at 460 to 540 F and the excess oxygen is
held at about 5 to 6 percent.  Fresh water is used in the venturi
scrubber.  TRS emissions are also reduced from lime kiln D by
maintaining the sulfide (Na^S) content in *he lime mud to about
0.3 percent.  The high TRS readings during the EPA testing coincide
with periods of low oxygen levels (2-4 percent) and high sulfide
content (1.0 percent) in the lime mud.  Noncondensable gases
from the multiple-effect evaporators were being burned in this
lime kiln during the tests.
Lime Kiln E
     The TRS emissions during six test runs from lime kiln E during the EPA
                         1 5
tests were under 2.0 ppm. "  These data are presented in Figure 6-15.
The TRS emissions are controlled by maintaining a high cold-end
temperature of 555 to 740°F and the excess oxygen between 2.5 and 4.5
percent.  In addition, a sodium hydroxide solution is added to the fresh
make-up scrubbing water in the venturi scrubber to reduce hydrogen
sulfide emissions.  Continuous monitoring data, Figure 6-16, obtained
from the operator covering a period of 13 months show that TRS
emissions from lime kiln E ranged between zero and 10.1 ppm and
averaged 0.63 ppm on a maximum daily average.  Four-hour averages
would likely be a bit higher.
                                                                    31
     EPA analyzed one month of TRS emission data from this facility.
The data were collected with a coulometric titrator and reduced into
consecutive four-hour averages.  During the period analyzed, there
were more excess emissions than the average month reported by the
operator.  Therefore, this month represents a type of worst case
                               6-44

-------
                                                          Figure q-15


                                           TRS Emissions  From  Lime Ki]n System         15
                                    Utilizing Caustic Scrubbing (Lime Kiln E; EPA Data)
01
i
     I/)



     (O
     in
     to
     en
     -a


     cu
E
a.
Q.
     C

     O
     ai
     u
     c
     o
     in
     on
          5 I	

                Proposed NSPS Level
                                                                                           14     15     16
                                                      Sample  Number
                                                      — 4  Hours	

-------
                                                Figure 6-16
      JS
      VI
      re
      en
       OJ
       Q.
       D.
       C
       O
       ro
      -4->
       C
       OJ
       o

       o
      o

      CO
      o:
                                     TRS Emissions  From  Lime  Kiln System
                          Utilizing Caustic Scrubbing  (Lime Kiln E;  Operator Data)
Month
                                                                             Key
                                                                  e Maximum Daily Average
                                                                    During Month
                                                                  0 95% Confidence  Limit;
                                                                    Based on Daily  Average
                                                                            Proposed MSPS Level
May   June   July
No. of Daily 31
Averages
       27
31
 Aug.    Sept.   Oct
— 1973 	
 24       30     31
Nov.

 30
Dec.

 24
Jan.
•
 30
Feb.  March
 	1974	
 28    31
April

 29
30

-------
analysis.  The results of the study show that the four-hour
average TRS emission level was below 5 ppm about 94 percent of
the time.  The study excluded emissions during periods of start-up,
shutdown, and malfunction.  Vent gases from the digesters, evaporators,
condensate stripper, and miscellaneous storage tanks were burned
in the lime kiln during the EPA tests.
Lime Kiln K
     The TRS emissions from lime kiln K during the EPA tests ranged
between 4.0 and 12.5 ppm and averaged 6.0 ppm.    These data,
Figure 6-17, are the results of six four-hour test runs.  The TRS
emissions are controlled by maintaining the cold-end temperature
around 700°F and the excess oxygen concentration level in the kiln
between 6 to 7 percent.  Analyses showed that the sulfide content
of the lime mud to kiln K was about 0.4 percent.  Fresh water is
used as make-up to the venturi scrubber used for particulate control.
     Noncondensable gases from the digesters, multiple-effect
evaporators, and turpentine system are burned in this lime kiln.
Lime Kiln 0
     Lime kiln 0 was not tested by EPA.  Continuous monitoring data
(daily averages) was obtained from the local agency for a period of
          32
17 months.    These data, presented in Figure 6-18, show that the
TRS emissions range between 3 and 32 ppm and average 9 ppm on a daily
average.  Lime kiln 0 operates at about 3-4 percent oxygen concen-
tration and at about 300°F at the cold end.  Fresh water is used as
make-up to the venturi scrubber used for particulate control.
                              6-47

-------
cr,
i
      -Q
      •>
      c:
      O
      c
      Ol
      CO
      DC
                                                        Figure  6-17
                                            TRS Emissions  From  Lime Kiln System  Not       -
                                       Utilizing Caustic Scrubbing (Lime Kiln  K,  EPA Data)
                                                                              (11.9)
            10 -
             9 -
7 -
  c

                         — C-
   KEY
o  Run No. 1
«  Run No. 2
A  Run No. 3
•  Run No.
c  Run No. 5 .!
A Run No. 6
                                                 \
                                              rri


-A-
^-L—~. ....
7

w -v" /
;'
" -A- - -X
_J 	 i 	 	 1 . . - -1. . .
8 9 10 11
Sample Number
'• • "A
•A

.. j i ... . i_... _ i .. .. i.
12 13 14 15 16


-------
                                                      Figure  6-18
               TRS  Emission From Lime  Kiln  System Not Utilizing Caustic  Scrubbing (Lime  Kiln  0;  Operator Data)  ~
     1/1    /in
     s_
     T3
     OJ
     E
     O
    >
     O.
     Q-
     C
     O
     to
     i_
     •f-J
     OJ
     u
     O
     O
     c/o
     Qi
Month
          30
             .
          20 _
                                       Key
                            » Maximum Daily  Average Reported
                              During Month
                              95% Confidence Limit;     *
                              Based on Daily Averages    \

                                                        I  \
Jan.
	!..__	L«_. ._._1___L.	1__,-.....L__.._.J		, i	_.l_	J	   I  .    J
 Feb.   March April May    June  July  Aug.  Sept.  Oct.   Nov.  Dec.  Jan.
                                                                                                                 \
No. of Daily
Averages     26   27      30    30   30     30     22   30     27    18    28     24
                                                                                        31
Feb.  March

	1974


 23    28
                                                                                                           i      1J
                                                                                                          Apri1  May
                                                                                               28    31

-------
6.2.7  Condensate Stripping System
     Vent gases from condensate stripping systems are low volume
(about 4000 cfm for a 1000 TPD mill) and can easily be incinerated
in a lime kiln.  Presently three domestic mills are successfully
incinerating these gases.   Two are air strippers and the third is
a steam stripper.  The vent gases from one of the air strippers are
incinerated in a recovery  furnace while the vent gases from the
other air stripper are burned in a separate incinerator unit.   The
vent gases from the steam stripper are being incinerated in a  lime
kiln (lime kiln E).  The effectiveness of incineration for removing
TRS from noncondensable gas streams has been demonstrated in an
EPA test on an incinerator burning noncondensables from the digesters
                                24
and multiole-effect evaporators.    Since the emissions from the stripper
system are similar to the  emissions from the digesters and evaporators
and are of low volume, the use of the same control technology  is a
practical application.  Therefore, the results of the incinerator
tests are applicable to the emissions from this facility.  Incineration
of the off-gases from the  condensate stripper system in the lime kiln
or other combustion device will be capable of achieving an emission
concentration of below 5 ppm.
                                6-50

-------
                           References

 1.  Air Pollution Emission Test 72-PC-ll  (Recovery Furnace  A),
     March 1975.

 2.  Air Pollution Emission Test 72-PC-13  (Recovery Furnace  B),
     March 1975.

 3.  Air Pollution Emission Test 73-KPM-2  (Recovery Furnace  D),
     January 1975.

 4.  Air Pollution Emission Test 74-KPM-5  (Recovery Furnace  D),
     November 1975.

 5.  Air Pollution Emission Test 74-KPM-13 (Recovery Furnace I),
     January 1975.

 6.  Air Pollution Emission Test 74-KPM-12 (Recovery Furnace J),
     January 1975.

 7.  Air Pollution Emission Test 74-KPM-15 (Recovery Furnace K),
     June 1974.

 8.  Air Pollution Emission Test 74-KPM-17 (Recovery Furnace L),
     November 1974.

 9.  Air Pollution Emission Test 72-PC-13  (Smelt  Dissolving  Tank B),
     March 1975.

10.  Air Pollution Emission Test 74-KPM-5  (Smelt  Dissolving  Tank D),
     November 1975.

11.  Air Pollution Emission Test 74-KPM-4  (Smelt  Dissolving  Tank E),
     November 1975.

12.  Air Pollution Emission Test 74-KPM-10 (Smelt Dissolving Tank  F),
     January 1975.

13.  Air Pollution Emission Test 74-KPM-9  (Smelt  Dissolving  Tank G),
     February 1975.

14.  Air Pollution Emission Test 74-KPM-5  (Lime Kiln D),  November  1975.

15.  Air Pollution Emission Test 74-KPM-4  (Lime Kiln E),  November  1975.

16.  Air Pollution Emission Test 74-KPM-15 (Lime  Kiln K),  June 1974.

17.  Air Pollution Emission Test 74-KPM-1A (Lime  Kiln K),  November 1974.

18.  Air Pollution Emission Test 74-KPM-17 (Lime  Kiln L),  December 1974.
                                 6.51

-------
19.   Air Pollution Emission Test 74-KPM-20 (Lime Kiln M),  March  1974.

20.   Air Pollution Emission Test 74-KPM-19 (Lime Kiln N),  January 1975.

21.   Air Pollution Emission Test 74-KPM--11 (Lime Kiln P),  January 1975.

22.   Air Pollution Emission Test 72-PC-ll  (BLO System A),  March  1975.

23.   Air Pollution Emission Test 73-KPM-1A (Noncondensable Incinerator C),
     January 1975.

24.   Air Pollution Emission Test 73-KPM-1B (Noncondensable Incinerator C),
     January 1975.

25.   Air Pollution Emission Test 73-KPM-2A (Brown Stock Washers  and
     BLO System D), January 1975.

26.   Personal communication with S.  Snader, Manager of Engineering
     and Design, Koppers Company, September 17, 1974.

27.   Memo from James HeHihy (EPA)  to James Durham (EPA) on the
     Air Pollution Control  at U.S.  Kraft Mills (State of the Art),
     May 18, 1972.

28.   Letter dated November 17, 1972, from Russell  0.  Blosser of  NCASI  to
     Paul Boys of EPA.
29.   Letter dated July 23, 1974, from S.  T.  Potterton of Babcock and
     Wilcox to J. A.  Eddinger of EPA.

30.   Factors Affecting Emissions of Odorous  Reduced Sulfur Compounds
     from Mi seel 1aneous Kraft Proces s Sources,  NCASI  Technical  Bulletin
     No.  60, March 1972.

31.   Reduction of Total Reduced SulfurData  from a Kraft Pulp Mill
     Lime Kiln, Emission  Standards and Engineering Division,  U.S.  EPA,
     December 1975.

32.   Monthly Reports  to Humboldt County Air  Pollution Control District,
     January 1973 to  May  1974.

33.   Letter from Andrew Ryfun, Manager of Environmental  Services,
     Brunswick Pulp and Paper Company to James  Herlihy of EPA
     dated October 5, 1973.

34.   Information received by EPA from Buckeye Cellulose  Corp. at
     meeting with industry at Research Triangle Park, N.C., March 7, 1975.

35.   Information obtained from the Washington Department of Ecology.
                                 6-52

-------
36.  Letter from James Farmer of Buckeye Cellulose Corp.  to James  Herlihy
     of EPA, dated February 4, 1974.

37.  Data supplied to EPA by Champion Paper Company,  Pasadena,  Texas.

38.  Data supplied to EPA by Escanaba Pulp and Paper  Company,  Escanaba,
     Michigan, July 2, 1974.

39.  Data supplied to EPA by the Humboldt County Air  Pollution  Control
     Agency, May 10, 1973 and July 1, 1974.
                                  6-53

-------

-------
                  7.   ENVIRONMENTAL  IMPACT
     The purpose of this chapter is to identify, quantify, and
evaluate the positive and negative environmental impacts of the
alternative control systems presented in chapter 4 for kraft
pulp mills.  The impacts on total mass emissions and ambient
concentrations of TRS and particulate matter, water supply and
treatment requirements, solid waste handling and disposal,
noise and radiation, and energy requirements for each alternative
system are discussed.  Both primary and secondary impacts
are considered.  Primary impacts are those directly attributable
to each alternative control system.   Secondary impacts are
indirect or induced impacts which arise from the application
of these systems.  In general, for kraft pulp mills the use of
one of the alternative control systems will  have an overall
beneficial impact on ambient air quality and slight adverse impacts
on solid waste handling and disposal, and energy demand.  No
impacts on water treatment and supply are anticipated.   Impacts due
to an  increase  in noise as a  result of the use of one of the alternative
control systems  can  be anticipated, but have not been quantified.  It is
assumed that any increases would  i:e negl ig'iolc when compared to J:h^
existing  levels.  Mo  impacts  due  to a change in radiation  levels are
anticipated as  a result of the  proposed standards.
     A summary  of the anticipated secondary environmental  effects
associated with  the  alternative control standards is  presented in Table 7-1.
Impacts on air  quality, water  supply and treatment, solid  waste impact, and
energy consumption  are identified.  These impacts will  be  discussed in more
detail later in  this  chapter.
                                7-1

-------
                                          Table 7-1.   Secondary Environmental Impacts of Individual Control Techniques
i
r-o
AFFECTED
FACILITY
RECOVERY
FURNACE
SMELT
DISSOLVING
TANK
LIME
KILN
DIGESTER
SYSTEM
MULTIPLE EFFECT
EVAPORATORS
CONDEHSATE
STRIPPER
SYSTEM
BROWN STOCK
WASHERS
BLACK LIQUOR
OXIDATION SYSTEM
CONTROL
TECHNIQUE
ESP
SECONDARY ENVIRONMENTAL IMPACTS
AIR
IMPACT
Increased Emissions
from Power Plant(a)
ii Increased Emissions
Scrubber jj froia power Plant'3'
Scrubber
Demister
Caustic Scrubber
ESP
Incineration
in Lime Kiln
Separate
Incinerator
Scrubber
Incineration
in Recovery Furnace
Increased Emissions,
from Power Plant'^
l
WATER
I "PACT


SOLID WASTE
IMPACT
ENERGY
CONSUMPTION
Increased Fovsr
Requirement

Increased Power
Rec/ji recent j
j ! Increased Pcwer
j Requirement
;
Increased Emissions,
from Power Plant^3'

Increased Emissions
from Power Plant'8'
and from incinera-
tor unit
(
! :
:
i
. .... _ j 	
S02, CO, and NOX i
emissions
Increased Emissions. ;
from Power Plant*3'



Possible Handling
Problem with NaOH






	 • 	 "~ 1
Increased power
Requireir-nt
i
Increase in Power
Requirement and Added
Fuel Requirement
for Incinerator
Slight Increase in
Fuel Requirement
Significant Increase ir
Fuel Requirement
Increased Power
Requirement
Slight Increase in
Fuel Requirement
          Notes:
          (a)  S02, CO, NOX.

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7.1  AIR POLLUTION IMPACT
7.1.1  Primary Impacts
     The primary impacts that can be attributed to the use of
the alternative control  systems can be measured in two ways:
the reduction in total mass emissions of TRS and particulate
matter and the reduction in the maximum predicted ambient air
concentration due to these emissions.  As a baseline upon which
to measure the impacts due to the proposed standards, an average
mill controlled to the levels specified by typical state standards
was chosen.  These baseline emission values are summarized in
chapter 4 as control system number 1.  Emission rates were
then determined for the facilities controlled with the alternative
systems, also summarized in chapter 4.
7.1.1.1  Mass Emissions
     The reductions in mass emission levels were calculated
on the basis of pounds of pollutant per ton of air-dried pulp
produced.  Taking into account the average yearly growth rate
for the industry, an assumed rate of capacity utilization
of 0.95, and the rate of production capacity increase (new
capacity plus replacement capacity), the industry-wide reduction
In emfssfons c?n be calculated.
     The total reductions in emissions achievable through the
application of the various control techniques discussed in
detail in chapter 4, Emission Control Technology, are presented
in Table 7-2.  By combining the potential reductions for each
                              7-3

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                         TABLE 7-2.  Emission Reduction Under Alternative Control Techniques
                                              (1000 ton per day ADP Kraft Pulp Mill)
                                                                                    Controlled Emissions jib/ton ADP)
Participate
Recovery Furnace
Smelt Dissolving Tank

Lime Kiln

TRS
Digester System
Multiple Effect
 Evaporators
Brown Stock
Black Liquor
 Oxidation System
Recovery Furnace
                 (3)
Smelt Dissolving
Lime Kiln

Condensate Stripper
Notes

Alte
Control
(a)
(b)
(a)
(b)
(a)
(b)
(a)
(a)
(a)
(a)
(b)
(a)
(b)
(a)
(a)
(b)

rnative
Techniques
ESP
Scrubber
Dem's ter
Scrubber
30" venturi
ESP
Incineration
Incineration
Incineration
Incineration
Oxygen
Black liquor oxidation
Indirect-contact evaporators
Process control
Process control
Caustic addition
Uncontrolled
Emissions
(Ib/ton ADP)
180
180
8.0
8.0
1.0
1.0
1.5
1.0
0.3
0.1
0.1
15.0
15.0
0.2
0.8
0.8

Existing Emission
LeveiU)
4
4
0.5
0.5
1.0
1.0
0.01(2)
0.01(2)
0.3
0.1
0.1
0.5
0.5
0.2
0.2
0.2

Best Control
Level
2
14
1.6
0.3
0.5
0.17
n,Ai(2)
0.01(2)
0.01(2)
0.01(2)
0
0.15
0.15
0.025
0.050
0.025

Reduction
2
0
0
0.2
0.5
0.83
A
n
0.29
0.09
0.10
0.35
0.35
0.175
0.150
0.175
                           (a) Incineration
2.0
                 0.01
                                                                                       (2)
0.
     Existing emission levels based on average state emission standards.
     Controlled emission level  due to each facility after incineration.  In some cases this would actually be
     equal  to zero (0).
     These  facilities  are essentially uncontrolled at this time.

-------
facility, the total reductions attributable to the alternative
control systems can be determined.
     The reductions in total mass emissions achievable are summarized
in Table 7-3.  System number 1 is used as the baseline upon which
to measure the impacts.  The greatest impact on TRS emissions
is shown with systems 2 and 5 (81%); on particulate matter with
systems 4 and 5 (55$).  System 3 shows the least impact.
7.1.1.2. Ambient Concentrations
     For the purpose of evaluating the air pollution impacts
associated with the implementation of the proposed standards,
studies were performed on model kraft pulp mills.  The models
chosen were of average design and layout as shown in Figure 7-1,
and include the eight affected facilities controlled by the proposed
standards as well  as an average size treatment pond facility.
Modeling was performed for plants of 500, 1000, and 1500 tons per
day of air-dried pulp (ADP) produced, a range within which the
majority of kraft pulp mill capacities fall.
     Maximum ground-level concentrations of each pollutant were
determined for the emission rates corresponding to each control
system.  The concentrations decreased predictably with decreases
in the emission rates.  It was possible to adjust the meteorological
conditions of the study to achieve the worst cases that would be
expected to occur at and near a kraft pulp mill.
     Ambient concentrations of TRS and particulate matter due to
the alternative levels of control were calculated using state-of-
the-art modeling techniques.  These calculations are assumed to be
reliable within about a factor of two.  The following assumptions
                                7-5

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CT-
            TABLE 7.3.  PRIMARY IMPACT OF THE ALTERNATIVE CONTROL SYSTEMS ON MASS EMISSIONS

                                                                     Total  Reductions in Emissions
                                                                           Due  to New Source
                                      Total  Mass  Emissions                Performance Standards
             Alternative                   (Ib/T  ADP)                   (Ib/T ADP and % reduction)
           Control System           TRS          Particulate              TRS             Particulate
1
2
3
4
5
1.3
0.25
0.275
0.275
0.25
5.5
2.8
2.8
2.47
2.47
-
1.05 ;(81%)
1.025 (79%)
1.025 (79%)
1.05 (81%)
-
2.7 (49%)
2.7 (49%)
3.03 (55%)
3.03 (55%)

-------
                     FIGURE 7-1.  Typical Plant Layout (1000 ton per day kraft pulp mill)
-vj
I


« 	 ISO 	
H-50
H-50
4 	 1000
r
i
I
TREATMENT
POND
00 ACRES 1

— t
i
«—


2r
L 0
• — 100 — »
i
\
<
	 175 	 1
t
H-50 I
© r
© '
a ® ©
<4U» f /*""""\ ^-~\ * — 10D- »
* i C >• ail •( n i vx
|i?(T)4_3S_^'_eO-^_Jj<,005
•>« ™ IF I v " y I
ft 	 — -rn Z0 H 10 ,*. l " J 	
	 MI—— ^i-o" n^SKl)u « f
•1 I — ^—30 	 KRjMl^H-56 1
o 5 /— •>. /^S
E H-175 a a T ° xA, x— x C0^ 	 12° 	 ^
, n*l/s "("'/-N / \ / \ ^-i
I j«75H «-30*O r v — ' ^f^ 7
1 ... • — •• — i^il)
» |^ — 125 — >
" 'f
t-v . 2.'
9 © | 3
["V J'-^^LIO '.. _,., „, 4,
/--> / .«V,«— 111— *» r
vi; VJT^ H-SO § 4 5.
• - /~> 3D;-7 •* s Jr25"°16^ i 7-
W ^ T ... r0 SI 8'
i ?nn » 1 1 fl W *
1 ZOO 1 D ^
' _ x-v *-± 	 1-200 	 »l
	 i /- ^ / > -^ 	 • 	 -
(D (^J _£_
TANK«-> A - «' F - 50'
0-35' G - 15'
C - SO' H - 10'
D - 35' J - 12'
E - 60' K - 20'
•6 3
D~2
8
Stacks:
Recovery Furnace
Smelt Dissolving
Tank
Lime Kiln
Digesters
Evaporators
Brown Stock Washers
Oxidation System
Condensate Stripper

-------
were applied for the analytical approach:
     1.  There are no significant seasonal or hourly variations
         in emission rates for these plants.
     2.  The plants are located in flat or gently rolling terrain.
     3.  The meteorological  regime is unfavorable to the
         dispersion of effluents.  This assumption introduces
         an element of conservatism into the analysis.
Calculations were performed assuming both the presence and absence
of aerodynamic downwash effects on the emissions.  Unfavorable
design characteristics of the model mill such as (1) a 220-foot
structure adjacent to a 250-foot recovery furnace stack, (2) a
175-foot smelt dissolving tank stack next to a 175-foot building,
and (3) a two-foot stack for the black liquor oxidation tank atop
a 50-foot building will result in downwash in most situations.
However, stacks are generally designed to eliminate downwash
and a second set of calculations were made assuming a non-downwash
case.
     The results of the study that was performed to evaluate
maximum ground level concentrations due to emissions from kraft
pulp mills are presented in Tables 7.4 and 7.5.  The emission
rates upon which these calculations are based are presented in
Table 7.2.  The first case assumed the effect of aerodynamic
downwash to be present, an assumption which creates a worst
case analysis.  The second case assumes that aerodynamic downwash
does not occur.  The numbering system for the control alternatives
is identical to the systems described in detail in chapter 4.
                               7-8

-------
      TABLE 7.4.  Estimated Impact of Kraft Pulp Hill  Assuming the Occurrence of Aerodynamic Downwash
                                         (1000 ton per day kraft pulp mill)

                                       TOTAL REDUCED SULFUR (as H2S)

                                            Maximum
                                            Combined
            Control         Averaging      Concentration
          Alternative        Time         	(yg/m3)	

               1            10 sec.            V1400
                             1 hr.              185
                            24 hr.               44
—i
-D              2            10 sec.              225
                             1 hr.               30
                            24 hr.                7

               3            10 sec.              225
                             1 hr.               30
                            24 hr.                7

               4            10 sec.              225
                             1 hr.               30
                            24 hr.                7

               5            10 sec.              225
                             1 hr.               30
                            24 hr.                7
Contri
RF
^600
80
20
^190
25
6
VI 90
25
6
VI 90
25
6
VI 90
25
6
bution of Each Source (y(
SDT
^300
40
7
V35
5
1
V35
5
1
V35
5
1
V35
5
1
LK
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
BLO
Neg.
Neg.
Neg.
_
-
-
_
-
-
_
-
-
_
-
-
3/m3)
BSW

-------
  Control
Alternative

     1
     3


     4


     5
            Averaging
              Time

             24 hr.
             annual

             24 hr.
             annual

             24 hr.
             annual

             24 hr.
             annual

             24 hr.
             annual
                TABLE 7-"  (continued)

                  PARTICULATE MATTER

                          Maximum
                          Combined
                        Concentration
                           (yg/nr)

                             180
                              60

                              91
                              31

                              91
                              31

                              91
                              30

                              91
                              30
Note:
RF  =
SDT =
LK  =
BLO =
BSW ••
Neg.
 Recovery Furnace
 Smelt  Dissolving Tank
 Lime  Kiln
 Black  Liquor  Oxidation  Tank
 Brown  Stock Washer System
= Negligible
 Contribution of  ,
 Each Source (yo/m )
RF      SDT      LK
170
44
85
22
85
22
85
22
85
22
10
12
6
7
6
7
6
7
6
7
Neg.
4
Neg.
2
Neq.
2
Neg.
1
Neq.
1

-------
TABLE 7.5,   ESTIMATED IMPACT OF KRAFT PULP MILL EMISSIONS UNDER NON-DOWNWASH ASSUMPTION*
                                (1000 ton per day kraft pulp mill)

                             TOTAL REDUCED SULFUR (As H~S)
  Control
Alternative

     1
Averaging
  Time

 10 sec.
  1 hr.
 24 hr.

 10 sec.
  1 hr.
 24 hr.

 10 sec.
  1 hr.
 24 hr.

 10 sec.
  1 hr.
 24 hr.
                  10 sec.
                   1 hr.
                  24 hr.
   Maximum
   Combined
Concentration
   (yg/m3)

    •v!35
    18.4
     3.4

    VI 5
    r.o
    0.2
                                    1.9
                                    0.4
    1.9
    0.4

    -x.15
    1.0
    0.2
Contribution
RF SDT
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neq.
Neg.
Neg.
0.6
0.1
0.1
Neg.
0.1
Neg.
0.1
Neg.
0.1
Neg.
of Each
LK
1.4
0.3
VI 3
0.9
0.2
V2.8
1.8
0.4
i!s
0.4
"i Q
0.9
0.2
, , -3
Source (yg/m
BLO BSW
V70 0,50
9.4 7.0
2.1 0.9
-
— ~
_
-

-------
                Control          Averaging
              Alternative          Time

                   1              24 hr.
                                  annual
                         TABLE 7-5-(continued)

                          PARTICULATE MATTER

                                  Maximum
                                  Combined
                               Concentration
                                  (ug/m3)

                                    9.7
                                    2.2
              Note:
2              24 hr.               5.1
               annual               1.1

3              24 hr.               5.1
               annual               1.1

4              24 hr.               2.5
               annual               0.6

5              24 hr.               2.5
               annual               0.6

  RF   = Recovery Furnace
  SDT  = Smelt Dissolving Tank
  LK   = Lime Kiln
  BLO  = Black Liquor Oxidation Tank
  BSW  = Brown Stock Washer System
  Neg. = Negligible
   Contribution  of
     Each  Source
RF       SDT      LK
Neg.
0.2
Neg.
0.1
Neg.
0.1
Neq.
0.1
Neg.
0.1
1.8
0.4
1.1
0.2
1.1
0.2
1.1
0.2
1.1
0.2
7.9
1.6
4.0
0.8
4.0
0.8
1.4
0.3
1.4
0,3
*The non-downwash assumption is  ficticious in  the general  layout of the model  (Figure 7-1),
 included here since downwash could be eliminated through  design of the mill.
                                                                          It  is

-------
     Averaging times of 10 seconds, 1-hour, and 24-hours were selected
for the TRS calculations, representing shorthandilorig-term exposures.
The 10-second average would be considered a "whiff," and applicable
to the study of odorous emissions.  The one hour average gives an
indication of the level of exposure experienced through casual contact,
while the 24-hour average shows the level of exposure of a person living
near the mill.  Particulate matter concentrations were calculated for 24-
hour and annual averages.  These levels correspond with the averaging
periods used for the National Ambient Air Quality Standards (NAAQS).
Dispersion Calculations Assuming Downwash
     The diffusion calculations made assuming downwash (Table 7.4)  show-"that
TRS emissions from facilities controlled to average State standards
level produce an ambient concentration of about 185 yg/m3 (1-hour average).
This concentration is mainly caused by emissions from three facilities:
The recovery furnace, the smelt dissolving tank, and the brown stock
washer system.  Contributions due to emissions from the lime kiln and
black liquor oxidation system are negligible.  Application of emission
controls under systems 2,3,4, and 5 produce a significant reduction in
concentration, and results in a TRS concentration of about 30 yg/m^ on
an hourly average basis.  Since the contribution of the lime kiln is
negligible at the maximum point, no change in concentration is
perceivable.
     Similar results are seen for the dispersion calculations for
particulate emissions.  Emissions from the baseline control alternative
number 1 produce a maximum concentration of about 180 yg/ttr (24-hour
average).  The emissions from the lime kiln contribute only a negligible
amount to the total concentration.  Application of control systems

                             7-13

-------
2, 3, 4, or 5 produce reductions in concentrations to about 31 and
30 pg/m3 (24-hour average).
Dispersion Calculations Assuming No Downwasji
      Under the  non-downwash assumption (Table 7.5),  emissions  from the
 lime kiln  become significant while those from the recovery furnace are
considered to have a negligible contribution  toward the maximum
concentration.   Under control system number 1, the maximum TRS
concentration is about 18 yg/m3 (1-hr  average).  A large part, about 90%,
of this total  is due to emissions  from the black liquor oxidation tank
and the brown  stock washer system.   These two facilities are fully
controlled under systems 2, 3, 4,  and 5, and the emissions from
the lime kiln  are significantly reduced.  As a result, the TRS
concentration  under systems 2 and  5, where caustic scrubbing is
applied, averages about 1.0 ug/m3  (1-hour average).   Under systems 3
and 4, where TRS emissions from the lime kiln  are controlled by applying
good process controls,  the maximum concentration is  about 1.9 ug/m3
(1-hour average).
     Similar results are obtained  for emission of oarticulate
matter.  The 24-hour average concentration under the  baseline
system is about  10 pg/m3, 80 percent of which  is due  to emissions
from the lime  kiln.   The smelt dissolving tank contributes the
remainder;  the contribution from the recovery furnace emissions
is negligible.   Under systems 2 and 3, where emissions are
controlled with  a 30-inch venturi  scrubber, the 24-hour average
is about 5  yg/m3.  When an electrostatic prec^pitator is used in
systems 4 and  5, the maximum concentration is  further reduced to
about 2.5 yg/m3.
                            7-1 A

-------
 7,1.2   Secondary  Impacts
     Secondary  impacts  on  air quality will arise as a result of the
 electrical  requirements of certain control techniques that are used
 to control  kraft  mill emissions.  Additional emissions of particulate
 matter, NOX!> and  S02 from  the coal-fired power plant supplying the
 electrical  energy can be anticipated.  Based on the new source
 performance standards for  coal-fired power plants, promulgated in
 the FEDERAL REGISTER on December 23, 1971 (36 FR 24876), the additional
 emissions can be  estimated at 0.1 Ib of particulate matter, 0.7 Ib of
 NOX, and 1.2 Ib of S02 per 10^ Btu produced.   The amount of additional
 pollutant emissions  therefore are small when compared with the
 large reductions  in mass emissions achieved by implementation of the
 various alternative control systems.
     An additional adverse secondary air impact that must be
 considered  is the emission of SC^, CO, and NOX that may be
 generated as a by-product of the incineration process in the
 recovery furnace, lime kiln, or separate incinerator.  The
 incremental emissions of these pollutants due to the use of an
 alternative control system to meet the proposed standards are
 small.
7.2  WATER POLLUTION IMPACT
     No additional liquid  wastes will require treatment  or disposal  as a
result  of the implementation of any of the alternative systems.
Slurries from wet bottom electrostatic precipitators on  recovery
furnaces and scrubbing water from scrubbers on smelt dissolving
tanks are recycled to the  process.  Scrubbing water and lime mud
                               7-15

-------
wash water effluents from the lime kiln system are normally
recycled to the causticizing system for chemical recovery.
Incineration, the primary means of controlling TRS, does not
generate any liquid wastes.
     The Agency promulgated water effluent limitations for existing
sources in the pulp and paper industry on February 19, 1976 (41 FR 7662)
The 1983 standards for new and existing sources were proposed
at the same time.  For new sources, the proposed standards
limit discharge of wastes to the level achievable with "best
available demonstrated technology."  The use of any of the
alternative systems under consideration for control of TRS
and particulate emissions from kraft pulp mills will have no
effect on the ability of the kraft pulping industry to meet the
water effluent guidelines.
 7.3   SOLID  "ASTE  IMPACT
     The only control devices under consideration that would
collect particulates as a dry mass are dry-bottom electrostatic
precipitators operating on a recovery furnace or lime kiln.  The
dry particulate matter from the recovery furnace is primarily
Na2S04, which would be reused by dissolving it back into the
black liquor and returning it to the furnace for reduction
to Na2S.   The sodium salts, calcium carbonate, and calcium
oxide collected from the lime kiln emissions can similarly
be returned to the system in the causticizing unit.   Therefore,
no solid waste will  require additional  handling and disposal
as a result of the use  of any of the  alternative control  systems.
                              7-16

-------
     A secondary impact concerning solid waste may be caused
when a caustic scrubber is used to control lime kiln emissions.
If the mill at which the control system is applied cannot accept
the added sodium in the form of caustic due to total mill chemical
balance, some sodium waste may have to be removed and disposed of.
This is not expected to cause a significant impact on land disposal.
7.4  NOISE AND RADIATION IMPACT
     Any increases in noise levels that may arise as a result
of the proposed standards have not been quantified.  It is
assumed that any increases are negligible when compared to
the existing levels at presently operating mills.  There are no
known or anticipated impacts resulting from any increases in
radiation levels at kraft pulp mills.
7.5   FHERGY  PTACT
     The energy requirements associated with the various control
techniques are presented in Table  7.6.  The control techniques
which correspond to three levels of control - economic recovery
level, average state standards level, and the level required by
the proposed standards - are identified.  Where more than one
technique may be considered, all alternatives are listed.  The
incremental energy referenced to the economic recovery level is
calculated for both the state standards level and the proposed
new source standards level.  This calculation shows the energy that is
attributable only to control of pollutant emissions.  The increase
in energy required by the new source standards above that required
by the state standards is also presented in terms of 10  Btu per
                               7-17

-------
                                                          Table 7-6.   ENERGY IMPACT (1000-tcm-Der-dav kraft pulp mill!
co  i
Affected
Facility
Recovery
Furnace
Sr:elt Tank
Lime Kiln
i
Digester
Sys tern
v'jl. Effect
Evaporators
Control Technique Incremental Energy (Referenced to Economic Recovery Level)
Economic
Recovery
Level
99. C? ESP
De mister
Scrubber
None
None
Brown Stoclj None
Washers |
Black Liq.
Ox. System
Recovery
Furnace
Smelt Tank
Li"e Kiln
Condensate
Stripper
None
None
None
None
None
None
Average
State
Standard
Level
QQ fv/ rep
Scrubber
15" Venturi
scrubber
Incinera-
tion
Incinera-
tion
None
None
Process
controls
Process
controls
None
Process
controls
Incinera-
tion
New Source
Performance
Standard
29.5* ESP
Scrubber
30" Venturi
scrubber
ESP
Incinera-
tion
Incinera-
tion
Incinera-
tion
Incinera-
tion
(ton-contact
evaporator
Black Liq.
oxidation
Process
controls
p.c. & caus
tic additio
Incinera-
tion
State Standard
Fuel
Renui reinent
(TO6 Btu/da>
0
o
0
0
0
0
1090
0
0
n 0
0
Electrical
Requirement
)(k,,'hr/da.y)
0
2300
0
Total
(ID5 Btu/da;.
0
24.7
0
250 2.7
*
0
0
0
0
0
0
35
0
0
1090
• o
0
0
0.3
NSPS
h - - - -
Fuel
Reauirement
(106 Btu/
) day)
0
0
o
440
0
20
180
1090
0
0
135
0
Electrical
Requirement
(kwhr/diy)
0
2300
5100
0
"*• ' 	 —•—'•—•««—' 	
250
DIGESTER sy
200
610
0
12,100
0
0
35
Total
(iO5 Btu/day
0
24.7
51.9
440
2.7
23
186
1090
123
0
135
0.3
Increase in
Tctal Enerov
NS'S vs.
State
Standard
Level
(105 Btu/
) d?,y)
0
0
51.9
440
0
23
186
0
123
0
135
0
Increase in
Fuel
NSPS vs.
Standard
Level
(Bbl i'6
Fuel Oil/
day)
0
0
8.2
69.4
0
13.6
29.3
0
19.4
0
21.3
0
Increase in
Stanoerd
Lsvel
(Tons Eitl'rn.
Stea:": Co?V
d?.y)
0
,
0
2.4
19.1
0
t» !
1.0
8.1
0
5.3
0
5.8
° i

-------
day, number of barrels of #6 fuel oil, and tpns of bituminous-
high volatile C steam coal required per day.
     By combining the total incremental requirements, the amount
of energy attributable to each control system can be determined:
                             Increase in Energy
System
1
2
3
4
5
106 Btu/day
0
518.9
518.9
9ri7.0
9*5.0
BB1. of Oil/Day
0
81.9
81.9
143.0
149.1
Ton Coal /Day
0
V2.5
22.5
39.4
41.1
     Compared to the baseline system number 1, the incremental
values are greatest for systems 4 and 5.  This is directly attributable
to the added fuel requirement of a separate incinerator  that  is
needed when an ESP is used to control particulate emissions from
the lime kiln.  There is no increase between systems 2 and 3
since it is assumed that there is no energy requirement attributable
to the addition of caustic to the scrubber water.  The impact of
these energy requirements on the operating costs ($ per ton)  for
each alternative control system is discussed in Chapter 8,
     The total energy required by an average lOOO-ton-per-day
mill  is about 505 x 106 Btu per hour for process fossil fuel  and
electrical requirements including particulate control  to the
process recovery level.  This does not include the energy produced
by the combustion of the black liquor in the recovery furnace.
Compared to this baseline the percent of this total  that would be
required by the alternative control  systems  to meet the proposed
standards ranges from 4. 3 percent for systems 2 and 3  to 7-^ percent
                              7-19

-------
for system 5.  The estimated energy that would be required to control
all new, modified, and replaced affected facilities at kraft pulp
mills constructed during the five-year period through 1980 to
comply with the proposed standards is about 1,440,000 barrels of
Number 6 fuel oil per year in 1980 (about 9.2 x 1012 Btu per year).
7.6  OTHER ENVIRONMENTAL CONCERNS
7.6.1  Irreversible and Irretrievable Commitment of Resources
     The standards of performance will require the installation
of additional equipment over that now required by State standards.
This will require the additional use of steel and other resources.
This commitment of resources is small compared to the national
usage of each resource.  Much of these resources will ultimately
be salvaged and recycled.  There are not expected to be significant
amounts of land resources required to install control equipment
because most control systems are located on buildings and if not,
require a relatively small amount of space.  Therefore, the
commitment of land resources for siting additional control devices
is expected to be minor.
     The use of sodium hydroxide for the lime kiln scrubber to
remove TRS will slightly increase the usage of this commodity
Which reportedly is now in tight supply.  The amount of caustic used
hy the industry as required by the proposed standard is small compared
to the total  amount normally used at kraft mills and is minor when
compared to the amount of caustic used on a national level. The caustic
is recycled within the mill complex; therefore, only a small amount
of make-up caustic needs to be added as a result of the standard.
                                7-20

-------
     The proposed standards will require the increased usage of
energy which is a scarce resource to operate emission control
devices.  This energy will not be retrievable but will result in
the control of significant quantities of TRS and particulate matter.
Compared to the total amount of energy consumed in the United States,
the amount of energy needed to operate these control devices is small.
7.6.2  Environmental Impact of Delayed Standards
     Delay of the proposed standards for kraft pulp mills will
have major negative environmental effects on emissions of TRS
and particulate matter to the atmosphere and minor positive
impacts on water, land, and energy.  There are no new technologies
presently being developed for control of emissions from kraft pulp
mills which would significantly reduce emissions compared to
the levels of best demonstrated technology, considering costs,
that are currently available.  Therefore, there is no reason
why the standard should be delayed because of new technology
for the facilities affected by the proposed standards.
     One potential source of TRS emissions that has not been regulated
because control technology and emission measurement methodology
have not been identified is the water treatment ponds at kraft
mills.  The Agency is further investigating this potential source
and will take action if the investigation shows that it is a
significant source of TRS emissions and there is available technology
to control it.  This study is likely to take two years.  If the
standard is delayed until this potential source is investigated, it
                                 7-21

-------
will result in the emission of 6.8 million pounds of TRS, 14.2 million
pounds of particulate matter in the two-year period, that would have been
controlled by the proposed standards.   In addition, this source
could be amended to the kraft mill regulation at a later date
if it is determined to be necessary.   Therefore, there appears
to be no valid reasons to delay the kraft mill standard.
7.6.3   Environmental  Impact of No  Standard
     Based on the growth projections presented  in Chapter 8,
the  adverse environmental  impact of no standard  is summarized in
Table 7.7.  Since there are little adverse water pollution and
solid waste impacts,  and only moderate energy consumption impacts
associated with each  of the alternative emission control systems
which could serve  as a basis for  the standards, not setting
standards presents little  trade off of potentially adverse impacts
in these areas against the resulting adverse impact on air quality.
                                7-22

-------
                 Table 7-7.   ENVIRONMENTAL IMPACT  OF NO STANDARD
A.  IMPACT  DUE TO NEW KRAFT  MILLS AND CAPACITY ADDITIONS AT EXISTING  KRAFT MILLS
                                                NATIONWIDE EMISSIONS  (TO6 Ibs/yr)
                                                                             REDUCTION COMPARE.} TO ALTERNATIVE  1
                                                        alternative
Y^,.]v T_rr,.^p . C!n-;1?tiv« '•'•


r.7.? ii'^ •_ 6.Z


: ;:
/ ' °J3 ' 2^71 ; 11. .1


; 9S2 30S3 Ml 6. 8


: |
13?i 4433 ;•?.*. 4
! i:
i i ;
: ! 933 5421 M29.8

i .
l-itive 1 34?1 ' 5421 j:83.6
: ' ''
i \ '
'-• , 3 ; i : 5 j: 1

3.2 , J.2 ; 2.8 . 2.8 i! 1 .5
! -t
' . ! s
i • 'i
i ' ij
5.S 5.8 5.1 ' 5.1 ': 2.7
i

' 3.3 ! 5.5 7.5 i 7.5 |; 4.C
i ! i:
; ' .1

12.4 ;12.4 11 -11 ; 5.8

• J
15.2 15.2 13.4 H3.4 i 7.0


^5.1 45.1 J39.3 ;39.3 ,,21.0
. J 	 .; .... ' 	 ._...

i 2

i .3

i

i


.3



1.1


1.4


4.1


: 3

.3



.6


.8



1.2


1.5


4.4


4

: • 3



. 6


.8



1.2


1.5


4.4


5 ; 2

.3 :; 3



.5 5.6


.8 8.3



1.1 12


1.4 14.6

' 	 ~~
4.1 43.5


3.

3



5.6


8.3



12


14.6

._ - -
43.5


4

3.4



6.3


9.3



13.4
,

16.4


48.8


5 i

3.4



6.3

i
9.3



13.4

1
16.4


48.8

|
2
i
! ">•?


	
2.2
|
i
3.?



4.7


5.6


16.9


3

1 .. 2



2.1


3.2

	

4.5

	
5.5


16.6


4

1.2



2.1


3.2



4.6


5.5


16.6


5

1 .2



2.2


3.2



4.7

	 1
5.6


16.9


-------
                            Table 7-7  (cont.).  ENVIRONMENTAL IMPACT OF NO STANDARD
                              B.  IMPACT DUE TO REPLACEMENT OF EXISTING CAPACITY
CUMULATIVE EMISSION REDUCTION
(106 Ibs/year)
•
.
YEAR
1976
1977
1978
1979
1980
P ARTICULATE
ALTERNATIVE SYSTEM NUMBER
I
2
2.3
!
I 4.6
I
6.9
9.2
11.5
3
2.2
4.4
6.6
8.8
11.0
4
2.2
4.4
6.6
8.8
11.0
5
2.3
4.6
6.9
9.2
11.5
TRS
ALTERNATIVE SYSTEM NUMBER
2 3
I
4.3 f 4.3
8.6
12.9
17.2
21.5
8.6
12.9
17.2
21.5
4
4.7
9.4
14.1
18.8
23.5
5
4.7
9.4
14.1
18.8
23.5
I
ro

-------
                          References

1.  "Modeling Analysis of the Ambient Air Impact of Kraft  Pulp
    Mills," Walden Research Division  of Abcor,  Inc., prepared
    for the Source Receptor Analysis  Branch of  MDAD, OAQPS,  OAWM,
    EPA, October 1975.

2.  Memo from Phillip L.  Youngblood,  Transport  Simulation  Section,
    MDAD to Jack R. Farmer, Chief of  Standards  Development Branch,
    ESED, September 26, 1975.

3.  Thomas, D.L., "High Grade for Paper," Barron's, December 11,
    1972, p. 3.

4.  Environmental Protection Agency,  National  Primary and
    Secondary Ambient Air Quality Standards, Federal Register
    (36 FR 8186), April 30, 1971.

5.  Leonardof, G. et.al., "Odor Threshold Determinations of
    53 Odorant Chemicals," Journal  of the Air  Pollution Control
    Association, 19(2), February 1969, p. 91.

6.  Wilby, F.V., "Variation in Recognition Odor Threshold  of a
    Panal," Journal of the Air Pollution Control Association,
    19(2), February 1969, p. 96.

7.  Environmental Protection Agency,  Effluent Guidelines and
    Standards:  Pulp, Paper, and Paperboard Point Source Category,
    Federal Register (41  FR 7662),  February 19, 1976.

8.  Roberson, James E., "Energy and Air Emissions in the Pulp and
    Paper Industry," J.E. Sirrine Company (not  published).
                              7-25

-------

-------
                    8.  ECONOMIC IMPACT
     Chapter 8 contains 4 sections.   The industry is characterized
in section one.  Several industry aspects are discussed  there.
These include geographic distribution,  integration and concentration,
international influence, demand determinants, supply determinants,
and projected industry growth.
     In the second section,  control  costs and cost effectiveness  for
alternative TRS and particulate control systems  are developed and
described.  Included are costs  for 7 of the designated facilities,
4 mill sizes, and 2 recovery furnace configurations.  Both  new  and
existing mill situations are examined..
     Section three briefly describes other cost  considerations  and
their impact on the economic analysis of TRS and particulate control.
     In the final section of Chapter 8, the economic impact of  alterna-
tive TRS and particulate controls is analyzed.    Included  is an
assessment, of absolute and relative  control cost magnitudes, price
demand elasticity, and simulated return on investment impacts.
Analyses are conducted for new, modified, and reconstructed sources.
     The major finding of Chapter Sis the economic impact  of each
considered alternative is small.  In other words,  New Source Performance
Standards (NSPS) should not  preclude construction  of new, modified, and
reconstructed designated facilities.  Small control costs,  inelastic
price demand elasticity, and small simulited return on investment
impacts support the major finding of Chapter 8.
                                8-1

-------
8.1   INDUSTRY CHARACTERIZATION
8.1.1  Geographic Distribution
     As of December 1975, there were 56 firms operating about 120
kraft pulping mills in 28 states.  Most U.S. kraft pulping mills
and mill capacity is found in the South.  Alabama, Georgia, and
Louisiana are the leaders.  Alabama has 13 mills and 10 percent
of U.S. mill capacity.  Georgia has 11 mills and 13 percent of U.S.
mill capacity.  And Louisiana'has 11 mills and 11 percent of U.S.
capacity.  Over the past 20 years, growth in the kraft pulping
industry has occurred mainly in the South.   However,  recent 1974,
current 1975, and planned(1976 and later) modifications to existing
mills as well as plans for new mills are found in all  sections of
            p
the country.
8.1.2  Integration and Concentration
     Only about 1/3 of the 56 firms are producers of pulp, paper,
and/or paperboard exclusively.  The others are engaged in a wide
variety of activities.  The activities include chemical  manufacture,
detergent production, magazine publishing, land development,  and can
production.  The degree of dependency on kraft pulping and related
activities varies among these horizontally integrated  firms.   Whereas
International Paper Company derived 55.6 percent of their 1974
sales from pulp, paper, and paperboard production; Ethyl  Corporation
derived 11 percent of 1974 sales from pulp and paper operations.
     Besides being horizontally integrated,  the U.S. kraft pulping
industry is highly concentrated.  The 6 largest firms  in  terms of mill
capacity account for 40 percent: of U.S.  kraft pulp capacity.   The
10 largest account for 56 percent of U.S.  kraft pulp capacity.
                                 8-2

-------
     Vertical integration is another characteristic of the U.S.  kraft
pulping industry.  Only 41  U.S.  kraft pulping mills are listed in  the
directory of world market pulp producers.   The most prevalent kraft
grade listed is bleached hardwood followed closely by bleached soft-
wood.  Moreover, appearance in the directory does not mean the mills'
pulp cannot be used captively.  When available, pulp for market is
produced at the designated mills.  Really, nearly all kraft pulp
(about 90 percent) produced in the U.S.  is not marketed; but is used
captively.   In fact, 109 kraft pulping  mills also have facilities at
the same location for producing paper and  paperboard.  However,  these
mills cannot always satisfy the kraft pulping requirements of the
paper and paperboard facilities.   Often  times, intracompany transfers
from other U.S. and Canadian mills are required to fill  the kraft
pulping voids.
8.1.3  International Influence
     The U.S. kraft pulping industry is  not devoid of foreign influence.
Pulp, paper, and paperboard production in  other countries, especially
Canada, has a pronounced influence on U.S. kraft pulping firms and
trade balances.  Although the U.S. is the  world's largest producer of
kraft pulp and the fourth leading exporter (behind Canada, Sweden,
and Finland), the U.S.  has been a net importer of kraft pulp.   Over
90 percent of the kraft pulp imported to the U.S. comes from Canada.
This is not surprising  in view of the earlier statement about intra-
company transfers and the fact that a third of the U.S.  kraft pulp
producers have kraft pulping facilities  in Canada.
     The aforementioned industry characterization statements were
derived primarily from  Appendix  [; and Tables  8-1  and  8-2.   Appendix E displays
                                 8-3

-------
     Table 8-1.  SUMMARY INDUSTRY STATISTICS:  FIRMS-MILL NUMBER AND CAPACITY
                                     DISTRIBUTION
    Firm
Allied Paper, Inc.
 (sub. of SCM)
Alton Box Board Co.
American Can Co.
Appleton Papers, Inc.
 (Div. of NCR)
Boise Cascade Corp.
Bowater, Inc.
Brown Co.
Champion International
Chesapeake Corp. of Va.
Consolidated Papers, Inc.
Container Corp. of Amer.
 (sub. of Marcor)
Continental Can Co.
Crown Zellerbach
Diamond Int'l Corp.
Federal Paper Board
 Co., Inc.
Fibreboard Corp.
Georgia-Pacific Corp.
Oilman Paper Co.
P.  H. Glatfelter Co.
Great Northern Nekoosa
 Corp.
Green Bay Packaging, Inc.
Gulf States Paper Corp.
Hanrnermill Paper Co.
Hoerner Waldorf Corp.
Hudson Paper Co.
ITT Rayonier, Inc.
Inland Container Corp.
# U.S. Mills
1
1
2
1
5
2
1
3
1
1
2
4
5.5
1
]
1
4
1
1
3
1
2
2
2
1
1
1.5
% U.S. Total
1
1
2
1
4
2
1
3
1
1
2
3
5
1
1
1
3
1
1
3
1
2
2
2
1
1
1
Capacity
U.S. Mills
490
650
1,240
180
3,790
1,500
700
2,680
1,150
395
2,250
3,700
4,216
425
1,200
450
5,520
1,100
500
2,510
650
875
856
2,150
950
1,250
1,213
% of U.S.
Total
<1
<1
1
negligible
4
1
<1
3
1
negligible
2
4
4
negligible
1
negligible
5
1
negligible
2
<1
<1
<1
2
<1
1
1
                                      8-4

-------
     Table 8-1 (Continued).  SUMMARY INDUSTRY STATISTICS:  FIRMS-MILL NUMBER AND
                                         CAPACITY DISTRIBUTION
         Firm
      International Paper Co.
      Interstate Container Corp.
      Kimberly-Clark Corp.
      Lincoln Pulp & Paper Co.
       (Div. of Premoid)
      Longview Fibre Co.
      Louisiana Pacific Corp.
      MacMillan Bloedel Ltd.
      Mead Corp.
      Mosinee Paper Corp.
      01 in Kraft, Inc.
      Owens-Illinois, Inc.
      Oxford Paper
       (Div. Ethyl Corp,)
      Packaging Corp. of
       Amer. (A Tenneco Co.)
      Penntech Papers, Inc.
      Pineville Kraft Corp.
      Potlatch Corp.
      Procter & Gamble Co.
      St. Joe Paper Co.
      St. Regis Paper Co.
      Scott Paper Co.
      Simpson Lee Paper Co.
      Southland Paper Mills,  Inc.
      Southwest Forest Industries
      South Carolina Industries
       (79% owned by Stone Con-
       tainer Corp.)
      Tempie-Eastex, Inc.
       (sub. of Time, Inc.)
      Union Camp Corp.
      Western Kraft
      Westvaco Corp.
      Weyerhauser Co.
Totals      56
1 U.S. Mills
14
1
1
1
1
1
1
4
1
1
2
1
1
1
1
2
1
1
4
3.5
1.5
2
1
1
% U.S. Total
12
1
1
1
1
1
1
3
1
1
2
1
1
1
1
2
1
1
3
3
1
2
1
1
Capacity % of U.S.
U.S. Mills Total
15,985 14
550 <1
585 <1
320 <1
1,900 1
700 <1
925 <1
3,128 4
175 <1
1,150 1
1,775 2
585 <1
775 <1
180 negligible
880 <1
1,350 1
900 <1
1,300 1
5,381 5
2,700 3
760 <1
900 <1
600 <1
675 <1
                          1,300
3
3
4
7
3
3
3
6
4,980
1,370
4,254
6,195
5
1
5
6
119
                                                              105,567
                                             8-5

-------
       Table 8-2..  SUMMARY INDUSTRY STATISTICS:   STATES-MILL NUMBER AND CAPACITY
                                      DISTRIBUTION

State
Alabama
Arizona
Arkansas
California
Florida
Georgia
Idaho
Kentucky
Louisiana
Maine
Maryl and
Michigan
Minnesota
Mississippi
Montana
New Hampshire
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Number of
Mills
13
1
6
4
8
11
1
2
11
6
1
2
2
4
1
1
1
5
1
1
7
3
4
2
6
4
7
4
% of U.S.
Total
11
1
5
3
7
9
1
2
9
5
1
2
2
3
1
1
1
4
1
1
6
3
3
2
5
3
6
3
State Mill
Capacity
10,280
600
5,430
1,910
9,260
13,505
950
920
11,655
3,950
665
825
865
4,707
1,200
700
590
5,650
540
1,600
5,906
860
5,494
1,275
4,570
4,550
5,854
1,256
% of U.S.
Total
10
1
5
2
9
13
1
1
11
4
1
1
1
4
1
1
1
5
1
2
6
1
5
1
4
4
6
1
Totals
28
119
105,567
                                           8-6

-------
kraft mill characteristics.  Table 8-1  exhibits mill  number and
capacity distribution by firm.   Table 8-2 exhibits mill  number and
capacity distribution by state.
8.1.4  Demand Determinants
     Following traditional microeconomic theory, tastes,  other
demands, income, and prices are the determinants of kraft pulp demand.
8.1.4.1  Tastes
     Tastes are an important; albeit for forecast purposes, an elusive
demand determinant.  The main taste factor influencing  the demand  for
kraft pulp is strength.   The strength of kraft pulp is  superior to that
of other pulps (ex. other wood  and nonwood pulps).   Data  are available
which is consistent with, but by no means proves the role of superior
strength in kraft pulp demand determination.   Figure 8.1  reveals that
kraft pulp consumption is increasing relative to that of  other wood pulps.
     Taste can also influence the particular  grade of kraft which  is
desired.  Kraft pulp comes in unbleached, semi-bleached,  bleached,
alpha, and dissolving grades.  We don't know  the exact  role of tastes
in selecting a particular grade.  However, bleached and unbleached kraft
pulps, as revealed in Figure 8.2, are the dominant grades.  They account
for over 90 percent of total kraft pulp consumption.
8.1.4.2  Other Demands
     Other demands include those expressed desires and  abilities
to purchase kraft pulp complements (ex. bleached kraft  pulp and
paper) and substitutes (ex. bagasse and plastic).
                               3-7

-------
o
CL
e
§   50,0001
o
Q-

O


o   40,000
C\J
o

to

o
o
o
    30,OOCH
20,000-:
     10,0001
          oL
             Total Wood  Pulp  Consumption;


             Compounded  Average  Growth  ;

             rate is  5.08%/yr          J,
                                    .y--^'^-'"'"  V"     [total Kraft Pulp Consumption  Excluding

                               _^--' ,,.    '         \Dissolving Pulp


                        >-"""'''_..                        (Compounded Average  Growth  Rate  is  6.56%/yr
                        -f"""

                         vBleached and Unbleached Kraft Pulp Consumption


                         [Compounded Average Growth Rate is 6.77%/yr
                      1962
                              1964
1966
1968
1970
1972
              Figure  8-1.  Wood, Total Kraft, and Bleached and Unbleached  Kraft  Pulp  Consumption


               Source:   API, Statistics of Paper and Paperboard  1973,  p.  43
                                               8-8

-------
  3'. ,000
  30,000
  25?000
                                                  :Total  Kraft  Consumption
                                                  ^Excluding  Dissolving  Pulp
c
o
  20,000
3
O
O
O
o
CM
O

CO

O
O
o
  15,000
                               ^—

                                 -•*;•":  Unbleached  Kraft
  10,000-
Q.

3
1/1
C
O
   5,000
                                                 Bleached  Kraft
                                     iSemi-bleache-d  Kraft
                                        o	c
                                               		c">	/•

                                               [Total Alpha
                                              /[and  Dissolving
                    1962
1964
  j—

1966
1968
1970
—i --

 1972
        Fiqure 8-2. Consumption of Various  Kraft  Pulp  Grades

         The dissolving Pulp figures, although  small,  are  not distinguished as coining from
         Kraft or Sulfite mills.


         Data Sources:  API, Statistics of  Paper  and Paperboard  p.43,  1973
                        Chemical Economics  Handbook, Woodpulp Consumption p.2261180B
                                               8-9

-------
     Kraft pulp is an intermediate good; not a final  consumption
product, but one used in the production of other goods.   Kraft
pulp is usei.! in the production of paper and paperboard.   These are
kraft pulp complements.  An increase in the demand for paper and
paperboard, ceteris paribus (other things remaining the  same),
implies an increase in the demand for kraft pulp.   Figures 8.3 and
Table 8-3 support the above remarks.  Figure 8.3 depicts graphically
the movements of kraft pulp consumption, wood pulp consumption, and
paper and paperboard production with alternative observed levels of
real income,  Historical production figures for various  pulp, paper,
and paperboard grades are given in Table 8-3.
     The demands for kraft pulp substitutes also affect  the demand
for kraft pulp.  With changes in tastes and/or prices of substitute
goods come changes in demand for the kraft pulp substitutes and
subsequently changes in the demand for kraft pulp.  With significantly
higher prices for- plastic containers, ceteris paribus, consumers
would tend +n substitute paperboard containers for plastic ones,
which in turn would increase the demand for kraft pulp.   Although
true in a neoretical context, no empirical data are  available to
siDstcn  icome
     In:r"!]p along with prices affects purchasing power.   Through
the purxhavirvj power influence, income is a demand determinant
for kraft pulp.  The exact manner in which income plays  its demand
determining role is not known.  When the level of income in the
aggregate increases, it may mean more people have the same amount
                                8-10

-------
    65,000
    55,000
o
o
<: co
O E
CQ O

-------
                                     Table 8-3.   PULP,  PAPER,  AND PAPERBOARD PRODUCTION

                                                            (in short tons)

Pulp (in tons)
Unbleached kraft
Bleached kraft
Semi -bleached kraft
Paper
Printing, writing & related
Packaging & industrial converting
Tissue & other machine-creped
Paperboard
Solid woodpulp furnish
(ex. corrugating medium,
mill carton)
Combination furnish
(ex. linerboard)
Wet machine board
Construction paper and board
1965

12,698,000
7,280,000
1,531,000

11,321,518
4,978,556
2,886,968

12,743,997


8,089,588

143,872
3,915,381
1970

16,217,000
11,348,000
1,906,000

14,368,527
5.446,050
3,594,500

18,496,113


6,968,950

139,055
4,316,198
1971

16,309,000
11,685,000
1,557,000

14,504,607
5,457,576
3,875,657

19,157,527


6,962,971

137,825
5,351,863
1972

17,792,000
12,460,000
1,574,000

15,705,240
5,705,891
4,024,207

21,126,635


7,395,326

147,914
5,351,863
1973

18,164,000
12,848,000
1,826,000

16,828,249
5,723,102
3,984,598

21,527,339


7,932,196

149,035
5,539,319
1974

16,982,000
13,938,000
1,422,000

16,826,820
5,935,700
3,908,907

21,411,119


7,310,660

134,928
5,092,944
co
i
   Data Source:   American Paper Institute.

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of income; some: people have more income; or more people have more
income.
     Real personal disposable income is positively correlated with
kraft pulp consumption, wood pulp consumption,  and paper and paper-
board consumption.  However, the slope of the implicit functional
relationship is not as great for kraft pulp.  This observation is
displayed in Figure 8.3.  The smaller implied response of kraft pulp
consumption to disposable income changes (e.g.  smaller slope)  could
mean the prices of kraft pulp and other goods have a  more active role
in kraft pulp demand determinations.
8.1.4.4  Prices
     The role of prices as demand determinants  can be described in
terms of elasticity.  Price elasticity of demand is a measure of the
responsiveness of quantity demanded to price changes, ceteris paribus.
It can be expressed as the percentage change in quantity demanded
divided by percentage change in price.  The direct price elasticity
is probably less than 1.0 for kraft pulp.  The  limited uses  of kraft
pulp; the availability of only a few close substitutes;  and  the small
portion of final demand product or service value accounted for by the
price of kraft pulp support the belief of relatively  inelastic demand.
In addition, one expert has indicated the coefficient of direct price
elasticity is about 0.5 for domestic wood pulp.   Small  increases in
the price of kraft pulp, everything else remaining the same  will  not
decrease the total revenue from kraft pulp sales.   Though no quantitative
indirect (cross price) elasticity estimates are available, the prices
of kraft pulp substitutes (recycled paper, non-wood pulps, and often
                                8-13

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times other wood oulos)  and complements (bleaching chemicals, paper,
paperboard), do not appear to measurably affect the quantity of kraft
pulp demanded.
8.1.5  Supply Determinants
     The determinants of kraft pulp supply are the production,  expen-
diture, and revenue functions of kraft pulp suppliers.
8.1.5.1  Production
     The kraft pulping production function has several  advantages.
The process can be used with resinouswoods, hardwoods,  softwoods,
and bark free mill residue.  Hence, the wood inputs are readily
available.  For a chemical pulping process, kraft has a high yield
per ton of pulp wood input.  In addition,  the process yields the side
products of tall oil and turpentine from resinous woods inputs.  However,
kraft pulp is more difficult to bleach than other pulps (i.e.,  sulfite).
Also, the air pollution problems are more serious.
8.1.5.2  Expenditures
     Wood, chemicals, labor, energy, and capital are expenditures of
kraft pulping.
    "Mood - Besides increased demands for all pulp producers, pulpwood
faces increased demands from the recreation area, building construction,
and home furniture sectors.  With the higher pulpwood prices, kraft
pulp producers have been encouraged to use more bark free mill  residue
as well as tree tops and limbs,
                               8-14

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     0 Chemicals - Sodium carbonate, sodium sulfate,  sodium sulfide,
sodium hydroxide, and calcium oxide are chemicals used in the fcraft
pulping process.  With improved sulfur recovery techniques for pollution
control, consumption of sodium sulfate has been declining.  The other
chemicals are generally currently in short supply.   But,  new chemical
plants coming on stream in the next two years should relieve much  of
the supply problem.
     ° Labor - Labor expenses have moved with improved productivity in
the pulp, paper, and board industry.  Productivity and wage data is
not available for kraft pulping alone.
     ° Energy - Higher fuels and electricity cost have induced energy
conservation and trends toward self sufficiency.   Expenditures in
energy conservation and self sufficiency projects and subsequent
energy savings have recently been evidenced.
     ° Capital - Capital  spending for the pulp and paper  industry
has increased rapidly over the last decade.  To finance these expen-
ditures, debt financing has been used extensively.   For the pulp,  paper,
and board industry long term debt as a percent of the total capital
structure has increased from about 21 percent to 32 percent.   Non-
capacity increasing capital expenditures have increased in recent
years.  These include control of certain air and water effluents
along with investments in non-paper industries.  Interest rates are
currently high and projected to remain so.  Profits have  historically
been quite volatile.  With debt financing already extensively utilized,
capacity growth displaced by other capital expenditures,  interest  rates
high, profits historically volatile; less costly means of finance,  less
                               8-15

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capital spending, and less capital demanding ways to expand capacity
will be induced.
8.1.5.3  Revenue Function
     The revenues of kraft pulp producers have been historically unstable.
When the industry expanded, it expanded markedly.  With supply increases,
prices declined and with inelastic demand so did profits.  In the
ensuing years, non-price related demand increases (i.e., income
increase) occurred leading to higher prices, higher profits, and the
inducement for another round of supply expansion.  Recently though,
prices of pulp have remained high and even increased.   (See Table 8-4.)
Large additional supply increases are not yet in the construction
stages.  Perhaps rising factor costs have erased or reduced what would
have been extremely high profits at these higher prices.  And/or
maybe the displacement of capacity expanding investment by other
capital expenditures can explain the apparent change in the historically
unstable revenue function.
8.1.6  Projected Industry Growth
8.1.6.1  Net Capacity Additions
     According to the American Paper Institute (API),  the U.S. kraft
pulping capacity grew at about 5.5%/yr. from 1956 to 1975.  The same
source indicates growth will  decrease to 2.5%/yr. in the 1976 to 1978
period.  However, large capacity additions are currently under
consideration for 1979 and 1980.  If constructed, the  industry will
return to a higher growth rate (about 3.4%/yr.).
                                  8-16

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                         Table 8-4.   PRICES OF KRAFT PULP
               (U.S.  Delivered; Dollars per Ton of Air Dried Pulp)
Year
1972
1972
1973
1973
1973
1973
1974
1974
1974
1974
1975
1975
1975
1975
and Quarter
2nd
4th
1st
2nd
3rd
4th
1st
2nd
3rd
4th
1st
2nd
3rd
4th
Kraft Pulp Forms
Unbleached
130-145
130-145
145-147
N.A.
167-170
193
N.A.
N.A.
315-318*
345-360*
345-360*
345-360*
345-360*
345-360*
Semi bleached
163-164
163-164
158-165*
158-165*
172-180
200
200
N.A.
315-318
337-362
337-362
337-362
337-362
337-362
Bleached Softwood
169-172
169-172
157-169
175-185*
175-202
203-210
203
265
325
340-372
340-369
340-372
340-372
340-372
Bleached Hardwood
146-155
146-155
155
157-170*
157-168-193
189-193
193
255
320
320-335
320-335
320-335
320-335
320-335
*U.S.  and Canadian Prices.
Data Source:  Paper Trade Journal, Vance Publishing Co.,  N.Y.C.  and Official
              Board Markets, Magazine for Industry, Inc., Chicago.
                                        8-17

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     The distribution of projected capacity growth between new and
existing plants is unknown.  But, the equivalent of thirty-three
500 tpd mills will be needed to meet projected growth and
capacity considerations through 1980.
8.1.6.2  Designated Facility Replacement Rate
     In addition, industry will have to replace worn-out designated
facilities to maintain the existing capital stock.  However, whether
or not these designated facilities will be replaced in kind or with
larger facilities (to meet growth requirements) is not known.  Moreover,
because of variations in capacity utilization and maintenance, the
timing of designated facility replacement is also an unknown.
     But, given three assumptions, replacement rates can be projected.
First, the estimated average designated facility lives are 25 years for
recovery furnaces and smelt dissolving tanks, 22 for digesters and multiple
effect evaporators, 35 for lime kilns, 15 for brown stock washers, and  10
years for black liquor oxidation units.  Second, the designated facility
age is distributed evenly.  For example, 1/25 of the recovery furnaces
are 25 years old; 1/25 are 24 years old, etc.  And third, each of the 119
mills has one set of each designated facility.  Then, projected annual
replacements would be five sets of digesters, multiple effect evaporators,
recovery furnaces, and smelt dissolving tanks,  (e.g. 1/25 x 119 = 5;
1/22 x 119 = 5).  In addition, there would be 4 sets of lime kilns, 8 brown
stock washer systems, and about 11 black liquor oxidation systems
replaced annually.
                                   8-18

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8.2  CONTROL COSTS AND COST EFFECTIVENESS
8.2.1  New Sources
8.2.1.1  Introduction
     The purpose of this section is to develop estimates of capital
and annualized costs for alternative control systems exemplary of best
controls taking into account cost.  The cost to achieve various levels
of control will be presented for each of the affected facilities for
three sizes of kraft mills:  500, 1000, and 1500 tons per day of air
dried pulp.  Following the presentation of control costs for the individual
affected facilities is a section showing the aggregate incremental con-
trol costs over requirements for typical state standards.   Aggregate in-
cremental control costs will be presented for the four alternative
control systems discussed in Chapter 4 for the three sizes of kraft mill
models.  The cost effectiveness of the alternative control systems will
then be discussed.
     Throughout this section the terms capital cost and arinualized cost
are used; therefore, a brief definition is in order.  The capital  cost
includes all the cost items necessary to design, purchase and install the
particular device or system.  The capital cost includes the purchased
cost of the major control device (ESP or scrubber) and auxiliaries such
as pumps, fans, and instrumentation; the equipment installation cost in-
cluding foundations, piping, electrical wiring, and erection; and the
cost of engineering, construction overhead, and contingencies.  In
general offsite costs such as utility facilities are not included.  Ex-
ceptions or other special factors are pointed out in the discussion of
each affected facility.  The sources of cost data are given for each control
device or system.  All costs are in terms of (4th quarter) 1975 dollars.
                                 8-19

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     The annualized cost of a control system is a measure of what it
costs the company to own and operate that system.  The annualized cost
includes direct operating costs such as labor, utilities, and maintenance;
and capital related charges such as depreciation, interest, administrative
overhead, property taxes, and insurance.  The actual costs experienced
by different mills can vary considerably.  The following values were chosen
as typical  and should provide a reasonable estimate of the annualized cost
of the control systems.
     Operating labor is charged at a rate of $8 per hour.  Utility rates
are:
     Electricity - 2<£ per Kwh
     Fuel - $1.50 per million BTU
     Cooling water - $0.05 per thousand gallons
     Process water - $0.25 per thousand gallons
Unless otherwise known from specific operating experience annual main-
tenance labor and materials are estimated as a percentage of the capital
cost.  The percentage used is in the range of 2 to 5 percent depending on
the severity of the service.
     The method used to account for depreciation and interest is through
the use of a capital recovery factor.  The capital cost of the project
is multiplied by the capital recovery factor to give the amount of equal
annual payments that would pay for the project, plus interest over the
life of the equipment.  The numerical value of the capital recovery fac-
tor depends on the life of the equipment and the interest rate.  Unless
otherwise noted, the numerical value of the capital recovery factor used
                              8-20

-------
in this section is based on 15 year life and 10 percent interest.  Other
capital related charges are administrative overhead at 2 percent of
capital and property tax and insurance at 2 percent of capital.  The
final item considered is any credit due to value of recovered material.
Any credit for recovered material is an offset against the annualized
cost of the control device.  The basis for valuation of credits is given
in the discussion of the applicable affected facility.
8.2.1.2  Unit Cost for the Affected Faci11 ties
     The proposed standards of performance cover particulate and total
reduced sulfur (TRS) emissions.  The cost for controlling the affected
facilities which emit particulates are discussed first followed by a dis-
cussion of the affected facilities which emit TRS.  Three of the affected
facilities which emit both particulates and TRS are discussed in each
section.
     A.  Unit Costs for Particulate Sources
         a)  Direct Contact Recovery Furnace - The direct contact recovery
     furnace system employs a direct contact evaporator using the hot
     flue gas from the furnace to evaporate water from the black liquor
     feed to the furnace.  The direct contact evaporator removes some
     of the particulates from the flue gas.  Thus the control device
     following the direct contact evaporator can be smaller and less
     expensive than the control device on an indirect contact furnace.
          Capital costs, annualized costs, and credits for recovered
     particulate are shown in Table 8-5 for electrostatic precipitators
     (ESP) for two different levels of control and for a venturi
     scrubber.  The costs for the first ESP case are based on a study
                                8-21

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                            Table 8-5.  CONTROL COSTS FOR DIRECT CONTACT RECOVERY FURNACES
      Mm Size. TPD
      Capital Cost ($)
      Gross Annualized Cost3 ($/Yr)
      Credits5 ($/Yr)
                                       500
                     1000
1500
                                          High Efficiency Precipitator (99.5%)
                                       1,440,000            2,560,000          3,660,000
                                         364,000              633,000            895,000
                                        (892,000)          (1,784,000)        (2,680,000)
oo
ro
ro
Capital  Cost ($)
Gross Annualized  Cost9 ($/Yr)
Creditsb ($/Yr)
   Medium Efficiency Frecipitator (99.0%)
1,250,000            2,100,000          2,725,000
  316,000              519,000            666,000
 (890,000)          (1,780,000)        (2,668,000)
      Capital Cost ($)
      Gross Annualized Cost3, ($/Yr)
      Credits ($/Yr)
                                                    Venturi  Scrubber (92%)
                                         650,000            1,100,000          1,625,000
                                         420,000              830,000          1,215,000
                                        (824,000)           (1,650,000)         (2,480,000)
       Gross annualized costs do not include credits.
      Credits based on Na^SO, at $50 per ton and 7884 hours operation per year.  These credits do not
       include the recovered Material collected by the direct contact evaporator.

-------
done for EPA by the Industrial  Gas Cleaning Institute (IGCI).7
The cost for the second ESP case is an EPA estimate based on the
                                                                  P
IGCI study, and the venturi costs are based on the Sirrine report.
The credits for recovered particulate are calculated assuming that
all the particulate is salt cake valued at $50 per ton.   Although
some of the particulate is Na^CO.,, it is close in price to salt cake;
thus, the assumption that the particulate is all  salt cake should
not result in a significant difference.
     For each of the control devices in Table 8-5, the credits exceed
the costs.  Since the particulate is a valuable material (mainly
salt cake), it is economical to recover the particulate emissions
up to some recovery level.  Beyond that level the value of the ad-
ditional particulate recovered is not enough to justify the additional
investment; that is, the incremental return on the incremental in-
vestment drops below the acceptable level for the individual com-
pany.  The optimal economic recovery level is very difficult to
define, even in this analysis with the two basic design differences
in the recovery furnaces.
     Furthermore, this analysis focuses on the incremental costs
between two levels of control, and thus the optimal recovery level
is no longer relevant.  What is important is the incremental (net)
cost between the high efficiency precipitator and the baseline
medium efficiency precipitator required for typical state standards.
The incremental control costs for the high efficiency precipiator
are presented in Table 8-6.  The annualized cost per ton of product
is based on production at 90 percent of capacity.
                          8-23

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CO
           Table 8-6.  INCREMENTAL CONTROL COSTS3 FOR DIRECT CONTACT RECOVERY FURNACES OVER STATE
                                                REGULATORY REQUIREMENTS

         Mm Size. TPD                         500                    1000                    1500
                                                      High Efficiency Predpltator (99.5%)
          Capital Cost  ($)                     190,000                 460,000                 935,000
          Annualized Costb ($/Yr)               46,000                 110,000                 217,000
          Annualized Cost per Tonc ($/T)         0.280                   0.335                   0.440
          The difference between the high efficiency precipitator and the typical state regulatory require-
          ment (Equivalent to 99.01 efficiency).
          The credits have been accounted for in calculating the incremental annualized costs.
         cBased on 7884 hours of operation per year.

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     b)  Indirect Contact Recovery Furnace - In contrast to the
previously discussed recovery furnace, the indirect contact recovery
furnace does not have a direct contact evaporator.   This results
in higher inlet concentrations to the control device.   In addition
the physical properties of the particulate are somewhat different
from the direct contact furnace case.  These factors cause the ESP
to be larger and more expensive in order to achieve the same exit
particulate concentration.  Because of the higher particulate inlet
concentrations, the credits for recovered particulate  appear to be
greater for the indirect contact furnace.  The fact is that the combi-
nation of the direct contact evaporator plus the precipitator collect
as much salt cake for the direct contact furnace as the comparable
precipitator does for the indirect contact recovery furnace.
     The same references were used as the sources of the control
costs for this furnace design as for the direct contact recovery
furnace.  Table 8-7 shows the capital, annualized costs, and
credits for two levels of precipitation and one level  of venturi
scrubber.  Table 8-8 shows the incremental costs for the high efficiency
precipitator over the medium efficiency precipitator,  the latter
being the baseline for state regulatory requirements.
     c)  Smelt Dissolving Tank - Two control alternatives are pre-
sented for the smelt dissolving tank.  The first is a  mesh pad de-
mister.  The demister is a very simple and inexpensive device which
has been used extensively in the industry.  The second alternative
is a packed bed scrubber which gives a higher control  efficiency
than the demister.  The costs shown on Table 8-9  for  the demister

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                     Table 8-7.  CONTROL COSTS FOR INDIRECT CONTACT RECOVERY FURNACES
CO
CTl
Mill Size, TPD
Capital Cost ($)
Gross Annuali zed Costa ($/Yr)
Credits5 ($/Yr)
500
High
2,310,000
511,000
(1,754,000)
1000
Efficiency Precipitator
4,000,000
879,000
(3,508,000)
1500
(99.8%)
5,500,000
1,210,000
(5,262,000)
Medium Efficiency Precipitator (99.6%)
Capital Cost ($)
Gross Annual ized Cost3 ($/Yr)
Credits'3 ($/Yr)
Capital Cost ($)
Gross Annualized Cost3 ($/Yr)
Credits5 ($/Yr)
2,000,000
442,000
(1,752,000)
650,000
420,000
(1,616,000)
3,380,000
743,000
(3,504,000)
Venturi Scrubber (92%)
1,100,000
830,000
(3,232,000)
4,675,000
1,030,000
(5,236,000)
1,625,000
1,215,000
(4,848,000)
     Gross annualized costs do not include credits.

     'Credits based on Na2SO, at $50/ton and 7884 hours of operation per year.   In  comparison  with  the
     direct contact furnace, the direct contact evaporator itself would recover approximately fifty
     percent of the total generated emissions, or 50 percent of these  credits.

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              Table 8-8.  INCREMENTAL CONTROL COSTS3 FOR INDIRECT CONTACT RECOVERY FURNACES
                                        OVER STATE REGULATORY REQUIREMENTS
       Mill Size. TPD                       500                    1000                    1500
                                                  High Efficiency Precipitator (99.8%)
       Capital Costs ($)                  310,000                 620,000                 825,000

       Annualized Cost5 ($/Yr)             67,000                 132,000                 154,000

       Annualized Cost per Tonc ($/T)       0.408                   0.402                   0.304

^      The difference between the high efficiency precipitator and the typical state regulatory
^      requirement (equivalent to 99.6% efficiency).
        The credits have been accounted for in calculating the incremental annualized costs.
       °Based on 7884 hours of operation per year.

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                        Table 8-9.    CONTROL COSTS FOR SMELT TANK CONTROL SYSTEMS
oo
i
1X3
CO
Mill Size, TPD

Capital Cost ($)
Gross Annualized Cost3 ($/Yr)
Creditsb ($/Yr)

Capital Cost {$)
Gross Annualized Cost3 ($/Yr)
Credits5 ($/Yr)
500

23,750
5,000
(35,000)

87,500
24,800
(42,000)
1000
Demister System (80%)
28,750
5,900
(70,000)
Scrubber System (96%)
138,000
41 ,600
(84,000)
1500

35,000
7,030
(105,000)

175,000
55,900
(128,000)

         Gross  annualized  costs do not include credits.

        5Credits  based on  Na^SO,  at $50/ton and 7884 hours of operation per year.

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                                g
are based on the Sirrine report.   The cost for the demister includes
the mesh pads and a water spray system.  Since the pressure drop is
low (less than 0.2 inches of water), no fan has been included in
the cost estimate.  The credit for recovered particulate is based
on 80 percent recovery of the uncontrolled emissions.  The value of
the recovered particulate is calculated on the basis of recovered
sodium where the sodium would be made up using salt cake at $50
per ton.
     The scrubber system is a packed tower with associated fan,
liquid recirculation pump, and controls.  Cost data for this type of
control system were collected from several operating companies in
addition to the information in the Sirrine report.    The costs for
the scrubber system are shown in Table 8-9.   Credits for recovered
particulate are calculated in the same manner as for the demister
case except that the recovery efficiency is 96 percent.
     The incremental control costs for best controls (the 96 percent
efficiency scrubber) over typical state regulatory requirements
(achievable by the demister) are shown in Table 8-10.  These costs
are the residuals after deducting for credits.
     d)  Lime KjIn - Costs for the two basic types of collection
devices are examined for control of particulate emissions from the
rotary lime kiln, namely venturi scrubbers and electrostatic
precipitators.  The analysis for these controls is somewhat compli-
cated by the interrelationship of controlling TRS emissions (dis-
cussed in the next section).around the lime kiln facility.  For
example, the use of a precipitator would dictate (for safety reasons)
                            8-29

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c»
GO
o
             Table 8-10.   INCREMENTAL  CONTROL  COSTS3  FOR THE  SMELT  DISSOLVING TANK OVER STATE
                                              REGULATORY REQUIREMENTS
Mill Size, TPD
Capital Cost ($)
Annualized Costb ($/Yr)
Annualized Cost per Tonc ($/T)
500
63,750
12,800
0.078
1000
109,300
21,700
0.066
1500
140,000
25,870
0.053

          The  incremental  cost  is  the  difference  in  cost  between  the scrubber  and  the  demister  system,
          which  is assumed to be acceptable  for typical state  regulations.

          Based  on 7884 hours of operation per year.
         £
          The  credits have been accounted for in  calculating the  incremental annualized  costs.

-------
the application of a separate incinerator for handling TRS noncon-
densibles from digester and multiple-effect evaporator relief
vents.  When scrubbers are used to control lime kiln emissions,
normally the lime kiln can be the incineration point for these TRS
noncondensibles.
     Three different control alternatives are examined:  (1) a 15-inch
pressure drop scrubber, (2) a 30-inch pressure drop scrubber, and
(3) a high efficiency electrostatic precipitator equivalent to the
30-inch pressure drop scrubber.  The costs for installation and opera-
tion of the particulate control devices are based on a study by the
Industrial Gas Cleaning Institute.    In addition, the costs of a
separate incinerator and fuel for destruction of the aforementioned
TRS emissions are included in the precipitator costs.  The costs
for thermal destruction in this manner have been developed from
                                         12
information provided by Rust Engineering.    Credits for recovered
particulates have been valued on the basis of makeup ground lime-
stone (CaCO-) at $20 per ton.  The costs of these scrubbers and
the precipitator (with separate incineration) are shown in Table 8-11.
     The incremental costs for alternative controls over state
requirements (assuming the 15-inch scrubber as an acceptable control
device) are shown in Table 8-12.  Here, the controls have been identi-
fied with alternatives 2, 3, 4, or 5, which are discussed in
Section 4.3.  The costs in Table 8-12 represent only those costs
associated with particulate removal.  Alternative 5 will also include
a scrubber, which follows the precipitator, for introducing the
caustic into the gas stream for TRS absorption service.  See
Section 8.2.1.2B(g).
                            8-31

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                            Table 8-11.  CONTROL COSTS FOR LIME KILNS
oo
GO
no
Mill Size, TPD
High Efficiency Precipitator
Capital Costs ($)
Gross Annual ized Costs ($/Yr)b
Credits ($/Yr)c
30- Inch Pressure Drop Scrubber
Capital Costs ($)
Gross Annual ized Costs ($/Yr)
Credits ($/Yr)
15-Inch Pressure Drop Scrubber
Capital Costs ($)
Gross Annualized Costs ($/Yr)
Credits ($/Yr)
500

306,000
185,000
(75,250)

119,000
73,400
(75,000)

99,000
51 ,300
(72,500)
1000

442,000
329,000
(184,500)

165,000
136,400
(184,000)

140,000
93,300
(181,000)
1500

545,000
467,000
/9Q1 7Cn\
\i-^ 1 ,/ *JU J

214,000
200,000
(291,000)

178,000
134,700
(289,000)

         Costs for precipitator include separate incinerator and fuel to destroy digester and
         multiple-effect evaporator TRS noncondensibles.

         Gross annualized costs exclude credits.
        c

         on 7884 hours of operation per year.
Credits for recovered particulates are valued as ground CaCO., at $20 per ton, based

-------
              Table 8-12.  INCREMENTAL CONTROL COSTS OVER STATE REQUIREMENTS FOR LIME  KILNS0
co
CO
OJ
Mill Size, TPD
High Efficiency Precipitator
(Alternative 4, & 5)
Capital Costs ($)
Annualized Costs ($/Yr)b
Annualized Cost per Ton ($/T)c
30-Inch Pressure Drop Scrubber
(Alternatives 2 & 3}
Capital Costs ($)
Annualized Costs ($/Vr)b
Annualized Costs per Ton ($/T)
500
207,000
131,000
0.800
20,000
19,600
0.120
1000
302,000
232,200
0.707
25,000
40,100
0.122
1500
367,000
329,600
0.670
36,000
63,300
0.128

         The baseline for determination of incremental costs is the 15-inch pressure drop scrubber.
        3Annualized costs are net after credits.
        "Based on 7884 hours of operation per year.

-------
B.  Unit Costs for Total Reduced Sulfur Sources
    a)  Digesters and Mu1ti p1e-Effect Eyaporators - The vent gas
streams from the digesters and the multiple-effect evaporators are
similar; that is, small gas volumes but high TRS concentrations.
Since it is common practice in the industry to combine and treat
the emissions from both affected facilities together, the control
costs are presented for a combined treatment system.  The two
types of control techniques discussed are scrubbing with white
liquor and incineration in the lime kiln.  One additional variable
has an effect on the cost of the control systems.  That variable
is the type of digester--batch or continuous.
     The scrubbing alternative has limited effectiveness because
the scrubbing liquor will only absorb some of the TRS compounds.
The scrubber system consists of a gas collection and delivery
system, a scrubbing tower, and liquid piping.   The system is de-
signed to handle the maximum gas flow from the digester system.
During periods of low flow, make-up air is used to maintain a
constant gas flow rate to the scrubber.  One consequence of this
design feature is that the cost of this scrubber system is the
same for the three model mills.  The Sirrine report is the main
                                    13
source of cost data for this system.    The costs are presented in
Table 8-13.
     The second alternative is incineration of the emissions in the
lime kiln, another furnace, or boiler.  The system consists of the
necessary piping and blowers to collect the gas streams, and
delivery piping and controls to inject the gases into the incinera-
tion point, the lime kiln.  A separate incinerator could be used
                            8-34

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                  Table 8-13.   CONTROL COSTS FOR THE DIGESTER AND THE MULTIPLE EFFECT EVAPORATORS
CO
in
     Mill Size. TPD

     Capital Cost ($)
     Annual!zed Cost ($/Yr)
     Annualized Cost per Ton ($/T)a
  500
1000
        Scrubbing with White Liquor - Batch Digesters
57,500                      57,500
17,800                      17,800
 0.108
0.054
 1500

57,500
17,800
 0.036
     Capital Cost ($)
     Annualized Cost ($/Yr)
     Annualized Cost per Ton ($/T)a
        Scrubbing with White Liquor
47,500                      47,500
15,000                      15,000
 0.092                       0.046
                                                                              - Continuous Digesters
                           47,500
                           15,000
                            0.031
     Capital Cost ($}                    129,000
     Annualized Cost ($/Yr)               28,000
     Annualized Cost per Ton ($/T)a        0.170
                                                   Incineration in the Lime Kiln  - Batch Digesters
                           176,000
                            40,300
                             0.123
                          243,000
                           56,100
                            0.114
     Capital Cost ($)                     60,000
     Annualized Cost ($/Yr)               15,000
     Annualized Cost per Ton ($/T)a        0.091
         Incineration in the Lime Kiln  - ContinuousDigesters
                            86,000                     114,000
                            22,000                      30,000
                             0.067                       0.061
      Based on 7884 hours of operation per year.
     3It is assumed that a typical  state regulation requires incineration; therefore, no incremental
      control costs exists for this affected facility.

-------
as an alternative incineration point, particularly where explosion
hazards are a concern, such as the case where an electrostatic
precipitator may be used.  See Section 8.2.1.2A(d) on the lime kiln.
     The system for batch digesters requires a vapor sphere to
act as a gas accumulator during the digester blows.  The vapor
sphere smoothes out the surges and allows a constant gas flow to be
delivered to the lime kiln.  Sources of cost data for this system
include a design engineering company, operating companies, and
                   14
the Sirrine report.    The costs for this alternative for batch and
continuous digesters are shown in Table 8-13.  As noted in the
table, no incremental costs over state standards are assumed to occur
for this affected facility.
     b)  Brown Stock Washers - The gas stream from the brown stock
washers is a relatively large stream with a low concentration of TRS.
The only control alternative judged feasible for this affected facili-
ty is incineration in the recovery furnace or another boiler within
the mill.  Since actual experience with this control alternative
is limited, the degree of confidence in the control costs is not
as good as the other cases.
     The cost estimate includes the washer hoods, ducts, damper
controls and an allowance for corrosion resistant features in the
recovery furnace combustion air fan.  The EPA cost estimate is
based on the experience at the American Can Company mill at
Halsey, Oregon.     Estimates from the National  Council  of
the Paper Industry for Air and Stream Improvement, Inc. agree closely
with the cost estimates presented in Table 8-14.    In building a
                          8-36

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                        Table 8-14.  CONTROL COSTS FOR THE BROWN STOCK WASHERSa'b
oc
I
CAJ
       Mill Size. TPD                      500                    1000                    1500


       Capital Cost ($)                  217,000                352,000                  470,000




       Annualized Cost ($/Yr)             43,000                 70,000                   94,000




       Annualized Cost per Ton ($/Ton)c    0.261                  0.213                    0.190
        Based on incineration in the recovery furnace.

        Typical state regulations do not require any controls; therefore, the presented costs are also

        incremental control costs over State requirements.

       cBased on 7884 hours of operation per year.

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new mill two design considerations could offer the opportunity
of lowering the cost for this control alternative.  One possibility
is to provide more completely enclosed hoods on the washers so
that less air is drawn into the exhaust vent.  This would reduce
the volume of gas to be handled.  The second possibility is to lo-
cate the washers close to the recovery furnace, thus minimizing
the length of the duct.
     Presently, very few states require incineration or equivalent
methods of control.  Hence, the control costs presented in Table 8-14
are also incremental costs over what the typical states may require.
     c)  Direct Contact Recovery Furnaces - The methods used to
reduce TRS emissions from direct contact recovery furnaces are by
close monitoring and control of the process variables and by oxidiz-
ing the black liquor to reduce the sulfides content that can cause
TRS emissions when the black liquor contacts the furnace flue gas
in the direct contact evaporator.  No costs are assessed on
maintaining closer control of the process variables on the recovery
furnace.  Black liquor oxidation can be accomplished by using either
air or pure oxygen as the oxidizing agent.  When air is used the
oxygen deficient air stream carries with it a small amount of TRS
compounds as it leaves the oxidation tanks.  When pure oxygen is
used no gases are vented from the process.
     The black liquor oxidation costs shown in Table 8-15 are
based on data from a company that designs these systems.    The
costs are based on weak liquor oxidation with a strong liquor
touch-up system, or two-stages of oxidation.  An alternate method
                           8-38

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                                  Table 8-15.  BLACK LIQUOR  OXIDATION  COSTS
03
OJ
Mill Size, TPD
2-Stage Air Oxidation
Capital Costs ($)
Annualized Costs ($/Yr)
Annualized Costs per Ton ($/T)
1 -Stage Air Oxidationb
Capital Costs ($)
Annualized Costs ($/Yr)c
Annualized Costs per Ton ($/T)
2-Stage Oxygen Oxidation
Capital Costs ($)
Annualized Costs ($/Yr)
Annualized Cost per Ton ($/T)
500
395,000
141,000
0.858
286,000
91,000
0.554
195,000
193,000
1.175
1000
575,000
210,000
0.639
416,000
144,800
0.441
285,000
350,000
1.065
1500
770,000
290,000
0.588
557,000
200,000
0.406
380,000
511,000
1.037

    aBased on 7884 hours of operation per year.
      Requirements for meeting state  regulations  (direct  contact furnaces).
      Oxygen costs, $20 per ton oxygen, based  on  a  500  TPD  oxygen plant.

-------
is single stage weak liquor oxidation which has lower costs and
can be used to satisfy state regulations for recovery furnace
emissions.  The costs in Table 8-15 compare closely with cost
                                                                   18
data gathered from operating companies and from the Sirrine report.
     An analysis was performed to estimate the costs for a black
liquor oxidation system using pure oxygen.  Since this method is
only practiced in a couple of mills where low cost oxygen is
available, it is not possible to make a precise cost estimate.   The
delivered cost of the oxygen is the variable that has the most signi-
ficant effect on the cost of this alternative.  For this analysis
an oxygen cost of $20.00 per ton was assumed.  This is the updated
                                                                   19
cost for a 500 ton per day oxygen plant based on an earlier report.
Obviously, only in special cases could a kraft pulp mill get oxygen
at a delivered cost at $20.00 per ton or less.  Examples of these
special cases would be if the mill had its own oxygen plant to
supply its oxygen bleaching plant or if the mill was located near
a source of oxygen.  Since no specific data is available on the
capital cost for oxygen black liquor oxidation, the capital cost was
estimated to be 50 percent of the capital cost for the air oxidation
case.  The costs for oxygen black liquor oxidation are shown in
Table 8-15.
     Table 8-16 shows the incremental costs for two-stage air
oxidation systems versus the single stage air oxidation system
suitable for compliance in most states.
     d)  Indirect Contact RecoveryFurnaces - The control technique
for reducing TRS emissions is the basic design of the indirect
contact furnace system.  The major recovery furnace manufacturers
                          8-40

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CD
           Table 8-16.   INCREMENTAL CONTROL COSTS FOR BLACK LIQUOR OXIDATION OVER STATE REQUIREMENTS
                                    (Air Oxidation Systems3 for Direct Contact Furnaces)
Mill Size, TPD

Capital Costs ($)
Annuali zed Costs ($/Yr)
Annualized Costs per Ton ($/T)
500

109,000
50,000
0.304
1000

159,000
65,200
0.198
1500

213,000
90,000
0.182

         a2-stage versus 1-stage systems.

          Based on 7884 hours of operation per year.

-------
have several different furnace designs which can be classified as
indirect contact furnaces.   In general this means that the furnace
system does not have a direct contact evaporator.  Several methods
are used to accomplish the function previously performed by the
direct contact evaporator such as increasing the economizer section
to recover more heat from the flue gas, adding a steam heated concen-
trator to evaporate water from the black liquor, or using combustion
air heated by the furnace flue gas to evaporate water from the
black liquor in an air contact evaporator.
     The following procedure was used to estimate the incremental
cost for indirect contact recovery furnaces over the requirements
of typical state standards.  The incremental costs were determined
by taking the average cost difference^reported by the two major
furnace manufacturers, between the indirect contact furnace and a
direct contact furnace which has a direct contact evaporator and
single-stage air oxidation of black liquor feed, and adding the
                                                                   ?n
cost of the concentrator reported by an engineering design company.
     The annualized cost is made up of maintenance, capital
recovery, administrative overhead, property tax and insurance,
and a charge for the incremental heat loss of the indirect contact
furnace compared to the direct contact furnace.  The heat loss is
calculated assuming that the flue gas is 120°F hotter than the
direct contact furnace flue gas.  The cost of the heat loss is
based on the following factors:  the heat is made up by burning fuel
valued at $1.50 per million Btu to produce steam in a boiler of 90
                           8-42

-------
percent thermal efficiency.  The annualized cost assumes a 90
percent operating factor or 7884 hours per year.  The incremental
capital and annualized costs are shown in Table 8-17.  These
costs are also the incremental control costs over the typical state
requirements which could be met with a direct contact furnace plus
a single stage of black liquor oxidation.
     e)  Black Liquor Oxidation System - The exhaust gases from
air oxidation systems contains some TRS compounds.  If these off-
gases are to be controlled, the required control method is in-
cineration.  Two ways of designing incineration systems were con-
sidered.  The first alternative involves incineration of the off-
gases in the recovery furnace.  Since the off-gas stream has a high
moisture content, a condenser was considered a necessary part
of the system.  The second alternative investigated was incineration
in a separate incinerator with heat recovery.  An economic compari-
son of these two alternatives showed that incineration in the
recovery furnace had a somewhat higher capital cost due to the
condenser, but the annualized cost was considerably lower than
for the separate incinerator.  Given the rising cost and restricted
availability of natural gas, the separate incinerator alternative
is not considered to be a preferred alternative for this affected
facility.
     Since there are no existing installations of this type,
no actual costs are available for this alternative.  The costs in
Table 8-18 represent EPA's best estimate of the cost of incineration
                        8-43

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            Table  8-17.   INCREMENTAL  COSTS  FOR  INDIRECT  CONTACT  RECOVERY  FURNACE  OVER TYPICAL
                                              STATE  CONTROL  REQUIREMENTS
CD
Ji
Mill Size, TPD
Capital Cost ($}a
Annual! zed Costs ($/Yr)b
Annualized Costs per Ton ($/Ton)c
500
299,000
349,000
2.12
1000
469,000
673,000
2.05
1500
593,000
1,000,000
2.03
          Capital based on difference between  indirect  furnace  plus  concentrator  and  direct contact
          furnace, which  includes direct contact  evaporator  and a  single  stage  of black liquor
          oxidation.

         ^Includes capital related  charges  and  heat  loss.
         "Based on 7884 hours of operation  per  year.

-------
  Table 8-18.  CONTROL COSTS FOR INCINERATION OF BLACK LIQUOR OXIDATION SYSTEM OFF-GASES
                                       IN RECOVERY FURNACE

oo
i
-P>
en

Mil] Size, TPD
Capital Cost ($)a
Annuali zed Cost ($/Yr)
Annual ized Cost per Tonb ($/T)

500
200,000
54,000
0.329

1000
305,000
89,000
0.271

1500
400,000
123,000
0.250

Based on condensation and incineration in the recovery furnace.
Based on 7884 hours of operation per year.

-------
in the recovery furnace.  Since most states do not require incin-



eration of oxidation vents, these costs are also incremental



control costs.  The system includes the duct, condenser, piping,



and controls required to transport the off-gases to the combustion



air system of the recovery furnace.  This system is similar to the



one described for the brown stock washers except for the addition



of a condenser.



     f)  Smelt Dissolving Tank - The control technique for reducing



TRS emissions from the smelt dissolving tank is to use fresh



water (or water which is essentially free of dissolved TRS compounds)



in the smelt dissolving tank scrubber.  This feature can be



designed into a new mill at essentially no cost.  Therefore,  no



control costs are presented for control of TRS emissions from this



affected facility.



     g)  Lime Kiln - Two general approaches exist for reducing TRS



emissions from lime kilns.  The first is to maintain proper process



conditions on parameters such as the cold end temperature, oxygen



content in the kiln, the sulfide content in the lime mud, and the



pH and the sulfide content of the scrubbing water.  To accomplish



some of these changes, more attention must be paid to operating



the process, but it is difficult to identify specific cost



penalties.  The only factor which can be well defined enough  to



make a cost estimate is the increase in cold-end temperature.  This



cost is estimated based on raising the cold-end temperature 100



from 350° to 450°F and assuming $1.50 per million Btu and 7884 hours
                           8-46

-------
of operation per year.  The control costs for each model mill
are shown in Table 8-19.
     The second approach to TRS removal is to add caustic to the
liquor in the lime kiln scrubber.  Caustic scrubbing will absorb
some of the TRS emissions.  For most mills caustic is part of the
ordinary makeup caustic to the mill.  In those cases, there is
essentially no cost associated with this alternative.  If the
caustic is not ordinary makeup, then there is an additional cost
for caustic addition.   By filtering out the solids and recycling
the caustic scrubbing liquid, consumption of caustic can be kept to
a minimum.  The cost for this caustic addition is calculated on the
basis of 0.633 pound of caustic (NaOH) per ton of pulp at a price
of $57 per ton of NaOH.  The cost for the addition of caustic is
shown in Table 8-19 where a scrubber is installed primarily for
particulate controls.
     In situations where electrostatic precipitators may be used
for removal of particulates, the addition of caustic would require
the installation of a scrubber to achieve TRS absorption.  This
unit would necessarily follow the precipitator in series.  The
rationale for the cost estimates of alternative 5 associated with
TRS control includes the capital and annualized costs of a low
energy scrubber in addition to the caustic consumption.  The costs
for the low energy scrubber are based on the estimates for the 15-
inch scrubber from Table 8-11.
     Table 8-20 shows the incremental control costs for alternative
controls 2 through 5 over state standards requirements.  Alternative
5 consists of combining process controls, a scrubber, and caustic
                         8-47

-------
                          Table 8-19.  CONTROL COSTS FOR LIME KILNS

Mill Size, TPD
Addition of 15"
with Caustic
Capital Cost ($)
Annuali zed Cost
Annuali zed Cost

Scrubber

($/Vr)
per Ton ($/T)a
500
99,000
54,300
0.331
1000
140,000
99,300
0.302
1500
178,000
143,700
0.292
oo
i. Addition of Caustic Only
Capital Cost ($)
Annuali zed Cost
Annuali zed Cost
Process Control
Capital Cost ($)
Annuali zed Cost
Annuali zed Cost

($/Yr)b
per Ton ($/T)a

($/Yr)c
per Ton ($/T)a
0
3,000
0.0183
0
30,000
0.183
0
6,000
0.0183
0
66,000
0.200
0
9,000
0.0183
0
103,000
0.209

Based on 7884 hours of operation per year.
This cost applied only to mills where caustic is not part of the ordinary makeup.
Based on fuel required to increase cold end temperature 100 F.

-------
                   Table  8-20.   INCREMENTAL  CONTROL  COSTS FOR ALTERNATIVE CONTROL SYSTEMS
                                     2  THROUGH 5 ABOVE STATE REQUIREMENTS (LIME KILNS)
oo

Mill Size, TPD
Alternative 5
Capital Cost ($)
Annualized Cost ($/Yr)
Annuali zed Cost per Ton ($/T)
Alternatives 3, 4
Capital Cost ($)
Annualized Cost ($/Yr)
Annualized Cost per Ton ($/T)
Alternative 2
Capital Cost ($)
Annualized Cost ($/Yr)
Annualized Cost per Ton ($/T)
500

99,000
84,300
0.513

0
30,000
0.183

0
33,000
0.201
1000

140,000
165,000
0.503

0
66,000
0.200

0
72,000
0.218
1500

178,000
246,700
0.501

0
103,000
0.209

0
112,000
0.227

-------
     addition.  Alternatives 3 and 4 include only process controls as
     defined above; and alternative 2, process controls and caustic
     addition.  The costs are derived from the estimates presented in
     Table 8-19.
          h)  Condensate Stripper - In mills that have condensate
     strippers, the TRS compounds vented from the stripper can be con-
     trolled by incineration.  The EPA cost estimate shown in Table 8-21
     is based on a system including a fan, duct, seal pot, and flame
     arrester.  The duct begins at the overhead condenser on the stripper
     and ends at the point where it connects with the non-condensible
     gas header which leads to the lime kiln.
          In the judgement of EPA, the states normally would require in-
     cineration of condensate stripper vents.  Hence, there are no in-
     cremental costs associated with this technique.
8.2.1.3  Discussion of Incremental Costs for Alternative Control Systems
     The purpose of this section is to summarize the incremental control
costs for each affected facility and to present total system costs which
reflect alternative control considerations for the lime kiln facility.
The total system costs (i.e., the aggregated incremental control costs
on a total mill basis) serve as the input for the economic analysis in
Section 8.4.
     An in-depth description of the alternative control systems
(Alternatives 1 through 5) is found in Section 4.3.   A brief description
in tabulated form of these alternative systems is presented in Table 8-22.
Alternative 1 represents the composite of state regulations interpreted
by EPA to be most typical for individual affected facilities.  These
                                8-50

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03
                    Table  8-21.   CONTROL  COSTS  FOR THE CONDENSATE STRIPPER
Mill Size, TPD
Capital Cost ($)
Annualized Cost ($/Yr.)
Annuali zed Cost per Ton (I
500
15,000
5,800
^/Ton)a 0.035
1000
21,000
7,200
0.022
1500
26,000
8,200
0.017
        aBased on  7884 hours of  operation  per year.

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                                          Table 8-22.  COMPARISON OF ALTERNATIVE CONTROL  SYSTEMS
    AFFECTED FACILITY
ALTERNATIVE CONTROLS
co

en
ro

Parti culates
Recovery Furnace
(Direct Contact Only)
Smelt Dissolving Tank
Lime Kiln
TRS Emissions
Di gester/Mul t1 pie-Effect
Evaporator
Brown Stock Washers
Recovery Furnace
(Direct Contact Only)
Black Liquor Oxidation
Vents
L1me K1ln
Condensate Stripper
la
Medium Efficiency
Precipitator (99.0%)
Demlster
l5-1nch Scrubber
Incineration
No Control
Single Stage
Oxidation
No Control
Some Process
Control
Incineration
2_
High Efficiency
Precipitator (99.5%)
Scrubber
30-inch Scrubber
Incineration
Incineration
Two Stage
Oxidation
Incineration
Improved Process
Control plus
Caustic
Incineration
3
Same
as 2
Scrubber
Same
as 2
Incineration
Incineration
Same
as 2
Incineration
Improved Pro-
cess Control
Incineration
4
Same
as 2
Scrubber
Electrostatic
Precipitator
Incineration
Incineration
Same
as 2
Incineration
Same
as 3
Incineration
5
Same
as 2
Scrubber
Electrostatic Precipitator
Incineration
Incineration
Same
as 2
Incineration
Improved Process Control
plus 15" Scrubber with
Caustic
Incineration
    Control methods applicable for compliance with typical state regulations representative for specific affected facility.

-------
regulations are not necessarily the most stringent ones that can be
found.  Rather, they are most representative of those states with pulp
mill regulations, on an individual affected facility basis.   Alternatives
2 through 5 are representative of more stringent levels of control.
     The summary of incremental control costs derived earlier for the
individual affected facilities is presented in Table 8-23.  From these
costs, total incremental costs for the alternative control systems can
be derived.  These are shown for the direct contact furnace only in
Table 8-24.
     Reviewing Table 8-23, the control costs on an unit basis tend to
be lower with increasing mill size.  However, the trend is not consistent
and the economies of scale are not significant.  For example, control
alternative 2 costs range from $1.57 per ton for a 500 TPD mill to $1.47
per ton for a 1500 TPD mill; but the intermediate size, the 1000 TPD
mill, has the lowest costs at $1.42 per ton.  This pattern holds for
alternative 3.  For control alternatives 4 and 5, the costs per ton for
the 1000 and 1500 TPD mills are practically the same at each level —
$1.99 per ton for alternative 4 and $2.29 per ton for alternative 5.
8.2.1.4  Cost-Effectiveness of TRS and Parti oil ate Emission Control
         Alternatives, Lime Kiln Facility
     With respect to lime kiln emissions, there are four levels that
were considered for investigation.  These levels which reflect the
various combinations of controlling particulates and TRS emissions in-
                                  8-53

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              Table 8-24.   SUMMARY OF AGGREGATE INCREMENTAL COSTS FOR ALTERNATIVE CONTROL SYSTEMS
                                       FOR DIRECT CONTACT RECOVERY FURNACE DESIGNS
       MILL SIZE/COST CATEGORY
CONTROL ALTERNATIVES
as

500 TPD
Capital Cost ($)
Annual i zed Cost ($/Yr)
Annuali zed Cost per Ton ($/T)
1000 TPD
Capital Cost ($)
Annuali zed Cost ($/Yr)
Annualized Cost per Ton ($/T)
1500 TPD
Capital Cost ($)
Annualized Cost ($/Yr)
Annualized Cost (Per Ton ($/T)
1 2

800,000
258,400
1.57

1,410,000
468,000
1.42

2,189,000
725,200
1.47
3

800,000
255,400
1.55

1,410,000
462,000
1.41

2,189,000
716,200
1.45
4

987,000
367,000
2.23

1,687,000
654,000
1.99

2,520,000
982,600
1.99
5

1,086,000
421,300
2.56

1,827,000
753,400
2.29

2,698,000
1,126,300
2.29

       Note:  Alternative 1 is the baseline representative of state requirements.

-------
         Table 8-25.   COST EFFECTIVENESS FOR 1000 TPD MILL (DIRECT CONTACT RECOVERY FURNACE)
PARAMETERS
  ALTERNATIVE CONTROLS
Incremental  TRS reduction
(lb/yr)

Incremental  TRS control
costs ($/yr)

Avg.  cost per unit of TRS
reduction ($/lb)

A Cost per A Ib TRS
reduction ($/lb)

    * * *
361,352
 0.820
 0.731
353,139     353,139    361,352
296,200      290,200     290,200    389,500
 0.822       0.822      1.078
                        12.09
Incremental Particulate
reduction (Ib/yr)

Incremental Particulate
control cost ($/yr)

Avg.  cost per unit of
particulate reduction ($/lb)

A cost per A Ib particulate
reduction ($/lb)
886,950      886,950     995,355    995,355
171,800      171,800     363,900    363,900
 0.194        0.194       0.366      0.366
                           1.77
 Alternative 1  is the baseline of control, which represents compliance with states' regulations.

-------
                          Table  8-23.
SUMMARY OF INCREMENTAL COSTS ABOVE STATE REGULATORY REQUIREMENTS PER AFFECTED FACILITY FOR DESIGNATED
                                       ALTERNATIVE CONTROLS
     Mill  Size.  TPO
                                                          500
                                                         1000
1500
Affected Facility
Parti culates
1. Recovery Furnace
(a) Direct Contact
(b) Indirect Contact
2, Smelt Dissolving Tank
3. Lime K1ln
(a) Alternatives 2.3
(b) Alternatives 4,5
TRS
1. Recovery Furnace
(a) Direct Contact
(b) Indirect Contact
2. Digester (Batch) and
Multiple-Effect Evaporators
3. Brown Stock Washers
4. Black Liquor Oxidation System Vents
{Direct Contact Furnace Only)
5. Lime Kiln
(a) Alternative 2
(b) Alternative 3,4
(c) Alternative 5
6. Condensate Stripper
Capital
Costs
($5
190,000
310,000
63,750
20,000
207,000

109,000
299,000
0
217,000
200,000
0
0
99,000
0
Annuali zed
Costs
($/yr)
46,000
67,000
12,800
19,600
131,000

50,000
349,000
0
43,000
54,000
33,000
30,000
84,300
0
Unit
Annuali zed
Costs
($/T)
0.280
0.408
0.078
0.120
0.800

0.304
2.12
0
0.261
0.329
0.201
0.183
0.513
0
Capital
Costs
($)
460,000
620,000
109,300
25,000
302,000

159,000
469,000
0
352,000
305,000
0
0
140,000
0
Annuali zed
Costs
($/yr)
110,000
132,000
21 ,700
40,100
232,200

65,200
673,000
0
70,000
89,000
72,000
66,000
165,300
0
Unit
Annuali zed
Costs
($/T)
0.335
. 0.402
0.066
0.122
0.707

0.198
2.05
0
0.213
0.271
0.218
0.200
0.503
0
Capital
Costs
($)
930,000
825,000
140,000
36,000
367,000

213,000
593,000
0
470,000
400,000
0
0
178,000
0
Annuali zed
Costs
($/yr)
217,000
154,000
25,870
63,300
329,600

90,000
1,000,000
0
94,000
123,000
112,000
103,000
246,700
0
Unit
Annuali zed
Costs
($/T)
0.440
0.304
0.053
0.128
0.670

0.182
2.03
0
0.190
0,250
0,227
0.209
0.501
0
CO
 I
en

-------
8.2.2.2  The Digester System
     Reconstruction of an existing digester, in which an expenditure of
more than 50 percent of the cost of a new unit is made, can be anticipated
to occur at some mills.  This action would require the control of the
affected facility to meet the proposed standard.  Control costs for two
situations are presented:
     1)  case where only piping constitutes the major expense
     2)  case where the existing blow heat recovery system may have
         to be replaced  (major costs for structural supports, blow heat
         tanks, heat exchangers).  Included in both situations are
         costs for 2000 feet of piping (from the source to the lime kiln),
         spark arresters, flame-out controls, and gas accumulator.
     The costs represent estimates based on information received via
                               21
contacts with several companies   for retrofitting controls in response
to state implementation requirements.  The costs estimates are presented
in Table 8-26 for a 250, 500, and a 1000 ton per day mill.
8.2.2.3  Brown Stock Hasher System
     In some situations, a mill may expand sufficient pulping capacity to
warrant a need for adding an additional washer stage to an existing
washer system.  Washer emissions may increase, thus subjecting the
facility to the modification provisions of Section 111.  In this parti-
cular case, the mill may have tightened down on all the major sources
(recovery furnace, digesters), having only the washer system as the
lone source for controls.  Retrofit control costs are presented for
such a situation.
                             8-59

-------
volve certain trade-off considerations that should be included in recom-
mending the lime kiln standards.
     The four levels have been described in detail earlier in Section 4.3.
Basically alternative 2 differs from alternative 3 only by the addition
of caustic (to a 30-inch pressure drop scrubber).   Alternative 4 requires
replacement of the 30-inch scrubber with an electrostatic precipitator
to improve particulate emission control.   In addition, a fuel penalty is
incurred for use of the precipitator because the lime kiln can no longer
be safely used as an incineration point for TRS emissions from other
affected facilities.  Alternative 5 represents an  addition of a 15-
inch pressure scrubber with caustic scrubbing liquid, to the alternative 4
controls, to achieve TRS absorption.
     The calculations for cost effectiveness of selective particulate
and TRS removals for ascending levels of control are presented in Table 8-25
for a direct contact recovery furnace design in a  1000 TPD pulp mill.
The cost-effectiveness technique employed here attempts to measure the impact
that a change in control technology has upon a reduction of a single
pollutant category.   Hence, the marginal  cost concept is used to measure
the sensitivity of such a change.
     The marginal cost per Ib. of pollutant reduction is calculated for the
caustic addition alone ($0.73 per Ib. of TRS reduction), for the electro-
static precipitator and separate incineration ($1.77 per Ib.  of particulate
reduction), and the addition of a scrubber with caustic scrubbing liquid
($12.09 per Ib. of TRS reduction).
     Average costs per Ib.  of pollutant reduction  are also shown in
Table 8-25 for each level.   The average costs shown for Alternative 2 are

                              8-56

-------
     The major factors involved in the magnitude of costs for retro-
fitting controls on brown stock washers are the accessibility of the
recovery furnace for incineration of TRS and the condition of the ventila-
tion system on the existing washers.  Costs are presented for two cases:
(1) major retrofit of ventilating system plus incineration in existing
recovery furnace and (2) major retrofit of ventilating system plus
destruction of captured TRS in a separate incinerator.  Costs for retro-
fit of ventilation systems have been developed on the basis of contacts
                            22
with several paper companies   and the National Council for Air and
                   23
Stream Improvement.    The cost for a separate incinerator was based on
transfer of technology from an incinerator application on an asphalt
saturator.
     The cost estimates for these two situations are presented in
Table 8-27 for 250, 500, and 1000 ton per day mills.  The design gas flow
rate for the incinerator was based on 100 acfm per ton per day pulp.
                                                                    25
This compares to a reported range of 75 to 250 acfm per ton per day.
Fuel costs  were based on a price of $1.50 per million BTU and a use of
1.75 million BTU per ton pulp.
8.2.2.4  Recovery Furnace Modification
     The only modification of a recovery furnace of any significance
occurs when a direct contact  design is converted to an indirect contact
design.   Only one situation of this nature has occurred in the industry
although further conversions are likely to take place.  For such a
modification, the increased emission of concern is particulates.
                                8-61

-------
in reality marginal costs incremental above the state level (alternative
1).  Alternative 2 average costs are calculated as if the alternative 1
costs were zero.  To compute these costs in any other manner would
entail the problem of defining the economic recovery for participate
emissions, which was discussed earlier in this chapter.
8.2.2  Modified/Reconstructed Sources
8.2.2.1  Introduction
     The purpose of this section is to present control costs for modified
and reconstructed sources that will evolve from the designation of cer-
tain affected facilities.  Frequently, a pulp mill may expand production
piecemeal, or improve production efficiency, by doing such things as
reconstructing an existing digester, adding an additional stage of pulp
washing, or converting to a more reliable fuel (such as converting
from gas to coal in the lime kiln).  Furthermore, a mill  may make some
major changes in its set-up in response to some non-production related
consideration.  An example of the latter would be the conversion of a
direct contact furnace to an indirect contact furnace design to achieve
reduction of TRS emissions for compliance with a state regulation.  The
examples presented here are precisely those that will  be  discussed with
presentation of cost estimate.
     Capital costs are based on 1975 dollars (Fourth Quarter of 1975).
Capital charges are based on 15 years for amortization and 100 percent
leading at 10 percent interest.   Administrative costs, taxes, and in-
surance are estimated at 4 percent of capital  investment.   Factor
prices for electricity and fuel  are assumed to be the same as those in
Section 8.2.1.   Maintenance costs were calculated as 2 percent of original
capital investments.
                                 8-58

-------
     The only cost impact resulting from the New Source Performance
Standards (NSPS) would be those costs related to the parti oil ate control
system.  Since most states have particulate standards already, only those
cost differences between compliance with the Federal NSPS and the state
regulation are of importance.  This means that the typical state regula-
tion would require a collection system capable of achieving approximately
99.6 percent collection efficiency.  In order to meet the Federal NSPS,
the mill owner would have to install a system capable of achieving 99.8
percent.  Since most of the retrofit costs, such as taking out the
direct contact evaporator, adding economizer, concentrator, fans, turbines,
piping, electrical, instrumentation, and engineering, would occur in
the absence of any regulation, the only cost directly affected by the
NSPS are the incremental precipitator costs.  Referring to Table 8-28,
these costs are presented for the 500 TPD mill and 1000 TPD mill situa-
tions.  The costs are the same as those shown for indirect contact furnace
precipitators in Table 8-8.  The 250 TPD mill situation would not likely
occur because most mills of that size would have furnaces approximately
twenty years old and would be uneconomical to convert.

        Table 8-28.  INCREMENTAL CONTROL COSTS FOR INDIRECT CONTACT
                        RECOVERY FURNACES OVER SIP REQUIREMENTS
Mill Size, TPD                         500                   1000
Capital Costs ($}
Annualized Cost ($/Yr. )
Annual i zed Cost per Ton ($/T)
310,000
67,000
0.41
620,000
134,000
0.41
                              8-63

-------
         Table 8-26.  CONTROL COST REQUIREMENTS FOR
                         DIGESTER RECONSTRUCTION
Case
Mill Size, TPD
Capital Cost ($)
Annual ized Costs ($/Yr)
Annual i zed Cost per Ton9
($/T)
1 . Piping Only.
250 500
$200,000 $350,000
51,000 90,000
0.621 0.548
1000
$500,000
136,000
0.414
                      Case  2.   Piping  and  Blow-Heat
                      	Recovery.	
Mill Size. TPD                 250          500          1000
Capital Cost ($)               $500,000     $2,000,000   $4,000,000
Annualized Costs ($/Yr)         116,000        453,000      906,000
Annualized Cost per Ton            1.41           2.76         2.76
($/T)
 Based on 7884 hours of operation per year.
                         8-60

-------
8.3  OTHER COST CONSIDERATIONS

     In addition to NSPS, the fundamental process economics of the

kraft pulping industry will be impacted by other regulations.  These

include Federal water regulations as well as occupational safety and

health regulations.  However, the imposition of these other regulations

will probably not affect the results of the analyses contained in

section 8.4.

     Arthur D. Little, Inc. has recently completed a comprehensive

analysis of air, water, and noise regulation impacts on the entire pulp
                   pc
and paper industry.    The kraft pulping sector was judged to be one of

the stronger industry segments.  Furthermore, ADL projected no closures

for the kraft pulping sector.
                              8-65

-------
          Table 8-27.   CONTROL COST REQUIREMENTS FOR
                      BROWN  STOCK WASHER MODIFICATIONS
Case 1. Incineration in Recovery
Furnace
Mill Size, TPD
Capital Cost ($)
Annual i zed Cost ($/Yr)
Annuali zed Cost per Ton
($/T)
Case 2.
Mill Size, TPD
Capital Cost ($)
Annual i zed Cost ($/Yr)
Annuali zed Costs per Ton
250
400,000
76,000
0.925
Separate
250
650,000
315,000
3.84
500
600,000
114,000
0.694
Incinerator
500
1,000,000
570,000
3.47
1000
1,200,000
228,000
0.694
1000
2,000,000
1,140,000
3.47
($/T)
                          8-62

-------
                                                 Table 8-30  ABSOLUTE AND RELATIVE INCREMENTAL CONTROL COSTS FOR NEH PLANTS
                                                                            (In 4th Quarter 1975 Dollars)
                                                                        Direct Contact Recovery Furnace Design
00

O1
Alternatives
Hill Size/Cost Category 1
500 tpd
Armuallzed Cost
Annual! zed Cost/Ton
Annuallzed Cost as a % of the 4th
Quarter 1975 Average Selling
Price of $345.50
Investment Cost
Investment Cost as a % of Base H111
Investment of $87.5 mm
1000 tpd
Annuall zed Cost
Annual 1zed Cost/Ton
Annuallzed Cost as a % of the 4th
Quarter 1975 Average Selling
Price
Investment Cost
Investment Cost as a % of Base Mill
Investment of $137,5 m
1500 tpd
Annuallzed Cost
Annuallzed Cost/Ton
Annuallzed Cost as a % of the 4th
Quarter 1975 Average Selling
Price
Investment Cost
Investment Cost as a % of Base Mill
Investment of $175.0 mm

Recovery Furnace Smelt Dissolving
Key: Parti culates TRS Parti culates
Alternative 1 - The 0.09 G/dscf 17.5 ppm 0.085 G/dscf
Average SIP
2 0.04 G/dscf 5 ppm 0.05 G/dscf
3 0.04 G/dscf 5 ppm 0.05 G/dscf
4 0.04 G/dscf 5 ppn 0.05 G/dscf
5 0.04 S/dscf 5 ppn 0.05 G/dscf
2
$258400-
$1.57
0.5%


$800000-
0.9%

$468000-
$1.42
0.4%


$1,410,000-
1.0%


$725200-
$1.47
0.4%


$2,189,000-
1.3%


Tank L1me K1ln
TRS Partlculates
65 ppm 0.12 G/dscf

5 ppn 0.06 G/dscf
5 ppm 0.06 G/dscf
5 ppn 0.02 G/dscf
5 ppm 0.02 G/dscf
3
$255400-
$1.55
0.4%


$800000-
0.9%

$462000-
$1.41
0.4%


$1,410,000-
1.0%


$716200-
$1,45
0,4*


$2,189,000-
1,3*

pLO
tents
Ths ^BT
40 ppn %fiO

5 ppn i
lOppi |
10pp« |
5 ppn 5
4
$367000-
$2.23
0.6%


$987000-
1.1%

$654000-
$1.99
0.6%


$1,687.000-
1.2%


$982600-
$1.99
0.6%


$2,520,000-
1.4%

Br. Stk. Digesters,
LHshrs. Evaporators
THS TRS
ppn t<150 ppm t5 ppm

ppn 5 ppm •vS ppm
ppm 5 ppm %5 ppm
ppn 5 ppn •vS ppn
ppn 5 ppn •vS ppn
5
$421300-
$2.56
0.7%


$1,086,000-
1.2%

$753400-
$2.29
0.7%


$1,827,000-
1.3%


$1,126,300-
$2.29
0.7%


$2,698,000-
1.5%

Multiple Effect
, Condensate Strippers








-------
8.2.2.5  Lime Kiln-Fuel Conversion
     The anticipated modification of this source would occur for a
conversion of gas fuel to oil for firing the kiln.  This conversion
would result in an increase of particulate emissions, thus subject
to the Federal New Source Performance Standards.
     The maximum impact foreseen would occur in the total replacement
of the existing scrubber system.  The costs for this situation which
reflect the installation of a higher energy scrubber system are presented
in Table 8-29.  The capital costs, reflecting retrofit penalties, are as-
sumed to be 25 percent greater than similar costs for a grass-roots
Venturi scrubber, with 30 inch pressure drop.   (The latter costs were
presented in Table 8-11).  The costs for the 250 TPD were obtained by
scaling the costs in Table 8-11  with the assumption of a 0.4 scalar
exponent over the 250-1500 TPD size range.  The incremental annual
costs include only the capital charges, taxes, insurance, and administra-
tive costs and incremental electrical energy consumption.  Maintenance
costs, labor costs, and by-product credits are assumed to remain the
same as those on the pre-retrofit scrubber.
     This control option would not require any additional TRS controls,
TRS emissions remaining the same as prior to retrofit.  Hence, no need
exists for addition of caustic.

    Table 8-29.  COST REQUIREMENTS FOR MODIFICATIONS TO LIME KILN SCRUBBER
Mill Size, TPD
Capital Cost ($)
Annual i zed Costs
Annual i zed Cost t


($/yr.)
>er Ton
250
113,000
27,000
0.33
500
150,000
41,000
0.25
1000
200,000
65,000
0.20
($/T)	
                                 8-64

-------
     Requisites of a return on investment assessment are the incre-
mental investment, variable, and capital  related control costs;  baseline
mill investment; variable process costs;  the necessary price change;
and demand elasticities.
     Four critical assumptions were used  in conducting the return on
investment assessment.  First, the project hurdle rate is 10% after
tax.  Second, variable process costs are  $150/ton of
pulp.  Third, the demand elasticity of -0.5 applies to the price
increase of each mill.  And, fourth, the  precontrol working year is
328.5 days.
     The results of the assessment are displayed on Table 8-31.   The
adverse before tax return on investment impacts range from 0.04% to
0.11% for all considered alternatives. These are very small  simulated
impacts, and, by themselves probably would not alter decisions
regarding new mill construction.
8.4.2  Modifications at Existing Plants
     Modifications stem from capital improvements which increase the
emission rate from a designated facility.  Consequently, a mill  segment
becomes an affected facility; and hence,  subject to "New Source  Performance
Standards" (NSPS).
     Since modifications stem from capital improvements, the owner
believes the mill, in the absence of NSPS, is a viable long run  project.
In essence, the owner makes the conscious decision to modify with the
expectation of improving his competitive  posture.
                                 8-69

-------
8.4  POTENTIAL ECONOMIC (INCLUDING SOCIAL AND INFLATIONARY)  IMPACT
8.4.1  Grass Roots New Plants and Capacity Additions at Existing Plants
     The projected Impact of each considered alternative control system
is small for grass roots new plants and capacity additions at existing
plants.  New source performance standards should not, by themselves,
preclude construction of grass roots new plants and capacity additions
at existing plants.
     Small absolute and relative control cost estimates, inelastic
price elasticity of demand estimates, and small simulated return on
investment impacts support the aforementioned statements.
8.4.1.1  Control Costs
     The absolute and relative magnitude of the estimated alternative
control systems' costs for grass roots new plants are displayed on
Table 8-30.  Regardless of the alternative of mill size, the estimated
absolute and relative incremental control costs are small.  At most,
the estimated amounts are $2.56 annualized cost per ton, 0.7% of the
average pulp sales price, and 1.51 of the baseline mill investment.   Al-
though control costs tend to be higher for smaller mills with indirect
contact recovery furnaces (See Table 8-23), the alternatives considered
are not expected to significantly affect new mill size or recovery furnace
design decisions.  The reason is that air pollution control  is just one
of several factors influencing mill size and recovery furnace design.
Moreover, the incremental control costs are small to begin with.
                               8-66

-------
     The fundamental question in the impact assessment is will the owner
still wish to modify in the face of NSPS.  For the 4 modification cases
analyzed, the control costs are probably affordable; the owner would
probably still modify.  Small incremental control costs, inelastic
demand estimates, and small simulated return on investment impacts
support the aforementioned statement.
     The probable modifications and their control costs are described
in Section 8.2.2.  Kraft pulp demand elasticity is described in Section
8.4.1.2.  The modification return on investment assessment employs
the same critical assumptions and requisite data as the new mill
assessment.  However, baseline mill investment for the modification
assessment is assumed to be 50% of the new mill assessment.
     The results of the modification assessments are displayed on
Table 8-32.   Adverse return on investment impacts range from a decline
of 0.01% to 0.32%.  Again, these are small numbers, and by themselves
would probably not alter a mill's decision regarding modification.
8.4.3  Reconstructions at Existing Plants
     Reconstructions may result when capital  expenditures on a
designated facility exceed 50% of the cost of a new facility.  The
absolute and relative magnitude of associated control costs would
probably be less than the previously analyzed new plant and modified
existing plant situations.  For example, piecemeal reconstructions
would have smaller associated gas volumes and hence,  smaller control  costs.
In addition, production levels are presumed to be the same in the modified
and reconstructed mill situations.   Consequently, the impacts on reconstruc-
tions at existing mills would probably be less.  Therefore, the concluded
impact of all alternatives on reconstructions at existing mills is small.
                                8-71

-------
     The relative control  costs associated with capacity additions
at existing plants should be even smaller; since,  there is more
production volume over which to spread the incremental  costs.
8.4.1.2  Price Elasticity of Demand
     However, impact upon the mill  or firm may depend on other
things besides the control cost magnitudes.  It might depend on the
ability to pass control costs onto  others.
     For example, if kraft pulp prices rose to cover incremental  control
costs and sales revenues increased, lessened mill  impact could result.
To have a revenue rise, the percentage change in quantity demanded of
kraft pulp divided by the percentage change in kraft pulp prices must
have a value between 0 and --1.0. This occurs when the  product's direct
price elasticity of demand is inelastic.
     Because kraft pulp is an intermediate good, has few close sub-
stitutes, and is a small part of final product value, most analysts
characterize kraft pulp demand as price inelastic.  This characteriza-
tion is supported by recent econometric studies which estimate a direct
price elasticity of demand value of -0.5.
8.4.1.3  Return on Investment
     Control cost magnitudes and demand elasticities are revealing
indicators of impact.  However, where feasible,return on investment
assessments are useful  additions.  Because such assessments focus on
the viability of a particular investment [i.e. whether  or not to
construct a new mill], they more clearly focus on  the issue of
affordability.
                               8-68

-------
Reconstructions at existing plants will  probably not be precluded by
an NSPS alone.
8.4.4  Summary
     In essence, the projected impact of all  considered alternatives
is small.   Again, small  incremental control  costs,  inelastic price
demand elasticity estimates, and small  simulated return on investment
impacts support the projected impact.  New source performance standards
by themselves should not preclude new mill construction or modification
and reconstruction of designated facilities  at existing mills.  Conse-
quently, adverse growth, output, and employment impacts are probably nil
                                 8-73

-------
                                                  TtbU  8-J1. f!*Mfrt KTUif * tNmtltNT IHMCT:  SRAS5 ROOTS NEW PLANTS
                                                                               Contact Recovery Furnace Design
CO
vanaoie control tosi/ion; rrice}
Quantity, Revenue, Cost, 5 Return
on Investment Impacts 1
500 tpd; $87.5 mm Base Investment
Variable Control Cost/Ton'
Price Increase2 ,
Quantity Demanded Decrease
4
Annual Revenue Change r
Annual Fixed Cost Change ,
Annual Variable Process Cost Change?
Annual Variable Control Cost Change
Annual Income Change Before Tax° g
Return on Investment Change Before Tsx
1000 tpd; $137.5 mm Base Investment
Variable Control Cost/Ton
Price Increase
Quantity Demanded Decrease
Annual Revenue Change
Annual Fixed Cost Change
Annual Variable Process Cost Change
Annual Variable Control Cost Change
Annual Income Change Before Tax
Return on Investment Change Before Tax
1500 tpd; $175.0 mm Base Investment
Variable Control Cost/Ton
Price Increase
Quantity Demanded Decrease
Annual Revenue Change
Annual Fixed Cost Change
Annual Variable Process Cost Change
Annual Variable Control Cost Change
Annual Income Change Before Tax
Return on Investment Change Before Tax
2

$0.73
$1.89
449
+$154500-
+ 137200-
- 67400-
+ 119600-
- 34900-
- 5754!

$0.68
$1.71
813
+$279500-
+ 241800-
- 122000-
+ 222800-
- 63100-
- 0. 05?

$0.71
$1.77
1262
+$433900-
+ 375400-
- 189300-
+ 349000-
- 101200-
- 0. 06i


3

$0.71
$1.87
444
+$152900-
+ 137200-
- 66600-
+ 116300-
- 34000-
- 07347

$0.67
$1.70
813
+$276200-
+ 241800-
- 122000-
+ 219600-
- 63200
- 0.05*

$0.69
$1.75
1248
+$428900-
+ 375400-
- 187200-
+ 339100-
- 98400-
- 0.06%


4

$1.20
$2.64
628
+$215000-
+169300-
- 94200-
+196300-
- 56400-
~- 0.06*

$1.11
$2.34
1112
+$381900-
+ 289300-
- 166800-
+ 363400-
-.104000-
_ 0_ Q7 jj-

$1.11
$2.33
1662
+$570000-
+ 432180-
- 249300-
+ 545100-
- 158000-
- 0.091


5

$1.43
$3.01
715
+$245200-
+ 185300-
- 107300-
+ 233900-
- 67700-
- 0.08*

$1.34
$2.67
1269
+$435300-
+ 313300-
- 190400-
+ 438500-
- 126100-
~ 0.09*

$1.35
$2.66
1897
+$650300-
+ 462710-
- 284550-
+ 662700-
- 190600-
- 0.11%


                Variable Control Cost/ton «  (Annuallzed Control Cost - Annual Fixed Cost) * (dally tonnage x 328.5 days}
                Price  Increase/ton - Variable Control Cost/ton +  [Investment Cost (.1989 + .04)] *  (dally tonnage x 328.5 days)
                Quantity Demanded Decrease * [0.5 x  (Price Increase * $345.50)] x (dally tonnage x 328.5 days)
                Annual Revenue Change • Price Increase x [(dally tonnage x 328.5) - Quantity Demanded Decrease]
                Annual Fixed Cost Change - Investment (depreciation and Interest factor of .1315 + property tax, insurance, and overhead factor of .04)
                Annual Variable Process Cost Change =• $150.00 x Quantity Demanded Decrease
              ^Annual Variable Control Cost Change • Variable Control Cost/ton x [(daily tonnage x 328.5) - Quantity Demanded Decrease]
                Annual Income Change Before Tax » Annual Revenue Changes - Annual Cost Changes
                Return on Investment Change Before Tax - Annual Income Change Before Tax * (Base Hill  Investment + Control Investment)

-------
16.  Correspondence from Mr. Russell  Blosser,  National  Council  for Air
     and Stream Improvement, Inc.,  to Mr.  Paul  A.  Boys, EPA,  November
     17, 1972.

17.  Correspondence from Mr. Carl Milk,  A.  H.  Lundberg, Inc., to
     Mr. Paul  A. Boys,  EPA,  dated September 22, 1972.

18.  Environmental  Engineering,  Inc., and  J.E.  SirrineCo.,  loc. cit.

19.  Investment and Operating Cost  Data  for Low Pressure Oxygen Plant
     Applicability  to Non-Ferrous Metallurgy,  Vulcan-Cincinnati,  EPA
     Contract No. 68-02-2099, Task  No. 2,  September 29, 1972.

20   Correspondence from (a) Mr. Peter H.  Miller,  Combustion  Engineering,
     Inc.,  to Mr. Robert T.  Walsh,  EPA,  January 31, 1972.  (b) Mr.  J.L.
     CT>ement,  Babcock & Wilcox,  to  Mr. Paul A.  Boys, EPA,  Nov. 9,  1972.
     (c) Mr. C. T.  Tolar, Rust Engineering Co., to Mr.  Paul A. Boys,
     EPA, Oct. 20,  1972.

21.  Communication  with personnel in  eight paper companies:   Weyehauser,
     Boise Cascade, Georgia  Pacific,  International  Paper,  Mead,
     St. Regis, and Westaco, May, 1975.

22.  Ibid.
23.  Russell  Blosser,  National  Council  for Air  and  Stream  and
     Improvement,  loc. cit.

24.  Industrial  Gas Cleaning Institute,  Contract No.  68-02-0289,  loc.  cit.

25.  Van Derveer,  Paul D.  loc.  cit.

26.  Arthur D.  Little, Inc.  loc.  cit.
                              8-75

-------
                                         Table 8-32.   SIMULATED RETURN  ON  INVESTMENT  IMPACT:   MODIFICATIONS AND RECONSTRUCTIONS AT EXISTING PLANTS
CO


ro



Mill iUe, base Mill Investaent,
Variable Control Cost/Ton, Price, Quantity,
tevenue. Cost, S Return on Investment
impacts

250 tpd; $21. 9 rnn Base Investment
Variable Control Cost/Ton
Price Increase
Quantity Dwri^ndod Decrease (Tons)
Annual Revenue Change
Annual Fixed Cast Change
Annual Variable Process Cost Change
Annual Varlablf* Control Cost Change
Annual Inwc Change Before Tax
Return on Inveotwnt Change Before Tax
600 tpd; $43.8 urn Base Investment
Variable Control Cost/Ton
Price Increase
Quantity Demanded Decrease (Tons)
Annual Revenue Change
Annual fixed Cost Change
Annual Variable Process Cost Change
Annual Variable Control Cost Change
Annual Incone Change Before Tax
Return on inveiUiic-iit Change Before Tax
1000 tpd; $68.8 mm Base Investment
V^rirtMe Control Cost/Ton
Price Increase
Quantity Demanded Decrease (Tons)
Annual Revenue Change
Annual Ft/ed Coit Change
Annual Variable Process Cost Change
Annual Variable Control Cost Change
Annujl !ncopw Change Before Tax
Return on Investment Change Before Tax

Digester
Case 1
Piping &
Stand-by

Reconstruction Brown
Case 2
Piping,
In- Heat Ex-
clnerator changer, S
Required Stand-by
Incinerator


$0.20
$0.78
91
$+31900-
+ 34300-
- 14000-
* 16400-
- 4800
-" 0.02?

$0.18
$0.69
164
$+56600-
+60000-
-24600-
+29500-
- 8300-
~O2*

$0.15
$0.51
242
$+83800-
iij5«00-
-36300-
+49200-
-14900-
- 0.02*
Required

$0.37
$1.82
216
$+74400-
+85800-
-32400-
+30300-
- 9300-
- 0.043;

$0.67
$3.58
851
$+290900-
+343000-
-127700-
+109500-
- 33900-
~0.dTi

$0.67
$3.58
1702
$+581900-
+686000-
-255300-
+219000-
- 67UOO-
- 0.09%

Stock Washer
Case 1
Incinerate 1n
Recovery Eur-
nace or Power
Boiler


$0.09
$1.25
149
$+51000-
+68600-
-??400-
+ 7400-
- 2BOO-
'-•'o.or.'

$0.06
$0.93
221
$+76200-
+102900-
-33200-
+ 9800-
- 3300-
- 0.261

$0.06
$0.93
442
$+152400-
+2051)00-
- 66300-
+ 19700-
- 6BOO-
- o. on

Stage Addition
C.ise 2
Separate
Incinerator
Required


.$2.48
$4.37
579
$+177300-
+111480-
- 77900-
+202400-
- 58700-
: 	 o.?fis:

$2.43
$3.88
922
$+315200-
+171500-
-138300-
+396900-
-114100-
- 0. iSi

$2.43
$3.88
1845.
$+630000-
+343000-
-276800-
+793800-
-230000-
- 0.32*
Convert from
Direct Contact
to Indirrct
Contact, Recovery
Furnace
Another PrectplU-
tor Required


Not
Applicable






V

$0.09
$0.54
128
$+444CO-
+532CO-
-192CO-
+148CO-
- 44CO-
-"O.CTf

$0. C9
$0.54
257
$+88500-
+106300-
-386CO-
+29500-
- 8700-
- 0.01!
Convert L}Fie
Kiln Fuel
frvuH fijs
to Oil*

A 30" A Scrub-
ber Required


$0.09
$0.42
50
$+i?eoo-
+19400-
= 7 L Q^l_
+ 7400-
- 2100-
- O.OVi

$0.09
$0.31
74
$+25300-
+25700-
-1)100-
+14SOO-
- 4100-
^D.TDT?

$0.10
$0.25
119
$*41POO-
+34300-
-17900-
+32600-
- 8200-
- 0.01*.
Footnotes ;
                       Replacenent of components costing more than 50 percent of the cost of a new facility.

                       If emissions  Increased  and  the  bubble concept could't be applied, washer stage addition would represent a modification under alternative 1, 2, 3,
                       4, or 5.

                       If emissions  Increased  and  the  bubble concept couldn't be applied, furnace conversion would represent a modification under alternative 1, 2, 3,
                       4, or 5.

                       If emissions  Increased  and  the  bubble concept couldn't be applied, and the kiln was designed for oil, fuel conversion would represent t
                       •edification  under  alternative  1, 2, 3, 4, or S.

-------
           9.  RATIONALE FOR THE PROPOSED STANDARDS
9.1  SELECTION OF THE SOURCE FOR CONTROL
     Kraft pulp mills contribute significantly to national emissions
of total reduced sulfur (TRS) and particulate matter.  There are
currently 120 mills located in 28 states that produce over 90,000 tons
of pulp per day.  Nationwide emissions of TRS from kraft pulp mills
exceeded 200,000 tons in 1973; emissions of oarticulate matter totaled
400,000 tons durina the same year.  The industry is exneriencinq
a moderate growth rate of about 2.5 percent that is predicted to
continue through the end of the decade.  However, the rate is predicted
to return to a higher growth rate by 1980.  Standards based on best
demonstrated technology would have a significant impact on emissions
from newly constructed and modified facilities.
Total Reduced Sulfur (TRS)
     The reduction in TRS emissions from all domestic affected
facilities due to the increased control requirements of the proposed
standards is estimated to exceed 14,350 tons per year in 1980.  This
number is based on anticipated growth rates in new and modified
facilities.  Compared to emission rates under present average state
control standards, an increase in TRS emission control efficiency
of about 96 percent can be anticipated.
     TRS is an extremely odorous  gas, often detectable at concen-
trations of a few parts ner billion.   Odors from noorly controlled
kraft pulp mills may affect larqe areas and populations and may cross
State and national  boundaries.   Interstate activities and international
air pollution problems have been  caused by these emissions.  For
example, the State of Vermont sued the State of New York and

                                9-1

-------
                         References
 1.  Guthrie, John A.   An Economic  Analysis of  the Pulp and Paper
     Industry.  Pullman,  Washington,  Washington State University Press,
     1972.  pp.  1-15.

 2.  Van Derveer,  Paul  D. Profiles  of the  North American Pulp and Paper
     Industry.  Pulp &  Paper.   June 30,  1975.   pp. 32-33; 36-38; 43-44;
     48-49.

 3.  Wood Pulp Statistics 36th  Edition.  Pulp & Raw Materials Group,
     New York, American Paper  Institute, Inc.,  October 1972.  pp. 63-83.

 4.  Guthrie, John A. op. cit.  p. 4.   See  also  Arthur D. Little, Inc.
     Economic Impact of Environmental  Regulation on the Pulp and Paper
     Industry, Spring,  1976.

 5.  Hollie, Pamela G.  Paper  Industry, Facing Energy Shortage Turns
     Partly to Using Its  Wastes as  Fuel.   Wall  Street Journal.  July
     30, 1973.  p. 4.

 6.  Statistics of Paper  and  Paperboard  1973.   American Paper Institute,
     New York, American Paper  Institute, 1973.   p. 31.

 7.  Air Pollution Control  Technology and  Costs:  Seven Selected
     EmissionSources,  Industrial Gas Cleaning  Institute, EPA Contract
     No. 68-02-1091, December  1974.

 8.  Control of Atmospheric Emissions  in the Wood Pulping Industry,
     Environmental Engineering, Inc.  and J.E.Sirnne Co., Contract No.
     CPA 22-69-18, March  15,  1970,

 9.  Ibid.
10.  Ibid.

11.  Air Pollution Control  Technology  and Costs in Seven Selected Areas,
     Industrial  Gas Cleaning  Institute,  Inc.,  EPA Contract No. 68-02-0289,
     December 1973.

12.  Correspondence from Mr.  C.  T.  Tolar, Rust Engineering Company,
     Birmingham, Ala.,  to Mr.  Paul  A.  Boys,  EPA, dated October 20, 1972.

13.  Environmental  Engineering,  Inc. and J.E.Sirrine  Co., loc. cit.

14.  Ibid.

15.  Correspondence from Mr. T.  W,  Orr, Manager, American Can Company,
     Halsey,  Ore.  to Mr.  Paul  A.  Boys, EPA,  dated August 15, 1972, and
     September 8,  1972.

                                8-74

-------
These concentration levels are of short duration and are representative
of tFie worst case that is predictable under the assumed emission
conditions.  Control of TRS emissions to the level  required by the
proposed standards will substantially reduce the intensity of the
odorous emissions and the affected area where the ordors are preceptable.
     The available Information on the effects of TRS on the
public health or welfare is oriented toward the effects of
hydrogen sulfide (H2$) and of odors.  Since approximately 75
percent of TRS emitted from kraft pulp mills is H2S, and odors
are linked to the emission of all four of the constituent gases
of TRS, the following discussion primarily addresses the effects
due to the presence of f^S and odors.
      The effects of h^S in the ranges predicted near kraft nuln
 mills are summarized in Table 9.1.   At the lower concentrations only
 odor nercention and slight eye irritation are noted.  As the concen-
 tration ranges above 15,000 yg/rrP,  other irritant effects may be
 experienced.   Above 3n,noO yq/nr the maximum occupational 8-hour exnosure
 limit is exceeded.  The Illinois Institute for Environmental Quality
 noted that at levels between 10,000 and 70,000 yq/rtr of I^S, symptoms
 such as eye irritation, fatigue, loss of appetite, insomnia, nausea,
 and headaches will occur following  long duration.   At very hi ah
                                    •3
 concentrations, over l,000,onn yq/m , exnosure to hydrogen sulfide
 can cause death quickly by paralysis of the respiratory center.  The
                                9-3

-------

-------
sensation of odor at these levels is often lost due to olfactory
fatigue after short exposure periods, which increases the danger
of exposure.  Concentrations at these levels, however, are not
expected to occur as a result of emissions from kraft pulp mills alone.
     Studies indicate little evidence that hydrogen sulfide causes
any significant injury to field crops at ambient concen-
trations below 30,000 yg/nr.  Effects have been noted, however, on
painted surfaces and metals.  HpS may react with paint containing
heavy metal salts to form a nrecipitate which can darken  and discolor
the surface.  Experiments have shown that darkening is dependent
on both the duration of exoosure and the concentration at the surface.
Darkening has occurred after exposure to H£$ concentrations as low
as 75 ug/m3 for two hours.  Damage to house paint caused  by HpS
emissions linked to a kraft pulp mill has been reported in studies
on the communities of Lewiston, Idaho, and Clarkston, Washington.  H2S
has been linked to the tarnishing of copper and silver surfaces exposed
                              q
to concentrations above 4 yg/nr for 40 hours.  It will also cause some
alloys of gold to tarnish and has been shown to attack zinc at room
temperature, forming a zinc sulfide film.  However, at concentrations
normally expected in the atmosphere at kraft pulp mills,  HpS is not
corrosive to ferrous metals.
     Hydrogen sulfide is characterized by a "rotten eggs" smell that
is perceptable at the low levels previously cited.  Several studies
have linked the presence of odors of the type emitted from kraft
pulp mills to trends in several effects on humans, such as poor
                                 9-5

-------
International Paper Company over odorous emissions linked to a
pulp mill at Ticonderoga, New York.  The suit resulted in
increase in TRS emissions control from the mill in an effort to
reduce the intensity and range of effect of the odors.  EPA was
retained as a friend of the court and supplied technical information.
Emissions from kraft pulp mills near several other State border
areas have prompted similar involvement by EPA in the settlement
of interstate odor problems.
     TRS at kraft pulp mills consists of hydrogen sulfide, methyl
mercaptan, dimethyl sulfide, and dimethyl di sulfide.  Based on the
results of several studies,1'2 the odor thresholds of these gases are:
                                            Odor Threshold
            Compound
    Hydrogen Sulfide - H2S             .0005-. 022      
-------
the Clean Air Act, particulate matter has  been designated as  a  criteria
pollutant, and thus must be controlled to  the degree necessary  to
attain the ambient standards.
      EPA  has  determined that  emissions of TRS  and particulate matter
from  kraft pulp mills  contribute to  air pollution which  causes
or contributes to the  endangerment of  the public health  or welfare.
 Interstate  and international  control  problems  have  prompted  the  need
 for control  of these  sources.  Significant  reductions  in the mass
 emissions from these  sources  are possible through application of best
 demonstrated technology,  considering costs.   With the  control of the
 mass  emissions,  large reductions in  the ambient concentrations can
 also  be realized.  A  1975 report by  The Research Corporation of
 New England performed for EPA5 lists kraft  pulp mills  high on the
 list  of major sources requiring nationwide  control  of  HUS.   The
 study concludes  that  control  of kraft pulp mill emissions through
 NSPS  will result  in significant beneficial  impacts  on  the quality
 of the air within the  affected regions.
      A survey of  the  social and economic  impact of  odors conducted
 for EPA in  1971-1973  by  Copley International  Corporation^ found  that
 the pulp  and oaoer industry was ranked in the  upper quarter  of all
 odor  sources in  terms  of  both odor producing  potential and objection-
 ability of  the odorous emissions.  For all  of  these reasons, the
 source category of kraft  pulp mills  has been  selected  for emission
 control.

-------
                                TABLE  9.1

                       EFFECTS OF HYDROGEN SULFIDE3
           Concentration
                (opm)                         Recorded Effects
1-45 (7.2 x 10"4 - 3.2 x 10"2)      Odor threshold.   No reported  injury  to
                                    health

10 (7.2 x 10~3)                     Threshold of reflex effect on eye
                                    sensitivity to  light

150 (0.10)                         Smell  slightly nerceotible

500 (0.40)                         Smell  definitely perceptible

15,000 (11.0)                      Minimum  concentration causinq eye  irritation

30,000 (22.0)                      Maximum  allowable occunational  exposure  for
                                    8 hours (ACGIH  Tolerance  Limit)

30,000-60,000 (22.0-43.0)          Strongly perceptible but not  intolerable
                                    smell.   Minimum concentration causing lung
                                    irritation

150,000 (110)                      Olfactory fatigue in 2-15  minutes; irritation
                                    of eyes and respiratory tract after 1 hour;
                                    death in 8 to 48 hours
                                   9-4

-------
  dissolved  sulfides  in  the water  and  the  generation of sulfides by
  biological  action within the pond.   Standards requiring aerobic
  operation  of treatment ponds at  kraft pulp mills have been proposed,
  and will prevent the anaerobic production of hydrogen sulfide.
  Stripping of the waste condensate stream will prevent the presence
  of the dissolved sulfides.   Methods for measuring TRS emissions
  from kraft pulp mill treatment ponds  are not presently available.
  EPA has decided not to propose standards to control  this source
at present but is considering further  investigation of possible
measurement and control  technology as  a basis for future Agency action.
Definition of Affected Facility
9.2.1  Digester System
     The number of digesters used at a kraft pulp mill is highly
variable.  As few as one and as many as 34 individual  digesters
are being used at mills in the United  States.  In addition, mills
may use either batch digesters or continuous digesters.   The
affected facility in this case could be defined as each individual
digester unit, all the digester units  at a mill, or all  the batch
digesters and all the continuous digesters at a mill.
     The definition of the affected facility affects  the way in
which the emissions from existing digesters are covered by the
modification provisions.  If the affected facility is  defined
as the system of units, an addition of a new digester would be a
potential modification.  The new digester would contribute additional
TRS emissions from the facility.  These emissions would have to
                                 9-9

-------
9.2  SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
     Emissions of TRS nrimarilv occur at eight facilities in a
kraft nuin mill:  the diqester svstem, the brown stock washers,
the multiDie-effect evanorators, the black liquor oxidation system,
the recovery furnace, the smelt dissolvinq tank, the lime kiln,
and the condensate strinninq system.  Siqnificant sources of parti-
culate emissions are the recovery furnace, the smelt dissolvino
tank, and the lime kiln.  These eiqht facilities account for virtually
all of the TRS and narticulate emissions from an averaqe mill.  A
breakdown of emissions from these facilities is discussed in chanter 2
and summaries of the levels obtained durina the test nroqram are
nresented in chanter 6 and Appendix A.
     Kraft nuin mills have also been shown to be sources of emissions
of SO-, NO , and CO.  These nollutants result from combustion in
     C,    A
the recovery furnace and the lime kiln.  The levels at which these
nollutants are released are relatively low with respect to such
larqe sources as nower plants.  Control of these pollutants from kraft
pulp mills under new source performance standards is not presently
being considered, however, since no economical control technology for
kraft pulp mills has been adequately demonstrated.
     An additional potential source of TRS at many kraft pulp mills is
the treatment nond facilities.  TRS emissions from these onerations
vary from mill to mill due to differences in wood tvne and content
of the effluent stream.  Two main causes of TRS emissions from
treatment nonds that have been identified are the liberation of

-------
the affected facility on the recovery furnace(s), because of the
variety of designs encountered in the industry.  Therefore, the
entire evaporator system is defined as the affected facility,
along with the "associated condenser(s) and hotwell(s) used to
concentrate the black liquor."
9.2.4  Black Liquor Oxidation System
     As with the multiple-effect evaporators, the design and
layout of the black liquor oxidation system varies from mill
to mill.  Single, double, and triple stage oxidation systems
are all presently used in the industry.  Oxidation of weak black
liquor and strong black liquor may also be found at one mill.
     The affected facility could be defined either as each
individual oxidation tank or as all of the black liquor oxidation
processes at a mill.  The main purpose of adding an additional
stage of oxidation at a mill is to decrease TRS emissions from
the recovery furnace.   Defining each individual oxidation tower
as the affected facility would require control of emissions from
the additional new unit, even though the increase in emissions
is small compared to the reduction in TRS emissions from the
furnace.  The second alternative, however, would allow the small
incremental  increase from the oxidation system to be traded off
under the "bubble concept" with the reduction in furnace emissions.
Therefore, the affected facility is defined as "all of the vessels
used to oxidize, with  air or oxygen, the black liquor, and associated
storage tanks."
                                 9-11

-------
be controlled or traded off,  under the "bubble concept,"  elsewhere
in the same mill.  If, however, each individual  batch or continuous
digester is defined as the affected facility, any additional
digesters would be designated as new facilities, the emissions
from which would be subject to the proposed standards.
     To obtain maximum control of the emissions from new and
reconstructed digesters, the affected facility is defined as "each
batch or each continuous digester used for the cooking of wood
in white liquor, and associated flash tank(s), blow tank(s),
chip steamer(s), and condenser(s)."
9.2.2  Brown Stock Washer System
     The brown stock washers at kraft puln mills are usually
of the vacuum filter design, employing either three or four
stages of washing in each line.  It is difficult to distinguish
between emissions from the individual washers in each line.  In
addition, the knotters, vacuum pumps, and filtrate tanks are
potential emissions points within a washer system.  The
affected facility is therefore defined to cover all of
the emissions from each line of washers:  "each system of washers,
knotters, vacuum Dumps, and filtrate tanks used to wash the
pulp following the digestion process."
9.2.3  Multiple-Effect Evaporator System
     The design of the evaporator system may vary from mill to
mill depending on the number and configuration of the associated
recovery furnaces.  Multiple lines of evanorators may serve one
furnace, or a single line of evaporators may feed to more than
one furnace.  It would be difficult to base the definition of
                                  9-10

-------
9.3  SELECTION OF BEST SYSTEM OF EMISSION REDUCTION CONSIDERING COSTS
     The purpose of the orooosed standards is to require that best
emission control technology, considerinq costs, for TRS compounds
and particulate matter be installed and operated at new and modified
kraft PU!D mills.  The individual emission sources to be controlled
include all process gas streams at kraft oulo mills which are significant
sources of TRS and narticulate matter.  The proposed standards are
based on data on emission control systems and methods of process
operation received through (1) on-site observations of plant processes
and control enuinment, (2) consultation with industry representatives
and control equipment vendors, (3) emission tests conducted by EPA
and operators of kraft pulp mills, and (4) meetings with the National
Air Pollution Control Techniques Advisory Committee (NAPCTAC).
     The selection of the best system of emission reduction considering
costs is based on an evaluation of the incremental impacts (compared
to average state standards) on air emissions, air pollution control
costs, energy requirements, water pollution and solid waste pollution.
The first step is to select the most effective emission reduction
methods for each affected facility.  Then the impacts of the individual
methods are comoared to determine the best emission reduction method.
The best system to control TRS and oarticulate matter from an entire
kraft mill is an assimilation of the best emission reduction method
or methods for each facility, since the emissions from each facility
at a kraft mill are independent of emissions from other facilities.
                                  '••13

-------
9.2.5  Recovery Furnace System
     Each recovery furnace is defined as an affected facility.
Generally, each furnace is a separate entity and does not interact
with any other furnace at a mill.  If a furnace is used for
recovery of materials from both kraft, and neutral sulfite semi-
chemical pulping operations, it is covered by the proposed
standards.
9.2.6  Smelt Dissolving Tank
     The smelt dissolving tank associated with each recovery
furnace is a separate unit with no interconnections with any
other tank at a mill.  Therefore, the affected facility is defined
as each "vessel used for dissolving the smelt collected from the
recovery furnace."
9.2.7  Lime Kiln
     Each lime kiln operates separately from any other kiln at
a mill, with no dependence or interaction between kilns.  Therefore,
the affected facility is defined as each "unit used to calcine
lime mud...into quicklime."
9.2.8  Condensate Stripper System
     Only three mills currently use a condensate stripper system,
and each of these mills has only one unit in operation.  Although
it is conceivable that a mill could operate multiple units in
parallel, it is expected that all new condensate strippers will be
installed as separate systems.  The definition of the affected
facility is therefore each "column, and associated condensers,
used to strip, with air or steam, TRS comnounds from condensate
streams from various processes within a kraft pulp mill."
                                 9-12

-------
option.   There are no additional  TRS reduction technologies  that are
expected to be demonstrated in the near future.
     The typical  state standard for recovery furnaces  is  about
17.5 ppm.  This level is achievable by the use of either  control
system,  indirect-contact evaporation or direct-contact evaporation
with black liquor oxidation.   However, EPA feels that  the indirect-
contact  evaporation system is capable of achieving much lower levels
and is more efficient than  would be required to meet the  average
state standard.  Therefore, the baseline system, upon  which  the impacts
associated with the alternative control levels are compared,
requires control  of TRS emissions with a single stage  of  black
liquor oxidation and application of process controls with a  direct-
contact  evaporator system.
     The two types of systems, indirect-contact evaporation  and
direct-contact evaporation with two or more stages of black  liquor
oxidation, are judged to be equally effective in controlling TRS
emissions to meet the level of the proposed standard.   Source tests
by EPA have shown that indirect-contact systems can achieve  a
slightly lower level in some cases.  However, when the fluctuations
in emissions from the indirect-contact system is taken into  account,
both systems are considered equivalent for TRS .cotitrol.
     Neither method produces significant water or solid waste pollution.
The indirect-contact furnace requires a larger capital expenditure
than a conventional furnace because a larger economizer section is
required on the furnace and an additional steam evaporator is also
required.  Consequently, the indirect-contact furnace has a  larger annual
                                 9-15

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expense,because of the annual charges associated with the increased
capital and a fuel charge due to heat loss.  This is discussed in
detail in chapter 8.  The incremental capital costs and operating
costs over the average State standards are considered to be reasonable
for both methods.  The energy requirements for a mill that uses an
indirect-contact furnace, as a percentage of the total plant fossil
fuel and electrical requirements, are as much as 10 percent higher
than the mill using a direct-contact furnace.  This is due to an
estimated effective flue gas heat loss of 120°F.  This heat loss
arises because the optimum economizer for an indirect-contact furnace
and the process stream requirements result in the combustion gases
leaving at a higher temperature, and some additional steam is also
required in the additional evaporator unit.
     Parti oil ate Emissions - The two demonstrated methods for controlling
particulate matter from the recovery furnace are scrubbing and electro-
static precipitation (ESP).  Fabric filtration has been considered by
some operators, but it has not, been demonstrated and is not considered
to be currently available.  For a scrubber to achieve the particulate
emission control levels attainable with an ESP (0.02-0.05 gr/dscf),
a very high pressure drop would be required.  The very few scrubbers
that are presently used for control of particulate emissions from
recovery furnaces have relatively low collection efficiencies compared
to an ESP.
     The industry'' has commented that there is a gradual deterioration
in performance over the life of an ESP in the kraft industry, even
                                 9-16

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 if the precipitator is well maintained.  The industry also commented
 that the performance of an ESP should be allowed to deteriorate
 until a sufficient amount of maintenance is necessary to justify
 shutting down the unit and performing the maintenance.
     EPA investigated these comments by contacting plant operators
                                                     11 1 ?
 and discussing these comments with equipment vendors.11'    EPA's
 conclusions, discussed in detail in chapter 4, are that a precipitator
 will not significantly deteriorate with age provided the wires,
 collection plates, and rapping system are well maintained.  The
 vendors contacted by EPA agreed that the design of precipitators
 to be used on kraft recovery furnaces should be more rugged than
 for most other applications because the particulate matter from
 kraft furnaces is sticky and requires intensive rapping to separate
 it from the collection plates, thereby requiring a more sturdily
 built precipitator.  Some precipitators that are ruggedly designed
 have recently been put into use in the domestic kraft pulping industry.
 The wires on this type of precipitator are fastened at five-foot
 intervals, and very few wires have broken in operation.
     Currently precipitators for the kraft industry are designed
to achieve an emission level  of 0.05 q/dscm.   EPA has tested three
units that achieve particulate concentrations below this desion
level.   EPA agrees with the industry that the performance of a
precipitator'should be allowed to deteriorate somewhat (until  a
sufficient amount of maintenance is necessary to justify shutting
down the unit and performing the maintenance],  but feels that  this
has been adequately considered in setting the proposed standard
of 0.10 g/dscm.

                                 9-17

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     There are no water or solid waste impacts associated with ESP's
used on recovery furnaces because the collected particulate matter,
which is salt cake, is recycled directly back to the process.   State
standards require a collection efficiency of approximately 99  percent;
however, precipitators that achieve a collection efficiency of approxi-
mately 99.5 percent are currently available.   The incremental  enerqy
requirement of a 99.5 percent efficient ESP compared to one with the degree
of efficiency required by state standards is neqliqible.   Data on the
enerqy consumption of these units are presented in chapter 7.   For
a 1000-ton-per-day kraft mill direct-contact recovery furnace,
the incremental  capital cost for the more efficient ESP over a state
standard is $460,000, and the incremental annual cost is  $110,000.
The incremental  costs and the total costs are considered  to be
reasonable.  Therefore, a precipitator with a collection  efficiency
of approximately 99.5 percent is considered to be the best method
of emission reduction, considerinq costs.
     Recovery Furnace Control System - The best demonstrated technology,
considering costs, for controlling both TRS and particulate matter
emissions from the recovery furnace is a 99,5 percent efficient
precipitator and either a direct-contact black liquor oxidation
furnace with two stage of bTack liquor oxidation and good combustion
control in the furnace or an indirect-contact furnace with good
combustion control in the furnace.
9.3.2  Smelt Dissolving Tank
     The smelt dissolving tank is a source of both TRS and particulate
emissions at a kraft pulp mill.  The particulate matter is comprised
                                  9-18

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of finely divided smelt particles that become entrained in the
steam emitted from the tank.   TRS emissions may be generated in
either the dissolving tank itself or in the participate scrubbing
device, and strongly depend on the quality of water used either to
dissolve the smelt or to carry out the scrubbing.
Participate
     Particulate emissions from the smelt dissolving tank are controlled
by using either wire mesh demister pads with countercurrent washing,
a low energy scrubber, or a combination of these two methods.  The
demister pads require very little energy to operate, the circulation
of the washing water being the major factor.   Consequently, the operating
costs are very low.   The second alternative,  the scrubber, has been
shown to be a more efficient  control device,  removing as much as
five times the amount of particulate matter as a demister,  The third
alternative, the combination  system, is similar in control efficiency
and costs to the scrubber. The energy requirement for the scrubber
is much greater than that for the demister, although small in comparison
to total process energy requirements at a kraft pulp mill.  The operating
costs for this alternative are slightly higher.   These costs, however,
are considered to be reasonable.
     TfiS - TRS emissions are  primarily caused by the presence of
reduced sulfur compounds in the smelt and in the water used to dissolve
the smelt.  Since a  portion of the TRS compounds is dissolved in the
condensed vapor, TRS removal  is related to the efficiency of the
particulate collection device.  When process- water contaminated by
sulfides and sulfates is used in the scrubber, reduced sulfur emissions
                                 9-19

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can be stripped from the scrubber water and emitted to the atmosphere.
These sources of emissions can be reduced at little cost by insuring
that the water for dissolving smelt and the scrubber water are
uncontaminated with dissolved sulfides.  The best system of emission
reduction  for TRS emissions from this facility is the use of water
that is not highly contaminated with dissolved sulfides from dissolving
the smelt  and for scrubbing.  This requires no additional energy,
and the costs for using water that is not highly contaminated are
very low and considered reasonable.
Best Method for TRS and Particulate Emission Reduction
     Cost, energy, water and solid waste impacts are not significantly
different  between the three systems considered.  Therefore, emission
reduction  efficiency is the determining factor.  The use of water
that is not highly contaminated with dissolved sulfides for dissolving
the smelt  and in the scrubber and the use of a low energy water
scrubber or a combination demister/low energy water scrubber is
considered to be the best system of emission reduction, considering costs.
9.3.3  Lfme Kiln
     TFie ITme kiln is a major source of both TRS and partTculate
emissions  from a kraft pulp mill.   Emissions from a poorly controlled
facility may range to over 100 ppm TRS,  and 4.0 Ib/ton ADP for particu-
late matter.
     Several  alternative systems for the control  of these  emissions
have been  identified and studied in detail.   These  are summarized for
a  1000  TPD  model  kraft pulp mill  in Table 9.2,  which outlines  the
control  technologies  that  are  considered to  be  most effective  for
the simultaneous  removal of TRS  and particulate matter.  This  allows
                                     9-20

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                                TABLE 9.2
COMPARISON OF THE ALTERNATIVE CONTROL SYSTEMS FOR THE LIME KILN SYSTEM
                  (1000 ton per day Kraft Pulp Mm)






Lire Kiln
^Control
System


1
Baseline

2

3

4
5
-a
-s
o
o
Ul
o
3
rl-
-5






X

X

X

X
X
_•
tn
...
m
3
-5
t/>

O"
o-
n>
-s


X






X
<*>

^
ni
3
c-t-

l/l
O
-5
rr
O"
ID
1




X

X



o
Q>
c
t/i
r*
n
Q_
Q.
^:
o







X




X
m
n>
Ct
rt-
O
OJ
rt
O
-o
0)
n
3
01
-o-






X
X

MAXIMUM fiWWD LEVEL
CONCENTRATION
(vq/m3)
LIME KILN CONTRIBUTION ONLY
(at distance from mill noted)


TRS
(1-hour average)

1,4
(4nn in.)
0.9
(650 m.)
1.8
(650 m.)
1.8
(650 m.)
0.9
(650 m.)

PARTI CULATE
(24-hour averaqe)

7.9
(800 m.)
4.0
(800 m.)
4.0
(800 m.)
1.3
(800 m.)
1.3
(800 m.)




TOTAL
INCREMENTAL
ENERGY
REOUIREMENT
(106 Btu/day)


0

187

187

575

613

INCREMENTAL
CONTROL COSTS
(December 1975 dollars)


Capital
Cost
($)


0

25,000

25,000

210.000

350.000


Annual
Costs
($/yr)


0

112,100

106,100

252.300

351,300

Annual
Cost
per ton
($/ton)


0

0.341

0.323

0.768

1.069

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a point-by-point comparison to be made nf all  of the major factors
that were considered in the selection of the best emission reduction
system.
     System number 1 was chosen as the baseline system with which
the other alternatives are compared.  This system is the type of
control technoloqv that is most often applied to lime kilns at existing
mills:  orocess control for limitino TRS emissions and a medium
pressure drop scrubber, approximately 15 inches water gauge, for
oarticulate control.
     System number 2 is based on more effective control technology
for both TRS and particulate matter emissions.  A 30-inch water gauge
pressure drop venturi scrubber is used to control the oarticulate
emissions.  More efficient process controls are applied to the
operation to reduce the TRS emissions; the cold end temperature
is  raised as much as 100°F, while the orooer r>2 concentration and
temperature are maintained to provide better combustion conditions
in  the kiln.  In addition, the efficiency of the mud washing that
is  used prior to the calcining process is improved.  These imoroved
process controls have been shown to have a significant effect on
the concentration of the emitted TRS.  In addition to the process
controls for TRS reduction, a caustic solution is used in the
scrubber.  It has been demonstrated that the addition of the caustic
to the scrubbing water has the capability of reducing the TRS
emissions by as much as 10 ppm at the level expected from a well-
controlled facility.  This type of system is presently in use on at
least two kilns in the U.S.
                                 9-22

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     System number 3 is similar to system 2 and uses the same type
 of  venturi scrubber and the same level of process controls.  However,
 caustic  is not added to the scrubbing fluid.
     System number 4 uses  the  same  orocess  controls  as  system number 2
for control of TRS.   However,  the venturi  scrubber is  reolaced
with a high efficiency electrostatic orecipitator (ESP), which provides
a larqer reduction of the  oarticulate matter emissions.   This system
is presently used at only  one  U.S.  mill.
     System number 5 represents a proposed  control  technique  that has not
 been aoolied in the industry.   The system is a combination of the
 best parts of the orecedinq alternatives, combininq the most effective
 process controls, caustic  addition to a scrubber of 15 inches water
 qauqe pressure drop, and an ESP with efficiency comoarable to that
 used in system number 4.  It is assumed that the scrubber and ESP
 can be installed in series with no major desiqn difficulties, althouqh
 this has not yet been demonstrated.  A low pressure drop packed
 tower would probably give more contact and retention time than a
 venturi scrubber and is considered to be more effective in controlling
 a gas than a venturi scrubber.
     The industry has commented that, if a lime kiln is controlled
with an ESP, it may not be feasible to combust the off-qases  from the
digester system, multiple  effect evaporator system, or condensate
 stripper system in the kiln; there would be a possibility of an
explosion of the gases from these systems  in the precipitator in
the event of a flameout in the kiln.  In such a case,  a separate

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incinerator is required for the control  of these gas streams.   The
enerqy requirements and incremental control costs for this unit are
included in the taBle for systems 4 and  5.
     The enerqy requirements and control costs for each alternative
control system are also presented in Table 9,2.   The incremental
values with system number 1 used as the  baseline are shown.
     The enerqy requirements for emission control are higher for
a system employing an ESP Csystems 4 and 5).   The amount consumed
by the ESP itself is a small portion of  the total.  The majority
of the consumption is the fuel  requirement of the incinerator
unit, the use of which is necessary with the  ESP,  The requirements
are increased further when the venturf scrubber is added to the
ESP in system 5.
     The environmental impacts associated with the use of the alternatives
have been evaluated and are discussed in chapter 7.  The conclusion
is that no significant water pollution or solid waste disposal
problems will be incurred due to the use of these control devices,
Selection of Best System
     In selecting the Best system of emission reduction considerino
cost from these alternatives, the air, cost,  energy, water, and
solid waste impacts were considered.  The water and solid waste
impacts are negligible and therefore are eliminated as a basis
for judgment.  Each system that utilizes an ESP has a higher energy
impact, a higher capital and annual cost impact and a higher impact
on particulate matter reduction.  Any system  which uses a caustic
scrubber without an ESP has a lower energy impact, a lower capital
                                 9-24

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cost impact, a slight annual cost impact, a high TRS reduction impact,
and a low particulate matter impact.
     The best system of emission reduction not considering energy
or cost is system 5 which employs the best of both the TRS and
particulate matter technologies.  In  comparison to system 2, which
uses the best TRS control, it uses about 85 percent more energy
(approximately 7.9% of total process  electrical and fossil fuel
and energy requirement), is significantly more costly and reduces
the particulate matter concentration  slightly.  System 2 was selected
over system 5 because it is less costly, provides the same reduction
of TRS emissions, and only slightly less particulate matter reduction.
The Agency does not think that the additional cost and energy
requirements are justified by the small  increase in the reduction
of particulate emissions.
     Comparing system 2 to system 4,  system 4 has a slightly higher
particulate matter reduction impact,  a lower TRS reduction impact,
a significantly high capital and annual  cost impact and an energy
impact (an increase of less than 7.5% compared to mill process
electrical and fossil fuel energy).  System 2 was selected over
system 4.
     System 2 was selected over system 3 because system 3 has a
significantly lower TRS reduction impact even though it has a
slightly lower annual cost imnact. Therefore, system 2 which
includes a 30-inch caustic scrubbing  system is considered to be the best
system of emission reduction considering cost for the lime kiln,
                                 9-25

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and the proposed standard is  based on the level  achievable  by
this method.
9.3.4  Diqesters, Brown Stock Washers, MuKiDie-Effect  Evaporators,
       Condensate Stripper snd Black Liquor Oxidation System
      Emissions  from the digesters, brown  stock washers,  black  liquor
 oxidation tanks, multiole-effect  evaporators,  and  condensate
 strippers account for approximately 25 percent of  the  total amount
 of TRS released from an average kraft oulp mill.   The  emissions
 from these facilities are generally of a  high  TRS  concentration
 and cause a  substantial part of the localized  odor problems associated
 with kraft nulp mills.
      Control of these gaseous emissions has been well  demonstrated
 at several sources by incinerating the gases in  the recoverv  furnace,
 the lime,,kiln,  and separate incineration  units.  With  nrooer  control
 of combustion conditions, the TRS can be  oxidized, thus  reducing
 TRS emission levels significantly from uncontrolled facilities.
 The cost impacts associated with  this method.of  control  are
 basically for the additional hooding, piping,  and  blowetfs
 required for collection of the gases and  delivery  piping and
 controls for the injection of the oases at the incineration point.
 Additional condensation equipment may also be  required for  the
 handling of  the vent streams from the brown  stock  washers and
 the black liquor oxidation system.  The streams  from these  two
 facilities are  often  very moisture laden and must be  condensed
 prior to incineration in the recovery furnace.
      Utilization of the non-condensables  from the  brown  stock washers
                                 9-26

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  and the oxidation tanks may require additional fuel consumption
  at the ooint of incineration, usually the recovery furnace.  Incineration
  of the non-condensable gases from the other three facilities would
  not require additional fuel if they are burned in the lime kiln
  as part of the primary air feed.
       A few facilities have been observed that are controlled
  by various types of scrubbing systems.   These systems are much  less
  efficient than incineration and incur an added energy impact.   Scrubbing
  is not considered to be the best method of emission reduction  considerng cost.
       Incineration is applicable to all five of the affected facilities
  and has no significant water, solid waste, or energy impacts.   TRS
  emissions are significantly reduced by incineration so there is a
  positive air impact, and the cost is considered to be reasonable.
  Therefore, incineration is considered to be the best method of
  emission reduction considering cost for these five TRS emission sources.
9.3.5  Best System of Emission Reduction Considering Cost for a
       Kraft Pulp Mill
     The best s.y;s.tem-af emission reduction for a kraft pulp mill,
is a collection of the best systems identified in section 9.3
for each of the affected facilities.  This system includes the following
methods of improved process operation, types of process equipment and
types of control equipment:
     Recovery Furnace - Process control, indirect contact
      System
                        evaporator, and ESP; or alternatively,
                        process control, direct contact evaporator
                        with additional black liquor oxidation and
                        ESP.
                                  9-27

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     Smelt  Dissolving - Use of water that is uncontaminated with
      Tank
                       sulfides for dissolving smelt and in the water

                       scrubber, and a low energy water scrubber.

     Lime Kiln        - Kiln process controls, more efficient lime

                       mud washing, and a 30'inch water gauge pressure

                       drop venturi scrubber with caustic addition.

     Other  Sources:   - Collection of fumes and incineration in lime
      Black liquor
       oxidation,       kiln, recovery furnace or separate incinerator.
       system
      brown stock
       washer
       system,
      multiple-effect
       evaporator
       system,
      condensate
       stripper
       system,
      and digester
       sys tern

     The cost  for  the  aggregate  of these  systems  for

each facility  has  been  evaluated in chapter 8,  and  the  total  costs

are considered reasonable.   Therefore,  this  is  the  best system

of emission reduction  for a kraft pulp  mill,  considering cost,

and the proposed standards  are  based  on this  system.
                                  9-28

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9.4  SELECTION OF THE FORMAT OF THE PROPOSED STANDARDS
     Standards for kraft pulp mills could be expressed in terms of
either mass emissions ner unit of production or a concentration
of pollutant in the effluent gases.  The most common format now
used by the industry and state control  agencies is pounds of
pollutant per ton of air-dried unbleached nulp produced (Ib/T ADP).
This format offers the advantage of preventing circumvention of
the standards bv the addition of dilution air or the use of
excessive guantities of air in process  operations.  The principal
disadvantage is that a control agency cannot readily or accurately
measure the pulp production over the short term.  Due to storage
capacity of the mill, the recovery furnace, smelt dissolvina tank,
lime kiln, concentrate strippers, black liguor oxidation tanks, and
multiple-effect evaporators can be operating on accumulated inventories
when the digesters are off stream (no oulo production).  Similarly,
the above facilities can be operating below capacity even though
the pulp production may be at design rates.
9.4.1  Particulate Standards
     Concentration units are recommended as the format for the proposed
Particulate standards for the recovery  furnace and lime kilns.  The
reasons for this decision are outlined  below:
     a.  Concentration units can be corrected for excess oxygen in
the lime kiln and recovery furnace exhaust streams, precluding
circumvention of the standards by dilution.
     b.  Only precise measurement of emissions and gas velocities
are reguired to determine compliance with a concentration standard;
therefore, accurate measurement of production of feed rates is not reguired.
                                 9-29

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     c.   Most of the data (EPA, state and local  control  agency, and
company data) which are used to support the proposed standards are
in the format of concentration units.  The bases used by onerators
and control agencies to convert from concentration to Ib/ADP in manv
cases are not consistent and are not clearly defined.  Converting
the data to another basis could introduce substantial inaccuracies.
     The format for the oroposed narticulate matter and TRS standards
for smelt dissolving tanks is discussed under section 9.4.3.
9.4.2  TRS Standards
     Concentration units are also recommended as the format for
the oroposed TRS standards for the digesters, the brown stock
washers, the black liquor oxidation system, the multiple-effect
evaporators, the recovery furnace, the lime kiln, and the condensate
stripping system.  The reasons for the selection of this format are
outlined below:
     a.   Same as a. and c. under the nrevious section for narticulate
standards format.
     b.   The reference test method for TRS reads out data in
concentration units.  No conversion factors are therefore required
in determining compliance for the affected facilities.
     c.   Average concentrations are prooosed rather than instantaneous
concentrations to allow for fluctuations in emissions which occur
even during periods of normal operation.
     Four hours was chosen as the averaqing period in order to
allow a sufficient number of test readings to be taken.   The proposed
reference test method, gas chromotoaranhy, requires readinas to be
taken at 15-minute intervals.  A 4-hour average would allow enough
                                  9-30

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readings (sixteen) to make some allowance for short-term emission
peaks, while being short enough to allow for a reasonable testing
period.
     d.  Commercially available continuous monitors that may be
used to measure emissions from these facilities indicate concen-
tration directly.  A direct indication of performance of the control
systems would be available, and therefore the operator would be
aware of excess emissions that require corrective action.
9.4.3  Standards for Smelt Dissolving Tanks
     The proposed particulate and TRS standards on smelt dissolving
tanks are expressed in grams per kilogram ADP (g/Kg ADP) to prevent
circumvention by dilution.  EPA tests show that gas volumes from
existing smelt tanks vary in exhaust concentrations by a factor
of as much as 2.5 even though the smelt dissolving tanks have the
same mass emission rate (g/Kg ADP).   Dilution cannot be prevented
by correcting for excess oxygen because the exhaust stream discharged
from the smelt dissolving tank is mostly ambient air.
                                 9-31

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9.5  SELECTION OF THE EMISSION LIMITS
     Limitations for control  of emissions of TRS and particulate
matter are set to the level  attainable using the best demonstrated
technology, considering costs, for each affected facility.   This
control technology is identified in section 9.3.  The purpose
of this section is to quantify the proposed standards by specifying
the emission limits.  The rationale for selecting the proposed standards
over alternative emission levels is presented in this section.
     In section 9.4 the format of the proposed standards is discussed.
Concentration standards for TRS and particulate matter for all
affected facilities excepting the smelt dissolving tank are proposed
in ppm and g/dscm, respectively.  The proposed TRS and particulate
standards for the smelt dissolving tank are in terms of mass oer
unit of production (g/Kg ADP).
     A presentation of the emission data that were gathered during
the source testing program is summarized in chapter 6,  A description
of the facilities tested and all pertinent information relative to
the operation of testing of each facility is included.  A complete
summary of all the tests is presented in Appendix C.
9.5.1   Recovery  Furnace
     As  discussed  in  section  9.3.1,  two  classifications of  recovery
furnaces  in  use  in  the  kraft  pulping industry  today are (1) the conventional
system which uses  a direct contact evaporator  and requires  oxidation
of the black liquor,  and  (2)  the newer system which  uses an indirect-contact
evaporator.   Good  control of  combustion  is  necessary to maintain
the best  levels  of TRS  control.  Best demonstrated  narticulate control
                                  9-32

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for both systems is achieved by the use of a high efficiency ESP.
Particulate Emissions
     Four recovery furnaces were tested by EPA for particulate
emissions:  two direct contact systems and two indirect contact
systems.  All four systems are controlled by electrostatic orecinitators,
with design efficiencies of 99.5 to 99.8 percent.
     Furnace J has two stacks, both of which were tested by EPA.
Stack J" had emissions hiaher than would normally be expected from
the design efficiency, and much higher than stack J'.  Both predpitator
systems were of equal design and each handled approximately 50 percent
of the exhaust flow.   Upon investigation it was found that precipitator
J" was probably not operating in a normal manner during the
test.  The turning vanes and air distribution plates were caked with
particulate salt, resulting in improper air patterns within the pre-
cipitator and reduced collection efficiency.  The unit had not been
recently cleaned, as  had unit J1, and there was no cleaning mechanism
operating on the precipitator during the tests.  The results of six
test runs on this unit showed an average concentration of 0.12 g/dscm
(0.054 gr/dscf), well above the levels measured on stack J1.  The  remainder
of this section deals only with the results of the valid stack tests.
     The average of  the remaining tests was 0.03 g/dscm (0.013 gr/dscf).
The  range of the individual test runs was 0.01 to 0.08 g/dscm  (0-008
to  °-°35^r/c|scf)i   TI^ proposed standard for particulate matter emissions
from the recovery furnace is 0.10 g/dscm (0.044 gr/dscf}, a level
adequately substantiated by the emission tests.  Both types of
furnace systems have been shown to be capable of meeting this emission
limit.  With proper  maintenance of the wires, collection plates, and
rappers, the efficiency of the control system can be maintained at
this level.
                                 M3

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      As  discussed  in  section  9.3,  precipitator  performance may
 deteriorate  due  to broken  wires  and  ooor air  distribution within
 the precipitator.   This  may gradually  occur over periods of  12
 to 18 months of  normal operation,  at which  time maintenance  of  the  unit
 will  result  in a return  to the  design  efficiency.   The  level  of
 0.10 g/dscm  (0.044 gr/dscf) will  reauire that the best  system of
 emission reduction, considering costs, to be  properly operated
 and maintained.

TRS Emissions
     TRS emissions were tested from three recovery furnaces:   two
direct contact systems and one Indirect contact system.   The  two
direct contact systems employ black liquor oxidation for reduction
of TRS from the furnace.   Proper combustion parameters are maintained
to control emissions from the furnace firing process on  both  types
of systems.  The  emissions tested from these two facilities ranged
from about 1  ppm  to 7 ppm, and averaned about 3  ppm (4-hour averages).
The test data from the one indirect contact system averaged about n.6 ppm.
The range of the  Individual test runs was 0.2 to 1.6 ppm (4-hour
averages).
Oxyaen Correctt_on_
     The oxygen content of the flue gas measured during the tests
varied between 5  and 10 percent.  Measurements of the concentration

-------
in the gas stream before and after the precipitator indicate that
leakage into the unit can be expected, thus diluting the particulate
concentration.  Although regulations prohibiting circumvention
of the concentration standard by dilution are in effect, it is
difficult to distinguish between process  air and dilution  air.
Therefore, some provision is needed to correct for excess  air
inleakage in the outlet stream.  When the oxygen concentration exceeds
8 volume percent 0~, the correction will  be made down to 8 percent.
Well operated and controlled furnace and  precipitator systems will
normally operate below 8 percent 02, so corrections will not be
required in every case.
      In summary,  the emission  test data  show that both types of
 furnace systems are capable of achieving TRS concentrations below
 5 ppm on a four-hour average.   TRS emissions fluctuate over long
 periods and may exceed the 2 to 3 ppm averages  reported.   These
 variations are unaccountable in terms of furnace operation, but
 must be taken into consideration in the  selection of the  emission
 limit.   The chosen level  of 5  ppm (4-hour average, corrected to
 3 volume percent 02 when the concentration exceeds 8 percent)
  reflects the levels that are achievable, while allowing  for some
  variation in emissions over a four-hour period.  This 5  ppm level
  will also allow flexibility in the choice of furnace system
  to be used.
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9.5.2  Smtlt Dissolving Tank
     Tht use of a low energy scrubber with uncontamlnated water
In the tank and scrubber column was identified as the best emission
control system, considering costs for this facility.   This tyne
of system was tested by EPA on two facilities for particulate
matter and two facilities for TRS.
     The format for the nronosed standards for this facility is
discussed in section 9.4.  A mass per unit of production format,
g/Kg ADP, is proposed to prevent circumvention of a concentration
standard due to the large amount of process air normally present.
Particulate Emissions
      The data for particulate emissions from the four units tested
 ranged from about 0.05 to 0.22 q/Kg ADP.   The average of the test
 runs was approximately 0.13 g/Kg ADP.  Emissions from these facilities
 vary over long periods of operation.   By oroposinq the standard at
 0.15 g/Kg ADP, this fluctuation is taken into account while still
 reguiring the use of best demonstrated technology, considerina costs.
 TRS Emissions
      Two smelt dissolving tanks were tested for TRS  emissions, yielding
 results of 0.004 and 0.008 g/Kg ADP.   Twelve facilities were tested
 by the National  Council of the Paner Industry for Air and Stream
 Improvement (NCASI) showing values ranging from less than 0.001 to
 0.06 g/Kg ADP.  The higher data, however, are from tests on facilities
 that do not use  the best control system previously outlined.   But
 the results indicate that there is a large range of  variation in
 emissions from even well  controlled facilities.   The pronosed emission
 limit of 0.0125  g/Kg ADP  requires that the most  efficient control

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system be used, while allowing for some degree of variation in the
emissions.
9.5.3  Lime Kiln
     The proposed standards are based on control of TRS and particu-
late emissions from the lime kiln through good orocess controls,
use of a 30-inch pressure drop venturi scrubber, and addition of
a caustic solution to the scrubbing water.  A detailed discussion
of this technology is fin chapter 4, and the reasons for its
selection as the best demonstrated technology, considering costs,
is presented under section 3 of this chapter.
Particulate Emissions
     EPA  performed tests for  particulate  emissions  on  four lime
 kilns.  Emissions from each kiln  were  controlled by a  venturi
 scrubber, with  a  ranqe of pressure  drops  of  15  to 33 inches water
 gaijcje.  Where  possible, separate  tests were  performed  while the
 kilns were  burning oil and  natural  gas; it was  noted that  the
 particulate emissions were much higher when  fuel  oil was burned.
 The  test  results  are  nresented in chanter 6  along with a short dis-
 cussion of  each facility tested.  A complete summary of each
 test run  is presented in Appendix C.
     Tests  on  Kiln D  show very high emissions,  not  considered
 representative  of control with best demonstrated technology.  These
 results were presented to show the  range  of  emissions  encountered
 during the  test nrogram.  The data  were not  used in the selection
 of the emission limits for  lime kiln  particulate emissions.
     Tests  on  the three  remaining kilns show that much lower  emission
 concentrations are achievable.  When  burning natural  gas as fuel,
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participate test runs showed a range of 0.05 to 0.15 g/dscm (0.022
to 0.066 gr/dscf) and an average of about 0.09 g/dscm (0.04 gr/dscf).
Emissions were higher when oil was burned instead of gas.  Tests
on Kiln L were particularly high, averaging 0.548 g/dscm (0.24 gr/dscf),
It was concluded that these high concentrations resulted from
incomplete combustion of the oil.  These results were not used in the
selection of the emission limits.  The results of the remaining two
tests showed individual runs ranging from 0.07 to 0.29 g/dscm
(0.03 to 0-13 gr/dscf).  The average of the five runs was 0.10 g/dscm
(0.04 gr/dscf).  When during any of the above reported tests the
oxygen content of the exhaust stream exceeded 10 volume percent,
the measured emissions were corrected to 10 percent $2-
TRS Emissions
     Tests on three lime kilns for TRS emissions show a range of
from less than 1 nnm to about 24 onm, on a four-hour average.  Two
facilities are controlled through application of good process controls.
Emissions from Kiln D averaged 9.8 ppm (four-hour average) over
six test runs.  Emissions from Kiln K averaqed about 6 ppm (four-
hour average) also over six runs.  In both cases, fresh water was
used as makeup to the scrubbers for narticulate control, and the
sulfide content of the lime mud was quite low, between 0.3 and 0.4
percent.  Noncondensab3e gases from the digester system, the multiple-
effect evaporators, or turpentine recovery system were burned in
the kilns during the tests.
     Six test runs on Kiln E resulted in a range of four-hour average
emissions of H.3 to 1.7 ppm, averaging 0.7 pom.  TRS emissions are
controlled at this kiln by maintaining good process controls and
by adding a sodium hydroxide solution to the fresh scrubbing water.
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     Further test data were supplied by the mill  that operated the
caustic scrubber to give an indication of the variations in the emission
concentrations over a longer period of time.  The period selected
was 3D days, which Included the time when the EPA source tests were
performed.  Data were continuously monitored and recorded with
a coulometric titrator manufactured by ITT-Barton, which was
operated according to the specifications set by the manufacturer.
     EPA analyzed the data for the entire 30-day period
excluding periods of start-up, shutdown, and malfunction.  Readings
were recorded every 15 minutes in order to compute 1-hour averages
and then 4-hour averages.  When any point within a specific one-hour
period exceeded 5 pom TRS, a manual integration was performed
using a planimeter.  The four-hour averages were computed using both
of the data sets.  A summary of the data analysis is presented in
Tables 9.3 and 9.4.9
     The analysis shows that for the neriod under consideration,
the four-hour average TRS concentration exceeded 5 ppm only 6 percent
of the time, and the maximum four-hour average did not exceed in opm.
A twelve-month period which includes the month of data analyzed by
EPA was reported by the mill operator to have a total of 58 such excursions
above 5 ppm TRS.  This total, however, included emissions during
periods of start-up, shutdown, and malfunction, and must be reduced
to reflect the number of excursions during periods of normal operation.
At least 12 excursions must be subtracted from the total; this leaves
46 excursions, which is an average of less than 4 per month.  Therefore,
it is probable that the period of operation analyzed by EPA represents
a month in which excursions were more numerable than usual.  Since the

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                                TABLE 9.3

                                Lime  Kiln E
                          Distribution of TRS Data
                      Four-hour Average Concentration:
                       September 1  -  October 1,  1973
4-Hour Average*
    .EEEL
Number of Readings
Exceeding Average
Percent of Total
Exceeding Average
0
1
2
3
4
5
6
7
8
9 - 26
96
31
13
9
6
8
2
2
1
0
57.1
18.5
7.7
5.4
3.6
4.8
1.2
1.2
0.6
0
    Totals
       168
         (rounding
   100.1  off error)
      *Four-hour averages calculated from strip chart readings taken
       every 15 minutes.
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                               TABLE 9.4

                               Lime Kiln  E
                          Distribution  of TRS Data
                      Four-hour Average Concentrations
                       September 1  - October  1,  1973
4-Hour Average*
     ppm
Number of Readings
Exceedinq /W?r?qe
Percent of Total
Exceeding Average
0
1
2
3
4
5
6
7
8
9
10 - 26
96
28
16
13
5
5
1
2
1
1
0
57.1
16,7
9.5
7.7
3.0
3.0
0.6
1.2
0.6
0.6
0
  Totals
       163
    100.0
  *Foui'-hour averages calculated from combination of strip chart readings
   taken every 15 minutes and planimeter integration determinations where
   > 5 ppm excursions occurred.
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 monitoring  specifications for TRS monitors  have not yet been developed,
 it is  not known  for  certain whether  the monitoring instrument used to
 obtain this  data will meet these specifications.  The TRS continuous
 monitoring  system  specifications are expected  to  be proposed in the
 near future.  A  standard of 10 ppm  (four-hour  average) was considered
 as an  alternative  to allow for these few excursions above 5 ppm.  However,
 a  standard  of this level would not  require  the use of the best system
 of emission  reduction,  considering  costs, and  was therefore rejected.
 The proposed requirements for reporting excess emissions will, as
 discussed under  section 9.8 of this  chapter, accommodate an appropriate
 rate of excursions above  5  ppm as  a part  of normal  operation.
 Further, the probability that a performance test will  demonstrate
 emissions above 5 ppm TRS is  less  than indicated above because
 compliance will  be based on the average of three runs  of the
 reference test method for TRS emissions.
 Oxygen Correction
      Lime kilns  normally operated  with exhaust end oxygen concen-
 trations below about 10 volume percent.   The 02 concentrations
 measured in the  emissions from the three  lime  kilns  tested for
 TRS ranged  from 2.5  to 7  volume  percent;  those from the three kilns
 tested for particulate emissions ranged from 1.9 to 11.5 percent.
 To avoid excess  dilution, the particulate and  TRS concentrations
 measured in lime kiln emissions  should be corrected  to 10 volume
 percent 0£» when the actual  concentration exceeds 10 percent.  The
data obtained during  tests with  02  concentrations  exceeding  10
percent have been corrected  to that baseline.
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Selection of the Emission Limits
     The proposed standards for the lime kiln system, based on the
best system of emission reduction, considering costs, are therefore
as follows:
Particulate matter
     0.15 g/dscm when burning natural  gas, corrected to 10 volume
percent oxygen when the actual oxygen  content exceeds 10 percent.
     0.30 g/dscm when burning fuel oil, corrected to 10 volume
percent oxygen when the actual oxygen  content exceeds 10 percent.
TRS
     5 ppm (four-hour average), corrected to 10 volume percent oxygen
when the actual oxygen content exceeds 10 percent.
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9.5.4  Digester System, Brown Stock Washers, Black Liauor Oxidation
       System, Multiple-Effect Evaporator System, and Condensate
       Stripper Column
     The best control  technology, considering costs, for these five
sources of TRS is incineration.   This incineration can be accomplished
in the recovery furnace, the lime kiln, and a separate incineration
unit.  Maintenance of proper combustion parameters, basically tempera-
ture and residence time, will assure complete oxidation of the gases.
     Test data on one incineration unit, burning non-condensable
TRS gases from the digester system and multiple-effect evaporator
system, show that levels ranging from 0.5 to 3 opm (4-hour average)
are achievable.  The incinerator was operating at 1000°F with a
retention time for the gases of at least 0.5 seconds.  Similar
results can be expected when the TRS gases are incinerated in
either the recovery furnace or lime kiln.  Tests on one recovery
furnace in which gases from the brown stock washers were being
incinerated indicate no effects on the performance of the furnace.
Tests on lime kilns that were burning gases from the digesters,
evaporators, condensate striopers, and miscellaneous storage tank vents
indicate similar results.
     The proposed TRS standards for these five affected facilities
are set at 5 ppm (4-hour average).  A concentration standard was
chosen as the format of the proposed standards for the reasons
presented in section 9.4.  Test data support these proposed limits
and show that incineration, the best control technique, considering costs,
would be reguired to achieve the proposed standards.
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9.6  VISIBLE EMISSION STANDARDS
     The opacity of visible emissions is a measure of mass concentration
of some pollutants.  Various studies have shown that opacity varies
directly with mass concentrations of particulate matter.   The applicability
and enforcement of opacity standards related to narticulate matter have been
established in several court cases for facilities subject to new source
performance standards under section 111  of the Clean Air Act.
     Opacity standards help to assure that sources and emission control
systems are properly maintained and operated so as to comply with mass
emission standards on a continuing basis.  Opacity test methods are
quicker, easier to apply and less costly than particulate concentration/
mass tests.  EPA considers opacity standards to be a necessary supplement
to particulate mass emission standards and, therefore, opacity standards
are established as independent enforceable standards.
     Where opacity and concentration/mass standards are applicable to
the same source, EPA establishes opacity standards that are not more
restrictive than concentration/mass standards.  The opacity standard
is achievable if the source is in compliance with the concentration/
mass standard.
     Visible emission data were obtained during the development
of the proposed standards at three recovery furnaces, three smelt
dissolving tanks, and at one lime kiln during the time that parti-
culate emission tests were being performed.
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Recovery Furnace System
     Visible emissions data were obtained during four tests of three
recovery furnace systems that were using electrostatic precipitators.
All of the opacity data were obtained as specified in EPA Reference
Method 9.  Over 900 six-minute average opacities were obtained that
ranged from a low of 0% opacity at a mass concentration of 0.02 g/dscm
to a high of 50% opacity at a mass concentration of 0.11 g/dscm.  The
concentration/mass standard that has been established to reflect
best demonstrated technology considering costs for particulate
matter control of kraft recovery furnace systems is 0.10 g/dscm
(0.044 gr/dscf).  A least squares fit of all the opacity/particulate
concentration data collected during the emission measurement program
shows that, on the average, a mass concentration of particulate
matter of 0.10 g/dscm corresponds to approximately 27% opacity.
Taking the variability of the 6-minute averages into consideration
and normalizing all data to a three-meter diameter stack, the plus
95% confidence value of opacity at the level of the proposed mass
concentration is approximately 35% opacity.  Since the data were obtained
by Reference Method 9, they include observer error.  A discussion of
the data analysis is given in chapter 6.
     The ontions considered were settina the standard at:  (1)  the
averaae level  of onacity that corresponds to the oronosed mass  concen-
tration, (?.}  the nlus 95% confidence level  which considers variations
in 6-minute averages, (3) and at the nlus 99% confidence level  which
also considers variations in 6-minute averaaes.  The nlus 95% confidence
level  was chosen because:  (1)  the average  onacitv would frequently
be exceeded even when the oarticulate matter standard is being  met;
                                p./if.

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(?) the 99% level would orobablv not ensure nroner oneration and
maintenance of control equioment; and (3) infrequent excursions above
the 95% level can be accommodated for monitorinq and compliance nurnoses
by proner definition of excess emissions and by collecting a sufficient
amount of data when checking comnliance.  Therefore, the onacity
standard that is oronosed is 35% onacity as measured by Method 9.
     The majority of the existina recovery furnaces in the industry
use a continuous soot blowing cycle.  According to a furnace vendor,
most new furnaces will also use a continuous soot blowing cycle.  For
some smaller furnaces it is more economical to blow soot periodically,
but the cost of alternative continuous blowinq is considered reasonable.
The prooosed standard is based on onacity data from furnaces that
use continuous soot blowinq.
Smelt Dissolving Tank
     Data were obtained on three of the smelt dissolvino tanks tested
for particulate emissions by EPA.  However, the data for each smelt
tank were obtained over two or more periods of observation for a
total observation time of onlv about one hour.  The steam plumes
associated with these smelt tanks made it difficult to obtain
readings on the residual nlumes since the olumes tended to mix with
other olumes in the mill prior to the dissination of the steam.
Therefore, these data are not considered sufficient to support a
visible emission standard.  Based on these observations, EPA believes
that an ooacity standard would in most cases be ineffective.  Therefore,
no opacity standard is oronosed for this facility.
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Lime Kilns
     Visible emissions data were obtained on only one lime kiln tested
for oarticulate emissions by EPA.  The data from this one lime kiln
are not considered sufficient to support a visible emission standard.
EPA was not able to obtain opacity data on the residual  plumes of
the other lime kilns tested because the nlumes mixed with other olumes
in the mill nrior to the dissipation of the steam.  As with smelt
dissolving tanks, EPA has concluded that an opacity standard for lime
kilns would be ineffective in most situations.  Accordingly, no opacity
standard is proposed for lime kilns.
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9.7  MODIFICATION AND RECONSTRUCTION CONSIDERATIONS
     The proposed standards would apply to all affected facilities
within a kraft pulo mill  that are constructed or modified after
the date of proposal of the standards.  Chanqes that could possibly
be considered as modification or reconstruction were presented in
Chapter 5 alonq with explanations as to the choice of these types
of chanqes.
     The purpose of this  section is to identify any exemptions or
special allowances that should be incorporated into the proposed
standards coverinq changes to facilities that could be considered
as modifications or reconstructions.  The followinq physical
chanqes and chanqes in method of operation were considered:
     (1)  Conversion of a direct-contact furnace system to an
indirect-contact system.
     (2)  Conversion of a lime kiln from burninq natural  qas  to
burning oil.
     (3)  Adding an additional stage of washing capacity to an
existing brown stock washer system.
     There appears to be no reason for excluding any of the above
physical changes or changes in method of operation from the modification
and reconstruction provisions of new source performance standards.
In all cases the costs associated with the modification or reconstruction
are judged to be affordable.  The bases used for judging the affordability
                                   9-49

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of each case are presented in detail  in chapter 8, Economic Impact.
No special allowances or exemptions are therefore proposed for
these cases.
     Most recovery furnaces at existing kraft mills are not designed
to accept gaseous emissions from brown stock washer systems and
black liquor oxidation systems.  If a brown stock washer or black
liquor oxication system are modified, reconstructed, or replaced,
then the gases from these facilities would have to be controlled
as required by the proposed standards.  In this case it would
mean that these gases would have to be incinerated in a separate
incinerator.  This is very costly and requires a significant
amount of fuel.  For these reasons new and modified black liquor
oxidation and brown stock washer systems located at an existing
kraft mill where the gaseoosremissions from these facilities
cannot be incinerated in an existing recovery furnace because
of technical or economic reasons are exempted from the proposed
standard until the furnace is modified, reconstructed or replaced
so that the gases can be incinerated.
     The industry has expressed concern about the proposed standard
covering any black liquor oxidation systems at existing plants.
Their contention is that it is a method of controlling TRS
emissions from the recovery furnace and since black liquor oxidation
systems always result in controlling more TRS emissions than they
create, they should never be covered at existing plants.   The
proposed standard accommodates their concerns for the most part.
                               9-50

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According to the industry, very few mills do not have at least
one stage of oxidation.  Therefore, most of the black liquor oxida-
tion system construction will  be additions to existing stages.   This  will  he
a modification because of the  way that the affected facility is
defined for black liquor oxidation systems.  Therefore, the
increased emissions of TRS from the added black liquor oxidation
tank can be traded off.  If a  plant would replace an existing
black liquor oxidation system  or if one is installed at an
existing plant that previously had none, then the black liquor
oxidation system will  be covered only if the black liquor oxida-
tion system gases can be incinerated in the existing furnace.
According to vendors and the industry, most existing furnaces
are not designed to accept black liquor oxidation system gas
streams.  Whenever the existing furnace is modified, reconstructed,
or replaced with a furnace that can accept these gases, then the
black liquor oxidation system  gases must be controlled.  All
black liquor sxidation systems at new mills must be controlled.
     It is EPA's judgment that these provisions for the modifications
or reconstructions of black liquor oxidation systems are reasonable.
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9.8  SELECTION OF MONITORING REOUIREMENTS
     Under section 114(a) of the Clean Air Act, the Administrator
may require the owner or onerator of an emission source to install,
use, and maintain monitorinq equipment or methods.  EPA has exercised
this authority to require for new source performance standards the
monitorina of pollutant emissions or parameters that are indicators
of pollutant emissions.  The monitorinq requirements are necessary
to determine whether an affected facility is beinq operated and
maintained prooerly and also to aid in determininq whether a performance
test should be required.  The costs of installinq and oneratinq the
monitorinq svstems and devices discussed below are considered reasonable.
TRS Stack HasMonitoring
     The volume concentration of TRS emissions can be monitored by use
of monitorinq systems that meet the proposed instrument performance
specification.  There are no process or control device parameters
that are indicators of concentrations of TRS emissions from recovery
furnace systems and lime kilns.  Therefore, the gas stream TRS monitoring
system is the only method of monitorinq concentrations of TRS emissions
from these affected facilities, and a requirement for monitoring
of TRS concentrations from the lime kiln and recovery furnace is
proposed.  The continuous monitoring system specifications for TRS
monitors are being developed and it is expected that they will be
proposed in the near future and be promulgated with the kraft mill
standards.
     Since the standard  for smelt dissolvino tanks is exnressed in a
format of pollutant mass ner unit of production, the qas flow rate
and the Production rate  would have to be measured simultaneously  to
                                  9-52

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reduce the TRS concentrations measured by the monitor to units  of
the nronosed standard.   Inaccuracies would arise from measuring
velocities continuously, and the production rate cannot be measured
accurately except over relatively long periods of time.  The inaccuracies
involved in continuously measuring emissions from the smelt dissolving
tank are felt to be sufficiently large that EPA has determined that the
direct monitoring of TRS emissions from the smelt dissolving tank
is not practical.
     Another method exists for continuously monitoring the proper
operation of smelt dissolving tanks to ensure that TRS emissions
are well controlled.  TRS emissions from the smelt dissolving tank
are related to the concentration of dissolved sulfides in the smelt
dissolving water and in the water used in the scrubber.  The concen-
tration of the dissolved sulfides could be monitored, but neither
EPA nor the industry have experience with this type of monitoring.
The proposed standards therefore do not require the monitoring of
dissolved sulfides in the smelt dissolving water or the scrubber
water.
     TRS concentrations in the effluent gases from an incinerator
that controls TRS emissions can be measured by a continuous monitoring
system.  However,  there are less costly means of monitoring the proper
operation of incinerators that control TRS emissions.
     An EPA test and previous work done on incinerators for kraft
pulp mill TRS control have shown that TRS concentrations do not
exceed 5 ppm if a temperature of 1000°F and a residence time of
at least one-half second in the fire box are maintained.  Incinerators

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are designed for a particular residence time that will  not be
reduced if the incinerator is not operated above its designed
capacity.  While it is very cumbersome and costly to measure the
parameters that are necessary to determine the fire box residence
time, the fire box temperature is readily measured and recorded.
EPA has concluded that continuously measuring and recording
the fire box temperature is an effective alternative method of
monitoring the TRS concentrations.  If non-condensable oases
from facilities that are covered by the standard are incinerated
in the recovery furnace or the lime kiln, the TRS monitoring system
on the furnace or the lime kiln will  serve to monitor the sources
that are being incinerated.
^articulate and Visible Emissions Monitoring
     Opacity monitors are available that meet EPA's published
specifications for continuous monitoring systems.  These monitors
were considered for measuring the opacity of emissions from recovery
furnace systems and lime kilns.  Opacity monitoring systems on
recovery furnaces are well demonstrated.  Therefore, the use of
a continuous monitoring system is proposed as a requirement for the
recovery furnace.
     EPA and industry have no experience with opacity monitors on lime
kilns.   The reason for this is that since most lime kilns use scrubbers,
the interference caused by entrained water droplets causes an error
that cannot be corrected.   Therefore, the data obtained by the
monitoring system would be questionable.   The Agency is  therefore
not requiring the  continuous  monitoring of opacity from  lime kilns.
                               9-54

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There are other methods of monitorinq the nroner oneration and
maintenance of narticulate control devices on lime kilns which
are discussed below.
     Onacity monitorinq systems cannot be applied to the smelt
dissolving tank because of entrained water and condensed steam
that are nresent.
     The device used most frequently to control  emissions from
a lime kiln is a venturi scrubber.  The pressure dron for the
venturi scrubber and the liauid flow rate are indicators of
the performance of the scrubber.   Instead of requirinq the use
of a continuous onacity monitorinq system, the nronosed regulations
require the use of monitorinq devices for continuous monitorinq
of the pressure loss throuqh the venturi  constriction and the
scrubbinq linuid supply pressure to the control  device.  The
performance of the scrubber would therefore be monitored by comparing
the values of the  pressure parameters with the values at the time the
performance test for particulate  emissions was performed.
     The continuous monitorinq of the pressure drop and water
flow rate for the  low energy pressure drop scrubber used to
control particulate matter from the smelt dissolvinq tank is
reauired to determine if the scrubber is  beina properly operated.
Oxygen Monitoring
     The proposed  TRS and particulate concentration standards for
the lime kiln and  the recovery furnace are corrected to 10% and
8% oxygen concentration, respectively, when the oxygen concentration
is above  these levels.  The reason for this is that the excess air

                              9-55

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used in the combustion process and the air inleakage into the gases
from these facilities vary and a correction to an oxygen concentration
level is needed.  It is EPA's judgment that an oxygen concentration
of 8 volume percent for the recoverv furnace and 10 volume percent
for the lime kiln represent excessive process air dilution of the
gas stream.  Therefore, the proposed standards require that the
concentrations of particulate matter and TRS from the recoverv
furnace and lime kiln be corrected to 8 and 10 volume percent
oxygen when the oxygen concentrations are above these levels.
It is proposed that an oxygen monitor be Installed downstream of
the control device so that the TRS concentrations that are measured
from the lime kiln and recovery furnace can be corrected to 10%
and 8% oxygen, respectively, when the actual oxygen concentrations
are above these levels for the purpose of determining excess emissions.
The oxygen monitor must measure the oxygen concentration on a dry
basis.  The specifications for the oxygen monitoring system were
promulgated on October 6, 1975 (40 FR 46240).
Excess Emissions
     As specified in section 60.7(b) and (c) of the regulations
(Notification and Recordkeeping), the operator of any source
subject to the proposed standard would be required to maintain
records of the occurrence and duration of any start-up, shutdown,
or malfunction in the operation of an affected facility, any
malfunction of the air pollution control equipment, or any periods
during which a continuous monitoring system or monitoring
device is inoperative.  All excess emissions due to malfunctions,
start-ups or shutdowns, and other excess emissions as defined
                                 9-56

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 in each applicable subpart, must be reported to EPA for each
 calendar quarter.  Generally, excess emissions are defined in
 terms of the applicable standards.  For example, if the standard
 for a particular facility is 5 ppm of TRS, four-hour average, then
 excess emissions would usually be defined as all  occurrences
 during the quarter for which 5 ppm TRS, four-hour average, was
 exceeded.   In some special cases where excess emissions can be
 predicted to normally occur at a well  operated facility for
a small  percentage of the time, this is reflected in the definition
of excess  emissions.   The definition of excess emissions for
each affected facility at a kraft mill  is  discussed below.
Recovery Furnace Systems
     Excess emissions of TRS from a recovery furnace are defined
 as all four-hour averages of TRS concentrations above 5 ppm.   EPA
 data indicate that a well operated plant applying best technology
 will not exceed a concentration of 5 ppm on a four-hour average
 basis.
      Excess emissions of  opacity from  a recovery furnace  are
 defined as all  six-minute average opacities that exceed 35 percent,
 except  5 percent of  all the 6-minute averages  except those which
 occur during start-up,  shutdown, or malfunction of  the  facility
 or  control device.   EPA's analysis of  Method 9 data indicates
 that  there is a 5 percent probability  that a six-minute average opacity
 will  exceed 35  percent  when the stack  gas emissions are equivalent
 to  the  mass emission standard.   It is  the Agency's  judgment that
 Method  9 data are more  variable than transmissometer data.  Therefore,
                                 9-57

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 this data will  not be more restrictive when applied  to transmissometer
 data obtained during monitoring.
 Lime Kiln
     Excess emissions  of TRS  from a lime kiln  are defined as all
four-hour average TRS  concentrations above 5 ppm except that 6 percent
of all  four-hour averages of  TRS concentrations except those which
occur during start-up, shutdown or malfunction of the facility
and control device are not considered to be excess emissions if
they are less than 10  ppm.  EPA analyzed one month of continuous
TRS monitoring data from a plant that uses the technology on which
the standards are based.  The data analvsis showed that when the
facility and control  system were properly operated and maintained
there were no four-hour average TRS con-entrations that exceeded
10 percent, and 6 percent of  these four-hour average concentrations
were greater than 5 ppm.  Therefore, the excess emissions were
determined on the basis of these data.
 Incineration
     Excess TRS emissions from  the  incineration  of gases from
 affected facilities other than  lime  kilns, recovery  furnaces, or
 smelt dissolving  tanks  are defined as all TRS  concentrations that
 exceed  5 ppm on a four  hour average.  EPA has  concluded  that a
well operated incinerator applying best technology will not exceed
 5 ppm on a four hour average basis except during malfunctions,
 start-ups and shutdowns.
                              9-58

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9.9  SELECTION OF PERFORMANCE TEST METHODS
     Test methods for the measurement of particulate matter and TRS
emissions from kraft pulp mills are proposed for determining corn-
pi icance with the proposed standards.  EPA Reference Method 5 would
be used for the measurement of particulate emissions.  Reference
Method 16, "Semicontinuous Determination of Sulfur Emissions from
Stationary Sources," which is being nroposed concurrently with the
standards, would be the reference test method for the measurement
of total reduced sulfur (TRS).  The performance test methods are
discussed in detail in Appendix D.
     Reference Method 16 was develoned specifically for the test
program during the development of the proposed TRS standards for
kraft pulp mills.  Several alternative methods were considered
including colorimetry, spectronhotometry, coulometry, and gas
chromatography.  The colorimetric method suffers from limited
test ranges, variable collection efficiency, and sensitivity to
light and humidity.  The use of infrared and mass  spectrophotometry
were considered expensive, time consuming, and not suitable for
routine field annlications.  Split beam ultraviolet spectrophotometry,
more promising for application to kraft pulp mills, was rejected
because of a low end accuracy of 10 ppm, higher than emissions
expected from well controlled facilities.  Coulometric titration
has been widely used in the kraft pulping industry as a continuous
monitor.  The use of this method as a performance  test did not
appear to be as promising, due to the lesser sensitivity of the unit
compared to gas chromotography.  The  gas chromotography (GC) method,
combined with analytical determination  by the flame photometric

-------
detector (FPD) has a sensitivity of less than 5 Darts per billion,
well below the levels expected from well controlled facilities.
Interfering components, carbon monoxide and moisture, can be
selectively removed with a strinner column.  The GC/FPD method,
due to the better sensitivity of measurement and ease of application
to qas streams in kraft oulp mills, was chosen as the best system
for the measurement of reduced sulfur compounds at kraft pulp mills.
     In addition to Method 5 and Method 16, Reference Method 2 for
velocity and volumetric flow rate, Reference Method 3 for qas
analysis, and Reference Method 9 for visible emissions would be
used to determine compliance.  These Reference Methods have been
applied to other categories of stationary sources for which new
source performance standards have been developed, and have been
published in Appendix A to Part 60.
     Method 17 is also being proposed as an alternate test method
for the measurement of particulate emissions from recovery furnaces
at kraft pulp mills.  This method involves the use of an in-stack
filter, a simpler operation than that prescribed in Method 5.
Method 17 was found to have a consistent relationship with Method 5
which can be used to correct the measured particulate concentration.
The method is presented and discussed in detail in Appendix 0.
                                 9-60

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                           References

 1.  Atmospheric Emissions from the Pulp and Paper Manufacturing
     Industry, EPA-450/1-73-002, September 1973 (also published by
     NCASI as Technical Bulletin No.  69, February 1974).

 2.  Preliminary Air Pollution Survey of Odorous Compounds, APTD
     69-42, Litton Systems, Inc., October 1969.

 3.  Preliminary Air Pollution Survey of Hydrogen Sulfide,  APTD
     69-37, Litton Systems, Inc., October 1969.

 4-  A Study of the Social and Economic Impact of Odors,  Copley
     InternationaT~Corporation, EPA Contract No. 68-02-0095,
     February 1973.

 5.  Impact of New Source Performance Standards on 1985 National
     Emissions from Stationary Sources, The Research Corporation
     of New England, EPA Contract No. 68-02-1382, Task #3,
     October 24, 1975.

 6.  Modeling Analysis  of the Ambient Air Impact of Kraft Pulp
     Mi 11s, Walden Research Division of Abcor, Inc., prepared for
     the Source Receptor Analysis Branch, MDAD, OAQPS, OAWM,
     EPA, October 1975.

 7•  Hydrogen Sulfidehealth Effects and Recommended Air  Quality
     Standard, Illinois Institute for Environmental Quality,
     March 1974, distributed by the National Technical Information
     Service, U.S. Department of Commerce.

 8.  Air Quality Criteria for Particulate Matter, AP-49,  U.S.
     Department of Health, Education, and Welfare, Washington,
     D.C. , January 1969.

 9.  Reduction of Total Reduced Sulfur Data from a Kraft  Pulp Mill
     Lime Kiln, EmissTbn Standards and Engineering Division,
     U.S. EPA, Research Triangle Park, N.C., December 1975.

10.  Meetino between EPA and representatives of the kraft pulping
     industry at Research Trianqle Park, N.  C.  on March 7, 1975.

11.  Eddinqer, James A., EPA, Trip Report - "Koppers Company at
     Baltimore, Maryland, and Research Cottrell at Bound  Brook,
     New ilersfiv," August 25, 1975.

12.  Fddinaer, .lames A., EPA, Trip Report - "Wheelabrator Frye at
     Pittsburnh, Pa.,"  Aunust 25, 1975.
                                 9-fil

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            APPENDIX A



EVOLUTION OF THE PROPOSED STANDARDS

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                                                    APPENDIX A
                                      EVOLUTION OF THE  PROPOSED STANDARDS
 Date
11/4/70

8/19/71

8/19/71

8/20/71
1/22/72
1/27/72
2/9/72
2/17/72
2/24/72
3/1/72
3/2/72
4/4/72
4/5/72
4/7/72
Company, Consultant
	or Agency
EPA
Alton Box Board Co.

Container Corporation
of America
International Paper Co.
Mestern Kraft
American Can Co.
International Paper Co.
Alton Box Board Co.
Champion International
Crown Zellerhach
Boise Cascade Corp.
Westvaco
'•'estvaco
Chamnion International
  •fcocatron
Durham, N.C.

Jacksonville, Fla.

Ferdnandina Beach,
 Fla.
Panama City, Fla.
Albany, Ga.
Halsey, Oreqon
Ticonderoga, N.Y.
Jacksonville, Fla.
Court!and, Ala.
Port Townsend, Mash.
Wallula, Hash.
Wickliffe, Ky.
Charleston, S.C.
Pasadena, Texas
              Nature- of Action
Kraft pulp mills were selected as a source
category for inclusion in the original Group II
standards package.
Presurvey of recovery furnace and lime kiln
for TRS testing,
Presurvey of the mill  for TRS testing.
Presurvey of the mill for TRS testing.
Presurvey of the mill for TRS testing.
Presurvey of recovery furnace for TRS testing.
Presurvey of recovery furnace for TRS testing.
Presurvey of recovery furnace for TRS testing.
Presurvey of the mill for TRS testing.
Presurvey of the mill for TRS testing.
Presurvey of the lime kiln for TRS testing.
Presurvey of incinerator for TRS testing.
Presurvey of the mill for TRS testing.
Presurvey of recovery furnace for TRS testing.

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                                               APPENDIX A  (continued)

                                          EVOLUTION OF THE  PROPOSED STANDARDS
i
CO
                  Company, Consultant
     Date          	or Agency	

    4/21/72        Weyerhauser Co.

    6/3-9/72       Champion International
7/13/72        National  Council  of  the
               Paper Industry  for Air
               anH  Stream Improvement
               (NCASI),  and  industry
               reDresentatives from
               various  companies.

7/13-21/72     American  Can  Co.
    7/24/72        Heyerhauser Co.
    10/2-7/72       Westvaco

    10/18/72        NCASI  and  industry
                   representatives
    10/24/72-
    11/3/72
               Champion International


11/10-19/72    Champion International
                                                 Location

                                              Vallient,  Okla.

                                              Pasadena,  Texas
                                                 New  York City,
                                                  N.Y.
Halsey, Oregon




Everett, Nash.


Wfcklfffe, Ky.

New York City,
 N.Y.

Courtland, Ala.


Courtland, Ala.
                                  Nature of Action
                         Presurvey of the mill for TRS testing.

                         Source tests on the recovery furnace for
                         TRS and particulate emissions, and the
                         black liquor oxidation system for TRS
                         emissions.

                         EPA met with representatives of the kraft
                         pulpina industry to discuss the selection
                         of pollutants and affected facilities,  and
                         the testing program.
Source tests on the recovery furnace for TRS
and particulate emissions, and on the smelt
dissolvina tank for TRS and particulate
emissions.

Presurvey of the smelt dissolving tank for
TRS testing.

Source test on the incinerator for TRS emissions,

EPA met with industry representatives to discuss
the development of the standards.

Source test on the recovery furnace for TRS
and particulate emissions.

Source test on the recovery furnace for TRS
emissions, on the brown stock washers for
TRS emissions, and on the black liquor oxi-
dation system for TRS emissions.

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                                            APPENDIX A (continued)

                                      EVOLUTION OF THE PROPOSED STANDARDS
               Company,  Consultant
 Date          	or Agency	

12/11-14/72    Westvaco


12/21/72       Industry representatives



1/30/73        EPA


2/20/73        EPA



3/5/73         Industry representatives



3/27/73        NCASI


4/73           EPA
  Location

Wickliffe, Ky.


Durham, N.C.



Durham, N.C.


Raleigh, N.C.



Durham, N.C.



Durham, N.C.


Durham, N.C.
Nature
                     Action
Source test on the incinerator unit for
TRS emissions.

EPA met with industry representatives to
discuss the draft package of the standards
for control of TRS emissions.

EPA Working Group reviewed the recommended
standards .

Review of the recommended standards by the
National Air Pollution Control Techniques
Advisory Committee (NAPCTAC).

EPA met with industry representatives to
discuss their comments on the recommended
TRS standards.

EPA met with NCASI to discuss the recommended
TRS standards.

EPA decided to expand the standards package
by including all  sources of TRS and the three
significant sources of partioulate matter at
a kraft pulp mill.  Further source testinq
was authorized to obtain data to support the
additional standards.

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                                         APPENDIX  A  (continued)

                                   EVOLUTION  OF  THE  PROPOSED  STANDARDS
Date
5/3/73



6/18/73


6/20/73


6/21/73


6/22/73


6/25/73


6/26/73


7/11/73
Company, Consultant
	or Agency	

International Paper Co.
            INtHiJ.
            Escanaba  Paper Co.
            (Head Corp.)

            Fibreboard Kraft Mill
            Louisiana-Pacific Coro,
            Crown Zellerbach Corp.
            St. Reqis Paper Co.
            Heverhauser Co.
            NCASI
                                                 Location

                                             Panama City, Fla,
                               Durham,, N.C,



                               Escanaba,  Mich.


                               Antioch, Cal.


                               Samoa, Cal.


                               Wauna, Oreqon


                               Tacoma, Hash.


                               Longview, Wash.


                               Durham, N.C.
          Nature of Action
Presurvey of the lime kiln for TRS and
particulate testing.  Experimental source
test on the lime kiln to determine if the
particulate dust affects the accuracy of
the TRS measurements,

EPA met with NCASI to discuss the development
plan for control of particulate emissions and
for control of additional TRS sources.

Presurvey of all facilities for possible
TRS and particulate testing.

Presurvey of the mill for TRS and particulate
testing.

Presurvey of the lime kiln for TRS and
particulate testing.

Presurvey of the lime kiln for TRS and
particulate testing.

Presurvey of the mill for TRS and particulate
testing,

Presurvey of the lime kiln for TRS and
particulate testing.

EPA met with NCASI to discuss the development
of additional  TRS and particulate standards.

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                                           APPENDIX  A  (continued)

                                      EVOLUTION  OF THE  PROPOSED STANDARDS
               Company,  Consultant
 Date          	or Agency	

9/11/73        Crown Zellerbach  Corp.


9/12/73        I'leyerhauser Canada  Ltd.
9/13/73        British  Columbia  Forests
               Products Kraft  Pulp  Mill

9/17-27/73     Escanaba Paper  Co.
               (Mead  Corp.)
10/5/73        Boise  Cascade  Corp.


10/8-12/73     Weyerhauser  Co.



10/15-20/73    Crown  Zellerbach  Corp.
10/29/73-
11/8/73
11/1/73
Champion International
                                 Location
                               Camas, Wash.
                               Kami oops, British
                                Columbia, Canada

                               MacKenzie, British
                                Columbia, Canada

                               Escanaba, Mich.
St. Helens, Oregon


Everett, Wash.



Camas, Wash.



Courtland, Ala.
                                     Nature of Action
Brunswick Pulp and
Paper Co.
Brunswick Ga.
Presurvey of the smelt dissolving tank for
TRS and participate testing.

Presurvey of recovery furnace for TRS and
particulate testing.

Presurvey of recovery furnace for TRS and
particulate testing.

Source tests on the lime kiln for TRS
emissions, and on the smelt dissolving tank
for TRS and particulate emissions.

Presurvey of the lime kiln for TRS and
particulate testing.

Source test on the smelt dissolving tank
for particulate emissions.  Visible emissions
data were also recorded.

Source test on the smelt dissolving tank
for narticulate emissions.  Visible emissions
data were also recorded.

Source tests ofi the lime kiln for TRS emissions,
on the recovery furnace for particulate emissions,
and on the smelt dissolving tank for TRS and
particulate emissions.  Visible emissions data
were also taken for the smelt dissolving tank.

Presurvey of recovery furnace for particulate
testing.

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                                           APPENDIX A  (continued)

                                      EVOLUTION  OF THE  PROPOSED  STANDARDS
               Company,  Consultant
   Date             or Agency	

11/13-16/73    Weyerhauser Co.
11/19/73       Brunswick  Pulp and  Paper
               Co.

12/11-13/73    Alton  Box  Board
1/21-25/74     Brunswick  Pulp  and  Paper
               Co.
1/24/74        Gilman Paper  Co.


1/25/74        Buckeye Cellulose Corp.


2/12-19/74     St.  Regis  Paper Co.


3/12/74        Mead Corp,
3/13/74        Great Northern Paper
               Co.
   Location

Vallient, Okla.


Brunswick, Ga,


Jacksonville, Fla.


Brunswick, Ga,



St. Mary's, Ga,


Foley, Fla.


Tacoma, Wash.


Chillicothe, Ohio



Cedar Springs, Ga.
             Nature of Action

Source test on the lime kiln for particulate
emissions.

Record visible emissions data on the recovery
furnace plume.

Source test on the recovery furnace for parti-
culate emissions.

Source test on the recovery furnace for parti-
culate emissions.  Visible emissions data were
also recorded.

Presurvey of recovery furnace for particulate
testing.

Presurvey of recovery furnace for particulate
testing.

Source test on the recovery furnace for parti-
culate emissions.

Presurvey of the lime kiln for emissions
testing.  Obtain information on additional
processes.

Presurvey the lime kiln for TRS and particulate
testing.

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                                               APPENDIX A (continued)

                                         EVOLUTION OF THE PROPOSED STANDARDS
co
               Company,  Consultant
  Bate         	or Agency	

4/1-10/74      St.  Reqis Paper Co.

4/29/74-       Buckeye Cellulose Corp.
5/3/74


5/7-14/74      Buckeye Cellulose Corp.



7/16/74        Chamnion International




7/26/74        NCASI


8/5-12/74      Mead Corp.
   9/17-19/74     Great Northern Paper
                  Co.

   1/21/75        EPA
    2/20/75        EPA
  Location

Tacoma, Mash.

Foley, Fla,



Foley, Fla.



Pasadena, Texas




Durham, N.C.


Chillicothe, Ohio



Cedar Springs, Ga.


Durham, N.C.


Atlanta, Ga.
             Nature of Action

Source test on the lime kiln for TRS emissions.

Source test on the lime kiln for particulate
emissions.  Visible emissions data were also
recorded.

Source test on the recovery furnace for parti-
culate emissions-.  Visible emissions data were
also recorded.

Plant visit to obtain design and performance
data on the electrostatic precipitator used
to control partfculate emissions from the
lime kiln.

EPA met with NCASI to discuss the additional
data and the levels of the emission standards.

Source test on the lime kiln for particulate
emissions.  Visible emissions data were also
recorded.

Source test on the lime kiln for particulate
emissions.

The EPA Working Group reviewed the recommended
standards.

Review of the recommended standards by the
NAPCTAC.

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                                               APPENDIX A  (continued)

                                          EVOLUTION OF THE  PROPOSED  STANDARDS
E»
I
O
 Date

3/7/75



5/1/75



5/14/75

7/16/75


7/17/75


8/1/75


9/  /75


10/7/75
                  Company, Consultant
                  	or Agency	

                  NCASI  and  industry
                  representatives
Babcock and Wilcox



St. Reqis Paper Co.

Koppers Co.


Research Cottrell


Wheelabrator-Frye, Inc.


St. Reqis Paper Co.
                   Escanaba  Paner Co.
                   (Mead  Corp.)
                                   Location

                               Research Trianqle
                                Park, N.C.
Durham, N.C.



Tacoma, Wash.

Baltimore, Md.


Bound Brook, N.J.


Pittsburgh, Pa.


Tacoma, Wash.


Escanaba, Mich.
                                       Nature of Action
EPA met with NCASI and industry representatives
to discuss their comments on the recommended
standards.

EPA met with representatives of Babcock and
Wflcox to discuss problems with burning vent
gases in existing recovery furnaces.

114 request for ESP maintenance records.

EPA met with Koppers to discuss ESP performance
and maintenance requirements.

EPA met with Research Cottrell  to discuss ESP
performance and maintenance requirements.

EPA met with Wheelabrator-Frye  to discuss ESP
performance and maintenance requirements.

Request for lono-term opacity data on the
recovery furnace plume.

EPA met with Mead representatives to discuss
the performance of the TRS monitoring system
in use at Escanaba, and the effectiveness of
caustic scrubbing in the control of TRS from
the lime kiln.

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                                            APPENDIX A (continued)

                                      EVOLUTION OF THE PROPOSED STANDARDS
               Company,  Consultant
 Date               or Agency

11/5/75        Teller Environmental
               Systems,  Inc.  (TESI)
11/12/75       Escanaba Paper Co.
               (Mead Corp.)
 3/8/76         EPA


 4/23/76        EPA


8/5/76         EPA



8/17/76        EPA
   Location

Worchester, Mass.




Escanaba,  Mich.



Durham,  N.C.


Uashinaton, D.C.


Washington, D. C.



Washington, D. C.
             Nature of Action
EPA met with TESI to discuss application
of a cross flow scrubber for control of
TRS and particulate emissions from kraft
recovery furnaces.

EPA obtained one month of TRS data from the
continuous monitor on the lime kiln at
Escanaba .

The EPA Working Group reviewed the proposed
                                                                       "'"he EPA Stee*"^"" C:~srTi'T"''ttpe ^eviewe^  the
                                                                       proposed standards.

                                                                       The proposed standards package completed
                                                                       external  review by  Federal  Agencies and
                                                                       departments.

                                                                       The package was forwarded to  Washington for
                                                                       final  concurrance.

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                          APPENDIX B
         INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
     This appendix consists of a reference system, cross-indexed
with the October 21, 1974, FEDERAL REGISTER (39 FR 37419) containing
the Agency guidelines concerning the preparation of Environmental
Impact Statements.  This index can be used to identify sections
of the document which contain data and information germane to any
portion of the FEDERAL REGISTER guidelines.

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                                        CROSS  INDEXED  REFERENCE  SYSTEM TO HIGHLIGHT
                                       ENVIRONMENTAL  IMPACT  PORTIONS  OF THE  DOCUMENT
       Agency Guideline for Preparing  Regulatory Action
        Environmental  Impact Statements  (39  FR  37419)
                                                                     Location  Within  the Standards Support
                                                                      and  Environmental  Impact Statement
  1.  Background and description  of the  proposed  action,

      -Describe the recommended or  proposed  action  and
       its purpose.
TO

IVJ
    -The relationship  to  other  actions  and  proposals
     sianificantly  affected  by  the  proposed action
     shall  he  discussed,  including  not  only other
     Agency activities  but also those of other
     governmental and  private organizations,

2.  Alternatives  to the proposed action.

    -Describe  and objectively weigh  reasonable
     alternatives to the  proposed action, to  the
     extent such  alternatives are permitted by the
     law.  . .  For use  as  a reference point  to which
     other  actions  can  be compared,  the analysis of
     alternatives should  include the alternative of
     taking no action,  or of postponing action.  In
     addition,  the  analysis  should  include alterna-
     tives  having different  environmental impacts,
     including proposing  standards,  criteria, pro-
     cedures,  or  actions  of  varying  degrees of
     stringency.  When  appropriate,  actions with
     similar environmental impacts  but  based  on
     different technical  approaches  should  be
     discussed.  This analysis  shall evaluate
     alternatives in such a  manner  that reviewers
     can judge their relative desirability.
The proposed standards are summarized in chapter 1,
section 1,1.  The statutory basis for the proposed
standards (section 111 of the Clean Air Act, as amended)
is discussed in the Introduction.  The purpose of the
proposed standards is discussed in chapter 9, sections
9.1 and 9.2.

Hater effluent limitations for sources in the pulp
and paper industry are discussed in chapter 7, section
7.2.  Discussion of the economic impacts that the
proposed new source performance standards may have
on these effluent guidelines is presented in chapter 8.
                                                                 The alternative control systems, based upon the best
                                                                 combinations of control techniques, are presented in
                                                                 chapter 4, section 4.3.  A discussion of the alternative
                                                                 of taking no action and that of postponing the proposed
                                                                 action is presented in chapter 7, sections 7.6.2 and
                                                                 7.6,3.  The alternative systems are discussed throughout
                                                                 the document in the evaluation of the environmental and
                                                                 economic impacts associated with the proposed standards.

                                                                 The selection of the best system for emission reduction,
                                                                 considering costs, is presented in chapter 9, section 9.3,

                                                                 The alternative formats for the proposed standards are
                                                                 discussed and the rationale for the selection of the
                                                                 proposed formats are discussed in chapter 9, section 9.4.

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                                      CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
                               ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued;
      Aqency  Guideline for Preparinn Requlatory Action
       Environmental  Impact Statements  (39 FR 37419)
03
I
CO
-The analysis  should be  sufficiently detailed to
 reveal  the Agency's comparative evaluation of
 the beneficial  and adverse environmental, health,
 social,  and economic effects of the proposed
 action  and each reasonable alternative.
                                                                 Location Hi thin the Standards Support
                                                                  and Environmental Impact Statement
The emission limits for participate matter and TRS
and the rationale for their selection are discussed
in chapter 9, section 9,5.  The alternatives considered
in the selection of a visible emissions standard for
the recovery furnace is presented in chapter 9, section
9.6.

A summary of the environmental and economic impacts
associated with the proposed standards are presented
in chapter 1, section 1.2.

A detailed discussion of the environmental effects
of each of the alternative control systems can be
found in chapter 7.  This chapter includes a discussion
on the beneficial and adverse impacts on air, water,
solid waste, energy, noise, radiation, and other environ-
mental considerations.

A detailed analysis of the costs and economic impacts
associated with the proposed standards can be found in
chapter 8.

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                                       CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
                                ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued)
      Agency Guideline for Preparing Regulatory Action
       Environmental Impact Statements (39 FR 37419}
                                                                  Location  Within  the  Standards  Support
                                                                   and  Environmental  Impact  Statement
CO

45.
-Where the  authorizing  legislation  limits  the
 Agency from  taking  certain  factors  into account
 in its decision making,  the comparative evalua-
 tion should  discuss all  relevant factors,  hut
 clearly identify  those factors which  the
 authorizing  legislation  requires to be the
 basis of the decision  making.

-In addition, the  reasons why the proposed
 action is  believed  by  the Agency to be the
 best course  of action  shall  be explained.
 3.  Environmental impact of the proposed action.

     A.  Primary impact

         Primary impacts are those that can be
         attributed directly to the action, such as
         reduced levels of specific pollutants
         brought about by a new standard and the
         physical  changes that occur in the various
         media with this reduction.
                                                                 The factors which the authorizing legislation requires
                                                                 to be the basis of the decision making are discussed
                                                                 in the Introduction.
The rationale for the selection of TRS and particulate
matter from kraft pulp mills for control under the
proposed standards is discussed in chapter 9, section
9.1,

The Administrator's decision to control TRS emissions
under Federal standards and the reasons for regulating
TRS under section 111 of the Clean Air Act is discussed
in the Introduction.
                                                           The primary  impacts on mass emissions  and  ambient  air
                                                           quality  due  to  the alternative  control  systems  is
                                                           discussed  in chapter  7,  section  7.1.1.  These impacts
                                                           are summarized  in Table  1-2, Matrix of Environmental
                                                           and Economic Impacts  of  the Alternative Standards,
                                                           chapter  1, section 1.2.

-------
                                       CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
                                ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued)
       Agency  Guideline for  Preparing Regulatory Action
        Environmental  Impact Statements  (39 FR 34719)
      Location Within the Standards Support
       and Environmental Impact Statement
CD
I
cn
      B.   Secondary  impact

          Secondary  impacts are  indirect or induced
          impacts.   For example, mandatory reduction
          of specific pollutants brought about by
          a  new  standard  could result  in the adoption
          of control technology  that exacerbates another
          pollution  problem and would  be a secondary
          impact.
  4.   Other  considerations.

      A.   Adverse  impacts which cannot be avoided
          should the proposal be implemented.  Describe
          the  kinds and magnitudes of adverse impacts
          which cannot be reduced in severity to an
          acceptable level or which can be reduced to
          an acceptable level but not eliminated.  These
          may  include air or water pollution, damage
          to ecological systems, reduction in economic
          activities, threats to health, or undesirable
          land use patterns,  Remedial, protective, and
          mitigative measures which will be taken as
          part of  the proposed action shall be identified.
The secondary environmental impacts attributable to the
alternative control systems are discussed in chapter 7.
These impacts are summarized in Table 7-1, Secondary
Environmental Impacts of Individual Control Techniques,
chapter 7, introduction.

Secondary impacts on air quality are discussed in
chapter 7, section 7.1,2.

The anticipated impacts on energy requirements due to
each alternative control system is discussed in chapter 7,
section 7.5.
A summary of the potential adverse environmental and
economic impacts associated with the proposed standards
and the alternatives that were considered is discussed
in chapter 1, section 1.2 and chapter 7.

-------
                                      CROSS  INDEXED  REFERENCE SYSTEM  TO  HIGHLIGHT
                               ENVIRONMENTAL IMPACT  PORTIONS OF THE DOCUMENT (continued)
     Agency Guideline for Preparing  Regulatory Action
      Environmental  Impact Statements  (39 FR 37419)
                                                              Location Within the Standards Support
                                                               and Environmental  Impact Statement
03
I
cr>
    C.
Relationship between local  short-term uses
of man's environment and the maintenance
and enhancement of long-term productivity.
Describe the extent to which the proposed
action involves trade-offs  between short-
term environmental gains at the expense of
long-term losses or vice versa and the extent
to which the proposed action forecloses
future options.  Special attention shall be
given to effects which pose long-term risks
to health or safety.   In addition, the
timing of the proposed action shall  be
explained and justified.

Irreversible and irretrievalbe commitments
of resources which would be involved in
the proposed action should  it be implemented.
Describe the extent to which the proposed
action curtails the diversity and range of
beneficial - uses of the environment,   For
example, irreversible damage can result if
a standard is not sufficiently stringent.
                                                                The  discussion of the use of man's  environment is
                                                                included in  chapter 7, section 7.6.1.   A discussion
                                                                of the effects of TRS and particulate  emissions
                                                                from kraft pulp mills is  included in chapter 9,
                                                                section 9.1.
Irreversible and irretrievable commitments of resources
are .discussed in chapter 7, section 7.6.1.

-------
                          APPENDIX C
               EMISSION SOURCE TEST DATA SUMMARY
INTRODUCTION
     This section presents the summaries of the source tests and
visible emission measurements cited in Chapter V.  Tests were conducted
by EPA at 12 mills and include 9 tests for TRS, 13 tests for narticulate,
and 3 tests for visible emissions.  A total of 6 recovery furnaces,
4 smelt dissolving tanks, 4 lime kilns, and one incinerator were
tested by EPA for either oarticulate, TRS, or both.  Emission data
obtained from operators or state aqencies are also reported for some
of the facilities.  The facilities are identified by the same coding
that is used in Chapter V.
     Particulate tests were conducted as specified in Method 5,
promulgated in the Federal Register on December 23, 1971 (36 FR 24877).
Tests for TRS were conducted using EPA Method 16, "Setnicontinuous
Determination of Sulfur Emissions from Stationary Sources," which
will be proposed in the Federal Register at the same time as the
kraft mill standards.   Visible emission data were gathered by
EPA Method 9, originally promulgated in the Federal Register on
December 23, 1971  (36  FR 24877) and revised on November 12, 1974
(39 FR 39872).
     A description of  the facilities tested during the study are
presented below.   The  data presented in this appendix for a facility
is referred to by the  appropriate letter.
PARTICULATE EMISSION  DATA
     Recovery Furnaces:
     D.  Conventional  type  recovery furnace designed for equivalent pulp
                                C-l

-------
    production  of  602  tons  per  day.  Furnace was operating between
    90 and 95  percent  of  designed  capacity  during  the test period.
    Particulate emissions are controlled by a  wet-bottom electrostatic
    precipitator which has an operating collection efficiency  of
    99.5 percent.
J.  Low-odor type recovery furnace designed for an equivalent  pulp
    production of 1100 tons per day.   Furnace  was  operating  at
    design capacity during the test period.  Particulate emissions
    are controlled by a dry-bottom electrostatic precipitator  which
    has a design collection efficiency of 99.8.  Tests  Jl were
    performed by EPA.   Data 02 were obtained from the operator.
K.  Low-odor type recovery furnace designed for an equivalent  pulp
    production rate of 863 tons per day.  The  furnace was operating
    at 74 percent of design capacity during EPA test period.
    Particulate emissions are controlled by a  dry bottom electrostatic
    precipitator which has a design collection efficiency of 99.5
    percent.  Data Kl  were obtained from EPA tests, while data K2
     were obtained from the state agency.
 L.  Conventional type recovery furnace designed for an equivalent
     pulp production of 550 tons per day.  Furnace was  operating
     16 percent above design capacity during EPA test period.   The
     particulate emissions are controlled by an electrostatic
     precipitator with a design collection efficiency of 99.5
     percent.   Data LI were obtained during EPA tests,  while data
    L2 were obtained from the operator.
Smelt Dissolving Tanks:
D.   Particulate emissions are.controlled by a wet scrubber.  Demister
    pads are also installed to aid the scrubber.  The associated
                              C-2

-------
    recovery furnace operates at an equivalent pulp production rate
    of 570 tons per day.
E.  Particulate emissions are controlled by a wet scrubber which is
    basically a wet fan cyclone.  The associated recovery furnace
    operates at an equivalent pulp production rate of 770 tons per day.
F.  Particulate emissions are controlled by a packed scrubber tower.
    The associated recovery furnace operates at an equivalent pulp
    production rate of 450 tons per day.  Data Fl are results of
    tests performed by EPA, while data F2 were obtained from the
    state agency.
G.  Particulate emissions are controlled by a packed scrubber tower.
    The associated recovery furnace operates at an equivalent pulp
    production rate of 300 tons per day.  Data Gl are results of
    tests performed by EPA, while data G2 were obtained from the state
    agency.
Lime Kilns:
K.  Rotary lime kiln operating at an equivalent pulp production rate
    of 320 tons per day.  Particulate emissions are controlled by a
    venturi  scrubber which has an operating pressure drop of 31 to 33
    inches of water.  The lime kiln was tested by EPA on both No. 6
    fuel oil (Data Kl) and natural gas  (Data K2).  Data K3 was obtained
    from the state agency.
L.  Rotary lime kiln operating at an equivalent pulp production rate
    of 500 tons per day.  Particulate emissions are controlled by a
    venturi scrubber which has an operating pressure drop of 15 to 18
                          C-3

-------
        inches of water.   The lime  kiln was  tested  by  EPA on  No.  2 fuel
        oil  (Data LI)  end natural  gas  (Data  L2).  Data L3 was obtained
        from the operator.
    N.  Rotary lime kiln  operating  at  an equivalent pulp production  rate  of
        about 840 tons per day.   Particulate emissions are  controlled by  a
        venturi scrubber  with an operating pressure drop of 18  inches of
        water.  The lime  kiln was  tested by  EPA on  No. 6 fuel oil  (Nl)
        and on natural gas (N2).

TRS EMISSION DATA
    Incinerator:
        The incinerator handles  the noncondensable  gases from a continuous
        digester system and a multiple-effect evaporator system.   The
        continuous digester was  producing 670 tons  of  pulp  per  day.
        The incinerator was operating  at 1000°F with a retention time
        for the gases  of at least 0.5  seconds.  Natural gas is  fired in
        the incinerator.
    Recovery  Furnaces:
    A.  Conventional  type recovery furnace designed for an equivalent
        pulp  production  rate of 657 tons per day.  TRS emissions are
        controlled by using black liquor oxidation and maintaining proper
        furnace operation.  The furnace was  operating  near its  design
        capacity during  the EPA test period.  Continuous  monitoring data
        were  also obtained from the operator.
    B.  Low-odor type recovery furnace designed for an equivalent pulp
        production of 300 tons per day.  During the EPA testing, the
                             C-4

-------
    furnace was operating at a rate of about 345 tons  of pulp  per
    day.  TRS emissions are controlled by eliminating  the direct contact
    evaporator and maintaining proper furnace operation.   Noncondensable
    gases from the brown stock washer system are burned  in this furnace.
    Continuous monitoring data were also obtained from the state agency.
D.  Conventional type recovery furnace designed for an equivalent  pulp
    production rate of 602 tons per day.  TRS emissions  are controlled
    by black liquor oxidation and maintaining proper furnace operation.
H.  Low-odor type recovery furnace operating at an equivalent  pulp
    production rate of about 200 tons per day.  TRS emissions  are
    controlled by maintaining proper furnace operation.   Data  were
    obtained from the state agency.
K.  Low-odor type recovery furnace designed for an equivalent  pulp
    production rate of about 863 tons per day.  TRS emissions  are
    controlled by maintaining proper furnace operation.   Data  were
    obtained from state agency.
 Smelt Dissolving Tanks
 D.   A wet fan type scrubber is employed to  control  the particulate
     emissions.  Weak wash liquor is  used  as  the scrubbing  medium.
     The associated recovery furnace  operates  at an equivalent pulp
     production rate of 570 tons per  day.
 E.   A wet fan type scrubber is employed to  control  the particulate
     emissions.  Fresh water is used  as  the  scrubbing  medium.  The
     associated recovery furnace operates  at an equivalent  pulp production
     rate of 770 tons per day.
                          C-5

-------
Lime Kilns
D.  Rotary lime kiln operating at an equivalent pulp  production rate
    of 570 tons per day.   TRS emissions  are  controlled  by maintaining
    proper kiln combustion and proper lime mud  washing.  Noncondensable
    gases from the multiple-effect evaporators  are  burned in  the  kiln.
E.  Rotary lime kiln operating at an equivalent pulp  production rate
    of about 770 tons per day.  TRS emissions are controlled  by
    maintaining proper combustion in the kiln,  maintaining  proper
    lime mud washing, and using a caustic solution  in the particulate
    scrubber.  Noncondensable gases from the digesters,  multiple-effect
    evaporators, condensate stripper, and miscellaneous  storage tanks
    are burned in the kiln.  Continuous  monitoring  data  were  also obtained
    from the operator.
K.  Rotary lime kiln operating at an equivalent pulp  production rate
    of about 320 tons per day.  TRS emissions are controlled  by main-
    taining proper combustion in the kiln and proper  lime mud washing.
    Noncondensable gases  from the digesters, multiple-effect  evaporators,
    and turpentine system are burned in  the  kiln.
0.  Rotary lime kiln not  tested by EPA.   Continuous monitoring data
    was obtained from the local agency.   TRS emissions  are  controlled
    by maintaining process conbustion in the kiln.
                         C-6

-------
               Table  1  -  Particulate and  Visible Emission Data
                                for Recovery  Furnace D
                             Summary of Results

Run Number                      1           2         3

Date -  1973                    11/1       11/1      11/2

Test Time - minutes             128        128       128

Production Rate - TPH

Stack Effluent

     Flow rate - DSCFM (X1000)  85         91        80

     Flow rate - DSCF/ton        -
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol . % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
321
30.3
8.7
9.8
0


.031
.014
22.5
-

.041
.019
30.2
310
31.5
9.9
10.6
0


.029
.013
22.6
-

.045
.021
35.3
304
33.6
10.2
10.6
0


.021
.010
14.7
-

.043
.020
29.7
     Ib/ton of product
                                        C-7

-------
                              TABLE 1  (cont.)

Visible Emissions (Normalized to a 3.0 m stack diameter)

                     Opacity       Number of 6-Minute
       Test            (_%)         Averages in Range        % of Total

         10-50                    0
     (11/1/73)         5-10                0                    0
                      10-15                1                   25
                      15-20                0                    0
                      20-25                0                    0
                      25-30                3                   75
         2
     (11/1/73)                     No readings taken

         3             0-5                 1                  33.3
     (11/2/73)         5-10                1                  33.3
                      10-15                1                  33.3
                                    r  o
                                    L-o

-------
                 Table 2 - Particulate and Visible Emission Data
                                 for Recovery Furnace j'l
                             Summary of Results
Run Number
Date -  1974
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM (XI000)  99
     Flow rate - DSCF/ton
     Temperature - °F
     Water vaoor - Vol.  %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - Vol. % dry
Particulate Emissions
  Probe and filter catch
     qr/DSCF
     gr/ACF
     Ib/hr
     Ib/ton of product
  Total catch
     gr/DSCF
     qr/ACF
     Ib/hr
     Ib/ton of Product
                                        C-9
1
1/22
162
45.8
99
405
27.2
12.6
6.8
0.1
.011
.005
9.4
.21
.017
.007
14.0
.31
2
1/23
162
45.7
93
445
30.7
14.7
4.7
0.1
.018
.007
14.4
.31
.03
.012
23.6
.52
3
1/23
162
44.9
91
433
28.5
14.1
5.4
0
.013
.005
9.9
.22
.027
.011
21.0
.47
4
1/24
162
45.8
96
434
29.7
13.4
6.0
0
.01
.004
8.2
.18
.02
.008
16.4
.36
5
1/24
162
45.4
93
430 .
29.6
14.0
5.2
0.2
.01
.004
8.1
.18
.021
.009
17.1
.38
6
1/25
162
45.5
98
434
28.8
13.1
6.6
0.2
.014
.006
11.8
.26
.025
.01
21.0
.46

-------
                              TABLE 2 (cont.)

Visible Emissions  (Normalized to a  3.0 m stack diameter)

                     Opacity       Number of 6-Minute
       Test            (%)          Averages in Range        % of Total

         1              0-5                30                     55.5
     (1/22/74)         5-10              19                     35.2
                      10-15                5                     9.3

        2             0-5                48                   100
     (1/23/74)         5-10                 0                     0

        3             0-5                15                    75.0
     (1/23/74)         5-10                5                    25.0

        4             0-5                47                   100
     (1/24/74)         5-10                 0                     0

        5             0-5                34                    85.0
     (1/24/74)         5-10                »                    15-0

        6             0-5                34                    97.1
     (1/25/74)         5-10                1                     2.Q
                                  C-10

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Table 3 - Particulate and Visible Emission Data
                for Recovery Furnace J"l
          Summary of Results
Run Number
Date - 1974
Test Time - minutes
Production Rate - TPH
Stack Effluent
Flow rate - DSCFM (X1000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor -Vol. %
C02 - Vol. % dry
02 - Vol . % dry
CO - Vol . % dry
Parti culate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
Ib/ton of product
1
1.22
162
45.8

112
147
449
27.9
14.9
4.7
0


.058
.024
56.0
1.2

.067
.028
64.7
1.4
2
1.23
162
45.7

106
139
403
27.8
14.7
4.7
0.1


.055
.024
50.5
1.1

.063
.028
57.5
1.3
3
1.23
162
44.9

108
• 144
401
29.5
11.4
8.5
0


.052
.022
48.4
1.1

.062
.027
57.5
1.3
4
1.24
162
45.8

107
140
408
29.0
13.2
6.1
0


.057
.024
51.9
1.1

.064
.028
59.0
1.3
5
1.24
162
45.4

108
143
400
29.7
14.0
5.2
0.2


.051
.022
47.0
1.0

.061
.026
56.8
1.3
6
1.25
162
45.3

109
144
393
29.1
13.2
6.2
0


.052
.023
48.6
1.1

.065
.028
61.0
1.4
                    C-ll

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                              TABLE 3 (cont.)

Visible Emissions  (Normalized to a 3.0 PI stack diameter)

                     Opacity       Number of 6-M1nute
       Test            (%)          Averages  in  Range

         1             0-10                 0
     (1/22/74)       10-20                 5
                     20-30                22
                     30-40                27
                     40-50                 0
                                        of Total

                                           0
                                           9.3
                                          40.7
                                          50.0
                                           0
     (1/23/74)
     (1/23/74)
     (1/24/74)
     0/24/74
     (1/25/74)
 o-in
10-20
20-30
30-40
40-50

 0-10
10-20
20-30
30-40
40-50

 0-10
10-20
20-30
30-40
40-50

 0-10
10-20
20-30
30-40
40-50

 0-10
10-20
20-30
30-40
40-50
50-60
 0
 1
 2
23
22

 0
11
12
12
 1

 0
 1
 6
18
10

 0
 0
 5
24
 4

 0
 0
 5
14
17
 2
 0
 2.1
 4.2
47.9
45.8

 0
30.6
33.3
33.3
 2.8

 0
 2.9
17.1
51.4
28.6

 0
 0
15.2
72.7
12.1

 0
 0
13.2
36.8
44.7
 5.3
                                   C-12

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            Table  4  -  Particulate  Emission  Data for Recovery  Furnace Kl

                             Summary of Results
Run Number
Date -  1974
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM (X1000)  141,923
     Flow rate - DSCF/ton
     Temperature - °F
     Water vapor - Vol. %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - Vol. % dry
Particulate Emissions
  Probe and filter catch
     qr/DSCF
     gr/ACF
     Ib/hr
     Ib/ton of product
  Total catch
     gr/DSCF
     qr/ACF
     Ib/hr
     Ib/ton of product
                                       C-13
1
2/2
224
141,928
338
21.5
8.9
9.9
0
.003
.001
3.2
.008
.004
9.8
2
2/13
224
148,427
349
22.8
9.7
9.8
0
.003
.002
4.0
.011
.006
13.7
3
2/14
448
159,325
361
23.1
9.6
9.7
0
.002
.001
3.4
.005
.002
6.2
4
2/15
162
160,461
347
22.1
8.9
10.0
0
.002
.001
3.0
.009
.005
12.0
5
2/18
336
148,
345
22.9
8.5
10.5
0
.003
.001
3.5
.011
.006
14.5

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          Table 5 - Particulate and Visible Emission Data for
                               Recovery Furnace LI
                             Summary of Results
Run Number
Date - 1974
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM (XI000)  112
     Flow rate - DSCF/ton
     Temperature - °F
     Water vapor - Vol.  %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - Vol. % dry
Particulate Emissions
  Probe and filter catch
     qr/DSCF
     gr/ACF
     Ib/hr
     lb/ton of product
  Total catch
     gr/DSCF
     qr/ACF
     Ib/hr
     Ib/ton of product

                                       C-14
1
3.7
288
112
301
31 .9
13.5
5.4
1.4
.014
.007
13.9
.046
.022
45
2
5/8
240
118
293
29.6
11.3
6.9
1.4
.012
.006
12.2
.048
.024
49
3
5/9
240
113
307
32.6
9.5
8.2
2.3
.012
.006
12.8
.044
.021
43
4
5/10
240
114
304
32.3
8.7
8.9
1.9
.016
.006
11.7
.034
.016
33
5
5/13
240
120
291
32.1
9.1
8.2
2.2
.015
.008
15.5
.063
.03
62
6
5/14
240
115
276
32.4
9.0
6.2
3.8
.014
.007
15.8
.056
.05
105

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                              TABLE 5 (cont.)

Visible Emissions  (Normalized to a 3,0 m stack diameter)

                     Opacity       Number of 6-Minute
       Test            (50         Averages in Range        % of Total

                                                                 41.3
                                                                 58.7

                                                                 61.3
                                                                 38.7

                                                                 63.8
                                                                 36.2

                                                                 61.2
                                                                 38.8

                                                                 63.0
                                                                 37.0

                                                                 52.3
                                                                 47.7
R-7
(5/7/74)
R-8
(5/8/74)
R-9
(5/9/74)
R-10
(5/10/74)
R-11
(5/13/74)
R-12
(5/14/74)
0-5
5-10
0-5
5-10
0-5
5-10
0-5
5-10
0-5
5-10
0-5
5-10
31
44
46
28
30
17
42
26
46
25
45
41
                                   C-15

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                                  Table  6

                   ADDITIONAL  PARTICULATE EMISSION  DATA
                           FOR RECOVERY  FURNACES
                             Date
Concentration
   gr/dscf
Emission Rate
Ib/hr   Ib/ton
Recovery Furnace J 2
Test 1
Test 2
Average
Recovery Furnace J 2a
Test 1
Test 2
Average
Recovery Furnace K2
Low
High
Average
Recovery Furnace L2
Low
High
Average

12/19/72
7/23/73


12/19/72
7/23/75


9/7/73
3/18/75


4/30/73
2/21/73


.0163
.0179
.0171

.060
.0385
.049

.001
.05
.017

.005
.023
.01

14.9
14.3
14.6

46.5
28.7
37.6

1.2
64.4
22.3

4.5
28.5
11.3

-
-
-

-
-
-

0.05
3.0
0.86

-
-
_
 Tested by operator using in-stack filter.

 Tested by operator using Washington State  sampling train (in-stack filter
 plus impingers)

cTested by operator using total  EPA sampling train.
                                    C-16

-------
Table 7 - Particulate and Visible Emission Data for Smelt Dissolving Tank D







                         Summary of Results
Run Number
Date - 1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
Flow rate - DSCFM (X1000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol. % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
Ib/ton of product
1
11/1
144
25.9

8880
20,571
172
41.2
0.1
19.4
0


.058
.028
4.4
0.17

.09
.044
6.9
0.266
2
11/2
144
25.6

9339
21,888
172
41.0
0.1
20.4
0


.051
.025
4.1
0.16

.067
.032
5.3
0.207
3
11/2
144
25.6

10787
25,282
170
33.2
0.1
20.7
0


.027
.015
2.5
0.098

.037
.02
3.3
0.129
                                  C-17

-------
Table 7 •  Particulate
                                                                    Tank  D
                                                                inued)
        Test      °P^C;ty      Number of  6-MTnute
        -        lxl
          _(*.        		

                               	—     JLofJotal
          0-5                ,
          5-10               °                  100

o                                               *"*
          0-5               ,
          5-10              J                  100
                             C-18

-------
Table 8 - Particulate Emission Data for Smelt Dissolving Tank E






                    Summary of Results
Run Number
Date - 1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
Flow rate - DSCFM (XI 000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol . % dry
CO - Vol . % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
1
9/18
120
30.1

19,542
38,954
150
23.8
0.3
21.8
0.2


.024
.015
4.0
0.133

.037
.024
6.2
0.206
2
9/19
120
34.1

18,760
33,009
151
25.8
0.2
21.3
0.1


.026
.016
4.1
0.12

.036
.023
5.8
0.17
3
9/19
120
34.1

18,720
32,938
153
26.5
0.2
21.3
0.1


.023
.014
3.6
0.106

.035
.021
5.6
0.164
                               C-19

-------
Table 9 - Particulate and Visible Emission Data for Smelt Dissolving Tank Fl
                         Summary of Results
Run Number
Date - 1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
Flow rate - DSCFM (XI 000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor - Vol . %
C02 - Vol . % dry
02 - Vol. % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
1
10/11
220
17.5

3710
12,720
174
44.8
0.0
20.6
-


.114
.053
3.6
.206

.121
.056
3.8
.218
2
10/12
220
18.8

3600
11,489
180
47.4
0.2
19.8
-


.141
.062
4.4
.231

.149
.065
4.6
.244
3
10/12
220
19il

3420
10,743
177
47.8
0.2
19.8
-


.129
.056
3.8
.198

.136
.059
4.0
.208
                                    C-20

-------
Table 9 - Participate and Visible Emission Data for Smelt Dissolving Tank Fl
                                                                (continued)


                    Opacity      Number of 6-Minute
          Test        (%)        Averages in Range       % of Total

            1         0-5                9                  100
                      5-10               0                   0
                                    C-21

-------
Table 10 - Particulate and Visible Emission Data for Smelt Dissolving Tank 61
                          Summary of Results
Run Number
Date - 1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
Flow rate - DSCFM (XI 000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol. % dry
CO - Vol . % dry
Particulate Emissions
Probe and filter catch
gr/DSCF .
gr/ACF
Ib/hr
lb/ ton of product
Total catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
1
10/16
180
12.3

5170
25,220
160
35.1
0
20.6
-


.043
.024
1.9
.155

.049
.028
2.2
.177
2
10/18
180
10.5

5280
30,171
168
35.1
0
20.7
-


.066
,037
3.0
.286

.071
.04
3.2
.308
3
10/19
180
10.4

5470
31,558
167
37.7
0
21.0
-


.094
.05
4.4
.422

.096
.051
4.5
.433
4
10/20
180
12.4

4840
23,419
165
34.2
0
20.8
-


.061
.034
2.5
.205

.069
.037
2.8
.223
                                      C-22

-------
Table 10 - Participate and Visible Emission Data for Smelt Dissolving  Tank  Gl
                                                            (continued)


                   Opacity      Number of 6-Minute
         Test        (%)        Averages in Range       % of Total

           1         0-5                2                 '100

           2         0-5               10                  100
                                   C-23

-------
                                 Table 11

                ADDITIONAL PARTICIPATE EMISSION DATA FOR
                         SMELT DISSOLVING  TANKS*
                                         Concentration
                              Date          gr/dscf
Emission Rate
Ib/hr   Ib/ton
Smelt



Smelt



Dissolving Tank F2
Low
High
Average
Dissolving Tank 62
Low
High
Average

8/12/73
9/17/73


9/11/73 '0.037
1/11/73 0.075
0.056

0.08
0.48
0.19

0.13
0.4
0.21
*Tested by operators using Washington State sampling train (in-stack filter
and impingers)
                                   C-24

-------
                 Table 12 - Particulate Emission Data for Lime Kiln Kl









                             Summary of Results



Run Number                      1           2         3



Date - 1974                     2/12       2/13      2/14



Test Time - minutes             120        120       120



Production Rate - TPH           0.1        0.1       0.1



Stack Effluent



     Flow rate - DSCFM (XI000)  14,755     14,292    13,165



     Flow rate - DSCF/ton        -
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol . % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
qr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
151
25.2
9.8
11.5
0


.108
.07
13.7
-

.113
.073
14.3
151
24.3
11.5
10.5
0


.097
.064
11.9
-

.105..
.069
12.8
151
25.5
11.5
10.9
0


.102
.066
11.6
-

.116
.076
13.1
     Ib/ton of product
                                      C-25

-------
                Table 13 - Particulate Emission Data for Lime Kiln K2

                             Summary of Results
Run Number                      1           2
Date -  1974                    2/14       2/14
Test Time - minutes             120        120
Fuel                            Gas        Gas
Stack Effluent
     Flow rate - DSCFM (X1000)  13,896     11,560
     Flow rate - DSCF/toh
Temperature - °F
Water vapor - Vol . %
COg - Vol. % dry
02 - Vol . % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
156
27.0
9.8
10.9
0.1


.06
.038
7.1
-

.089
.056
10.6
152
24.5
9.7
10.9
0


.037
.024
3.7
-

.064
.042
6.4
     Ib/ton of product
                                       C-26

-------
        Table 14 - Participate and Visible Emission Data for Lime Kiln LI

                             Summary of Results
Run Number                      1           2         3
Date - 1974                     5/2        5/2       5/3.
Test Time - minutes             144        144       144
Fuel                            °il        Ol'l       Ofl
Stack Effluent
     Flow rate - DSCFM (X1000)  14,663     15,214    14,984
     Flow rate - DSCF/ton        -          -         -
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol . % dry
CO - Vol . % dry
Parti cul ate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
171
41.0
20.7
3.2
.3


.25
.128
32.0
-

.259
.13
32.5
168
38.5
20.7
3.2
.3


.261
.137
34.1
-

.274
.143
35.7
169
39.0
21.6
3.0
.9


.233
.121
29.9
-

.237
.123
30.5
     Ib/ton of product
                                        C-27

-------
Table 14 - Participate and Visible Emission Data for Lime Kiln LI
                                                     (continued)
              Opacity      Number of 6-Minute
    Test        (%)        Averages in Range       % of Total

     1A         0-5                0                   0
                5-10              21                  100

     IB         0-5                0                   0
                5-10              23                  100

     2A         0-5                0                   0
                5-10              20                  100


     28         °~?n         	  STEAM INTERFERENCE 	
                b- ID

     3A         0-5                0                   0
                5-10              16                  100

     38         °'5Q         	  STEAM INTERFERENCE 	
                              C»28

-------
        Table  15  -  Participate  and  Visible  Emission  Data  for  Lime  Kiln  L2
Run Number
Date -  1974
Test Time - minutes
Fuel
Stack Effluent
     Flow rate - DSCFM (XI
     Flow rate - DSCF/ton
     Temperature - °F
     Water vapor - Vol.  %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - Vol. % dry
Particulate Emissions
  Probe and filter catch
     gr/DSCF
     gr/ACF
     Ib/hr
     Ib/ton of product
  Total catch
     gr/DSCF
     gr/ACF
     Ib/hr
     Ib/ton of product
Summary of
1
4/30
144
Gas
') 15,170
170
41.0
17.1
3.4
0
.033
.016
4.3
.037
.019
4.8
Results
2
5/1
144
Gas
15,761
163
34.5
16.8
1.9
0.1
.026
r.014
3.5
.031
.017
4.2

3
5/1
144
Gas
14,453
171
41.0
18.0
2.8
0
.021
.011
2.7
.028
.014
3.4
                                      C-29

-------
Table 15 - Participate and Visible Emission Data for Lime Kiln L2
                                                      (continued)
              Opacity      Number of 6-Minute
    Test        (%)        Averages in Range       % of Total
4A

4B
5A


5B
6A


6B
0-5
5-10
0-5
5-10
0-5
5-10
10-15
0-5
5-10
0-5
5-10
10-15
0-5
5-10
0
13

STEAM
0
7
14
f"rr~ « M
STEAM
0
0
22
j->Tp fl M
ol tAM
0
100

INTERFERENCE "
0
33
67
T ll^-r-r*F"r-r*r-»i ^^r-
INTERFERENCE
0
0
100
T fcr"T"i™r»r-r- r\r**mr-
INTERFERENCE
                              C-30

-------
                Table 16 - Particulate Emission Data for Lime Kiln Nl


                             Summary of Results
Run Number                      1          2         3
Date -  1974                    9/19       9/19      9/20
Test Time - minutes             120        120       120
Fuel                            oil        Oil       O"1"1
Stack Effluent
     Flow rate - DSCFM  (X1000)  21,159     25,575    33,475
     Flow rate - DSCF/ton        _          _         _
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % drv
02 - Vol . % dry
CO - Vol. % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
qr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
148
36.5
13.8
7.4
0,1


.031
.02
5.6
-

.06
.039
10.9
152
32.6
14.8
7.3
0.4


.092
.057
20.1
-

.107
.067
23.5
149
36.3
19.3
4.7
0.5


.095
.06
27.1
-

.123
.08
36.0
     Ib/ton of product
                                       C-31

-------
           Table 17 - Particulate Emission  Data for Lime  Kiln  N2
                        Summary of Results
Run Number
Date - 1974
Test Time - minutes
Fuel
Stack Effluent
Flow rate - DSCFM (X1000)
Flow rate - DSCF/ton
Temperature - °F
Water vapor - Vol . %
C02 - Vol. % dry
02 - Vol. % dry
CO - Vol . % dry
Particulate Emissions
Probe and filter catch
qr/DSCF
gr/ACF
Ib/hr
Ib/ton of product
Total catch
gr/DSCF
qr/ACF
Ib/hr
1
9/17
120
Gas

24,054
-
155'
41.2
16.9
4.8
0.7


.107
.063
22.6
-

.156
.092
32.2
2
9/13
120
Gas

22,342
-
151
41.0
10.4
7.8
0,7


..034
.021
6.6
-

.113
.069
21.5
3
9/18
120
Gas

24,964
-
154
39.0
15.9
5.7
0.3


.048
.029
10.3
••

.086
.052
18.3
Ib/ton of product

-------
                             Table 18

              ADDITIONAL PARTICULATE EMISSION DATA
                         FOR LIME KILNS
Lime Kiln L3**
                                Concentration
                     Date          gr/dscf
Emission Rate
Ib/hr   1b/ton
Lime Kiln K3*
Low
High
Averaae

10/29/73
2/26/73


.014
.073
.045

1.0
5.3
3.5

0.1
.62
.26
Lov^
High
Average
11/8/73
11/8/73

.017-
.066
.041
2.4
9.2
5.2
*Tested by operators using Washington State sampling train (in-stack
filter and impingers).

**Tested b> operator using total  EPA sampling train.
                                C-33

-------
                  Table  19  -  TRS  Emissions  from  Separate  Incinerator
                             Summary of Results
Run Number
Date - 1972
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM (XI000) 2610
     Flow rate - DSCF/ton
     Temperature - °F
     Water vanor - Vol.  %
     C02 - Vol. % dry
     O^ - Vol. % dry
     CO - opm
TRS Emissions
     ppm
     Ib/hr
     1b/ton of nulo
SO? Emissions
     pnm
     Ib/hr
     Ib/ton of nulo
1
10/5
240
2610
805
6.3
2.6
.11.8
0
2.8
1.5
0.06
25
9.4
0.4
2
10/6
240
2223
805
4.3
2.4
12.0
0
0.4
0.2
0.007
306
96.9
3.8
3 4
10/7 12/13
240 240
2302
805
5.4
2.1 9.0
12.7 15.7
0 0
1.6 0.9
0.6 0.4
0.02 0.02
1050
358
13.9

-------
                     Table  20 - TRS Emissions from Recovery Furnace A
                             Summarv of Results



Run Number



Date - 1972



Test Time - minutes



Production Rate - TPH



Stack Effluent



     Flow rate - DSCFM (XI000)  142



     Flow rate - DSCF/ton



     Temperature - °F



     Water vaoor - Vol.  %



     C02 - Vol. % dry



     02 - Vol. % dry



     CO - opm



TRS Emissions



     pnm



     Ib/hr



     1b/ton of nulp



S02 Emissions



     nnm



     Ib/hr



     Ib/ton of nuln
1
6/3
240
142
314
25.5
10.4
10.7
153
2.0
1.5
45
85.0
2 3
6/4 6/5
240 240
145
304
25.3
8.2 10.7
11.4 11.4
93 84
1.4 1.4
1.1 1.1
116 79
- -
456
6/6 6/7 6/8
240 240 240
148
303
21.9
11.8 12.9 11.1
10.1 10.1 9.9
95 102 51
1.5 0.7 1.6
1.2 0.6 1.2
118 50 119
_
                                       C-35

-------
                    Table 21 - TRS Emissions from Recovery Furnace B

                               Summary  of  Results
  Run Number
  Date -  1972
 Test Time - minutes
 Production Rate - TPH
 Stack Effluent
      Flow rate - DSCFM (XIOOO) 85
      Flow rate - DSCF/ton
      Temnerature - °F
      Water vanor - Vol .  %
      C02  - Vol.  %  dry
     02 -  Vol. % dry
     CO -  opm
TRS Emissions
     pnm
     Ib/hr
     Ib/ton of nulp*
SO? Emission^
     pom                       0.9
     Ib/hr
     Ib/ton of  nulo
1
7/13
240
85
395
0
1.6
.05
2 3
7/14 7/15
240 240
84 86
400 415
12.3 12.4
8-1 7,6
0 0
0.2 0.5
0.7 0.1
.01 .02
4 5 6
7/18 7/19 7/20
240 240 240
12.7 12.0 12.4
7.7 8.0 8.0
000
0-3 0.4 0.3
0.2 0.2 0.2
•01 .01 .01
  *  Based on  334,5 ATDP/day

-------
1
n/n
240
2
IT/12
240
3
11/13
240
4
11/14
240
5
11/15
240
                  Table 22 - TRS Emissions from Recovery Furnace D








                             Summary of Results



Run Number



Date - 1972



Test Time - minutes



Production Rate - TPH            -           -



Stack Effluent



     Flow rate - DSCFM (X1000)   73.2       73.2      73.2      73.2    73.2



     Flow rate - DSCF/ton



     Temperature - °F



     Water vanor - Vol .  %       35         35        35        35      35



     C02 - Vol . % dry



     02 - Vol. % dry



     CO - opm



TRS Emissions



                                3.1        2.8       3.9       7.0     2.8
     Ib/hr                      55.1       48.9      53.7      12.5    46.0



     1 b/ton of nulo             -          -                    -       -



SO? Emissions



     nnm                        15.5       1.0       22.9      5.0     14.2



     Ib/hr                      162        10        239       52      149



     1 b/ton of nulo              -                    -
                                       C-37

-------
           Table 23

ADDITIONAL TRS EMISSION DATA
   FOR RECOVERY FURNACES*
Month
July 1971
Aug.
Sept.
Oct.
Nov.
Dec.
Jan. 1972
Feb.
March
Apri 1
May
June
July
Aug.
Sept.
Oct.




*Tested by
Recovery
Furnace A
TRS Concentration
(ppm, daily average
basis)
Maximum Average
6.0
20.0
5.0
10.9
4.4
9.8
5.5
3.3
2.5
5.3
5.5
8.2
9.8
9.0
4.9
6.1




3.1
2.4
1.5
2.8
1.3
1.8
1.6
1.3
1.0
2.0
2.1
3.8
3.7
3.3
2.9
2.2




!
•
• Month
April 1972
May
June
I July
Aug.-
Oct.
Nov.
Dec.
Jan. 1973
Feb.
March
April
May
June
| July
Aug.
Sept.
Oct.
Nov.
Dec.
Recovery
Furnace B
TRS Concentration
(ppm, daily average
basis)
Maximum Average
1.4
2.3
2.8
4.6
5.0
1.9
0.7
1.0
1.5
2.6
2.4
1.5
1.6
1.9
1.6
3.1
1.8
2.0
1.6
3.4
0.7
1.2
1.5
1.1
1.5
0.7
0.4
0.7
0.8
1.0
0.9
0.8
1.0
1.1
1.0
1.2
0.8
0.9
0.8
1.6
operators using barton titrators.
              C-38

-------
       Table 23 (cont.)

ADDITIONAL TRS EMISSION DATA
   FOR RECOVERY FURNACES
Recovery Furnace A
TRS Concentration
(ppm, daily average
basis)
Month Maximum Average





j
Month
Jan. 1974
Feb.
March
April
May
June
Recovery Furnace B
TRS Concentration
(ppm, daily average
basis)
Maximum Average
1.4 0.8
1.9 1.3
5.0 1.6
2.4 1.2
1.8 1.0
1.5 1.0
Month
April 1972
May
June
June 1972
July
Aug.
Sept.
Oct.


Recovery
Furnace H
TRS Concentration
(ppm, daily average
basis)
Maximum Average
3
4
7
8
4
4
2
6


2.1
2.1
3.5
3.1
2.4
1.9
1.3
1.8


Recovery Furnace K
Month
Aug. 1973
Sept.
Oct.
Nov.
3
Dec.
Jan. 1974
Feb.
March
April
May
TRS Concentration
(ppm, daily average
basis)
Maximum Average
6.2
32.0
7.3
17.0
1.2
1.8
2.4
9.7
3.0
3.4
1.0
5.2
2.4
4.1
0.7
0.6
1.0
2.3
1.4
1.4
              C-39

-------
                  Table 24 - TRS Emissions frorr Smelt Dissolving Tank D

                               Summary of Results
  Run Number                      1           2         3
  Date -   1973                     10/31       11/1       11/2
  Test Time  - minutes              240         240        240
  Production Rate  - TPH            25.1        25.9       25.6
 Stack Effluent
      Flow rate - DSCFM          9000       8880      9400
      Flow rate - DSCF/ton       21514      20571      22031
      Temperature -  °F
      Water  vanor -  Vol.  %       37          41         40
      C02  -  Vol.  % dry
      02 - Vol. %  dry
      CO - opm
TRS Emissions
     pnm
     Ib/hr
     Ib/ton  of  nulo
8.1
0.43
0.017
8.8
0.44
0.017
6.9
0.38
.015
                                   C-40

-------
               Table 25 - TRS Emissions from Smelt Dissolving Tank E
Run Number
Date -  1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM
     Flow rate - DSCF/ton
     Temperature - °F
     Water vanor - Vol.  %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - opm
TRS Emissions
     nnm
     Ib/hr
     Ib/ton of nuln
Summarv of Results
   1           2
   9/18       9/19
   240        240
   30.1       34.1
   19542
   38954

   26
   2.4
   0.27
   0.009
18740
32974

26
1.9
0.20
.006
3
9/20
240
31.3

19100
36613

23.3
2.7
0.28
.009
                                      C-41

-------
1
11/5
240
2
11/7
240
3
11/7
240
4
11/7
240
5
11/8
240
6
11/8
240
                       Table 26  -  "RS  Emissions  from Lime  Kiln  D

                               Summary of Results
  Run  Number
  Date  -   1973
  Test  Time  - minutes
  Production Rate - TPH
 Stack Effluent
      Flow rate - DSCFM (X1000)
      Flow rate - DSCF/ton
      Temnerature -  °F
      Water  vanor -  Vol.  %      43         35        40        38      41       31
      C02  -  Vol.  % dry
     02 - Vol. % dry
     CO - opm
TRS Emissions
     pnm                        3.5         24.1       2.8        5.7      4.6     17.8
     Ib/hr
     Ib/ton  of  pulo
                                      C-42

-------
1
9/24
240
2
9/25
240
3
9/26
240
4
9/26
240
5
9/27
240
6
9/27
240
                       Table 27 - TRS Emissions from Lime Kiln E

                             Summary of Results
Run Number
Date -  1973
Test Time - minutes
Production Rate - TPH
Stack Effluent
     Flow rate - DSCFM (XI000)
     Flow rate - DSCF/ton
     Temperature - °F
     Water vaoor - Vol.  %
     C02 - Vol. % dry
     02 - Vol. % dry
     CO - Vol. % dry
TRS Emissions
     pom                        1.7        0.8       0.5       0.4     0.3     0.5
     Ib/hr
     Ib/ton of nulo
76.1
9.4
13.2
0,2
61.3
10.2
11.0
0.2
71.9
10.0
12.2
0.1
59.9
9.8
12.0
0.3
56.4
8.2
13.1
0.1
72.0
9.8
11.8
0.2
                                       C-43

-------
                     Table 28 - TRS Emissions from Lime Kiln K

                               Summary of Results
  Run  Number
  Date -   1974
  Test Time  - minutes
  Production Rate - TPH
 Stack Effluent
       Flow rate - DSCFM (X1000)  13.8
       Flow rate - DSCF/ton
      Temoerature - °F
      Water vaoor - Vol.  %
      C02  -  Vol.  %  dry
      02 -  Vol. % dry
      CO - opm
TRS Emissions
      pom
      Ib/hr
     Ib/ton of nulo
SOp Emissions
     nnm
     Ib/hr
     Ib/ton  of  nulD
1
4/5
240
13.8
142
21.8
13.0
7.6
0
4.6
0.34
52
7.2
2 3 4 5 6
4/5 4/9 4/9 4/10 4/10
240 240 240 240 240
13-8 14.0 13.4 13.6 14.2
142 146 152 155 154
21 -8 22.9 26.0 25.8 26.8
13-° 14.2 14.2 14.6 14.2
7-6 7.1 7.1 6.4 7.2
0 o ooo
12.0 4.5 4.8 4.0 5.2
0-88 0.33 0.34 0.29 0.39
42 25 18 16 37
5-8 3.5 2.4 2.2 5.2

-------
                                  Table 29

                       ADDITIONAL TRS EMISSION DATA
                              FOR LIME KILNS*
Month

May 1973
June
July

Aug.

Sept.
Oct.
Nov .
Dec.
Jan. 1974
Feb.
March
April
May




Lime Kiln E

TRS Concentration
(ppm, daily average)
Maximum Average

1.4
3.4
2.1

1.4

10.1
7.1
5.9
8.9
3.4
2.6
0.7
3.1
2.9




Month
li
0.3
0.7
0.4

0.3
l
1.5
1.0
0.8
1.0
0.6
0.2
0.1
0.6
0.7




Jan. 1973
Feb.
March

April

May
June
July
Aug.
Sept.
Oct.
Nov.
Dec.
Jan. 1974
Feb.
March
April
May
Lime
Kiln 0
TRS Concentration
(ppm, daily average)
Maximum Average

14
20
14

32

16
10
9
12
17
34
12
22
30
33
30
40
25

6.8
9.3
7.6

9.6

4.7
3.4
4.5
3.8
5.0
8.2
5.7
9.8
17.9
21.1
19.3
16.2
12.3
Avpraap = 9.7
*Tested by operators using barton titrators,
                                      C-4S

-------

-------
                        APPENDIX D
                   EMISSION MEASUREMENT

     Test methods for the measurement of participate and TRS
emissions from kraft pulp mills are specified as a means of
determining compliance with the proposed standards.  The sampling
and analytical techniques associated with each method are discussed
in this section.
     EPA Standard Method 5 is used for the measurement of particu-
late emissions from the recovery furnace, the smelt dissolving
tank, and the lime kiln.  The provisions of this method were
promulgated in the Federal Register on December 23, 1971 (36 FR
24877).
     The reference test method for measurement of TRS emissions
from kraft pulp mills is Method 16, "Semicontinuous Determination
of Sulfur Emissions from Stationary Sources."  The provisions of
this method will be proposed in the Federal Register at the same
time as the proposal  of the new source performance standards
for kraft pulp mills.
1.   Particulate Sampling
     Recognizing that there is probably no universal, absolutely
accurate methods of particulate sampling, and that all available
methods will likely give varying results for any single test, the
reasoning for the selection of Method 5 as the test method to determine
                             D-l

-------
compliance with the proposed  particulate standards for kraft
recovery furnaces,  lime  kilns,  and smelt dissolving tanks is presented
below:
     For  participate matter  omissions  in  stacks, CPA  relics  primarily upon
liethod  5  for  gathering  the new source  performance standard data base.
Method  5  provides  detailed sampling methodology; for  example,  the  selection
of the  site  at which  to sample stacks  or  ducts  is  tightly  controlled,
along with the number  of sample points and  the  method by which the sampling
 probe will traverse the area to be  sampled.   Method  5 equipment and
 procedures provide a  means  for realtime isokinetic  sampling  and for
 verification that isokinetic sampling  was maintained within  acceptable
 limits.  Few other commonly  accepted  methods provide this  level of detail,
 which  is necessary to minimize subjectively, and to ensure reproducibility
 and representativeness of test results.
      Since particulate matter is not  an absolute quantity, but rather,
 is a function of temperature and pressure, it is necessary that particulate
 sampling methods take  these parameters into account.  Method 5, which
 includes  an out-of-stack filter, provides a means for controlling temperature,
 Pressure  within the sampling  train exerts essentially no effect on  indicated
 results.  Although selection  of temperature can be varied from industry to
                                    D-2

-------
industry, a sampling temperature of 250°  is  used for most industrial
sources.   Reasons for selection of 250° include:
     a,.  Filter temperatures must be held above 212°F at sources  where  moist
yas streams are present.  Below 212°F, condensation can occur and result
in plugging of filters and possible gas/1jquid reactions.  A design
temperature of 250° allows for expected temperature variation within the
train, without dropping below 212°.
     b.  Systems of emission reduction capable of controlling matter
which  exists in participate form at 250° can be employed on most industrial
processes.
     c.  Adherence  to one established  temperature  (even  though some varia-
tion will  be needed at  some source  categories)  allows  comparison from
source category.  This  (limited) standardization is of benefit to equip-
ment vendors and to source  owners  not  subject  to SPMSS because it provides
a  certain  predictive  capability,  i.e., by sampling  at  250°,  results can be
obtained which will in  most cases  be  comparable to SPNSS development data.
In-stack filtration,  by comparison, takes place at  stack temperature, which
usually  is  not constant from one source  to  the  next.   Since  the  temperature
varies,  in-stack filtration does not  necessarily provide a  consistant
definition  of  participate matter.
     Method 5  was  used  to obtain  the  data base  for  particulate emission
standards  for  kraft mill  recovery  furnaces,  lime kilns,  and  smelt dissolving
 tanks.  Consequently, Method  5 is  recommended 'for  use  as  the reference
cornpl iance method.
      Sampling  problems^.  Since control devices  of  kraft recovery furnaces,  lime
 kilns, and smelt dissolving tanks  are generally followed by duct work  and a
 stack, no  special  problems  are anticipated.
                                 D-3

-------
      AI lornn_te _Me Llj£ds_J'oj^_Krcj_f t _Recovu, y J:u_r nances



      (Recognizing  that in-slack  filtration  results  in a  simplification of



 compliance  test  procedures,  EPA  is  not adverse to  the idea of using such



 a  method  whenever:



      a.   The method produces  the  same results or  have  a known relation-



 ship to  the method  used for  data 
-------
that a constant value  of O.U04  gr/dsc1  is  added  to  the  results  of Method 17



and the stack temperature is  no greater than  400°F.




2 •   IB. S Compliance Test i n 9



     The need for an effective  test method for measurement  of  reduced  sulfur



emissions from stationary sources resulted from  a  standard  of  performance  for



new stationary source (SPNSS) program to establish  performance standards for a



variety of kraft mill  unit processes with respect  to malodorous emissions.  As



with  previous SPfISS programs, test methodology was. needed to gather (a)  accurate



data  which would demonstrate emission limitations  attainable through the  use of



best  available emission control systems and (b)  enough sampling and



analytical data such that a  reference method for performance testing could



be  prescribed.



      At  the  inception of  the SPNSS  kraft  mill program in January of 1972,




o  survey was made  to evaluate existing  test methods for potential  use.



This  survey  included a  review of the literature, contact with mill  per-



sonnel,  and  review  of previous  research and evaluation of analytical



techniques by  the  Environmental  Protection Agency(EPA).  Since the degree



 to which methods  are available  for  field  use  in odor measurements is



directly  related  to the  complexity  of  the odorant mixture to be measured,



 it was  fortunate  that  the nature of emissions from  kraft pulping operations



 had been  well  defined.   Emissions  consist primarily of sulfur dioxide



 (SOp) and  four reduced  sulfur  compounds—hydrogen sulfide  (HpS), methyl



 mercaptan  (CfLSH),  dimethyl  sulfide (DMS), and  dimethyl disulfide  (DMDS).



 These compounds  are highly  reactive, particularly the H?S-SOo mixture



 which form elemental  sylfur, and are present  in low concentrations  in well



 controlled sources.  In addition,  the  sources of these emissions (recovery



 furnaces,  lime kilns,  smelt  dissolving tanks, digesters, multiple-effect




                                 D-5

-------
evaporators, washer systems, oxidation systems,  and  concensate  strippers)



are characterized by high temperatures and moist,  particulate-laden  effluent



s treams.



     After careful consideration, it was determined  that an additive total



reduced sulfur (TRS) standard, reflecting all  sulfur compounds  present



minus S0?, was desired.  Considering  this and  the  previously mentioned



source conditions, a field method which could  measure reduced sulfur com-



pounds, either individually or collectively, was sought.



     a-  [je thods Su rveyed.  A rev lev/  of the literature revealed that



analytical methods fell into four main categories:  colorimetry, direct



spectrophotornetry, coulometry, and gas chrornatography.  Although most of



 the methods  surveyed were developed for measurement of ambient concentrations,



 this did  not preclude  their possible  application to  the measurement of stack



 eini ssions .



      (1)  Colorimetry.  A  sample  is  bubbled  through  a  solution which selectively



 absorbs  the  component  or  components desired.  The absorbed  compound is then



 reacted  with specific  reagents to  form a  characteristic color which is



 measured spectrophotometrically.



      An  example  of a  colorimetric  method  is the methylene. blue method



 which  involves the absorption of TRS  compounds  in an  alkaline  suspension



 of cadmium hydroxide  to  form a cadmium sulfide  precipitate.  The  precipi-



 tate is  then reacted  with a strong acidic solution  of N,  N,  dimethyl.P-



 phenylene-diamine and ferric chloride to give methyiene blue,  which is



 measured spectrophotometrically.  Automated sampling and  analytical  trains



 using sequential techniques are  available for tnis  procedure.   Inherent



 deficiencies for stack sampling  applications  include variable  collection



 efficiency,  range limitations, and interferences  from oxidants.




                                 D-6

-------
     Another colorisnetrie method is  the  use  of paper tape  samplers



impregnated with  either lead acetate or  cadmium hydroxide.   These  compounds



react specifically with I!?S and the  resultant colored compound can be



measured directly with a densitometer.   Tape samplers would not be



appropriate for all TRS compounds unless they were all reduced quantitatively



to HpS.  In addition, the range is limited and the method  suffers  from light



sensitivity, fading, the necessity for precise humidity control, and



variability in tape response.



     (2) Spectrophotome try.  The use of infrared and mass  spec trophotoiv.etry



and other sophisticated spectroscopic methods for analysis of  individual oclorants



is well established.  However,  these methods were considered expensive, time



consuming,  and not suitable  for  routine field applications.



     One promising method  in this area was  split-beam ultraviolet spectro-



photometry, which  utilizes  the  strong absorption of  ultraviolet radiation



at 582  mm  by S0?.   In  tin's  method the gas sample is  mixed with air, filtered



and split  into two streams.  One  stream passes  through a catalytic oxidation



furnace where  sulfur  constituents are oxidized  to S0? and  then through  an



optical cell where  its  absorbance is measured.  The  second  stream passes



through a  dummy  furnace and then  into a reference optical  cell.  The dif-



ference in  absorbance values between the  two  cells  is a measure of  the  non -



SCL  sulfur constituents in the  sample stream.   The  system  is  capable of



SOp/TRS concentrations  in the  range of  10 to  2500 ppm.  Since  well-con-



 trolled kraft  mill  sources fall  below the minimum range of 10  ppm,  this



method was  considered not applicable.



      (3)  Coulometry.   Coulometric titration is  based on the principle  of



electrolytically generating a  selected  titrant in a titration cell.   The



 titrant may be a free halogen  (bromine  or iodine)  in aqueous  solution  as





                                 D-7

-------
an oxidizing agent, or a metal  ion (silver),  as  a  reducing  agent.  -The



electrolytic current required to generate the titrant,  as  it  is  consumed,



is a linear measure of the concentration of reactive compounds  in  the  gas



sample,.



     The bromine coulometric titrator has been widely used  by the  kraft



industry as a continuous process monitor for a number of years.   Its



distinct advantage over other coulometric devices  is its ability to respond



to a large variety of alkylsulfides ,  mercaptans , and thioethers, as well



as H?S and SCU.  However, the response to each compound is  different,  making



standardization of  the  instrument and reporting of data difficult.  For



example, H?S gives  a response four times as high as the response of dimethyl



sulfide  for  the same concentration.  This problem was recognized by the paper



industry and the coulometric titrator was modified  to correct this problem.



The modified procedure  (Barton Titrator  Model 400)  utilizes a wet chemical



scrubber  (3% aqueous potassium  acid  phthalate) to remove SO- from the sample.



The sample  is  then heated  to convert the remaining  TRS  compounds  to S0?



which  is measured  by  the  coulometric titfrator.  Using  this procedure, the



 instrument  can  be  standardized  with  SOp  and  all data reported as  TRS.



     The  literature,  verbal  communications with users  of this method, and



 experience  reveal  several  potential  problem  areas:



      a.   Deposition of elemental  sulfur  on  the  electrode,  reducing sensi-



 tivity.



     •b.   Maintenance problems  with the  SCU  scrubber solution,  resulting



 in variable collection efficiency.



      c.   Variations in^response of pollutant concentrations  and excessive



 zero  drifts due to changes in  sample flow  rate.



      d.   Over-oxidation of TRS compounds to sulfur trioxide  (SO.,),  which  is





                                  D-8

-------
not detected by the coulometer.



     (4) Gas Chromatography.   This  system is  based on the  ability  of  the



gas chromatographic columns to separate individual sulfur  compounds,



which are then determined individually by various analytical  techniques.



The most sensitive determination is the flame photometric  detector (FPD).



This technique involves measurement of light emitted from  the excited



S? species formed when a sulfur compound is burned in a hydrogen-rich



f1ame.



     The GC'/FPU system has several  advantages.  It can separate and detect



the  individual TRS compounds.  The sensitivity of detection of each sulfur



compound is less than 5 parts per billion-- a level below concentrations



in wel1-controlled sources.   By placing  a narrow  band-pass optical filter



between  the flame  and a photomultiplier  tube, a high specificity ratio



(30,000:1)  of  sulfur  to non-sulfur bearing constituents can be obtained,



thereby  eliminating most  interferents.   Other interfering components,



carbon  oxides  and  moisture,  both can  be  selectively  removed with a stripper



col utnn.



     b•  Methods  Development.



      0) Anal y t i c a 1 _ _T_ech n i q u es .  Based on  the survey,  the GC/FPD technique



was  considered to  be  the  most promising  and  was  selected  for  field



evaluation.   At  several  of the  plants, the  coulometric titrator was  also



 tried  since this  instrument  was widely used  by  the industry  at the time.



      (2) Sample  Col leetion.   Considering the sulfur compound  reactivity,



 high moisture, and presence  of particulate  matter, EPA developed  a special



 sample  handling  system^.   It  utilizes  a sampling probe  enclosed in  a  stainless



 steel  sheath  with inlet ports perpendicular to  the stack  wall.  A  deflector



 shield is  fixed on the under side  to  deflect the heavier  particles while






                               D-9

-------
the probe is  pocked  with  glass  wool  to  '.i jp  finer  particles.  Teflon  tubing



healed to 25Q°F is  used  to  carry  the sample  from the  probe  to a dilution



system where  the sample  is  routinely diluted 1:9 with clean dry air,



Tiie heated sample line prevents condensation and teflon  does  not  react



with sulfur compounds.  After the sample is  diluted  in a heated dilution



box, its moisture content is reduced so that the dew  point  is below  ambient



temperature,  preventing condensation and sample loss  during analysis.



     (^)  Calibration of Instruments^  For delivery  to and  calibration  of



analytical .instruments, a special system containing  permeation  tubes with



appropriate concentrations of SOp, ''US' DMS, DMDS, and CILSH were installed



into  the  sampling and analytical system.  These gas  permeation  tube  standards



were developed  by EPA personnel specifically for use with GC systems.



      (4)  Field  Evaluation.   Since 1972, EPA has used  the sample delivery



system,  dilution system, calibration system, and  the  GC/FPD methods  at



a  number  of kraft mills.  Two  separate  GC/FPD systems were employed  to



facilitate the  rapid  analysis  of both  high  and low molecular weight sulfur



compounds.  One system resolved  f-LS, SOp, CH.,SH,  and  DMS, while the other



simultaneously  resolved  DMDS and other high molecular weight homologs.



To ensure reliability of the data,  the GC/FPD systems were  frequently



 calibrated with standards  of each of the  sulfur compounds.



      Field experience has  shown  that the  GC/FPD method  is  most reliable,



 sensitive, and precise  for determination  of TRS.  This  has  also  been



 substantiated via  verbal  communications with  industry experts.



      Conversely, at six  of these kraft mills,  two different coulometric



 instruments  have yielde_d poor  results, possibly due  to  the low concentrations



 encountered,  and the operational problems mentioned  earlier.  This  instrument



 is .unacceptable for compliance testing.





                                       D-10

-------
     APPENDIX E



MILL CHARACTERISTICS

-------
                                                      APPENDIX E
                                                  MILL CHARACTERISTICS*
Owners
Allied Paper, Inc.
(Subsidiary of SCM)
American Can Company
Champion International
Container Corporation of
71 America (Sub. of MARCOR)
Georgia Kraft Corp.
(50% owned by Inland
Container; 50% owned
by Mead Corp.)
Gulf States Paper Corp.
Gulf States Paper Corp.
Hammermill Paper Co.
*Derived from: Post's 1973,
Size
(Ton/Day)
490
900
500
850
975
400
475
500
1974, 1975, 1976
No. 7; and Control of Atmospheric Emissions
Location
ALABAMA
Jackson
Butler
Court! and
Brewton
Mahrt
Demopolis
Tuscaloosa
Selma
Pulp and Paper Di
Capacity
Additions**

Market Pulp
Grades***

Recent, current 1 ,2
None
Planned
None
None
Planned
None
None
rectory; Pulp and
in the Wood Pulping Industry, Vol. 1
1,2,4
None
None
None
None
None
1,2
Paper magazii
, a report ti
                                                                                               Paper & Paperboard Produced
                                                                                                    at this Location
                                                                                               Printing & Writing Papers

                                                                                               Tissue; toweling; box, paper,
                                                                                               & pkg board
                                                                                               Uncoated Printing, Writing,
                                                                                               Business & Converting Papers
                                                                                               Paperboard; Food-liquid
                                                                                               board; Kraft paper; linerboar*
                                                                                               Linerboard; kraft board
                                                                                               Paperboard
                                                                                               Kraft Bag & Wrapping
                                                                                               None
Pollution Control  Administration,  1970;  and  discussions with  industry.
                                                                                                           Note
 **Recent:   took  place  in  1974;  Current:  took place in 1975;  Planned:  will take place from 1976 and later.
   these capacity additions may  be at operations ancillary to the pulp mill.
***!.   bleached kraft hardwood pulp; 2.  bleached kraft softwood pulp; 3.  unbleached kraft pulp; 4.  semi-bleached pulp.

-------
                                                        MILL CHARACTERISTICS*
m
i
CO
Owners


International  Paper Co.
Kimberly-Clark Corp.
MacMillan Bloedel  Ltd.
Scott Paper Co.
Union Camp Corp.

Southwest Forest  Industries

Georgia-Pacific  Corp.

Great Northern Nekoosa  Corp.

Green Bay Packaging,  Inc.
International  Paper Co.
International  Paper Co.
Weyerhauser Company
Size
(Ton/Day)
1,350
585
925
1,400
930

Location
ALABAMA (Con't)
Mobile
Coosa Pines
Pine Hill
Mobile
Montgomery
ARIZONA
Capacity
Additions**
None
Planned
None
None
Planned

Market PI
Grades*
None
1,2,3
None
None
None

                                       600
Snowflake
Current
                                                       ARKANSAS
1,500
400
650
750
1,900
230
Crossett
Ashdown
Morri 1 ton
Camden
Pine Bluff
Pine Bluff
Recent
Recent &
Current
Recent
None
Recent
None
1,2,3
1,2
3
None
None
None
,4





                                                                                    Market  Pulp     Paper  &  Paperboard  Produced
                                                                                                        at  this  Location
Paper
Newsprint
Paperboard
Tissue & Other Paper Grades
Paperboard

Newsprint, Linerboard

Kraft Paper, Tissue, &
Paperboard
Business Communications
Papers
Paperboard
Paper
Paper & Board
Paper & Board
None

-------
                                                     MILL CHARACTERISTICS*
  Owners

  Crown Simpson Co. (jointly
  owned by Crown Zellerbach &
  Simpson Lee Paper Co.)
  Fibreboard Corp.
  Louisiana-Pacific Corp.
  Simpson Lee Paper Co.
m
i
  Alton Box Board Co.
  Container Corp. of America
  (Sub. of MARCOR)
  Hudson Pulp & Paper Corp.
  International Paper Co.
  Procter & Gamble Co.
  St. Joe Paper Co.
  St. Regis Paper Co.
  St. Regis Paper Co.
Size
(Ton/ Day)
600
450
700
160
650
1,400
950
1,500
900
1,300
1,510
1,050
Location
CALIFORNIA
Fairhaven
Antioch
Samoa
Anderson
FLORIDA
Jacksonville
Fernandina Beach
Palatka
Panama City
Foley
Port St. Joe
Jacksonville
Pensacola
Capacity
Additions**
None
None
None
Current,
Planned
Current
None
Planned
None
None
None
Current
None
Market Pulp
Grades***
1,4
None
2
None
None
None
1,2,3
1,2
2
None
None
None
Paper & Paperboard  Produced
     at this Location
None
Paperboard
None
Coated Printing Paper,
Machine Finish Grades
Board
Paperboard

Tissue and Bag Papers
Containerboard
None
Paperboard
Kraft Paper & Board
Paper & Board

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                                                          MILL CHARACTERISTICS*
  Owners

  Continental Can Co.
  Continental Can Co.
  Brunswick Pulp & Paper Co.
  (50% owned by Mead Corp.;
  50% owned by Scott Paper)
  Georgia Kraft Corp.
  (50% owned by Inland
  Container Corp.; 50%
  owned by Mead Corp.)

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                                                     MILL CHARACTERISTICS*
  Owners
   Potlatch  Corp.
  Western  Kraft  (Div.  of
  Willamette  Industries,  Inc.)
  Westvaco
   Boise  Cascade  Corp.
71  Boise  Cascade  Corp.
en
   Continental  Can  Co.
   Crown  Zellerbach

   Crown  Zellerbach

   Georgia-Pacific Corp.
   International  Paper  Co.
   International  Paper  Co.
   Western  Kraft
Size
(Ton/Day)
950
320
600
1,250
325
1,400
1,350
500
1,600
1,100
1,650
450
Location
IDAHO
Lewiston
KENTUCKY
Hawesville
Wickliffe
LOUISIANA
DeRidder
Elizabeth
Hodge
BogaTusa
St. Francisville
Port Hudson
Bastrop
Springhill
Campti
Capacity
Additions**
Recent,
Planned
None
None
None
None
Current &
Planned
None
None
Planned
None
None
Recent,
Current
& Planned
Market Pulp
Grades***
2
1
1
None
None
None
None
None
1,2,3,4
None
1,2
1,2
Paper & Paperboard Produced
at this Location
Paperboard & Tissue
None
Fine Papers
Newsprint & Linerboard
Bag, Bag Lining, Convertin,
Envelopes, Wrapping
Coarse Paper & Paperboard
Paperboard, Kraft Wrapping
& Bag
Coated Papers, Kraft Paper
& Board
None
Kraft Paper & Board
Paper & Board
Paper & Board

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                                                       MILL  CHARACTERISTICS*
Owners
01 in Kraft, Inc.
Pineville Kraft Corp.
Diamond International Corp.


Georgia-Pacific Corp.

International Paper Co.
Lincoln Pulp & Paper Co., Inc.
Div. of Premoid

Oxford Paper (Div. of
Ethyl Corp.)
S. D. Warren Co.
Div. of Scott Paper Co.
Westvaco Corp.



Mead Corp.
Scott Paper Co.


Boise Cascade Corp.
  Size
(Ton/Day)


  1,150


    880
    425


  1,170

  1,150


    320


    585


    300
   465
Location
 Capacity      Market Pulp
Additions**     Grades***
  LOUISIANA (CONT.)
West Monroe          Recent &          None
                     Planned

Pineville
Recent, Current   None
& Planned
                                                        MAINE
Old Town
Current &
Planned
1
Woodland             Recent            1,2,3,4

Jay (Androscoggin)   Planned           None
Lincoln
Rumford
Westbrook
Recent
None
Recent, Current,  1
& Planned
None
None
                                                     MARYLAND
665

600
225

Luke
MICHIGAN
Escanaba
Muskegon
MINNESOTA
None

None
None

None

1,2
1,2,3




,4

Int'l  Falls
None
None
           Paper & Paperboard Produced
                 at this Location
            Kraft Paper and Board,
            & Corrigating Medium
            Kraft Liner Board
Tissue

Printing Papers & Newsprint
Bond, Carbonizing, & Coated
Printing Papers

Fine Paper & Tissue


Fine, Printing &
Publishing Papers
Specialty & Other Papers
                                                                Fine  Papers


                                                                Coated Printing  Papers
                                                                Fine  Papers
Printing, Publishing, &
White Papers; Insulation
Board

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                                                   MILL  CHARACTERISTICS*
Owners

Potlatch Corp.



International Paper Co.

International Paper Co.

International Paper Co.

St. Regis Paper Co.



Hoerner Waldorf Corp.



Brown Co.




International Paper Co.



Champion International
Size
(Ton/Day)
400
715
1,000
1,200
1,792
1,200
700
590

Location
. MINNESOTA
Cloquet (CONT.)
MISSISSIPPI
Moss Point
Natchez
Vicksburg
Monti cello
MONTANA
Missoula
NEW HAMPSHIRE
Berlin-Gorham
NEW YORK
Ticonderoga
NORTH CAROLINA
Capacity
Additions**
Recent, cur-
rent, planned
None
None
None
Current
Planned
Current
None

Market Pulp
Grades***
None
None
1,2
None
None
2,4
1,3
None

Paper & Paperboard Produced
at this Location
Printing & Business Paper
Paper
None
Containerboard
Linerboard & Paper
Paperboard
Paper, Printing, Industrial
Tissue and Towel, Corrugating
Book & Business Grades

1,360
Canton
Recent
None
Uncoated Printing, Writing,
& Converting Papers;
Bleached Paperboard for Milk
& Folding Cartons

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                                                 MILL  CHARACTERISTICS'
 Owners
 Federal  Paper Board Co.

 Hoerner  Waldorf Corp.
 Weyerhaeuser Co.
 Weyerhaeuser Co.
 Mead Corp.
i


 Weyerhaeuser Co.

 American Can Co.
 Boise Cascade Corp.
 Crown Zellerbach
Size
(Ton/Day)
1,200
950
640
1,500

540
1,600
340
1,050
916
Location
Capacity
Additions**
NORTH CAROLINA
Riegelwood (CONT.) Recent. &
Roanoke Rapids
New Bern
Plymouth
OHIO
Chillocothe
OKLAHOMA
Valliant
OREGON
Halsey
St. Helens
Clatskanie
current
Recent
None
Current,
Planned

Recent &
Planned
None
None
Current
None
Market Pulp
Grades***
1,2
None
1,2,4
None

None
None
1,2,4
None
None
Paper & Paperboard Produced
at this Location
Paperboard
Paperboard
None
Paperboard & Fine

Fine Papers
Paperboard
Tissue
Specialty & Fine
Newsprint, Tissue


Papers




Papers
,
                                                                                                   Industrial

-------
                                                     MILL  CHARACTERISTICS*
   Owners
   Georgia-Pacific
   International  Paper Co.
   Western  Kraft
   (Willamette  Industries,  Inc.)
   Weyerhaeuser Co.
   Appleton  Papers,  Inc.  (Div.
   of National  Cash  Register)
L  P.  H.  Glatfelter  Co.
o
   Penntech  Papers,  Inc.
   Bowater,  Inc.
   International  Paper Co.

   South  Carolina Ind.,  Inc.
   (79% Owned  by  Stone Cont.  Corp.)
   Westvaco  Corp.
   Bowater,  Inc.
   Packaging Corp.  of  America
   (Sub.  of  Tenneco)
Size
(Ton/Day)
1,250
600
600
1,150
180
500
180
Location
OREGON (CONT.
•*- -1 1 -.-„- _. :rr^:::^_ ::::::, „ Am ml ILL- II
Toledo
Gardiner
Albany
Springfield
PENNSYLVANIA
P.oaring Springs
Spring Grove
Johnsonburg
Capacity
Additions**
Current
None
None
Planned
None
Current,
Planned
None
Market Pulp
Grades***
None
None
None
None
None
None
None
Paper & Paperboard Produrp,
at this Location
Kraft Paper, Paperboard
Paperboard
Kraft Papers, Corrugating
Medium
Paperboard
Fine Papers
Printing & Writing Papers
Fine, Printing, Publishing,
& Business Paper
SOUTH CAROLINA
1,000
1,830
675
1,989
500
775
Catawba
Georgetown
Florence
Charleston
TENNESSEE
Calhoun
Counce
Recent
Current &
Planned
Current
Recent
None
Current
1,2,4
None
None
None
4
None
Book Papers
Board & Corrugating Medium
Paperboard
Paperboard
Newsprint
Paperboard

-------
                                                    MILL CHARACTERISTICS*
Owners
Champion International

International Paper Co.
Owens-Illinois, Inc.
Southland Paper Mills, Inc.
Southland Paper Mills, Inc.
Tempie-Eastex, Inc.
(Sub. of Time, Inc.)
Chesapeake Corp. of Vir.

Continental Can Co.
Union Camp Corp.

Westvaco Corp.
Boise Cascade Corp.
Crown Zellerbach
Size
(Ton/Day)
820
650
900
500
400
1,300
1,150
900
1,500
1,000
700
730
Location
TEXAS (CONT.)
Pasedena
Texarkana
Orange
Houston
Lufkin
Evadale
VIRGINIA
West Point
Hopewel 1
Franklin
Covington
WASHINGTON
Wallula
Camas
Capacity
Additions**
Planned
Planned
Planned
Recent
Recent &
Planned
Planned
Recent,
Current
None
Current
None
Current
None
Market Pulp
Grades***
None
1,2
3
3,4
3,4
None
1,2,3
None
None
None
None
None
Paper & Paperboard Produced
at this Location
Uncoated & Coated Printing
Writing & Converting Papers
Paperboard
Board
Newsprint & Kraft Paper
Newsprint
Paper & Paperboard
Coarse Paper & Paperboard
Paperboard
Paperboard & Fine, Industrial
and Coarse Papers
Paperboard & Corrugating
Medium
Linerboard & Corrugating
Medium
Tissues, Industrial, & Fine
                                                                                                  Papers

-------
                                                          MILL CHARACTERISTICS*
   Owners

   Crown Zellerbach

   Longview Fibre Co.

   St.  Regis Paper Co.

   Weyerhaeuser Co.
m  Weyerhaeuser Co.
PO
   Consolidated Papers, Inc.

   Great Northern Nekoosa Corp.

   Hanrnermill  Paper Co.

   Mosinee Paper Corp.
Size
(Ton /Day)
420
1,900
1,029
375
700
395
330
356
175
Location
WASHINGTON (Con
Port Townsend
Longview
Tacoma
Everett
Longview
WISCONSIN
Wisconsin Rapids
Nekoosa
Kaukauna
Mosinee
Capacity
Additions**
't)
Current,
Recent
Current &
Planned
None
Current
Current
Recent &
Planned
Recent
Recent &
Planned
Planned
Market Pulp
Grades***
None
None
2,3,4
1,2,4
1,2,4
None
None
None
None
Paper & Paperboard Produced
at this Location
Paper & Paperboard
Paperboard & Kraft Paper
Linerboard, Natural & White
Paper
None
Paperboard & Bristol Papers
None
Business Communi cations
Papers
Packaging & Special
Industrial Papers
Paper & Paperboard

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                                  TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
1. REPORT NO.
 EPA-45Q/2-76-Q14a	
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
                                                           5. REPORT DATE
 Standard Support  and Environmental Impact  Statement
 VOLUME 1:  PROPOSED  STANDARDS OF PERFORMANCE
 FOR KRAFT PULP  MILLS	
               -Se
1976
              6. PERFORMING ORGANIZATION CODE
7. AUTHORIS)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 U.S. Environmental  Protection Agency
 Office of Air  Quality Planning and Standards
 Research Triangle  Park, N.  C.  27711
                                                           10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                           13. TYPE OF REPORT AND PERIOD COVERED
                                                           14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
                       Volume 1  discusses the PROPOSED STANDARDS and the resulting
 environmental and economic  effects.  Volume 2,  to  be published when the Standards
 are promulgated, will  contain  public comments on the Proposed Standards,  EPA
 responses, and a discussion of differences between  the  Proposed and Promulgated
 Standards.                                                      .._.._..._
16. ABSTRACT
  Standards of performance  for  the control of emissions  of total  reduced sulfur  (TRS)
  and particulate matter from new and modified kraft  pulp  mills are being proposed
  under the authority of section  111  of the Clean Air Act.   TRS emissions freifi kraft
  pulp mills are extremely  odorous, and there are numerous instances of poorly
  controlled mills creating  public odor problems.  The proposed standards would  prevent
  odor problems from most newly constructed kraft pulp mills,  except in the immediate
  vicinity of the mills on  occasions  when meteorological conditions produce downwash
  of stack plumes.  Particulate matter emissions from new  mills would be reduced
  by more than 99 percent below the levels that would result from no control and
  more than 50 percent below the  average levels that  are being achieved by existing
  facilities controlled to  the  average State standards.  Emissions of TRS would  be
  reduced by more than 95 percent below the uncontrolled levels and more than 80
  percent below the average  levels for existing sources.   An analysis of the environ-
  mental  and economic effects associated with the proposed standards is included  in
  this document.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
  Air pollution
  Pollution  control
  Standards  of performance
  Kraft pulp mills
  Total reduced  sulfur
  Particulate matter
                                              b.IDENTIFIERS/OPEN ENDEDTERMS
  Air pollution  control
                                                                         c.  COSATI Field/Group
13. DISTRIBUTION STATEMENT
  Unlimited
                                              19. SECURITY CLASS (This Report)
                                                  Unclassified	
                            21. NO. OF PAGES
                                398
 20. SECURITY CLASS (This page)
     Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)


        *U.b. GOVERNMENT PRINTING OFFICE: 1976-M1-301/5TO
F-l

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