EPA-453/R-96-012
       Technical Support Document:
CHEMICAL RECOVERY COMBUSTION
   SOURCES AT KRAFT AND SODA
             PULP MILLS
           Emission Standards Division
   U. S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Air and Radiation
      Office of Air Quality Planning and Standards
        Research Triangle Park, NC  27711
               October 1996

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This report has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and Standards, EPA, and
approved for publication.  Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use.  Copies of this report are available
through the Library Services Office  (MD-35), U. S. Environmental
Protection Agency, Research Triangle Ps.rk, NC  27711.
(919) 541-2777, or from National Technical Information Services,
5285 Port Royal Road, Springfield, VA  22161,  (703) 487-4650.
                                11

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                        TABLE OF  CONTENTS
1.0  INTRODUCTION	      1-1
     1.1  SCOPE OF THE TECHNICAL SUPPORT DOCUMENT  ....      l-l
     1.2  ORGANIZATION OF THE TECHNICAL SUPPORT
          DOCUMENT	      1-1

2.0  COMBUSTION PROCESSES IN THE KRAFT PULP INDUSTRY   .  .      2-1
     2.1  OVERVIEW OF CHEMICAL RECOVERY PROCESSES  ....      2-1
     2.2  COMBUSTION PROCESSES AND EQUIPMENT	      2-9
          2.2.1  Recovery Furnaces   	      2-9
          2.2.2  Smelt Dissolving Tanks 	    2-21
          2.2.3  Black Liquor Oxidation Systems  	    2-24
          2.2.4  Lime Kilns	    2-28
     2.3  BASELINE EMISSIONS	    2-34
          2.3.1  Federal and State Regulations Affecting
                 Kraft Pulp Mill Combustion Sources ...    2-34
          2.3.2  Baseline Emission Estimates   	    2-36
     2.4  REFERENCES FOR CHAPTER 2	    2-44

3;. 0  EMISSION CONTROL TECHNIQUES ,	      3-1
     3.1  ADD-ON CONTROLS	,	      3-1
          3.1.1  Electrostatic Precipitators   	      3-1
          3.1.2  Wet Scrubbers	    3-18
          3.1.3  BLO Control	    3-43
     3.2  EQUIPMENT CHANGES/MODIFICATIONS	    3-45
          3.2.1  .Elimination of Black Liquor used in
                 NDCE Recovery Furnace ESP Control
                 Systems	    3-45
          3.2.2  Conversion from a DCE Recovery
                 Furnace System to an NDCE Recovery
                 Furnace  	..........    3-50
     3.3  REFERENCES FOR CHAPTER 3	    3-60

4.0  MODEL PROCESS UNITS, CONTROL OPTIONS,  AND ENHANCED
     MONITORING OPTIONS 	      4-1
     4.1  MODEL PROCESS UNITS 	      4-1
          4.1.1  Recovery Furnace Models  	      4-1
          4.1.2  Smelt Dissolving Tank Models ......    4-11
          4.1.3  Black Liquor Oxidation Unit Models ...    4-14
          4.1.4  Lime Kiln Models	    4-17
     4.2  CONTROL OPTIONS	    4-21
          4.2.1  Recovery Furnace Control  Options ....    4-21
          4.2.2  SDT Control Options	    4-28
          4.2.3  BLO Unit Control Option	    4-34
          4.2.4  Lime Kiln Control  Options	    4-34
     4.3  ENHANCED MONITORING OPTIONS 	    4-38
          4.3.1  Recovery Furnace Enhanced  Monitoring . .    4-41
          4.3.2  Smelt Dissolving Tank Enhanced
                 Monitoring .  ".	    4-43

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                  TABLE OF CONTENTS  (continued)
5.0
6.0
          4.3.3  Black Liquor Oxidation Unit Enhanced
                 Monitoring 	 	
          4.3.4  Lime Kiln Enhanced Monitoring  .  .  .
     4.4  REFERENCES FOR CHAPTER 4  	
     5.2
            ,1.2
            ,1.3
            ,1.4
            ,1.5
            .2.2
            .2.3
MODEL PROCESS UNIT ENVIRONMENTAL AND ENERGY
IMPACTS  	
5.1  GENERAL APPROACH   	
     5.1.1  Air Pollution Impacts   	
            Energy Impacts  	
            Water Pollution Impacts  	
            Solid Waste Disposal Impacts  ....
            Other Impacts	
     RECOVERY FURNACE CONTROL'OPTIONS	
     5.2.1  PM Controls  	
            Wet to Dry ESP System Conversion  .  .
            Conversion of a DCE Recovery  Furnace
            System to an NDCE Recovery  Furnace  .
            Addition of Packed-Bed Scrubber   .  .
     BLACK LIQUOR OXIDATION UNIT CONTROL  OPTION
     5.3.1  Air Pollution Impacts   	
            Energy Impacts  	
            Water Pollution Impacts  	
            Solid Waste Disposal Impacts  ....
            Other Impacts   	
     SMELT DISSOLVING TANK CONTROL OPTIONS .  .  .
     5.4.1  PM Controls  	
     LIME KILN CONTROL OPTIONS 	
     5.5.1  PM Controls  .... 	
     REFERENCES FOR CHAPTER 5  	
          5.2.4
     5.3
          5,
          5,
          5,
          5,
3.2
3.3
3.4
3.5
     5.4
     5.5
     5.6
MODEL PROCESS UNIT CONTROL AND ENHANCED MONITORING
COSTS  	
6.1  CONTROL OPTION COSTS  	
     6.1.1  General Costing Approach  .......
            Recovery Furnace Control  Options  .  .  .
            Black Liquor Oxidation Unit Control
            Options  	
            Smelt Dissolving Tank Control Options
            Lime Kiln Control Options  	
     ENHANCED MONITORING COSTS 	
     6.2.1  Recovery Furnace Enhanced
            Monitoring  	
     6.2.2  Black Liquor Oxidation Unit Enhanced
            Monitoring  	  	
          6.
          6,

          6
          6
1.2
1.3

1.4
1.5
     6.2
                                                        4-44
                                                        4-44
                                                        4-46
 5-1
 5-1
 5-2
 5-5
 5-7
 5-8
 5-8
 5-9
 5-9
5-14

5-16
5-23
5-28
5-28
5-29
5-30
5-30
5-30
5-31
5-31
5-35
5-36
5-98
 6-1
 6-1
 6-2
 6-7

6-40
6-43
6-47
6-52

6-53

6-58
                                VI

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     6.3
                  TABLE OF CONTENTS  (continued)
6.2.3  Smelt Dissolving Tank Enhanced
       Monitoring 	
6.2.4  Lime Kiln Enhanced Monitoring
REFERENCES FOR CHAPTER 6  	
                                                             Page
 6-59
 6-60
6-127
APPENDIX A.
APPENDIX B.
   EVOLUTION OF THE TECHNICAL SUPPORT DOCUMENT
   EMISSION MEASUREMENT AND CONTINUOUS MONITORING
   FOR PULP AND PAPER COMBUSTION SOURCES
                               VI1

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                         LIST OF FIGURES
Figure 2-1

Figure 2-2
Figure

Figure

Figure

Figure

Figure
Figure
Figure
Figure
Figure
Figure
Figure
Figure
Figure

Figure

Figure

Figure
Figure

Figure

Figure

Figure

Figure

Figure

Figure

Figure

Figure
Figure
Figure
2-3

2-4

2-5

2-6

2-7
2-8
2-9
2-10a
2-1 Ob
2-lla
2-lib
2-12
2-13

2-14

2-13

3-1
3-2

3-3

3-4

3-5

3-6

3-7

3-8

3-9

3-10
3-11
3-12
Figure 3-13
Distribution of U.S. kraft and soda pulp
mills	•• •
Relationship of the chemical recovery
cycle to the pulping and product forming
processes  	
Kraft process--chemical recovery area
(DCE recovery furnace) 	
Soda process--chemical recovery area
(DCE recovery furnace) 	
Schematic of NDCE recovery furnace and
associated equipment  	
Schematic of DCE recovery furnace and
associated equipment  	  ,  • •
Cascade design evaporator  	
Cyclone design evaporator  .......
Recovery furnace zones and air stages
DCE recovery furnace age distribution
NDCE recovery furnace age distribution .
DCE recovery furnace size distribution .
NDCE recovery furnace size distribution
Smelt dissolving tank and wet scrubber .
Two-stage air-sparging black liquor
oxidation system .  	
Schematic of a lime kiln used at kraft
pulp mills	
Schematic of a lime kiln used at kraft
pulp mills 	
Rigid-electrode ESP   	
PM emission data for  recovery furnace
No. 3 at Mill A  .  .  	
PM emission data for  recovery furnace
No. 4 at Mill B  	
PM emission data for  recovery furnace
No. 3 at Mill B  	
PM emission data for  lime kiln No.  5  at
Mill C  	
PM emission data for  lime kiln No.  1  at
Mill D	
Acid gas control system configuration on
recovery furnace exhaust gases  	
Schematic of a counterflow" packed-bed
scrubber	
Schematic of a cross-flow packed-bed
scrubber  	
Schematic of a venturi scrubber   ....
PM emission data for  lime kiln at Mill A
PM emission data for  lime kiln No.  4  at
Mill B  	
PM emission data for  SDT No. 3 at Mill B
 2-2


 2-4

 2-5

 2-6

2-11

2-12
2-13
2-14
2-16
2-18
2-18
2-20
2-20
2-22

2-26

2-30

2-29
 3-5

3-10

3-11

3-12

3-17

3-19

3-21

3-22

3-23
3-34
3-38

3-39
3-40
                               vixi

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LIST OF FIGURES  (continued)
                                           Page
Figure
Figure
Figure

Figure


Figure

Figure

Figure

Figure

Figure
Figure
Figure
Figure

Figure

Figure

Figure

Figure

Figure

Figure

Figure

Figure

Figure

3
3
3

3


3

3

4

4

4
4
4
5

5

5

5

5

5

5

5

5

5

-14
-15
-16

-17


-18

-19

-la

-Ib

-2a
-2b
-3
-1

-2

-3

-4

-5

-6

-7

-8

-9

-10

PM emission data for SDT No. 4 at Mill B .
PM emission data for SDT No. 22 at -Mill C
Methanol emissions for NDCE recovery
furnaces 	
Methanol emissions for DCE recovery
furnace systems and NDCE recovery
furnaces .... 	
Emission sources for a DCE recovery
furnace system 	
Emission sources for an NDCE recovery
furnace 	
Size distribution for DCE recovery
furnaces 	
Size distribution for NDCE recovery
furnaces .... 	
DCE recovery furnace model size, ranges . .
NDCE recovery furnace model size ranges
Size distribution for lime kilns 	
Particulate matter emissions from model
NDCE recovery furnaces 	
Particulate matter emissions from model
DCE recovery furnaces 	
Gaseous organic HAP emissions from model
recovery furnaces 	
Total reduced sulfur emissions from
model recovery furnace systems 	
Hydrochloric acid emissions from model
recovery furnaces
Sulfur dioxide emissions from model
recovery furnaces 	
Gaseous organic HAP emissions from model
BLO units . . 	
Total reduced sulfur emissions from
model BLO units 	 	
Particulate matter emissions from model
smelt dissolving tanks 	
Particulate matter emissions from model
lime kilns 	
3-41
3-42

3-51


3-56

3-58

3-59

4-6

4-6
4-7
4-7
4-19

5-41

5-42

5-43

5-44

5-45

5-46

5-47

5-48

5-49

5-50
             IX

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                          LIST OF TABLES
TABLE 2-1
TABLE
TABLE

TABLE
TABLE

TABLE

TABLE

TABLE
TABLE
TABLE
2-2
2-3

2-4
2-5a

2-5b

2-6

3-1
3-2
3-3
TABLE 3-4
TABLE
TABLE
TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE
TABLE
3-5
3-6
3-7

4-la

4-lb

4-2a

4-2b

4-3a

4-3b

4-4a

4-4b

4-5
4-6a
 TABLE 4-6b
BLACK LIQUOR OXIDATION SYSTEMS:  EQUIPMENT
TYPES 	
CHEMICAL COMPOSITION OF LIME MUD FEED  .  .  .
NSPS AND EMISSION GUIDELINES FOR KRAFT PULP
MILL COMBUSTION SOURCES 	
HAP EMISSION FACTORS  	
(METRIC).  NATIONWIDE BASELINE GASEOUS HAP
EMISSION ESTIMATES  	
(English).  NATIONWIDE BASELINE GASEOUS  HAP
EMISSION ESTIMATES  	
NATIONWIDE BASELINE PM, PM HAP, AND TRS
EMISSIONS 	
PARTICULATE MATTER HAP CONTROL TECHNIQUES  .
GASEOUS HAP CONTROL TECHNIQUES   ......
SUMMARY OF DATA ON KRAFT RECOVERY FURNACE
COMBUSTION GAS CHARACTERISTICS   	
SUMMARY OF ACID GAS SCRUBBER PERFORMANCE
DATA	
HAP EMISSIONS FOR BLO UNITS	•
HAP EMISSIONS FOR NDCE RECOVERY  FURNACES
HAP EMISSIONS FOR DCE RECOVERY FURNACE
SYSTEMS AND NDCE RECOVERY FURNACES   ....
(METRIC).  RECOVERY FURNACE MODEL PROCESS
UNITS AND PROCESS PARAMETERS   	
(ENGLISH).  RECOVERY FURNACE MODEL PROCESS
UNITS AND PROCESS PARAMETERS   	
(METRIC).  SMELT DISSOLVING TANK MODEL
PROCESS UNITS AND PROCESS PARAMETERS   .  .  .
(ENGLISH).  SMELT DISSOLVING TANK MODEL
PROCESS UNITS AND PROCESS PARAMETERS   .  .  .
(METRIC).  BLACK LIQUOR OXIDATION UNIT
MODEL PROCESS UNITS AND PROCESS  PARAMETERS
(ENGLISH).  BLACK LIQUOR OXIDATION UNIT
MODEL PROCESS UNITS AND PROCESS  PARAMETERS
(METRIC).  LIME KILN MODEL PROCESS UNITS
AND PROCESS PARAMETERS   	
(ENGLISH).  LIME KILN MODEL  PROCESS UNITS
AND PROCESS PARAMETERS   	
RECOVERY FURNACE CONTROL OPTIONS  	
(METRIC).  RECOVERY FURNACE  MODELS:
LOW-ODOR CONVERSION CONTROL  OPTION
(INCLUDES WET TO DRY ESP SYSTEM  CONVERSION
AND PM  CONTROL TO NSPS LEVEL)  	
(ENGLISH).  RECOVERY FURNACE MODELS:
LOW-ODOR CONVERSION CONTROL  OPTION
(INCLUDES WET TO DRY ESP SYSTEM  CONVERSION
AND PM  CONTROL TO NSPS LEVEL)  	
Page


2-28
2-31

2-35
2-38

2-43

2-43

2-44
  3-2
  3-2

3-28

3-30
3-46
3-49

3-55

  4-2

  4-3

4-12

4-12

4-15

4-15

4-18

 4-18
 4-22
                                                              4-24
                                                              4-24

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                    LIST OF TABLES  (continued)
TABLE 4-7a
TABLE 4-7b
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
4-
4-
4-
4-
4-
4-
4-
4-
4-
8a
8b
9a
9b
lOa
lOb
lla
lib
12a
TABLE 4-12b


TABLE 4-13a

TABLE 4-13b

TABLE 4-14a

TABLE 4-14b

TABLE 4-15a


TABLE 4-15b


TABLE 4-16a

TABLE 4-16b
 (METRIC).   RECOVERY FURNACE MODELS:   LOW-
 ODOR CONVERSION CONTROL OPTION (INCLUDING
 WET  TO  DRY ESP SYSTEM CONVERSION AND PM
 CONTROL TO 0.034 G/DSCM)   	    4-25
 (ENGLISH).   RECOVERY FURNACE MODELS:  LOW-
 ODOR CONVERSION CONTROL OPTION (INCLUDING
 WET  TO  DRY ESP SYSTEM CONVERSION AND PM
 CONTROL TO 0.015 GR/DSCF)	    4-25
 (METRIC).   RECOVERY FURNACE MODELS:   WET TO
 DRY  ESP SYSTEM CONVERSION CONTROL OPTION  .    4-26
 (ENGLISH).   RECOVERY FURNACE MODELS:
 WET  TO  DRY ESP SYSTEM CONVERSION CONTROL
.OPTION	    4-26
 (METRIC).   RECOVERY FURNACE MODELS:   PM
 CONTROL OPTIONS (0.10 G/DSCM)  	    4-27
 (ENGLISH).   RECOVERY FURNACE MODELS:  PM
 CONTROL OPTIONS (0.044 GR/DSCF)  	    4-27
 (METRIC).   RECOVERY FURNACE MODELS:   PM
 CONTROL OPTIONS (0.034 G/DSCM)   	    4-29
 (ENGLISH).   RECOVERY FURNACE MODELS:  PM
 CONTROL OPTIONS (0.015 GR/DSCF)  	    4-30
 (METRIC).   RECOVERY FURNACE MODELS:   HC1
 CONTROL OPTION (PACKED-BED SCRUBBER)  ...    4-31
 (ENGLISH).   RECOVERY FURNACE MODELS:  HC1
 CONTROL OPTION (PACKED-BED SCRUBBER)  .  . .    4-31
 (METRIC).   RECOVERY FURNACE MODELS:   HC1
 CONTROL OPTION (PACKED-BED SCRUBBER  AFTER
 LOW-ODOR CONVERSION)	,    4-32
 (ENGLISH).   RECOVERY FURNACE MODELS:  HC1
 CONTROL OPTION (PACKED-BED SCRUBBER  AFTER
 LOW-ODOR CONVERSION)   .  	    4-32
 (METRIC).   SMELT DISSOLVING TANK MODELS:
 PM CONTROL OPTIONS(0.10  KG/MG BLS)   ....    4-33
 (ENGLISH).   SMELT DISSOLVING TANK MODELS:
 PM CONTROL OPTIONS  (0.20  LB/TON BLS)  ...    4-33
 (METRIC).   SMELT DISSOLVING TANK MODELS:
 PM CONTROL OPTIONS  (0.06  KG/MG BLS)  ....    4-35
 (ENGLISH).   SMELT DISSOLVING TANK MODELS:
 PM CONTROL OPTIONS  (0.12  LB/TON BLS)  ...    4-35
 (METRIC).   BLACK LIQUOR  OXIDATION UNIT
 MODELS:  METHANOL CONTROL  OPTION
 (INCINERATION)   	    4-36
 (ENGLISH).   BLACK LIQUOR  OXIDATION UNIT
 MODELS:  METHANOL CONTROL OPTION
 (INCINERATION)	    4-36
 (METRIC).   LIME KILN MODELS:   PM CONTROL
 OPTIONS  (0.15  G/DSCM)	 .    4-37
 (ENGLISH).   LIME KILN MODELS:   PM CONTROL
 OPTIONS  (0.067 GR/DSCF)  	    4-37

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                    LIST OF TABLES (continued)
TABLE

TABLE

TABLE
TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE

TABLE
4-17a

4-17b

4-18
5-la

5-lb

5-2a

5-2b

5-3a

5-3b

5-4a

5-4b

5-5a

5-5b

5-6a

5-6b

5-7

5-8a

5-8b

5-9a

5-9b

5-10a
MODEL NDCE RECOVERY FURNACE
MODEL DCE RECOVERY FURNACE
TABLE  5-10b
TABLE  5-lla
(METRIC).  LIME KILN MODELS:  PM CONTROL
OPTIONS (0.023 G/DSCM)   .........
(ENGLISH).  LIME KILN MODELS:  PM CONTROL
OPTIONS (0.010 GR/DSCF)  .  .  . .	
ENHANCED MONITORING OPTIONS  	
(METRIC).  MODEL NDCE RECOVERY FURNACE
PARAMETERS
(ENGLISH).
PARAMETERS  	
(METRIC).  MODEL DCE RECOVERY FURNACE
PARAMETERS
(ENGLISH).
PARAMETERS  	
(METRIC).  MODEL NDCE RECOVERY FURNACE
CONCENTRATIONS AND EMISSION  FACTORS  ....
(ENGLISH).  MODEL NDCE RECOVERY FURNACE
CONCENTRATIONS AND EMISSION  FACTORS
(METRIC).  MODEL DCE RECOVERY FURNACE
CONCENTRATIONS AND EMISSION  FACTORS  ....
(ENGLISH).  MODEL DCE RECOVERY FURNACE
CONCENTRATIONS AND EMISSION  FACTORS  ....
(METRIC).  PRIMARY PM AND  PM HAP EMISSIONS
FOR MODEL RECOVERY FURNACES  .  .  	
(ENGLISH).  PRIMARY PM AND PM HAP EMISSIONS
FOR MODEL RECOVERY FURNACES  	
(METRIC).  SECONDARY EMISSIONS FOR PM
CONTROL FOR MODEL RECOVERY FURNACES  ....
(ENGLISH).  SECONDARY EMISSIONS FOR  PM
CONTROL FOR MODEL RECOVERY FURNACES  ....
ENERGY IMPACTS FOR PM CONTROL FOR MODEL
RECOVERY FURNACES  	
(METRIC).  PRIMARY GASEOUS ORGANIC HAP
EMISSIONS FOR MODEL RECOVERY FURNACES  .  .  .
(ENGLISH).  PRIMARY GASEOUS  ORGANIC  HAP
EMISSIONS FOR MODEL RECOVERY FURNACES  .  .  .
(METRIC).  TOTAL REDUCED SULFUR COMPOUND
EMISSIONS FOR MODEL RECOVERY FURNACES  .  .  .
(ENGLISH).  TOTAL REDUCED  SULFUR COMPOUND
EMISSIONS FOR MODEL RECOVERY FURNACES  .  .  .
(METRIC).  SECONDARY  EMISSIONS FOR
LOW-ODOR CONVERSION FOR  MODEL DCE RECOVERY
FURNACES   	
(ENGLISH).  SECONDARY EMISSIONS  FOR
LOW-ODOR CONVERSION FOR  MODEL DCE RECOVERY
FURNACES   	
(METRIC).  ENERGY  IMPACTS  FOR  LOW-ODOR
CONVERSION FOR MODEL  DCE RECOVERY
FURNACES   	
Page


4-39

4-39
4-40

5-51

5-52

5-53

5-54

5-55

5-56

5-57

5-58

5-59

5-60

5-61

5-62

5-63

5-64

 5-65

 5-66

 5-67


 5-68


 5-69


 5-70
                                XI1

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                    LIST OF TABLES  (continued)
TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5

TABLE 5'
-lib

•12a

•12b

•13a

•13b

•14

•15a

•15b

•16a

•,16b

•17a
TABLE 5-17b


TABLE 5-18a

TABLE 5-18b

TABLE 5-19

TABLE 5-20a


TABLE 5-20b


TABLE 5-21a

TABLE 5-21b

TABLE 5-22a

TABLE 5-22b

TABLE 5-23a
 (ENGLISH).  ENERGY  IMPACTS  FOR LOW-ODOR
CONVERSION FOR MODEL DCE  RECOVERY FURNACES
 (METRIC).  PRIMARY  ACID GAS EMISSIONS  FOR
MODEL RECOVERY FURNACES  	
 (ENGLISH).  PRIMARY ACID  GAS EMISSIONS FOR
MODEL RECOVERY FURNACES  	
 (METRIC).  SECONDARY EMISSIONS FOR HCL
CONTROL  FOR MODEL RECOVERY  FURNACES  .  .  .  .
 (ENGLISH).  SECONDARY  EMISSIONS FOR  HCL
CONTROL  FOR MODEL RECOVERY  FURNACES  .  .  .  .
ENERGY IMPACTS FOR  HCL CONTROL FOR MODEL
RECOVERY FURNACES 	
 (METRIC).  WASTEWATER  IMPACTS FOR HCL
CONTROL  FOR MODEL RECOVERY  FURNACES  .  .  .  .
 (ENGLISH).  WASTEWATER IMPACTS FOR HCL
CONTROL  FOR MODEL RECOVERY  FURNACES  .  .  .  .
 (METRIC).  MODEL BLACK LIQUOR OXIDATION
UNIT PARAMETERS AND EMISSION FACTORS  .  .  .
 (ENGLISH).  MODEL BLACK LIQUOR OXIDATION
UNIT PARAMETERS AND EMISSION FACTORS  .  .  .
 (METRIC).  PRIMARY  GASEOUS  ORGANIC HAP
EMISSIONS FOR MODEL BLACK LIQUOR OXIDATION
UNITS 	
 (ENGLISH).  PRIMARY GASEOUS ORGANIC  HAP
EMISSIONS FOR MODEL BLACK LIQUOR OXIDATION
UNITS	
 (METRIC).  SECONDARY EMISSIONS FOR MODEL
BLACK LIQUOR OXIDATION UNITS  	
 (ENGLISH).  SECONDARY  EMISSIONS FOR  MODEL
BLACK LIQUOR OXIDATION UNITS  .......
ENERGY IMPACTS FOR  MODEL  BLACK LIQUOR
OXIDATION UNITS 	
 (METRIC).  TOTAL REDUCED  SULFUR COMPOUND
EMISSIONS FOR MODEL BLACK LIQUOR OXIDATION
UNITS 	
 (ENGLISH).  TOTAL REDUCED SULFUR COMPOUND
EMISSIONS FOR MODEL BLACK LIQUOR OXIDATION
UNITS 	
 (METRIC).  MODEL SMELT DISSOLVING TANK
PARAMETERS AND PM EMISSION  FACTORS  .  .  .  .
 (ENGLISH).  MODEL SMELT DISSOLVING TANK
PARAMETERS AND PM EMISSION  FACTORS  .  .  .  .
       (METRIC)
           PRIMARY PM AND PM HAP EMISSIONS
      FOR MODEL SMELT DISSOLVING TANKS   	
       (ENGLISH).   PRIMARY  PM AND PM HAP EMISSIONS
      FOR MODEL SMELT DISSOLVING TANKS   	
       (METRIC).  SECONDARY EMISSIONS FOR MODEL
      SMELT DISSOLVING TANKS  	
Page


5-71

5-72

5-73

5-74

5-75

5-76

5-77

5-78

5-79

5-79


5-80


5-80

5-81

5-81

5-82


5-83


5-83

5-84

5-85

5-86

5-87

5-88
                               Xlll

-------
                    LIST OF TABLES (continued)
TABLE 5-23b    (ENGLISH).  SECONDARY EMISSIONS  FOR MODEL
              SMELT DISSOLVING TANKS	'  -   5-88
TABLE 5-24    ENERGY REQUIREMENTS  FOR  MODEL  SMELT
              DISSOLVING TANKS   	     5-89
TABLE 5-25b    (ENGLISH) .  MODEL  LIME KILN PARAMETERS  AND
              PM CONCENTRATIONS	     5-91
TABLE 5-263.    (METRIC) .  PRIMARY PM AND  PM HAP EMISSIONS
              FOR MODEL LIME  KILNS	•  •     5-92
TABL3 5-26b    (ENGLISH) .  PRIMARY  PM AND PM  HAP EMISSIONS
              FOR MODEL LIME  KILNS	     5-93
TABLE 5-27a    (METRIC) .  SECONDARY EMISSIONS FOR MODEL
              LIME KILNS	     5-94
TABLE 5-27b    (ENGLISH) .  SECONDARY EMISSIONS  FOR MODEL
              LIME KILNS	     5-95
TABLE 5-28    ENERGY IMPACTS  FOR MODEL LIME  KILNS  ....     5-96
TABLE 5-29a    (METRIC) .  WASTEWATER IMPACTS  FOR MODEL
              LIME KILNS	     5-97
TABLE 5-29b    (ENGLISH) .  WASTEWATER IMPACTS FOR MODEL
              LIME KILNS	     5-97
TABLE 6-la     (METRIC) .  COSTS OF  ESP  REPLACEMENT TO
              CONTROL  PM TO 0.10 G/DSCM  FOR  MODEL
              RECOVERY FURNACES  (EXCLUDING PULP
              PRODUCTION LOSSES)   	 	     6-62
TABLE 6-2a     (METRIC) .  COSTS OF  ESP  REPLACEMENT TO
              CONTROL  PM TO 0.10 G/DSCM  FOR  MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)   	     6-64
TABLE 6-2b     (ENGLISH) .   COSTS  OF ESP REPLACEMENT  TO
              CONTROL  PM TO 0.044  GR/DSCF FOR MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)   	     6-65
TABLE 6-3     SUMMARY  OF ASSUMPTIONS USED IN ESP UPGRADE
              COSTS	     6-66
TABLE 6-4a     (METRIC). COSTS OF  SCHEDULE 1 ESP UPGRADE
              TO CONTROL PM TO  0.10  G/DSCM FOR MODEL
              RECOVERY FURNACES  (EXCLUDING PULP
               PRODUCTION LOSSES)   	     6-67
TABLE 6-4b     (ENGLISH).   COSTS  OF SCHEDULE  1 ESP  UPGRADE
               TO CONTROL PM TO  0.044 GR/DSCF FOR MODEL
              RECOVERY FURNACES  (EXCLUDING PULP
               PRODUCTION LOSSES)	     6-68
                                XIV

-------
                    LIST OF TABLES (continued)
TABLE 6-5a     (METRIC).  COSTS OF SCHEDULE 2  ESP UPGRADE
              TO CONTROL PM TO 0.10 G/DSCM FOR MODEL
              RECOVERY FURNACES  (EXCLUDING PULP
              PRODUCTION LOSSES)  	  	     6-69
TABLE 6-5b     (ENGLISH).  COSTS OF SCHEDULE 2 ESP UPGRADE
              TO CONTROL PM TO 0.044 GR/DSCF  FOR MODEL
              RECOVERY FURNACES  (EXCLUDING PULP
              PRODUCTION LOSSES)  	     6-70
TABLE 6-6a     (METRIC).  COSTS OF SCHEDULE 1  ESP UPGRADE
              TO CONTROL PM TO 0.10 G/DSCM FOR MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-71
TABLE 6-6b     (ENGLISH).  COSTS OF SCHEDULE 1 ESP UPGRADE
              TO CONTROL PM TO 0.044 GR/DSCF  FOR MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-72
TABLE 6-7a     (METRIC).  COSTS OF SCHEDULE 2  ESP UPGRADE
              TO CONTROL PM TO 0.10 G/DSCM FOR MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-73
TABLE 6-7b     (ENGLISH).  COSTS OF SCHEDULE 2 ESP UPGRADE
              TO CONTROL PM TO 0.044 GR/DSCF  FOR MODEL
              RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-74
TABLE 6-8a     (METRIC).  COSTS OF ESP UPGRADE TO CONTROL
              PM FROM 0.10 G/DSCM TO 0.034 G/DSCM FOR
              MODEL RECOVERY FURNACES  (EXCLUDING PULP
              PRODUCTION LOSSES)  	     6-75
TABLE '6-8b     (ENGLISH).  COSTS OF ESP UPGRADE TO CONTROL
              PM FROM 0.044 GR/DSCF TO 0.015  GR/DSCF  FOR
              MODEL RECOVERY FURNACES  (EXCLUDING PULP
              PRODUCTION LOSSES)  	     6-76
TABLE 6-9a     (METRIC).  COSTS OF ESP UPGRADE TO CONTROL
              PM FROM 0.10 G/DSCM TO 0.034 G/DSCM FOR
              MODEL RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-77
TABLE 6-9b     (ENGLISH).  COSTS OF ESP UPGRADE TO CONTROL
              PM FROM 0.044 GR/DSCF TO 0.015  GR/DSCF  FOR
              MODEL RECOVERY FURNACES  (INCLUDING PULP
              PRODUCTION LOSSES)  	     6-78
TABLE 6-10a    (METRIC).  WET- TO DRY-BOTTOM ESP
              CONVERSION COSTS FOR MODEL NDCE RECOVERY
              FURNACES	     6-79
TABLE 6-10b    (ENGLISH).  WET- TO DRY-BOTTOM  ESP
              CONVERSION COSTS FOR MODEL NDCE RECOVERY
              FURNACES	     6-80
                                xv

-------
                    LIST OF TABLES (continued)
TABLE 6-lla




TABLE 6-lib




TABLE 6-12a




TABLE 6-12b




TABLE 6-13a




TABLE 6-13b




TABLE 6-14a




TABLE 6-14b




TABLE 6-15a

TABLE 6-15b

TABLE 6-16
(METRIC).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.10 G/DSCM) FOR MODEL
DCE RECOVERY FURNACES  (EXCLUDING PULP
PRODUCTION LOSSES)  	
(ENGLISH).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.044 GR/DSCF) FOR MODEL
DCE RECOVERY FURNACES  (EXCLUDING PULP
PRODUCTION LOSSES)  	
(METRIC).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.10 G/DSCM) FOR MODEL DCE
RECOVERY FURNACES  (INCLUDING PULP
PRODUCTION LOSSES)  	
(ENGLISH).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.044 GR/DSCF) FOR MODEL
DCE RECOVERY FURNACES  (INCLUDING PULP
PRODUCTION LOSSES)	  .  .  .
(METRIC).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.034 G/DSCM) FOR MODEL
DCE RECOVERY FURNACES  (EXCLUDING PULP
PRODUCTION LOSSES)  	
(ENGLISH).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.015 GR/DSCF) FOR MODEL
DCE RECOVERY FURNACES  (EXCLUDING PULP
PRODUCTION LOSSES)  .  	
(METRIC).  CAPITAL COSTS OF LOW-ODOR
CONVERSION (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.034 G/DSCM) FOR MODEL
DCE RECOVERY FURNACES  (INCLUDING PULP
PRODUCTION LOSSES)  	
(ENGLISH).  CAPITAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING  ESP UPGRADE TO
CONTROL PM TO 0.015 GR/DSCF) FOR MODEL
DCE RECOVERY FURNACES  (INCLUDING PULP
PRODUCTION LOSSES)  	
(METRIC).  MODEL DCE RECOVERY  FURNACE/ESP
DESIGN PARAMETERS 	•
(ENGLISH).  MODEL DCE  RECOVERY FURNACE/ESP
DESIGN PARAMETERS	
SCENARIO 1: ANNUAL COSTS  OF LOW-ODOR
CONVERSION  (INCLUDING  ESP UPGRADE TO
CONTROL PM TO 0.10 G/DSCM [0.044 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (EXCLUDING
ANNUALIZED PULP PRODUCTION  LOSSES)   .  .  .  .
6-81
6-82
6-83
6-84




6-85




6-86




6-87




6-88

6-89

6-90




6-91
                                xvi

-------
                    LIST OF TABLES (continued)
TABLE 6-17
TABLE 6-18
TABLE 6-19
TABLE 6-20





TABLE 6-21





TABLE 6-22a

TABLE 6-22b
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
6-23a
6-23b
6-24a
6-24b
6-25
6-26
6-27a
6-27b
6-28
SCENARIO 2: ANNUAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.10 G/DSCM  [0.044 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (INCLUDING
BLEACHED PULP PRODUCTION LOSSES)  	    6-92
SCENARIO 3: ANNUAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.10 G/DSCM  [0.044 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (INCLUDING
UNBLEACHED PULP PRODUCTION LOSSES)  ....    6-93
SCENARIO 1: ANNUAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.034 G/DSCM  [0.015 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (EXCLUDING
ANNUALIZED PULP PRODUCTION LOSSES)  ....    6-94
SCENARIO 2: ANNUAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.034 G/DSCM  [0.015 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (INCLUDING
BLEACHED PULP PRODUCTION LOSSES)  	    6-95
SCENARIO 3: ANNUAL COSTS OF LOW-ODOR
CONVERSION  (INCLUDING ESP UPGRADE TO
CONTROL PM TO 0.034 G/DSCM  [0.015 GR/DSCF])
FOR MODEL DCE RECOVERY FURNACES  (INCLUDING
UNBLEACHED PULP PRODUCTION LOSSES)  ....    6-96
(METRIC).  GAS AND LIQUID STREAM PARAMETERS
FOR RECOVERY FURNACE MODEL PROCESS UNITS   .    6-97
(ENGLISH).  GAS AND LIQUID STREAM
PARAMETERS FOR RECOVERY FURNACE MODEL
PROCESS UNITS 	    6-98
(METRIC).  PACKED-BED SCRUBBER DESIGN AND
OPERATING PARAMETERS	    6-99
(ENGLISH).  PACKED-BED SCRUBBER DESIGN
AND OPERATING PARAMETERS   	    6-100
(METRIC).  UNIT COSTS FOR PACKED-BED
SCRUBBER	    6-101
(ENGLISH).  UNIT COSTS FOR PACKED-BED
SCRUBBER	    6-101
PACKED-BED SCRUBBER CAPITAL COSTS FOR
MODEL RECOVRERY FURNACES   	    6-102
PACKED-BED SCRUBBER ANNUAL COSTS FOR
MODEL RECOVERY FURANCES 	    6-103
(ENGLISH).  MODEL BLACK LIQUOR OXIDATION
UNIT DESIGN PARAMETERS	    6-104
(ENGLISH).  MODEL BLACK LIQUOR OXIDATION
UNIT DESIGN PARAMETERS	    6-105
CAPITAL AND ANNUAL COSTS OF COLLECTION
AND INCINERATION OF BLO VENT GASES FOR
MODEL BLACK LIQUOR OXIDATION UNITS  ....    6-106
                               xvi i

-------
                    LIST OF TABLES (continued)
TABLE 6-293.

TABLE 6-29b

TABLE 6-30a

TABLE 6-30b

TABLE 6-31

TABLE 6-32a


TABLE 6-32b


TABLE 6-33a


TABLE 6-33b
TABLE

TABLE

TABLE

TABLE

TABLE

TABLE


TABLE


TABLE


TABLE
TABLE
TABLE
6-34a

6-34b

6-35

6-36a

6-36b

6-37


6-38


6-39a


6-39b
6-40
6-41
        (METRIC).  SCRUBBER REPLACEMENT COSTS FOR
        MODEL SDT'S	
        (ENGLISH).  SCRUBBER REPLACEMENT COSTS FOR
        MODEL SDT'S  	
                   MODEL SDT/SCRUBBER DESIGN
                    MODEL SDT/SCRUBBER DESIGN
(METRIC).
PARAMETERS
(ENGLISH).
PARAMETERS   	
CAPITAL AND ANNUAL COSTS TO REPLACE MIST
ELIMINATORS WITH SCRUBBERS FOR MODEL SDT'S
(METRIC).  COSTS TO REPLACE SCRUBBERS
WITH ESP'S TO CONTROL PM TO 0.15 G/DSCM
FOR MODEL LIME KILNS  	
(ENGLISH).  COSTS TO REPLACE SCRUBBERS WITH
ESP'S TO CONTROL PM TO 0.067 GR/DSCF FOR
MODEL LIME KILNS	
(METRIC).  COSTS TO REPLACE SCRUBBERS WITH
ESP'S TO CONTROL PM TO 0.023 G/DSCM FOR
MODEL LIME KILNS  	
(ENGLISH).  COSTS TO REPLACE SCRUBBERS
WITH ESP'S TO CONTROL PM TO 0.010 GR/DSCF
FOR MODEL LIME KILNS  	
(METRIC).  MODEL LIME KILN/SCRUBBER
DESIGN PARAMETERS	
(ENGLISH).  MODEL LIME KILN/SCRUBBER
DESIGN PARAMETERS 	
ANNUAL COSTS FOR EXISTING LIME KILN
SCRUBBERS 	
(METRIC).  MODEL LIME KILN/ESP DESIGN
PARAMETERS   . 	
(ENGLISH).  MODEL LIME KILN/ESP DESIGN
PARAMETERS   	
ANNUAL COSTS FOR NEW LIME KILN ESP'S
CONTROLLING PM TO 0.15 G/DSCM
(0.067 GR/DSCF) 	
ANNUAL COSTS FOR NEW LIME KILN ESP'S
CONTROLLING PM TO 0.023 G/DSCM
(0.010 GR/DSCF) 	 	
(METRIC).  COSTS TO UPGRADE ESP'S TO
CONTROL PM TO 0.023 G/DSCM FOR MODEL LIME
KILNS	
(ENGLISH).  COSTS TO UPGRADE ESP'S TO
CONTROL PM TO 0.010 GR/DSCF FOR MODEL LIME
KILNS . . .	
SUMMARY OF ENHANCED MONITORING COSTS   .  .  .
OPACITY AND HCL CONTINUOUS EMISSION MONITOR
COSTS	
Page


6-107

6-108

6-109

6-110

6-111


6-112


6-113


6-114


6-115

6-116

6-117

6-118

6-119

6-120


6-121


6-122


6-123
6-124
6-125

6-126
                               XVlll

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               'LIST OF ACRONYMS AND UNITS OF MEASURE
 a.c.
 acfm
 acmm
 ADMBP/d
 ADMP
 ADMUP/d
 ADTBP/d
 ADTP
 ADTUP/d
 APCD
 As
 Be
 BLO
 BLRBAC
 Btu/lb
 Ca (OH) ,
 CAA
 CaCOo
 CaO
 Cd
 GEM
 CFR
 cm
 Co
 CO
 CO,
 Cr
 CRF
 CS9
 d/yr
 d.c.
 DAC
 DAS
 DCE
 DMF
 EMTIC

 EPA
 ESP
 FID

 ft9
 ftVl/000 acfm

 ft2
 FTIR
g/L
g/dscm
gal/acf
gal/yr
GC
GFC
gpm
gr/dscf
 alternating current
 actual cubic foot .(feet)  per minute
 actual cubic meter(s)  per minute
 air-dried megagram(s)  of  bleached pulp per day-
 air-dried megagram(s)  ton of pulp
 air-dried megagram(s)  of  unbleached pulp per day
 air-dried ton(s)  of bleached pulp per day
 air-dried ton(s)  of pulp
 air-dried ton(s)  of unbleached pulp per day
 air pollution control  device
 arsenic
 beryllium
 black  liquor oxidation
 Black  Liquor Recovery  Boiler Advisory Committee
 British thermal unit per  pound
 calcium hydroxide
 Clean  Air Act as  amended  in  1990
 calcium carbonate
 calcium oxide
 cadmium
 continuous emission monitor
 Code of Federal Regulations
 cent imeter(s)
 cobalt
 carbon monoxide
 carbon dioxide
 chromium
 capital recovery  factor
 carbon disulfide
 day(s)  per year
 direct current
 direct annual  cost(s)
 data acquisition  system
 direct contact evaporator
 N,N-dimethylformamide
 Emission Measurement Technical  Information
 Center
 U. S.  Environmental  Protection Agency
 electrostatic  precipitator
 flame  ionization  detector
 foot (feet)
 square  foot  (feet) per 1,000 actual  cubic feet
per minute
 square  foot  (feet)
 fourier  transform infrared
gram(s) per liter
gram(s) per dry standard  cubic meter
gallon(s)
gallon(s) per  actual cubic foot
gallon(s) per year
gas chromatography
gas filter correlation
gallon(s) per minute
grain(s) per dry standard cubic foot
                               xix

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HoO
HAP
HC1
Hg
HOMER
hp
hr/d
HSCSST
HVLC
HWI
IAC
IMS
in.
in. H20
ITAC
KC1
kg BLS/d
kg/ADMP
kg/Mg
kg PM/MWh
kJ/kg
kW
kWh
L/min
L
L/yr
L/acm
L/G
Ib PM/MM Btu
lb BLS/d
Ib/gal
Ib/ADTP
Ib/ton
LOQ
LVHC
mo    i
nc/(nr/sec)

m3
n£
rrr/sec
MACT
MEE
mg
 Mg/yr
 min
 MJ/yr
 ml
 mm Hg
 MM Btu/yr
 MM
 Mn
 MSD
 MST
 MWI
 Na2C03
                               rate
water
hydrogen sulfide
hazardous air pollutant
hydrochloric acid
mercury-
hazardous organic mass emission
horsepower
hour(s) per day
heated summa canister source sampling train
high-volume, low-concentration
hazardous waste incinerator
indirect annual cost(s)
ion mobility spectroscopy
inch(es)
inch(es) of water
incremental total annual cost(s)
potassium chloride
kilogram(s) of black liquor solids per  day
kilogram(s) per air-dried megagram of pulp
kilogram(s) per megagram
kilogram(s) of PM per megawatt-hour
kilojoule(s) per kilogram
kilowatt(s)
kilowatt-hour(s)
liter(s) per minute
liter(s)
liter(s) per year
liter(s) per actual cubic meter
liquid-to-gas
pound(s) of PM per million  Btu
     ''  ' of black  liquor  solids per  day
         per  gallon
         per  air-dried ton  of pulp
c	 per  ton
 limit of quantitation
 low-volume, high-concentration
meter(s)                                  ,
 square meter(s)  per cubic meter per second
 square meter(s)
 cubic meter(s)
 cubic meter(s)  per second
 maximum available control technology
 multiple-effect evaporators
 milligram(s)
 megagram(s) per year
 minute(s)
 megajoule(s)  per year
 milliliter(s)
 millimeter(s)  of mercury
 million Btu per year
 million(s)
 manganese
 mass selective detector
 Methanol Sampling Train
 medical waste incinerator
 sodium carbonate
pound(s)
pound(s)
pound(s)
pound(s)
                                 xx

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 Na2S
      0,
 NaCl
 NaOH  ,
 NCASI

 NCG
 NDCE
 NESHAP
 Ni
   ^
 NSPS
 NSSC

 °?
 OAQPS
 Pb
 PCDD/PCDF

 PM
ppm
ppmdv
ppmv
QA/QC
RRF
Sb
SCA
SDT
Se
sec
SIE. -
S02
T-R
TAG
TCI
TDS
THC
Tl
ton/yr
TPIEC
TRS
TSD
UV
IfOC
 sodium sulfide
 sodium thiosulfate
 sodium sulfate
 sodium chloride
 sodium hydroxide
 National Council of the Paper Industry for
 Air and Stream Improvement,  Inc.
 noncondensible gases
 nondirect contact evaporator
 national emission standards  for hazardous  air
 pollutants
 nanogram(s)
 nickel
 nitrogen oxides
 new source performance  standards
 neutral sulfite semichemical
 oxygen
 Office of Air Quality Planning and  Standards
 lead
 polychlorinated dibenzo-p-dioxins
 and dibenzofurans
 particulate matter
 part(s)  per billion
 part(s)  per million.
 part(s)  per million dry volume
 part(s)  per million by  volume
 quality assurance/quality control
 relative response factor
 antimony
 specific collecting area
 smelt  dissolving tank
 selenium
 second(s)
 specific ion  electrodes
 sulfur dioxide
 transformer-rectifier
 total  annual  costs
 total  capital investment
 total  dissolved  solids
 total  hydrocarbon
 thallium
 ton(s) per year
 Texas  Paper Industry Environmental Committee
 total  reduced sulfur
 technical support document
mi crometer(s)
ultraviolet
volatile organic  compound
                               xxi

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                        1.0  INTRODUCTION
     National emission standards for hazardous air pollutants
 (NESHAP} are under development for combustion processes in the
chemical recovery area of kraft and soda pulp mills under
authority of Section 112(d) of the Clean Air Act  (CAA) as amended
in 1990.  This technical -support document  (TSD) provides
technical information and analyses used in the development of
this NESHAP.  Effluent guideline limitations and a separate
NESHAP covering pulp and paper manufacturing processes are being
developed concurrently under the authority of the Clean Water Act
and the CAA, respectively; the technical information and analyses
for these regulations are found in separate documents.  The U. S.
Environmental Protection Agency (EPA) is coordinating these
efforts to produce air and water regulations, for'the pulp and
paper industry.  The remainder of this chapter describes the
scope and organization of this TSD.
1.1  SCOPE OF THE TECHNICAL SUPPORT DOCUMENT
     This TSD presents the technical information and the analyses
used in the development of the NESHAP for combustion processes in
the chemical recovery area of kraft and soda pulp mills.  The
chemical recovery combustion processes included in this NESHAP
are (1) recovery furnaces  (including associated smelt dissolving
tanks and black liquor oxidation systems)  and  (2)  lime kilns.
1..2  ORGANIZATION OF THE TECHNICAL SUPPORT DOCUMENT
     This TSD is organized into six chapters.  Chapter 2.0
describes the processes and equipment associated with the
                              a.*.
chemical recovery cycle at kraft and soda pulp mills, identifies
the hazardous air pollutants (HAP's)  emitted and the emission
                               1-1

-------
sources, and quantifies baseline HAP emissions.  Chapter 3.0
describes the emission control techniques that can be used to
reduce HAP emissions from chemical recovery combustion processes,
including add-on control systems and equipment changes.
Chapter 4.0 presents model plants and control and enhanced
monitoring options for chemical recovery combustion processes.
Chapter 5.0 discusses the environmental and energy impacts on the
model process units from the application of the HAP control
options presented in Chapter 4.0.  Finally, Chapter 6.0 presents
the model process unit control and enhanced monitoring costs for
the application of the control options.  Appendix A lists the
evolution of this technical support document.  Appendix B
summarizes the available HAP emissions data and discusses the
test methods and monitoring methods that could be used to
demonstrate compliance with proposed standards for chemical
recovery combustion sources at kraft and soda pulp mills.
                                1-2

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       2.0   COMBUSTION PROCESSES  IN THE KRAFT PULP INDUSTRY

     This chapter describes the combustion processes and
equipment associated with the chemical recovery cycle at kraft
and soda pulp mills, as well as the HAP's emitted from these
processes and equipment.  The chemical recovery process includes
four sources of HAP emissions that are the focus of this
document.  These sources are (1)  chemical recovery furnaces
(including direct contact evaporator  [DCE] recovery furnaces and
nondirect contact evaporator [NDCE] recovery furnaces), (2) smelt
dissolving tanks (SDT's), (3) black liquor oxidation  (BLO)
systems, and (4) lime kilns.  Section 2.1 provides an overview of
the kraft chemical recovery process.  More detailed information
on the combustion processes and equipment is included in
Section 2.2.  Section 2.3 presents existing Federal and State
regulations affecting kraft pulp mills, process emission factors,
and baseline HAP emissions.   The references to this chapter are
provided in Section 2.4.
2.1  OVERVIEW OF CHEMICAL RECOVERY PROCESSES
     This section provides an overview of the chemical recovery
cycle at kraft and soda pulp mills.  References 1 and 2 listed in
Section 2.4 provide more detailed descriptions of the chemical
recovery cycle.1'
     TJiere are approximately 122 kraft pulp mills currently
operating in tlie United States.3  There are only two soda mills
currently operating in the United States.4  One soda mill is
located in Pennsylvania and the other is located in Tennessee.4
Figure 2-1 shows the number of kraft and soda pulp mills located
in each State.   As shown in Figure 2-1, the majority  (52 percent)
of kraft pulp mills are located in the southeastern United
                               2-1

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                                                         •d
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                                                          m
                                                         -tJ
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2-2

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States.  The kraft process is the dominant pulping process in the
United States, accounting for approximately 85 percent of all
domestic pulp productipn.5  The soda pulping process is similar
to the kraft process, except that soda pulping is a nonsulfur
process.  One reason why the kraft process dominates the paper
industry is because of the ability of the kraft chemical recovery
process to recover approximately 95 percent of the pulping
chemicals and at the same time produce energy in the form of
steam.  Other reasons for the dominance of the kraft process
include its ability to handle a wide variety of wood species and
the superior strength of its pulp.
     The production of kraft and soda paper products from wood
can be divided into three process areas:   (1) pulping of wood
chips,  (2) chemical recovery/ and (3) product forming  (includes
bleaching).  The relationship of the chemical recovery cycle to
the pulping and product forming processes is shown in Figure 2-2.
Process flow diagrams of the chemical recovery area at kraft and
soda pulp mills are shown in Figures 2-3 and 2-4, respectively.
Kraft and soda chemical recovery processes are similar, except
that the soda process does not require BLO systems, which are
installed to reduce total reduced sulfur  (TRS) emissions from DCE
recovery furnaces.  Both kraft and soda mills have chemical
recovery furnaces, SDT's, and lime kilns.  This document focuses
on the four primary emission sources in the chemical recovery
area.  The emission sources covered in this document are the BLO
system  (kraft process only), the recovery furnace, the SDT, and
tiie lime kiln.  These emission sources are shaded in both process
flow diagrams.  Air emissions from these sources are expected to
be similar for both kraft and soda processes, with the exception
of TRS emissions.  The soda process does not utilize sulfur-
containing compounds; therefore, no TRS emissions are generated
by soda mills.
     Because of the similarities between the kraft and soda
process and the predominant use of the kraft process, the
information presented in the remainder of this document focuses
on the kraft chemical recovery process.
                               2-3

-------
    WOOD
                    PULPING
   PULP
              PRODUCT
              FORMING
                                                              PAPER OR
                                                            PULP PRODUCT
WHITE LIQUOR
BLACK LIQUOR
               CHEMICAL RECOVERY
       Figure 2-2.  Relationship of the chemical recovery cycle
             to the pulping and product  forming processes.
                                  2-4

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     The purpose of the chemical recovery cycle is to recover
cooking liquor chemicals from spent cooking liquor.  The process
involves concentrating black liquor,^. combusting organic
compounds, reducing inorganic compounds, and reconstituting
cooking liquor.
     Cooking liquor, which is referred to as "white liquor," is
an aqueous solution of sodium hydroxide  (NaOH)  and sodium sulfide
(Na2S) that is used in .the pulping area of the mill.  In the
pulping process, white liquor is introduced with wood chips into
digesters, where the wood chips are "cooked" under pressure.  The
contents of the digester are then discharged to a blow tank,
where the softened chips are disintegrated into fibers or "pulp."
The pulp and spent cooking liquor are subsequently separated in a
series of brown stock washers;  Spent cooking liquor, referred to
as "weak black liquor," from the brown stock washers is routed to
the chemical recovery area.  Weak black liquor is a dilute
solution (approximately 12 to 15 percent solids) of wood lignins,
organic materials, oxidized inorganic compounds (sodium sulfate
[Na2SO4], sodium carbonate [Na2C03]), and white liquor (Na2S and
NaOH).
     In the chemical recovery cycle,  weak black liquor is first
directed through a series of multiple-effect evaporators (MEE's)
to increase the solids content to about 50 percent.  The "strong"
(or "heavy")  black liquor from the MEE's is then either oxidized
in the BLO system if it is further concentrated in a DCE or
routed directly to a concentrator  (NDCE).  Oxidation of the black
liquor prior to evaporation in a DCE reduces emissions of TRS
compounds,  which are stripped from the black liquor in the DCE
when it contacts hot flue gases from the recovery furnace.   The
solids content of the black liquor following the final
evaporator/concentrator typically averages 65 to 68 percent.
     Concentrated black liquor is sprayed into the recovery
furnace, where organic compounds are combusted, and the Na2S04 is
reduced to Na2S.  The black liquor burned in the recovery furnace
has a high energy content (13,500 to 15,400 kilojoules per
kilogram [kJ/kg]  of dry solids [5,800 to 6,600  British thermal
                               2-7

-------
units per pound {Btu/lb} of dry solids]),  which is recovered as
steam for process requirements, such as cooking wood chips,
heating and evaporating black liquor, preheating combustion air,
and drying the pulp or paper products.  Particulate matter  (PM)
(primarily Na2S04) exiting the furnace with the hot flue gases is
collected in an electrostatic precipitator  (ESP) and added to the
black liquor to be fired in the recovery furnace.  Additional
makeup Na2S04, or "saltcake," may also be added to the black
liquor prior to firing.
     Molten inorganic salts, referred to as "smelt," collect in a
char bed at the bottom of the furnace.  Smelt is drawn off and  •
dissolved in weak wash water in the SDT to  form a solution of
carbonate salts called "green liquor," which is primarily Na2S
and Na2CO3.  Green liquor also contains insoluble unburned  carbon
and inorganic impurities, called dregs, which are removed  in a
series of clarification tanks.
     Decanted green liquor is transferred to the causticizing
area, where the Na2CO3 is converted  to NaOH by  the addition of
lime  (calcium oxide  [CaO]).  The green liquor is first
transferred to a  slaker tank, where  CaO from the lime kiln reacts
with water to form calcium hydroxide  (Ca(OH)2).  From the  slaker,
liquor flows through a series  of agitated tanks, referred  to as
causticizers, that allow  the causticizing reaction to go to
completion  (i.e., Ca(OH)2 reacts with Na2C03 to form NaOH  and
CaC03).
     The  causticizing product  is then routed to the  white  liquor
clarifier, which  removes  CaC03 precipitate, referred to as "lime
mud."  The lime mud, along with dregs from  the  green liquor
clarifier, is washed in  the mud washer to remove the last  traces
of sodium.  The mud from the mud washer  is  then dried and
calcined  in a lime kiln  to produce "reburned"  lime,  which  is
reintroduced  to  the  slaker.  The mud washer filtrate, known as
weak wash, is used  in  the SDT  to dissolve recovery  furnace smelt.
The white liquor (NaOH and Na2S)  from the  clarifier  is  recycled
to the digesters  in  the  pulping  area of  the mill.
                                2-8

-------
     At about 7 percent of kraft mills, neutral sulfite
semichemical  (NSSC) pulping is also practiced.6  The NSSC process
involves pulping wood chips in a solution of sodium sulfite and
sodium bicarbonate, followed by mechanical defibrating.  The NSSC
and kraft processes often overlap in the chemical recovery loop,
when the spent NSSC liquor, referred to as "pink liquor," is
mixed with kraft black liquor and burned in the recovery furnace.
In such cases, the NSSC chemicals replace most or all of the
makeup chemicals.  For Federal regulatory purposes, if the •
weight percentage of pink liquor solids exceeds 7 percent of the
total mixture of solids fired and the sulfidity of the resultant
green liquor exceeds 28 percent, the recovery furnace is
classified as a "cross-recovery furnace."7,8  Because the pink
liquor adds additional sulfur to the black liquor, TRS emissions
from cross recovery furnaces tend to be higher than from straight
kraft black liquor recovery furnaces.9
2.2  COMBUSTION PROCESSES AND EQUIPMENT
     The following section describes the process and
characterizes the equipment for:  .(1) recovery furnaces,
(2) SDT's, (3) BLO systems, and (4) lime kilns.
     The process descriptions presented in this section  provide
overviews of the various processes associated with the chemical
recovery cycle.  Much information is available on the kraft
chemical recovery cycle and associated equipment; therefore, the
process descriptions in this section do not cover every  aspect of
the chemical recovery cycle.  Additional information about the
chemical recovery' cycle can be found in References 1, 2, and 10
through 13 listed in Section 2.4.1/2,10-13
2.2.1  Recovery Furnaces
     2.2.1.1  Process Description.  The purpose of the kraft
recovery furnace is to (1) recover inorganic pulping chemicals
(e.g.,  Na2S)  and (2)  produce steam.  Inputs to the furnace
include concentrated black liquor, combustion air, and auxiliary
fuel (usually, auxiliary fuel is only used during shutdown or
startup).   Outputs include molten smelt (primarily Na2S  and
Na2CO3),  flue gases,  and steam.   The smelt exits from the bottom
                               2-9

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of the furnace into a SDT tank, where the recovery of cooking
chemicals continues.  Particulate matter  (primarily Na2S04 and
Na2C03) entrained in the flue gases is also recovered using an
ESP and subsequently added to the concentrated black liquor.
Steam produced by the recovery furnace is used in other processes
around the mill.
     Prior to being fired in the recovery furnace, the black
liquor is concentrated using an NDCE or DCE.  Figures 2-5 and 2-6
show the equipment associated with NDCE and DCE recovery
furnaces, respectively.  The NDCE is an indirect, steam-heated
black liquor concentrator.  Black liquor typically enters the
NDCE at a solids concentration of 50 percent and exits at a
concentration of 68 percent or higher.  The DCE uses the hot
combustion gases exiting the furnace to increase the solids
content of the black liquor from about 50 percent to 65 percent.
     Direct contact evaporators may be of the cascade or cyclone
design.  Figures 2-7 and 2-8 present detailed diagrams of the
cascade and cyclone designs, respectively.  The cascade
evaporator consists of a rotating assembly of tubes that are
alternately submerged in black liquor and exposed to hot flue
gases.  A cyclone evaporator is a cylindrical vessel with a
conical bottom.  Black liquor is sprayed into the side of the
evaporator, where it contacts the hot combustion gases that are
introduced tangentially, creating a "cyclone" effect.  The flue
gases exit from the top of the evaporator, and the concentrated
black liquor drains down to and exits from the bottom of the
evaporator.   .
     To minimize the stripping of TRS compounds when the hot flue
gases contact the black liquor in the DCE, most DCE's are
preceded by BLO units, which stabilize the sulfur compounds in
the black liquor.  Black liquor that is concentrated in NDCE's
does not contact the hot flue gases, and, therefore, does not
require oxidation.  Because the NDCE recovery furnace typically
has lower TRS emissions than does the DCE recovery furnace, the
NDCE recovery furnace is also referred to as the  "low-odor"
                               2-10

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                                              FLUE GAS
                         BLACK LIQUOR
Figure 2-7.  Cascade  design evaporator.
                  2-13

-------
                      FLUE GAS
                      TO STACK
LIQUOR TRANSFER
  TO SALT CAKE
    MIX TANK

  4-

      /
 MIXING TANK
LEVEL CONTROL
 BLACK LIQUOR
 INLET SPRAYS
 FLUE
GASES
                                          WALL WETTING
                                            NOZZLES
 BLACK LIQUOR
RECIRCULATING
   PUMPS
                                          CYCLONE
                                         EVAPORATOR
                                         LEVEL CONTROL
   Figure 2-8.   Cyclone design evaporator.
                       2-14

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design.  Since the 1970's, most new recovery furnaces have been
designed with NDCE's.
     Regardless of how the black liquor is concentrated, the
chemical reactions that take place inside an NDCE- or DCE-type
furnace are the same.  The concentrated black liquor is sprayed
into the furnace through fixed or oscillating nozzles or "guns"
mounted in the walls of the furnace.  Depending upon the design
and operation of the recovery furnace, the sprayed black liquor
may hit the opposing wall, where it dries and burns before
falling to the,hearth, or may fall short of the opposing wall and
dry and burn in suspension.  Combustion air is generally supplied
to the furnace at three levels, with two levels located below the
black liquor nozzles and one above.  Some furnaces may have only
two combustion air levels  (i.e.,- one above and one below the
liquor nozzles).
     The inorganic chemicals in the black liquor are recovered in
three distinct zones inside the recovery furnace.  Figure 2-9
shows where each zone is located in the furnace and the chemical
reactions that take place in each zone.  The area of the furnace
extending from the black liquor spray to just above the molten
smelt at the bottom of the furnace is referred to as the "drying
zone."  The purpose of the drying zone is to evaporate the water
from the liquor droplets.  The reducing zone is just below the
drying zone and includes the char bed.  The reduction of Na2S04
to Na^S takes place in the reducing zone.  Volatile gases that
are released in the drying and reducing zones of the furnace
travel to the highly turbulent upper section of the furnace,
referred to as the oxidizing zone, where the gases are
combusted.2  The heat generated from the combustion of these
gases is then used to generate steam as the combustion gases are
drawn through the heat exchanger section of the furnace (i.e.,
superheater, boiler bank, and economizer).
     For NDCE recovery furnaces, the design economizer exit gas
temperature ranges from 177° to 190°C  (350° to 375°F).1  For DCE
recovery furnaces, the heat from the recovery furnace is used to
evaporate -the black liquor.  Thus, the required economizer exit
                               2-15

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              OXIDIZING ZONE
        CO + 1/2O2
        H2S + 3/2 O2
        SO2 + 1/2 O2
        Na2S + 2C>2
               SO3
             3/2 O2 + CO2
     CO2
     SO2 + H2O
     S03
     N32SO4 + CO2
                DRYING ZONE
      ORGANICS + HEAT
          + CO2 + I
           CO2
• PYROLYSIS PRODUCTS
• Na2CO3 + H2S
             REDUCING ZONE
        ORGANICS + HEAT-
        Na2SO4 + C
        N32SO4 + 2C
              4C
  PYROLYSIS PRODUCTS
  Na2O + SO2 + CO
  Na2S + 2CO2
  Na2S + 4CO
       TERTIARY
          AIR
                                                    LIQUOR
                                                     GUNS
SECONDARY
   AIR
                           I
                        PRIMARY
                          AIR
                                                     SMELT
Figure 2-9.  Recovery furnace zones and air stages.
                        2-16

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gas temperature for DCE recovery furnaces, 370° to 430°C (700° to
800°F),  is much higher than that for NDCE recovery furnaces.
Because a large portion of the combustion heat from DCE recovery
furnaces is required for black liquor evaporation, less
combustion heat is available to produce steam.
     Flue gases exiting the economizer are routed either directly
to a PM control device (i.e., for NDCE recovery furnaces) or to a
DCE followed by a PM control device (i.e., for DCE recovery
furnaces).  The recovered PM (primarily Na2S04 [saltcake] and
Na2C03)  is subsequently added to the concentrated black liquor,
and the cleaned flue gas exits through the stack.  Approximately
95 percent of the Na2S04 is recovered; additional makeup saltcake
is added to the concentrated black liquor as needed.
     The inorganic chemical in the black liquor,  Na^O^, is
reduced to Na2S, a cooking liquor chemical, in the reducing zone
(lower section) of the furnace.  The Na2S and other inorganic
chemicals, predominantly Na2CC>2, drain as molten smelt from the
furnace bottom to the SDT, where reprocessing into cooking liquor
continues.'
     2.2.1.2  Equipment Characterization.  An estimated
211 recovery furnaces operate at U.S.  kraft pulp mills.3
Detailed information is available on about 85 percent of the
estimated number of furnaces.14  Based on the available data,
61 percent of these recovery furnaces are NDCE recovery furnaces
and 39 percent are DCE recovery furnaces.   Eight percent of the
recovery furnaces (76 percent of which are NDCE and 24 percent of
which are DCE recovery furnaces) are located at kraft pulp mills
that also practice NSSC pulping.6  The number of recovery
furnaces at these mills that can be classified as cross-recovery
furnaces is uncertain.
     The nationwide distribution of DCE and NDCE recovery
furnaces by age (i.e., original installation date) is provided in
Figures 2-10a and 2-10b,  respectively.3  As shown in
Figures 2-10a and 2-10b,  most recovery furnaces installed since
the 1970's have been NDCE recovery furnaces.  The first
installation of a new NDCE recovery furnace took place in 1969.15
                               2-17

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          1947-49    1950-59   1960-69   1970-79    1981X89   1990-94
                       Range of year installed
Figure  2-10a.  DCE recovery  furnace age distribution.
         1947-49    1950-59   1960-69   1970-79   1980-89   1990-94
                      Range of year installed

Figure 2-10b.   NDCE  recovery  furnace age  distribution.

                              2-18

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Although Figure 2-10b shows that approximately 22 NDCE recovery
furnaces currently in operation were installed in or before 1969,
most, if not all of these furnaces were originally installed as
DCE recovery furnaces and later converted to NDCE recovery
furnaces.  The most recent installation of a new DCE recovery
furnace occurred in 1988; however, prior to 1988, the last
installation of a new DCE recovery furnace was in 1979.3
     The nationwide distribution of DCE and NDCE recovery
furnaces by size (i.e., black liquor solids [BLS] feed rate) is
provided in Figures 2-lla and 2-lib, respectively.3  The DCE
recovery furnaces are not only typically older than NDCE recovery
furnaces, but, as shown in Figures 2-lla and 2-lib, DCE recovery
furnaces are also typically smaller.  The majority of DCE
recovery furnaces have a firing rate less than or equal to
900,000 kilograms of BLS per day  (kg BLS/d) (2 million pounds of
BLS/d  [Ib BLS/d]);  whereas, the majority of NDCE recovery
furnaces have firing rates greater than 900,000 kg BLS/d
(2 million Ib BLS/d).
     The two furnace types also differ in the types of ESP's that
are used to control particulate emissions from the furnace.  For
example, the ESP's that control PM emissions from DCE recovery
furnaces tend to be wet-bottom ESP's (i.e., the PM catch falls
directly into a pool of black liquor at the bottom of the ESP),
whereas ESP's on NDCE recovery furnaces tend to be dry-bottom
ESP's.  Other differences between DCE and NDCE recovery furnaces
include the following:  (1) the inlet loading of PM to the ESP
tends to be lower for DCE recovery 'furnaces than for NDCE
recovery furnaces due to the recovery of some PM as the flue
gases pass through the DCE; (2) emissions of TRS compounds tend
to be higher from DCE recovery furnaces; and (3) NDCE recovery
furnaces do not require black liquor oxidation, which eliminates
one source of emissions.
     Due to State and Federal regulations regarding PM emissions
and the economic benefits of recycling PM captured from the
recovery furnace flue gases, all kraft recovery furnaces are
equipped with add-on PM control devices.  Particulate matter
                               2-19

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  4CK
                Range of solids feed rates, MM ib BLS/d

Figure 2-lla.   DCE  recovery  furnace  size distribution.
         >0.4 and <=1'         >2 and <=3         >4 and <=5
                 >1 and <=2         >3 and <=4            >5
                Range of solids feed rates, MM Ib BLS/d


Figure 2-llbi  NDCE recovery furnace, size-, distribution.


                             2-20

-------
emissions from.- approximately 95 percent of all kraft recovery
furnaces are controlled with an ESP alone.3  The remaining
furnaces are controlled with ESP's followed by wet scrubbers
(4 percent)  or with wet scrubbers alone (1 percent).3  Additional
information on recovery furnace air pollution control devices
(APCD's) and the effectiveness of these APCD's in controlling HAP
emissions is provided in Chapter 3.
   In general, recovery furnaces are not used to incinerate waste
streams generated in other parts of the mill, with the exception
of a few recovery furnaces (approximately 3 percent) that receive
high-volume, low-concentration (HVLC) noncondensible gases
(NCG's) from the pulping area of the mill.14  Because of the
importance of the recovery furnace to the chemical recovery cycle
and the potential for catastrophic explosion  (due to water
entering the furnace during operation), the industry's Black
Liquor Recovery Boiler Advisory Committee  (BLRBAC) recommends
that the recovery furnace not be used for NCG incineration.1
2.2.2  Smelt Dissolving Tanks
     2.2.2.1  Process Description.  Molten smelt is one of the
main products from the combustion of black liquor.  Smelt, which
is predominantly Na2S and Na2CO3, is formed in the bottom of the
furnace.  Smelt, at approximately 1040° to 1150°C  (1900° to
2100°F), filters through the char bed and is continuously
discharged through water-cooled smelt spouts into the SDT.  In
the SDT, smelt is mixed with weak wash water from the
recausticizing area to form green liquor,  an aqueous solution of
Na2C03 and Na2S in about a three to one ratio.  The green liquor
is subsequently transferred to the recausticizing area for
reprocessing into cooking liquor  (i.e., white liquor).  A
schematic of an SDT with a wet scrubber is provided in
Figure 2-12.
     The SDT is a large, covered vessel located below the
recovery furnace.  Green liquor is maintained in the tank at a
level of about half the depth of the tank.  As the smelt exits
the water-cooled smelt spouts and falls several feet into the
SDT, it is shattered by high-pressure steam or shatter sprays of
                               2-21

-------
                                                   WET SCRUBBER
                                    TO STACK
                            SCRUBBER
                             BYPASS -
                             VALVE
SMELT
   \
WATER-COOLED
   SPOUT
     /   SHATTER
    /  SPRAY NOZZLE
                                                                  FAN
                                                   Nfl
OVERFLOW
  LINES -
1 1
A A A AAA

4
1
1
' X
\
A
\ A
1 1
/ 1
X



t L



/
                                                             WEAK
                                                             WASH
                                                             WATER
                                                        SCRUBBER WATER
                                                          DRAIN TO SDT
                                                            GREEN LIQUOR
                                                            TO CLARIFIER
           AGITATOR
                SMELT DISSOLVING TANK
       Figure  2-12.    Smelt dissolving tank and wet scrubber.

                                      2-22


-------
recirculated green liquor.  The steam or shatter sprays break the
smelt flow into small droplets and cool the smelt before it falls
into and reacts with the liquid in the SDT to form green liquor.
Large volumes of steam are generated when the molten smelt and
liquid mix.  The vapor space above the liquid level provides an
opportunity for water vapor and PM resulting from the quenching
of smelt to settle out of suspension into the green liquor.  An
induced-draft .fan*constantly draws the vapor and entrained PM
through a PM control device, generally a wet scrubber.  Scrubber
water is sprayed into the scrubber and allowed to drain directly
into the SDT, where it reacts with smelt to form green liquor.
     The SDT is constantly agitated to prevent formation of hot
spots on the surface of the liquor and to keep solids from
accumulating in the bottom of the tank.  Surface liquor hot spots
can contribute to the formation of explosive hydrogen gas from
the dissociation of water reacting with the hot smelt.
     Green liquor formed in the SDT is sent to the green liquor
clarifier in the causticizirig area.  Green liquor is converted to
white liquor (i.e., NaOH and Na2S) in the causticizing area.
     2.2.2.2  Equipment Characterization.  An estimated 227 SDT's
operate at U.S. kraft pulp mills.3  Detailed information is
available on approximately 83 percent of the estimated number of
SDT's.6  Smelt dissolving tanks are basically large, covered
tanks.  Some recovery furnaces have two SDT's, which explains why
the estimated number of SDT's is higher than the estimated number
of recovery furnaces.  When there are two SDT's under one
furnace, the flue gases from these SDT's may be combined or
treated separately.
     Due to State and Federal regulations regarding PM emissions,
all but two kraft SDT's are equipped with add-on PM control
devices.  Particulate matter emissions from approximately
8? percent of kraft SDT's are controlled with wet scrubbers.14
Particulate matter emissions from most of the remaining SDT's are
controlled with mist eliminators alone.14  Additional information
on SDT APCD's and the effectiveness of these APCD's in
controlling HAP emissions is provided in Chapter 3.
                               2-23

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2.2.3  Black Liquor Oxidation  Systems
     2.2.3.1  Process Description.   The  BLO  system reduces
malodorous TRS emissions  from  DCE  recovery furnaces at  kraft pulp
mills.  Total reduced sulfur compounds  (primarily hydrogen
sulfide  [H2S]) are stripped from black liquor when hot  flue gases
from the recovery furnace contact  the black  liquor in the DCE.
Hydrogen sulfide is stripped by the reaction between residual
Na2S in the black liquor  and carbon dioxide  (C02)  and water (H20)
in the recovery furnace flue gas,  as follows:
 Na2S
sodium
sulfide
CO,
H20
  Na2C03
 sodium
 carbonate
 H2S
hydrogen
sulfide
The BLO  system minimizes the stripping of TRS compounds in the
DCE by stabilizing the sulfur compounds in the black liquor prior
to evaporation in the DCE.   The main reaction that takes place in
the BLO  system is the oxidation of Na2S to nonvolatile sodium
thiosulfate  (Na2S203), as follows:
2Na2S
sodium
sulfide
 20-
 HoO
Na2S203
                        sodium
                        thiosulfate
 2NaOH
  sodium
  hydroxide
      The oxidation efficiency of the BLO process is measured by
the  percent conversion of Na2S to Na2S203 in the black liquor on
a  gram per liter (g/L)  (pound per gallon [Ib/gal])  basis.
Oxidation efficiencies greater than 99 percent are common.  High
oxidation efficiencies require good mixing and the avoidance of
excessive oxygen (02)  consumption to limit side reactions.
Sulfidity levels of the black liquor entering the DCE are
targeted to less than 0.2 g/L (0.002 Ib/gal) in order to meet TRS
emission limits for DCE recovery furnaces.1  Oxidizing black
liquor results in a slight increase (2 to 3 percent) in the
solids content of the black liquor and reduces its heating value
by 2 to 5 percent. °
                                2-24

-------
     The BLO system  is  typically located after the MEE, a process
referred to as  "strong" black liquor oxidation.  A small number
of mills oxidize black  liquor prior to evaporation in the MEE,
which is referred to as "weak" black liquor oxidation.  Other
options are to  oxidize both weak and strong black liquor or to
oxidize the black liquor between effects of the MEE.  To avoid
excessive foaming caused by tall oil components in weak black
liquor, mills in the south that pulp pine oxidize strong black
liquor.  With strong black liquor, the soaps and tall oil are
removed during  the soap-skimming process that follows black
liquor evaporation in the MEE.  With weak BLO systems, the
effects of partial reversing of the oxidation reaction  (i.e.,
oxidized sulfur compounds reducing to H2S) that occurs in the MEE
can be minimized by  adding a second oxidation step, such as
oxygen polishing of  strong black liquor.
     Black liquor can be oxidized using either air or pure
(molecular) 02.  Because of economic considerations, the majority
of BLO systems  use air as the oxidant.  Air BLO systems have
higher capital  costs than oxygen systems, but their operating
costs are usually much lower.
     Air-sparging units are the predominant type of BLO equipment
used-at kraft pulp mills.   Figure 2-13 shows a schematic of an
air-sparging BLO system.  Air-sparging units operate by bubbling
air, which is sometimes preheated, through the black liquor using
multiple diffuser nozzles.  Air systems require residence times
of several hours or more to obtain high oxidation efficiencies.
Because of this relatively long residence time,  large oxidation
tanks--on the order  of 9 meters (m) (30 feet [ft])  in diameter
and 12 m [40 ft] high)  must be used.  Air-sparging units have one
to three tanks  (or stages) that operate in series.   Air-sparging
units are equipped with mechanical foam breakers for foam
control; chemical defoamers (e.g., diesel oil,  turpentine,  and
kerosene)  may also be used.1'12  Each oxidation tank is vented.
Gases exiting the BLO system flow through cyclone separators- to
have entrained water droplets removed prior to being vented to
                               2-25

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-------
the atmosphere.  Add-on APCD's  typically are not used with air
oxidation units.
     Oxygen BLO systems require only  30 seconds  (sec) to
5 minutes  (min) residence  time,  which enables the use of in-line
reactors.  Since all  the gas  (i.e., pure O2) added to the system
is consumed in the  oxidation  reaction, a system vent is not
needed.16  The oxygen consumption  for weak black liquor oxygen
systems is 25 to 65 kilograms per  megagram  (kg/Mg) of pulp  (50 to
130 pounds per ton  [Ib/ton] of  pulp); strong black liquor oxygen
systems use 35 to 75  kg 02/Mg pulp (70 to 150 Ib 02/ton pulp.)17
     Oxygen polishing is sometimes used as a supplement to air
oxidation systems to  address  (1) stricter TRS standards, (2) an
overloaded BLO system resulting from  production increases, or
(3) peaks in TRS emissions resulting  from process upsets or
temporary production  increases.  In-line 02 polishing systems are
used to oxidize strong liquor and  may follow either a weak liquor
air system or a strong liquor air  system.  Polishing of strong
black liquor requires approximately 2.5 to 13 kg 02/Mg pulp  (5 to
25 Ib 02/ton pulp)  to achieve the  desired incremental increases
in oxidation efficiency.17
     2.2.3.2  Equipment  Characterization.  Of the 47 U.S. kraft
pulp mills that operate  DCE recovery  furnaces,  only 1 (with 1
DCE recovery furnace)  is known  to  operate without a BLO system.
Therefore, the nationwide number of BLO systems is estimated to
be 46.   Detailed information is available on approximately
91 percent of the estimated U.S. population.14'18  The type of
equipment operated  and the type of liquor oxidized for the BLO
systems is summarized in Table  2-I.3  Oxidation of strong black
liquor using air-sparging units is the predominant method of
black liquor oxidation and accounts for an estimated 89 percent
of the U.S. population.3  Seven percent of the mills operating
air-sparging units  also  have  added 02 polishing systems.  Of the
air-sparging BLO systems, 50  percent are two-stage systems,
31 percent are single-stage systems, and 18 percent have three
oxidation tanks.14
                               2-27

-------
  TABLE 2-1.  BLACK LIQUOR OXIDATION SYSTEMS:   EQUIPMENT TYPES
Equipment type
Air sparging
Air sparging with 02
polishing
Air, sieve tray tower
Molecular 0^
Molecular 07
Molecular 09
Total
Liquor type
Strong
Strong
Weak
Strong
Weak
Weak and strong

Estimated
No. in
U.S.
38
3
1
2
1
1
46
Percent
83
7
2
4
2
2
100
     Approximately 8.5 percent of BLO systems are molecular 02
systems.3  Strong black liquor is oxidized with 02 after the
second effect of the MEE  (26 percent solids) at two of the four
mills; weak black liquor  (i.e., prior to the MEE) is oxidized at
another mill; and both weak and strong liquor are oxidized with
02 at the fourth mill.3'14  One mill with a BLO system located
after the second effect of the MEE reported an oxygen usage rate
of 32 Mg/d  (35 ton/d)  (13 kg/Mg pulp  [25 Ib/ton pulp]).14
     Emissions from most air-based BLO systems (95 percent) are
uncontrolled.3  Based on available information, TRS emissions
from 5 percent of air-based BLO systems are currently controlled
by using a condenser or mist eliminator to remove the water vapor
and then venting the gas stream to a power boiler for
incineration.14  Molecular 02 systems do not require system vents
and, thus, have no emissions directly associated with the BLO
unit.13
2.2.4  Lime Kilns
     2.2.4.1  Process Description.  The lime kiln is part of the
causticizing process, in which green liquor from the SDT is
converted to white liquor.  The function of the lime kiln is to
                               2-28

-------
 convert lime mud (calcium carbonate  [CaC03])  to  reburned lime
 (calcium oxide [CaO]),  a process known as  calcining:
 CaC03
 lime mud/
 calcium carbonate
           heat
        CaO     +
        lime/
        calcium oxide
                                            [lime kiln]
 Lime  mud that is burned in the lime kiln is a  final  product of
 the following causticizing reactions:
 CaO
H20
lime/
calcium oxide
Ca(OH)2
calcium
hydroxide
Na2C03
sodium
carbonate
Ca(OH)2
calcium
hydroxide
                                NaOH   4
                                sodium
                                hydroxide
                                                        [s laker]
                                 CaCO,
                           [causticizer]
                                 lime mud/
                                 calcium carbonate
Lime  that  is  produced in the kiln is used in the causticizing
reaction that takes place in the green liquor slaker and
causticizers.   The lime kiln typically produces about 95 percent
of the lime needed for the causticizing reaction.  Either make-up
lime  or limestone  is purchased to account for losses.
      Prior to calcining,  lime mud from the causticizing tanks is
washed and dewatered.   Lime mud washers reduce the sodium and
sulfide content of the lime mud,  which lowers TRS emissions  from
the lime kiln.   The lime mud is typically dewatered to about
70 percent solids  using a rotary vacuum precoat filter.  The
precoat filter also helps reduce TRS emissions by oxidizing  any
remaining  sodium sulfide to sodium thiosulfate using air that is
pulled through the filter.
     Rotary lime kilns,  as  shown in Figure 2-14,  are typically
used at kraft  pulp mills.   In a rotary kiln,  lime mud from the
precoat filter is  introduced at the feed end (cold end) and  flows
downward towards the discharge end (hot end).   The chemical
composition of  the lime mud is presented in Table 2-2.  Natural
gas or fuel oil  are the fuels typically used to fire the kiln.
                               2-29

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       TABLE 2-2.  CHEMICAL COMPOSITION OF LIME MUD FEED
                                                        20
Component
Calcium carbonate
Alumina
Iron oxide
Calcium oxide
Sodium oxide
Silica
Sodium sulfide
Composition (%)
>95
<0.5
<0.5
<0.5.
<0.2
<0.2
<0.01
Primary combustion air is introduced through a concentric tube
around the fuel pipe, and preheated secondary combustion air is
introduced through the bottom of the firing hood.
     The majority of lime kilns at kraft pulp mills also burn
NCG's from various process vents, such as digester and evaporator
vents.  The NCG streams may be introduced into the kiln- through a
dedicated nozzle or combined and fed with either primary or
secondary air.  The components of the NCG stream include TRS
compounds, turpentine, methanol, acetone, alpha-pinene, water
vapor, nitrogen, and oxygen.1'19  To avoid excessive sulfur
dioxide (SO2) formation in the lime kiln, the NCG gas stream may
be scrubbed prior to incineration to remove TRS compounds.
Packed columns with white liquor as the scrubbing fluid are
commonly used.  The TRS removal efficiency is typically about
70 percent.1
     Rotary kilns have three internal zones:  (1) the drying
zone, (2)  the heating zone, and  (3) the calcining zone.  In the
drying zone, water is evaporated from the lime mud as it passes
througli metal chains that are suspended from the kiln shell in a
curtain or garland arrangement.  The lime mud is dried to about
95 percent or greater solids as it passes through the chains that
are heated by the hot flue gases that flow countercurrent to the
lime mud.   In addition to providing additional heat transfer area
for drying the lime mud,  the chains also help reduce the amount
                               2-31

-------
of lime dust exiting with flue gases.  In the heating zone, other
heat transfer devices, such as tumblers and lifters, are used to
heat the dried mud uniformly in preparation for calcining.  The
calcining reaction, which takes place in the calcining zone,
requires a minimum temperature of 815°C (1500°F); temperatures
greater than about 1150°C  (2100°F) can cause everburning, which
leads to a less-reactive lime product.1  Ideally, calcination
produces lime pellets that are about 2 centimeters  (cm)
 (0.75 inches  [in.]) in diameter; however,  if the lime mud is
improperly dried and heated, large lime balls may be produced.-1
The hot lime product is cooled by incoming secondary air as it
passes under the burner towards the discharge end of the kiln.
Newer kilns use integral tube coolers to preheat secondary
combustion air while cooling the discharged lime pellets.   In
this heat exchange process, the air is heated to about 315°C
 (600°F) and the lime is cooled to about 190°C  (375°F).  The
reburned lime product from the integral tube coolers, or from the
kiln discharge hoppers in the absence of coolers, is transported
to the lime storage bin and subsequently introduced into the
green liquor slaker.
     Combustion gases exit the lime mud feed end of the kiln at
temperatures of approximately 150° to 200°C  (300° to 400°F).  The
exhaust gases consist of combustion products, CO2 released  during
calcination, water vapor evaporated from the mud, and entrained
lime dust.  Particulate matter in the exhaust gas is mainly
sodium salts, CaC03, and CaO.  Add-on PM control devices are
required to meet Federal and State PM standards.  Venturi
scrubbers are the most commonly used control device, and water is
typically used as  the scrubbing fluid.  The exhaust stream may be
scrubbed with a caustic solution with the added benefit  of
lowering TRS and SO2  emissions.  However, Federal and  State TRS
standards can be met  through good lime mud washing  practices,
which reduces the  sulfide  content of the lime mud feed.   If a wet
 scrubber is used,  a cyclone separator may be installed upstream.
The dust collected by the  separator  is returned directly to the
 lime kiln.  In recent years, the use of ESP's  has been more
                               2-32


-------
prevalent.  As>-with the cyclone separator, the PM catch from the
ESP is returned directly to the lime kiln.
     2.2.4.2  Equipment Characterization.  An estimated 192 lime
kilns operate at U.S. kraft pulp mills.3  Detailed information is
available on about 85 percent of the estimated number of lime
kilns.14  Rotary kilns are the most commonly used type of lime
kiln at kraft pulp mills, accounting for about 98 percent of the
kilns.6'21  Fluidized-bed calciners are.also used by the kraft
pulp industry.  Industry representatives estimated the number of
fluidized-bed calciners at two to five, accounting for the
remaining 2 percent of lime kilns at kraft pulp mills.6'21  Based
on available data, the oldest operating lime kiln was installed
in 1940.14  New lime kilns were installed at a rate of
approximately three kilns per year from 1981 to 199I.14
     The predominant fuel used by the industry is natural gas,
accounting for about 68 percent of lime kilns.14  Fuel oil is the
primary fuel for about 29 percent of kilns.1   Petroleum coke is
fired in about 3 percent of the kilns as the primary fuel.
     Due to State and Federal regulations regarding PM emissions,
all lime kilns are equipped with add-on PM control devices.
Particulate matter emissions from the majority (90 percent) of
lime kilns at kraft pulp mills are controlled with wet scrubbers.
Two percent of these scrubbers are operated in series with a
second scrubber.  Venturi scrubbers are the most commonly used
type of wet scrubber.    Water is the typical scrubbing fluid,
but caustic and weak wash are also used.14  The scrubbing fluid
is recirculated, and the scrubber blowdown is recycled to the
lime mud washer.  Particulate matter emissions from the remaining
10 percent of lime kilns are controlled by single-chamber ESP's
(9 percent) or the combination of an ESP and scrubber
(1 percent},1   Installing ESP's to control PM from lime kilns
has been more widespread in recent years; about half of the APCD
installations since 1990 have been ESP's.
     An estimated 66 percent of lime kilns are either primary or
backup incineration devices for NCG streams.14  Of the lime kilns
that incinerate NCG's, 57 percent incinerate low-volume, high-
                               2-33

-------
concentration (LVHC) NCG streams; 28 percent incinerate HVLC NCG
streams; and 24 percent incinerate both LVHC and HVLC NCG
streams.  Approximately 33 percent of the lime kilns in which
NCG's are incinerated use an NCG scrubber prior to
incineration.14  The majority of these NCG scrubbers use white
liquor as the scrubbing fluid; a small percentage use water.
2.3  BASELINE EMISSIONS
2.3.1  Federal and State Regulations Affecting Kraft Pulp Mill
       Combustion Sources
     Federal regulations that affect the pulp and paper industry
include new source performance standards  (NSPS) for kraft pulp
mills.  The NSPS does not include soda mills.  The NSPS specifies
PM and TRS emission limits for various pulp mill equipment that
are constructed, modified, or reconstructed after September 24,
1976.7'8  Recovery furnaces,.SDT's, and lime kilns are regulated
under the kraft pulp mill NSPS.
     The percentage of recovery  furnaces, SDT's, and lime kilns
that are subject to the NSPS were estimated using installation
dates.  These estimates, therefore, do not include those recovery
furnaces, SDT's, and lime kilns  that are  subject to the NSPS
through the modification/reconstruction provisions.
Approximately 4 percent  (i.e., 3 of 83) of the DCE recovery
furnaces and 39 percent  (50  of 128) of the NDCE recovery furnaces
are subject to the NSPS.3  Based on recovery furnace installation
dates, approximately 29 percent  of the SDT's are subject to the
NSPS.3  Approximately 28 percent of the lime kilns are subject to
the NSPS.14  Nine new BLO systems have been  installed since the
1976 NSPS proposal  for kraft pulp mills;  eight of these new BLO
systems are still in operation,  making up 17 percent of the
                                             18
existing population of operating BLO systems.
     Table 2-3 lists the NSPS  PM and TRS  emission limits.  The
EPA TRS emission limit guidelines  for sources  not subject to  the
NSPS are also  listed in Table  2-3.  The TRS  guidelines are  the
same as the NSPS emission limits for NDCE and  cross-recovery
furnaces.  The NSPS emission limit  is 5 parts  per million dry
volume  (ppmdv) at  8 percent  O2.  For DCE  recovery furnaces,  the
                               2-34

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TRS guidelines are 20 ppmdv at 8 percent 02, which are higher
than the NSPS limit.  Similarly, the TRS guidelines for lime
kilns  (20 ppmdv at 10 percent 02) are higher than the NSPS limit
(8 ppmdv at 10 percent 02)-  The TRS compounds are hydrogen
sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl
disulfide.  None of these TRS compounds are currently listed in
the Clean Air Act for regulation under Section 112.  However, PM
emitted from kraft pulp mill sources does contain small amounts
of HAP compounds  (e.g., HAP metals).
     State regulations for PM and TRS emissions for new,
modified, and reconstructed recovery furnaces, lime kilns, and
SDT's are the same as Federal regulations, with a few
exceptions.22  The State  of Georgia has promulgated process-
weighted standards for PM, which, for some Georgia mills, are
slightly more stringent than the NSPS PM limits.  Also, the State
of Alabama requires new sources to use the  "highest and best
practicable controls for  PM."22  In addition, several States
regulate toxic air emissions from pulp mills.  These regulations,
however, tend to  limit the concentration of air toxics at the
pulp mill fence line, and thus  do not directly regulate emissions
from specific equipment in the  chemical recovery area of the
mill.  For existing recovery furnaces that  are not subject to the
NSPS,  most States have emission standards equivalent to or more
stringent than the EPA TRS emission limit guidelines.22'23   For
existing lime kilns that  are not subject to the NSPS, approxi-
mately half of the States with  kraft mills  have emission
standards equivalent to or more stringent than the EPA TRS
                           99 9^
emission limit guidelines.-"'^J
2.3.2  Baseline Emission  Estimates
     Section 2.3.2.1 presents the baseline  gaseous HAP  emission
estimates from combustion sources at kraft  and soda pulp  and
paper  mills.  Baseline gaseous  HAP  emissions  were  developed  for
DCE recovery  furnaces, NDCE  recovery furnaces, and BLO  systems.
Baseline  gaseous  HAP  emissions  were not  developed  for  lime kilns
and SDT's because the  gaseous HAP emissions from these  units
result from the use  of  contaminated condensates  in the  makeup
                               2-36

-------
waters.  The regulation of contaminated condensates is part of
the noncombustion source  category for kraft and soda pulp and
paper mills.  Section 2.3.2.2 presents baseline PM and TRS
emissions from combustion sources at kraft and soda pulp and
paper mills.
     2.3.2.1  Baseline Gaseous HAP Emissions.  Table 2-4 presents
gaseous HAP process emission factors for the two types of
recovery furnaces  (DCE and NDCE) used in the kraft chemical
recovery loop.  The process emission factors were calculated
based on available emission test data and process emission rates
for each of the recovery  furnaces.24  In the case of DCE recovery
furnace systems, emission points include the recovery furnace/DCE
stack and the BLO vent.   The only emission point associated with
NDCE recovery furnaces is the recovery furnace-stack.  As shown
in Table 2-4, the gaseous HAP compounds emitted in the largest
quantities from DCE and NDCE recovery furnaces are.hydrochloric
acid (HC1) and methanol.  The following sections discuss the
potential mechanisms by which HC1 and gaseous organic HAP's such
as methanol are emitted,  as well as the nationwide emissions of
these pollutants.
     2.3.2.1.1  HC1 emissions.  Typically, HC1 emissions from
combustion processes are  generated from oxidation reactions
involving chlorinated organic compounds in the fuel, and all of
the organic chlorine in the fuel is presumed to. be emitted as
HC1.  However, chlorine in black liquor is expected to be in the
form of inorganic chlorine.  Consequently, only a small fraction
(0 to 10 percent) of the  black liquor chlorine is believed to be
emitted from the recovery furnace as HC1.25  A possible mechanism
for HC1 formation in the  recovery furnace is gas phase reactions
of volatilized alkali chlorides with S02 in the presence of water
vapor and oxygen.25'26  The proposed reactions are as
follows:25'26
2NaCl(s) + S02(g) + 1/2 02 (g) + H20(g) -» 2HC1 (g) + Na2SO4 (s)  (1)
2KCl(s) + S02 (g) + 1/2 02 (g) + H20(g) -* 2HC1 (g) + K2SO4(s)    (2)
                               2-37

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These reactions are believed to occur at temperatures below about
900°C (1650°F) in the furnace post-combustion zone and in higher
temperature areas in the ductwork downstream from the
furnace.  '     Assuming the above reactions are the correct
mechanism for HC1 formation, HC1 emissions will be higher for
well-designed and operated combustion systems.  Combustion system
parameters that could potentially affect the amount of HC1 formed
include higher combustion zone temperatures leading to greater
emissions of volatile sodium chloride (NaCl) and potassium
chloride (KCl), furnace S02 generation rates, and good mixing of
combustion gases with excess air in the post-combustion zone.
     A review of the available emissions data indicates that HC1
emissions from recovery furnaces are highly variable.  A recent
study of kraft recovery furnace HC1 emissions conducted by the
National Council of the Paper Industry and Air and Steam
Improvement,  Inc. (NCASI) examined the relationships between
several recovery furnace operating parameters and HC1
emissions.     Some earlier studies had suggested that there may
be strong correlations between stack S02 emissions and HC1
emissions and between stack O2 concentration and HC1
          o c: o C.
emissions.  3/a  The NCASI study, which was based on tests of 14
recovery furnaces conducted specifically for this study,' examined
the relationship between HC1 emissions and each of the following
parameters:   stack SO2 concentration, as-firedrblack liquor
chloride content, stack O2 levels, chloride content of
precipitated ash, and furnace load or liquor firing rate.
Based only on the tests conducted in this study, NCASI found a
strong correlation using a Langmuir adsorption-type relationship
between HC1 emissions and S02 emissions for NDCE 'recovery
furnaces and found no clear correlation between these parameters
for DCE recovery furnaces.    The study found no clear
correlations between HC1 emissions and other recovery furnace
operating parameters.27
     As shown in Table 2-4, the HC1 emission factor presented for
both NDCE and DCE recovery furnace systems is the same.  Based on
a statistical analysis of the available HC1 emissions data, it
                               2-39

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was concluded that the NDCE and DCE recovery furnace HC1 emission
factors should be averaged together.  The range of HC1 emission
factors for NDCE recovery furnaces extends above and below the
range of factors for DCE recovery furnaces.  Both the 90 and
95 percent confidence intervals of the difference between the DCE
and NDCE recovery furnace means include zero.  Stated another
way, the hypothesis that the means are equal cannot be rejected
                                           
-------
high, then metihanol emissions from the DCE recovery furnace stack
were .low) . °
     No emission data are available from DCE recovery furnaces
with molecular oxygen BLO systems for comparison with DCE
recovery  furnaces with air-based BLO systems.  Therefore, the
effect of molecular oxygen BLO systems on total emissions from
the DCE recovery furnace system is uncertain.  Unlike air-based
systems', molecular, oxygen systems use pure oxygen, and thus, no
diluents are introduced that could strip organic compounds from
the black liquor; consequently, organic compounds not released
from the black liquor during the oxidation process could be
subsequently stripped, in theory, from the oxidized black liquor
when the black liquor enters the ESP or direct contact
evaporator.
     Most DCE recovery furnaces and some older NDCE recovery
furnaces are equipped with wet ESP systems.  Either black liquor
or HAP-contaminated process water may be present in the bottom of
these ESP's and in the system used to transport the collected PM
to the saltcake mix tank.  Also, for wet ESP systems, the PM may
be collected as a dry product in the bottom of the ESP (i.e., a
dry-bottom ESP) but black liquor or HAP-contaminated water is
used in the PM return system.  Because there is contact between
the hot recovery furnace flue gases and the black liquor or HAP-
contaminated process water in wet ESP systems, gaseous organic
HAP's are stripped from the liquor and emitted from the recovery
furnace stack.  Most newer NDCE recovery furnaces (i.e.,  those
constructed after 1989) emit lesser quantities of methanol and
other gaseous organic HAP's because they tend to be equipped with
dry ESP systems  (i.e., dry-bottom ESP's and dry PM return
systems).30
     Data are not available to determine the effects of
converting a wet ESP system to a dry ESP system on overall
gaseous HAP emissions for a DCE recovery furnace system.   Gaseous
organic HAP's that would have been stripped from the black liquor
in the wet ESP system potentially could be stripped from the
black liquor when it enters the DCE.  Also, based on emission
                               2-41

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data for NDCE recovery furnaces with wet ESP systems, the ESP is
a less significant source of gaseous organic HAP emissions than
the BLO' or DCE.  Data are available for NDCE recovery furnaces
with both wet ESP systems and dry ESP systems such that the
impacts that different ESP systems have on gaseous organic HAP
emissions from NDCE recovery furnaces can be determined.  These
impacts can be more readily determined since the ESP represents
the only opportunity where stripping can occur for NDCE recovery
furnaces.
     2.3.2.1.3  Nationwide gaseous HAP emissions.  Table 2-5
presents the nationwide baseline gaseous HAP emissions from
recovery furnaces.  The nationwide baseline total gaseous HAP
emissions from the estimated 128 NDCE recovery furnaces are
estimated to be 13,700 megagrams per year  (Mg/yr)  (15,100 tons
per year  [ton/yr]).  The nationwide baseline total gaseous HAP
emissions from the estimated 83 DCE recovery furnace systems
 (which includes BLO systems) are estimated to be 15,700 Mg/yr
 (17,300 ton/yr).  The baseline emissions shown in Table 2-5 were
calculated assuming no control of gaseous HAP's  (with  the
exception of the  two BLO systems with emissions controlled via
incineration) because gaseous HAP emissions from recovery
furnaces are highly variable and largely uncontrolled.  The
baseline emissions were  calculated by multiplying  the  gaseous HAP
emission factors  by the  process emission rate in kg  BLS/hr
 (Ib BLS/hr)  for each mill  for which data were available and  then
extrapolating  based on the available data  to account for  those
mills where  data  were unavailable.  The baseline emissions were
also  calculated based on the assumption that each  emission source
operates  24  hours per day (hr/d)  for 351 days per  year (d/yr),24
      2.3.2.2   Baseline  PM and  TRS  Emissions.  Table  2-6 presents
nationwide  total  PM,  PM HAP, and  TRS baseline emissions from each
 combustion  source.  The  HAP portion of  total PM consists  of  HAP
metals  and  accounts  for less than l percent of  the total  PM
 emitted on  average;  therefore,  only the total estimated quantity
 of HAP  metals  are presented in Table 2-6,  instead of presenting
 emission estimates for each individual  HAP metal.31   The baseline
                               2-42

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      TABLE  2-5a  (Metric).   NATIONWIDE  BASELINE  GASEOUS  HAP
                             EMISSION  ESTIMATES24
Gaseous HAP
Acetaldehyde
Benzene
Formaldehyde
Methyl ethyl ketone
Methyl isobutyl ketone
Methanol
Phenol
Toluene
Xylenes
Hydrochloric acid
Total gaseous HAP's
Nationwide emissions, Mg/yr3
DCE recovery furnace systems
Air-sparging BLO units
333
27.3
6.5
95.3
39.6
3,890
43.3
32.3
96.1
N/A
4,560
DCE recovery furnaces
769
373
72.6
220
312
4,390
1,020
251
637
3,090
11,100
NDCE recovery
furnaces
588
454
525
376
466
2,120
924
422
968
6,840
13,700
 aThe emissions in this table were calculated by multiplying the emissions in Table 2-5b by 0.9072.

     TABLE 2-5b  (English).   NATIONWIDE  BASELINE  GASEOUS HAP
:                             EMISSION  ESTIMATES24
Gaseous HAP
Acetaldehyde
Benzene
Formaldehyde
Methyl ethyl ketone
Methyl isobutyl ketone
Methanol
Phenol
Toluene
Xylenes
Hydrochloric acid
Total gaseous HAP's0
Nationwide emissions, ton/yra
DCE recovery furnace systems
Air-sparging BLO units
367
30.0
7.2
105
43.7
4,290
47.8
35.6
106
N/A
5,030
DCE recovery furnaces
848
411
80.0
242
343
4,840
1,120
276
702
3,410
12,300
NDCE
recovery
furnaces
648
501
578
414
513
2,330
1,020
465
1,070
7,540
15,100
     nationwide emissions were calculated using the following equation:
  Emissions, ton/yr = (emission factor, Ib/lb BLS) x (nationwide BLS firing rate, Ib/hr) x
 , (35_I d/yr) x (1 ton/2,000 Ib).
  Emlssiozss from the two BLO units that are controlled via incineration were multiplied by
  for aa estimated 98 percent emission reduction.
 cNumbers may not add exactly due to rounding.
(24 hr/d) x

0.02 to account
                                       2-43

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PM and TRS  emissions were calculated based on the sum of the  PM

or TRS emission rates calculated  for each combustion source at

each mill operating at the U.S.   The baseline emissions were  also

calculated  based on the assumption that each combustion source

operates 24 hr/d for 351 d/yr.32

   TABLE 2-6. NATIONWIDE BASELINE PM, PM HAP, AND TRS EMISSIONS
Combustion source
NDCE recovery furnaces
DCE recovery furnaces
Smelt dissolving tanks
BLO units
Lime kilns
Total0
Nationwide emissions, Mg/yr (ton/yr)
Total PM
29,400 (32,400)
16,000 (17,600)
7,680 (8,470)
—
8,830 (9,730)
61,900 (68,200)
PM HAP'sa
54(65)
31 (35)
5(5)
—
124 (136)
219 (241)
TRSb
658 (725)
2,720 (3,000)
7,350 (8,100)
658 (725)
648 (714)
12,000 (13,300)
  aOn average, PM HAP's account for 0.2 percent of total PM emitted from recovery furnaces,
   0.06 percent of total PM emitted from SDT's, and 1.4 percent of total PM emitted from lime kil
  bAs H2S.
  °Numbers may not add exactly due to rounding.
2.4   REFERENCES FOR CHAPTER 2
 1.   Green,  R. and G. Hough (eds.).  Chemical Recovery in the
      Alkaline Pulping Processes.   3rd Edition.   Prepared by the
      Alkaline Pulping Committee of the Pulp Manufacture Division.
      Atlanta, GA, TAPPI  Press.   1992.  196 p.

 2.   Smook,  G.  Handbook for Pulp and Paper Technologists.
      Montreal, Quebec, Canada.   Canadian Pulp and Paper
      Association.  Atlanta, GA, TAPPI Press.  1987.

 3.   Memorandum from Nicholson, R., MRI, to Telander,  J.,  ,
      EPA/MICG.  June 13,  1996.   Addendum to Summary of Responses
      to the 1992 NCASI  "MACT" Survey.

 4.   Lockwood Post's Directory of  the Pulp, Paper and Allied
      Trades, 1993.  San  Francisco, Miller Freeman Publications.
      1993.  966 p.
                                 2-44

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 5.  Pulp, Paper, and Paperboard Industry--Background Information
     for Proposed Air Emission Standards, Manufacturing Processes
     at Kraft, Sulfite, Soda, and Semi-Chemical Mills.  U. S.
     Environmental Protection Agency, Research Triangle Park, NC.
     Publication No. EPA-453/R-93-050a.  October 1993.

 6.  Memorandum from Nicholson, R., MRI, to the project file.
     September 20, 1996.  Semichemical Pulping Operations Co-
     Located at Kraft Pulp Mills.

 7.  U. S. Environmental Protection Agency.  New Source
     Performance Standards for Kraft Pulp Mills.  43 FR 7568.
     Washington, DC.  U.S. Government Printing Office.
     February 23, 1978.

 8.  U. S. Environmental Protection Agency.  New Source
     Performance Standards for Kraft Pulp Mills.  51 FR 18538.
     Washington, D.C.  U.S. Government Printing Office.
     May 20, 1986.

 9.  Review of New Source Performance Standards for Kraft Pulp
     Mills.  U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.  Publication No. EPA-450/3-83-017.
     September 1983.  p. 4-7.

10.  Stultz, S. and J. Kitto (eds.).  Steam: Its Generation and
     Use.  40th Edition.  Babcock & Wilcox.  New York.  1992.
     Chapter 26.

11.  Someshwar, A. and J. Pinkerton.  Wood Processing Industry.
     In: Air Pollution Engineering Manual, Air & Waste Management
     Association.  Buonicore, A. and W. Davis (eds.).  New York,
     Van Norstrand Reinhpld.  1992.  pp. 835-849.

12.  Proposed Standards of Performance for Kraft Pulp Mills.  In:
     Standards Support and Environmental Impact Statement.
     Volume 1.  U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.  Publication No. EPA-450/2-76-014-a.
     September 1976.

13.  Environmental Pollution Control:  Pulp and Paper Industry,
     Part I, Air.  U. S. Environmental Protection Agency.
     Cincinnati, OH.  Publication No. EPA-625/7-76-001.
     October 1976.

14.  Memorandum from Soltis, V., Nicholson,  R.,  and Holloway, T.,
     MRI, to Telander, J., EPA/MICG.  July 29, 1994.  Summary of
     Responses to the NCASI "MACT" Survey--Kraft and Soda Pulp
     Mills.

15.  Barsin, J.  Process Recovery Boiler Design Considerations.
   ,  Babcock and Wilcox.  (Presented at the Kraft Recovery
     Operations Seminar.  Orlando, FL.  February 10-14, 1986.)
                              2-45

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16.  Kirby, M.  Economic and Process Considerations in the Use of
     Oxygen for Black Liquor Oxidation.  Union Carbide Canada
     Limited.  Ontario, Canada.   (Presented at the 21st Pulp and
     Paper ABCP Annual Meeting.  Sao Paulo, Brazil.
     November 21-25, 1988.)  10. p.

17.  Cooper, H.  TRS Control Implications Reviewed, Part II.
     Southern Pulp and Paper.  April 1981.  p. 42-42.

18.  Memorandum from Soltis, V., MRI, to the project file.
     April 3, 1995.  Kraft and Soda Pulp Mill Combustion Sources
     Data Base.

19.  Walther, J. and H. Amberg.  Crown Zellerbach Corp.  A
     Positive Air Quality Control Program at a New_Pulp Mill.
     Journal of the Air Pollution Control Association.
     20(1):9-18.  January 1970.

20.  Reference 1, p. 156.

21.  Memorandum from Ramsey, M. , MRI, to Telander, J. , EPA/ISB.
     January 27, 1992.  Meeting minutes from the August 1,  1991
     meeting between National Council of the Paper Industry for
     Air and Stream Improvement,  Inc., American Paper_Institute,
     the U. S. Environmental Protection Agency, and Midwest
     Research Institute.

22   Memorandum from Subramarian, S. and Nicholson, R., MRI,  to
     the project file.  September 13, 1993.  State Regulations on
     Particulate Matter Emissions from Kraft Lime Kilns, Recovery-
     Furnaces, and Smelt Dissolving Tanks.

23.  Memorandum from Gideon, L. and Watkins, S., Radian Corp., to
     Lassiter, P., EPA/CPB.  January 22, 1992.  Summary of
     Regulatory Survey for  the  Pulp and Paper NESHAP.

24.  Memorandum from Randall, D., Jones, R., and Nicholson,  R.,
     MRI,  to Telander, J.,  EPA/MICG.  April 25, 1995.  Nationwide
     Baseline Emissions for Combustion Sources of  Kraft and Soda
     Pulp  Mills.

25.  Someshwar, A.  and A.  Jain.   Emissions  of Hydrochloric  Acid
     from  Kraft Recovery  Furnaces.  National Council  of the_Paper
     Industry  for Air  and Stream  Improvement, Inc.  Gainesville,
     FL.   (Presented at the 1992  TAPPI International  Chemical
     Recovery  Conference.   Seattle, WA.  June 18,  1992.)  14 p.

26.  Warnqvist, B.  and H.  Norrstrom.   Chlorides in the Recovery
     Boiler and Mechanism for  Chloride Removal.  TAPPI.
     59(11):89.  1976.
                               2-46

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27.  Someshwar, A.  A Study of Kraft Recovery Furnace
     Hydrochloric Acid Emissions.  National Council of the Paper
     Industry and Air and Steam Improvement, Inc.  New York.
     Technical Bulletin No. 674.  August 1994.

28.  Memorandum from Randall, D., MRI. to the project file.
     November 8, 1994.  Comparison of EPA and NCASI HC1 Emission
     Factors for Recovery Furnaces.

29.  Telecon.  Ramsey, M.,  MRI, with Morris, T., Westvaco Corp.,
     Covington, VA.  June 17 and 25, 1993.  Supplemental
     information for Westvaco emission test reports.

30.  Memorandum from Nicholson, R., MRI to the project file.
     March 31, 1995.  Methanol Emissions from Kraft NDCE Recovery
     Furnaces.

31.  Memorandum from Holloway, T., MRI, to the project file.
     June 14, 1996.  Summary of PM and HAP Metals Data.

32.  Memorandum from Holloway, T., MRI, to the project file.
     May 20, 1996.  Nationwide Baseline PM and TRS Emissions.
                              2-47

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                 3.0   EMISSION CONTROL TECHNIQUES

     This chapter discusses emission control techniques for
reducing HAP emissions from recovery furnaces, BLO systems,
SDT's, and lime kilns located at kraft pulp and paper mills.
Recovery furnaces include DCE recovery furnaces and NDCE recovery
furnaces.  Add-on controls and equipment changes/modifications
are discussed in Sections 3.1 and 3.2,  respectively.  Both PM and
gaseous HAP control techniques are included in this discussion.
Section 3.3 contains the references cited in this chapter.
     Tables 3-1 and 3-2 present applicable control techniques for
reducing PM and gaseous HAP emissions,  respectively, from the
aforementioned combustion sources located at kraft pulp and paper
mills.  These control techniques and their effectiveness in
reducing PM and gaseous HAP emissions are discussed below.
3.1  ADD-ON CONTROLS
     This section describes the various add-on air pollution
control equipment that can be applied to the combustion sources
located in the chemical recovery areas at kraft pulp and paper
mills.  Sections 3,1.1, 3,1.2, and 3.1.3 describe ESP's, wet
scrubbers, and BLO control, respectively; each section presents a
description of the control equipment and describes the
performance of the equipment in controlling HAP (PM and/or
gaseous) emissions from the applicable combustion sources.
3.1.1  Electrostatic Precipitators
     Electrostatic precipitators are a demonstrated control
technique for reducing PM emissions from kraft recovery furnaces
and lime kilns.  The PM emissions from over 98 percent of kraft
recovery furnaces and approximately 10 percent of kraft lime
kilns are controlled with ESP's.1  A general description of the
                               3-1

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         TABLE 3-1.  PARTICULATE MATTER HAP CONTROL TECHNIQUES
Source
Recovery furnace
Lime kiln
SDT
Control technique
ESP
ESP
Venturi scrubber
Wet scrubber
Percent PM reduction
99 +
99+
99 +
99+
                TABLE 3-2. GASEOUS HAP CONTROL TECHNIQUES
Source
NDCE recovery
furnace systems
DCE recovery furnace
system (includes air-
sparging BLO system)
Lime kiln
SDT
Control technique
Packed-bed scrubber
Elimination of black liquor
from ESP system
Packed-bed scrubber
Conversion to NDCE recovery
furnace with dry- ESP system0
Incineration of BLO vent gases
Control makeup water quality
in causticizing area
Control makeup water quality
in causticizing area
Percent reduction
HC1
Up to 99% or
5 ppmva
—
Up to 99% or
5 ppmva
_d
_e
Other HAP's
_
72%
_
93%
38%*
_g
_g
aControl efficiency depends on inlet HC1 concentration.  Based on manufacturers' guarantees,
 scrubbers can achieve either a 99 percent control efficiency or an outlet concentration of 5
 ppmv.
^Insufficient data are available to determine the emission reductions of other HAP's.
cConversion includes replacement of the DCE recovery furnace with an NDCE recovery furnace
 , and elimination of the BLO unit.                                       .         .  .
dHCl emissions are highly variable.  Available data indicate no overall change in HC1 emissions
 is expected from converting a DCE recovery furnace system to an NDCE recovery furnace.
?HCl is not emitted from BLO systems.
fThe overall percent reduction is based on average HAP emission factors for DCE recovery
 furnaces and air-sparging BLO systems, and on a control efficiency of 98 percent for HAP s
 emitted from the BLO system.
SWastewater control option performance is addressed in a separate wastewater regulatory
 development program.
                                        3-2

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types of ESP's''"used to control PM emissions from kraft recovery
furnaces and lime kilns is provided in Section 3.1.1.1, below.
The performance of these ESP's'is discussed in Section 3.1.1.2.
     3.1.1.1  Description.  The ESP's used to control PM
emissions from kraft recovery furnaces and lime kilns are
generally classified as plate-wire ESP's.  In plate-wire ESP's,
the flue gas flows between parallel sheet metal plates and high-
voltage electrodes.  The flue gas passes between collecting
plates into a field of ions that have been negatively charged by
                                                       o
the high-voltage electrodes located between the plates.   Each
paired set of electrodes and plates forms a separate
electrostatic field within the ESP.  Electrostatic precipitators
used to control PM emissions from kraft recovery furnaces
typically have two parallel precipitator chambers  (i.e., flu'e gas
passages) with three or four electrostatic fields per chamber.
Lime kiln ESP's typically have one chamber with two or three
electrostatic fields.1
     As the flue gas passes through each electrostatic field, the
particles suspended in the flue gas are bombarded by the ions,
imparting a negative charge to the particles.  The negatively
charged particles then migrate towards the positively charged or
grounded "collecting" plates, where the particles transfer a
portion of their charge, depending upon their resistivity.  The
particles are kept on the collecting plates by-*the electrostatic
field and the remaining charge.   At periodic intervals, the
collection plates are knocked  ("rapped"), and the accumulated PM
falls into the bottom of the ESP.  The recovered PM is
subsequently recycled to the black liquor in recovery furnace
applications or,-in lime,kiln applications, fed back to the kiln.
The ESP's used on recovery furnaces may be designed with either a
wet or dry bottom.  In wet-bottom ESP's, the collected PM falls
directly into a pool of liquid, which may be black liquor or
water, in the bottom of the ESP.  In dry-bottom ESP's, the
collected PM falls to the (dry) bottom of the ESP and is
transferred from the ESP bottom to a mix tank (containing black
liquor) via drag-chain or screw 'conveyors.  Black liquor is
                               3-3

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sometimes used to transport the dry collected PM to the mix tank.
More recent ESP installations employ a dry PM return system to
transport the PM to the mix tank.  Because the PM removed by the
ESP is recycled to the black liquor in the mix tank, the ESP is
an integral part of the chemical recovery loop as well as an air
pollution control device.
     The design of the plate-wire ESP's used to control PM
emissions from recovery furnaces and lime kilns may include
either weighted-wire electrodes cr rigid electrodes.  With the
weighted-wire design, the wire electrodes are suspended inside
the ESP, and weights are attached to the wires to maintain
tension.  In the rigid-electrode design, the discharge electrodes
are rigid tubes with pointed corona emitters welded to the
surface; each tube replaces two weighted wires.  Although the
weighted-wire design has been available for more than 50 years,
rigid-electrode ESP's have only been available since the late
1970's.  The rigid-electrode ESP represents the current stage of
development in ESP technology and offers the following advantages
over the weighted-wire design: a higher tolerance of in-service
abuse  (no wires to break), better collection efficiencies, and
better cleaning characteristics.4  According to one manufacturer,
all new ESP installations in the pulp and paper industry since
1990 have rigid-electrode designs.5  Additionally,  since 1981, 64
of the 66  (97 percent) recovery  furnace ESP installations
supplied by this manufacturer have been of the rigid-electrode
design, and approximately 80 percent of the lime kiln ESP
applications use rigid-electrode designs.5  Figure 3-1 is a
schematic of a rigid-electrode, plate-wire ESP.
     The average lifetime of an  ESP in service on a kraft
recovery furnace varies  depending upon the type of  ESP bottom
 (i.e., wet vs. dry), the inlet temperature of the gases, and
maintenance practices.   The  lifetime of ESP's used  to control PM
emissions from recovery  furnaces with NDCE's, which tend to
operate with dry-bottom  ESP's, typically  ranges from 12 to
15 years.4  After  that point, major repairs or a rebuild may be
required.  Recovery  furnaces with DCE's tend  to have cooler inlet
                               3-4

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Figure 3-1.  Rigid-electrode ESP.
               3-5

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gases and wet-bottom ESP's; these two factors promote corrosion
through condensation of acid gases and shorten the life of the
ESP.  The lifetime of an ESP on a DCE recovery furnace typically
ranges from 7 to 10 years.4
     Lime kiln ESP's operate in a "milder" environment (i.e.,
hotter temperatures prevent any acid gases from condensing and
corroding the ESP, and the primary constituent of the PM
collected is lime, which creates an alkaline environment that
further protects the ESP from acid gas corrosion).  Therefore,
lime kiln ESP's have fewer corrosion problems than do recovery
furnace ESP's.  The expected lifetime of a lime kiln ESP is
typically more than 15 years.6
     The size of the ESP is often expressed in terms of the
specific collecting area (SCA), which is defined as the total
collecting plate surface area divided by the flue gas flow rate.
Specific collecting areas of ESP's used to control PM emissions
from kraft recovery furnaces and lime kilns typically range from
about 39 to 160 square meters per cubic meter per second
 (m2/[m3/sec])  (200 to 800 square feet per 1,000 actual cubic  feet
per minute  [ft2/!,000 acfm]).1  The SCA's of ESP's used to
control emissions from DCE recovery furnaces tend to be somewhat
lower than those associated with NDCE recovery furnaces.  The
average SCA for ESP's used to control emissions from DCE recovery
furnaces is approximately 15 percent lower than for NDCE recovery
furnaces.1  The primary reason for the difference is that the DCE
removes 20 to 40 percent of the PM before the ESP; therefore, the
inlet loading of PM to the ESP operating on a DCE recovery
furnace is lower than that of an NDCE recovery furnace.7  The
lower SCA's for DCE recovery furnaces may also be because DCE
recovery furnaces tend to be older than NDCE recovery furnaces,
and most are not subject to the NSPS for Kraft Pulp Mills.
     3.1.1.2  Performance.  Electrostatic precipitators can
control PM HAP emissions but provide no control of gaseous HAP
emissions.  Properly designed and operated ESP's used on kraft
recovery furnaces and lime kilns routinely achieve PM removal
efficiencies of 99 percent or greater.  Although emission test
                               3-6

-------
data from recovery furnace ESP's on PM HAP performance are
limited, data collected from other combustion sources on the
relative performance of ESP's for PM and metals indicate that
those systems that achieve the greatest PM removal also provide
the best performance for the HAP portion of the PM.   Therefore,
total PM performance can be used as a surrogate for PM HAP's.
     Because performance guarantees made by ESP manufacturers and
permit limits are usually in the form of outlet PM emission
concentrations rather than in the form of achievable control
efficiencies, outlet concentrations will be the focus of the
discussion of the performance of ESP's on kraft recovery furnaces
and lime kilns in the following sections.  Following the format
of the NSPS, all PM concentrations for recovery furnace emissions
are corrected to 8 percent (%,, and those for lime kiln emissions
are corrected to 10 percent O2.  The discussion below also
addresses the factors that affect ESP performance.
     3.1.1.2.1  Recovery furnaces.  The PM emitted from the
recovery furnace and subsequently recovered by the ESP is
primarily composed of sodium sulfate (i.e., "saltcake") and
sodium carbonate, neither of which are HAP's.  Particulate matter
HAP's, which are primarily metals (although small quantities of
high-boiling-point semivolatile organic compounds also may be
emitted in particle form), are emitted from the ESP in small
quantities.  For any single metal, the quantity emitted from
either NDCE or DCE recovery furnaces is typically less than
140 kg/yr  (300 Ib/yr).9  The paragraphs below first discuss the
outlet concentrations achievable by ESP's based on information
compiled as a part of the previous NSPS development effort and on
long-term performance data compiled by the State of Washington.
Then factors that can affect ESP performance are described.
     The NSPS for kraft recovery furnaces requires that PM
emissions from recovery furnaces constructed, reconstructed, or
modified after September 24, 1976 be less than or equal to
0.10 grams per dry standard cubic meter (g/dscm)  (0.044 grains
per dry standard cubic foot [gr/dscf]  of flue gas).10'11  Based
on installation dates, approximately 39 percent of NDCE recovery
                               3-7

-------
furnaces (i.e., 50 NDCE recovery furnaces)  and 4 percent of DCE
recovery furnaces (i.e., 3 DCE recovery furnaces)  are subject to
the NSPS.12  In addition, some NDCE and DCE recovery furnaces not
subject to the NSPS are subject to State PM permit limits that
are less than or equal to the NSPS limit.13  Therefore,  about
25 percent of the 211 existing recovery furnaces nationwide are
required by regulation to emit PM in concentrations less than or
equal to 0.10 g/dscm  (0.044 gr/dscf).
     The NSPS emission limit was established based on the
performance of a weighted-wire ESP design,  taking into
consideration maintenance issues such as wire breakage,  the
corrosive and sticky nature of the PM removed, any long-term
deterioration in ESP performance, and the inherent variability of
ESP performance.14  In considering these issues, EPA found that
ESP's that formed the basis for the standard were installed with
added insulation or heated shells to maintain the gas temperature
throughout the precipitator to prevent corrosion.14  Also,
although some amount of wire breakage was noted, most occurred
soon after start-up and lessened in frequency with more operating
time.  A loss of 5 to 10 percent of the wires was determined to
have no noticeable effect on the performance of the ESP.
Finally, about long-term deterioration in ESP performance,
manufacturers of ESP's were emphatic in stating that a properly
maintained precipitator should not deteriorate over the expected
life of the unit.14  Based on a review of all available
information collected from both the industry and control device
manufacturers, ESP systems were determined to be capable of
meeting an emission limit of 0.10 g/dscm (0.044 gr/dscf) on a
continuous, long-term basis.14
     More recent information obtained from ESP manufacturers
indicates that since  the NSPS was promulgated, the industry has
demanded further improvements to ensure continued compliance with
PM emission limits associated with the NSPS or State permit
requirements.  Mills  often require that ESP manufacturers provide
emission limit guarantees such that the furnace can meet the
permitted limit  (e.g.,  0.10 g/dscm  [0.044 gr/dscf]) with only  one
                               3-8

-------
chamber .of the ESP in operation.  Two ESP manufacturers commonly
guarantee that the permitted emission limit will not be exceeded
while the recovery furnace  is operating at 70 percent capacity
with one chamber of the ESP in operation.4'6  Requests by mills
for these types of guarantees began in the late 1980's and have
resulted in the installation of ESP's that are sized to ensure
that these emission limits  are achieved continuously.  This
design provides mills with  the advantage of being able to make
ESP repairs to one chamber  of the ESP without disrupting the
operation of the furnace, and thus avoiding production losses
while maintaining the integrity of the ESP.  In addition, ESP's
that meet these design criteria routinely achieve PM outlet
emissions at levels less than or equal to half the NSPS (i.e.,
0.050 g/dscm  [0.022 gr/dscf]) under normal operating conditions.4
     The information supplied by manufacturers is supported by
long-term PM emission test  data for recovery furnace ESP's
supplied by the State of Washington.13  Figures 3-2 through 3-4
show monthly PM emission data for two kraft NDCE recovery
furnaces with older ESP's over a 6-year period from 1988 to 1994
and one kraft NDCE recovery furnace with a newer ESP over a
5K-year period from 1990 to 1995.  The figures provide an
indication of concentrations achievable by older systems designed
to meet the NSPS limits and by newer ESP's with improved design.
The data also demonstrate the variability in ESP performance.
     The data in Figure 3-2 were generated by an ESP of weighted-
wire design that was designed to comply with a permit limit of
0.10 g/dscm (0.044 gr/dscf).  The ESP was installed in 1974 and
has a design and operating SCA of about 92 m2/(m3/sec)
(467 ft2/!,000 acfm).15
     The data in Figure 3-3 were generated by another ESP of
weighted-wire design that was designed to comply with a permit
limit of 0.10 g/dscm (0.044 gr/dscf).   The recovery furnace was
originally installed as a DCE recovery furnace in 1975 and
converted to an NDCE recovery furnace in 1982.15  The ESP was
last upgraded in 1982 and has a design and operating SCA of about
75 m2/(m3/sec) (383 ft2/!,000 acfm).15  The control system is
                               3-9

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augmented with- a combination low-energy venturi scrubber and
packed-bed scrubber  in series installed in 1984.15  The scrubbers
provide some added PM removal and act as a heat-transfer unit "to
provide hot•water.1°
     The data in Figures 3-2 and 3-3 indicate that although
emissions are quite variable, these units can readily meet the
NSPS limit of 0.10 g/dscm  (0.044 gr/dscf) on a long-term,
continuous basis.
     Outlet PM emission concentrations at least as low as
0.002 g/dscm  (0.001 gr/dscf) for recovery furnaces with newer
ESP's have been documented in the Washington data as well as in
the data provided by individual pulp mills.13'15  However, the
ability of an ESP to maintain emissions on a continuous basis at
levels substantially below 0.034 g/dscm  (0.015 gr/dscf) has not
been demonstrated.13  However, the data in Figure 3-4 do
demonstrate that a system can readily meet a level of
0.034 g/dscm  (0.015 gr/dscf) on a long-term, continuous basis.
These data were generated by an NDCE recovery furnace with a
rigid electrode ESP followed by a packed-bed scrubber.  The
recovery furnace was originally installed as a DCE recovery
furnace in 1956 and converted to an NDCE recovery furnace in
1981.1S  Both the ESP and the scrubber were installed in 1989.15
     While the data in Figure 3-4 for recovery furnace No. 3 at
Mill B are somewhat variable, they show considerably less
variability and consistently lower emissions (less than
0.034 g/dscm  [0.015 gr/dscf]) than the data associated with the
two older ESP's.  The ESP on recovery furnace No. 3 at Mill B was
designed to achieve an outlet concentration of 0,069 g/dscm
(0.033 gr/dscf).  Furthermore, although the system was designed
with an SCA of 79 m2/(m3/sec) (400 ft2/!,000 acfm), the furnace
has operated at about 60 to 70 percent capacity over its life.16
Consequently,  the operating SCA of the unit is estimated to be in
the range of 110 to 130 m2/(m3/sec)  (570 to 670 ft2/!,000 acfm)
or 120 m2/(m3/sec)  (620 ft2/!,000 acfm), on average.  These data
demonstrate that systems comprising a recent ESP with an SCA of
about 120 m2/(m3/sec) (620 ft2/!, 000 acfm)  followed by a packed-
                              3-13

-------
bed scrubber can achieve a maximum 'outlet concentration of
0.034 g/dscm (0.015 gr/dscf) on a long-term, continuous basis.
     No single parameter in and of itself is a good predictor of
ESP performance.  Both the design of the ESP and operating
variables affect the performance of the ESP.  Although the SCA
may provide some indication of the expected efficiency of the
ESP, other design features, such as the location of the rappers
and plate spacing  (which differs from one ESP manufacturer to
another), also affect the ESP's performance.  For example,
differences in plate spacing from one manufacturer to another
have resulted in different manufacturers requiring different
SCA's for the same outlet PM concentration.2'4  Another factor
that complicates assessment of the effect of SCA on performance
is that the PM emission concentrations for newer ESP's may be
measured based on gas flow  through one chamber with the recovery
furnace operating at about  70 percent capacity.4  The mechanism
used to report emissions and calculate the SCA  (i.e., based on
gas flow at 70 or 100 percent capacity) can mask any relationship
between the SCA and PM emissions.4  Consequently, available data
for recovery furnaces show  only a limited relationship between
outlet concentration and SCA.
     The power input to the ESP can be a useful parameter in
monitoring ESP performance.  The value of the power input for
each field and for the total ESP indicates how much work  is being
done to collect the PM.  The power supply to the ESP consists of
four basic components:  (1)  a step-up transformer  (to step up  the
line voltage),  (2) a high-voltage rectifier  (to convert
alternating current  [a.c.]  voltage to direct current  [d.c.]),
 (3) a control element, and  (4) a control system sensor.17 Most
ESP's installed since the  1980's are equipped with primary-
voltage and current meters  on the low-voltage  (a.c.) side of  the
transformer and secondary voltage and current meters on the high-
voltage rectifier  (d.c.) side of the transformer.17  The  power
input for each transformer-rectifier  (T-R)  set  is calculated  by
multiplying the voltage and current values  of either the  primary
or secondary  side  of  the transformer.  The  ESP  control  system is
                               3-14

-------
 designed to provide the highest possible voltage without causing
 sustained sparking between the discharge electrode and the
 collection surface.  Spark meters" can be used to set the maximum
 voltage/current levels for efficient operation.   When the
 resistivity of the particulate is normal to moderately high,  ESP
 performance improves as the total power input increases.
 However, when particulate resistivity is either  low or very high
 or when spark rates are very high,  improving the performance of
 the ESP may require decreasing the power input.17  In addition,
 newer,  high-efficiency ESP's that are generously sized and
 sectionalized are relatively unaffected by changes in power
 input.   The normal power input of some of these  newer and larger
 ESP's may be reduced by one-half to two-thirds without
 substantially affecting performance.17  Therefore,  power  input
 cannot  be used as a sole indicator of ESP performance.
     Other operating variables that reportedly impact the
 performance of the ESP include temperature of the flue gas and
 maintenance practices.   When flue gas temperatures exceed 260°C
 (500°F),  the ESP's PM collection efficiency starts to decline.
 At  low  temperatures (less  than 150°C [300°F]), the ESP may
 perform as desired,  but corrosion will  be accelerated (due to
 condensation of  acid gases).4   To obtain optimal  control  on a
 continuous basis,  the system should be  operated within this
 temperature envelope.                          «
     Poor operating and maintenance practices may also  result in
 a decline in ESP performance,  and differences in  operating and
 maintenance practices  are  expected  to contribute  to the
 variability in emissions from  mill  to mill  and over time  at the
 same mill.   Repairs  (e.g., replacing broken wires) are often
 delayed,  and routine  on-line maintenance  is sometimes neglected.
Mills commonly solicit  bids  for maintenance and repair work from
 ESP manufacturers  and  contracting firms  that provide ESP
maintenance  services.4
     3.1.1.2.2   Lime kilns.  Although venturi scrubbers have
traditionally been the most  common  PM control device used  on
kraft lime kilns,  the use of ESP's  to control PM emissions from
                               3-15

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lime kilns has steadily increased since about 1980.   The ESP is
generally mounted on top of the lime kiln feed building, and the
captured dry PM is rerouted to the kiln by gravity feed.18  The
trend towards ESP's as PM control devices at new lime kiln
installations and as replacement control devices for older
scrubbers is primarily related to the lower energy costs, reduced
maintenance, and increased reliability of the ESP's in comparison
to venturi scrubbers that provide equivalent control.  An added
benefit is that lime kiln ESP's produce a dry product that can be
recycled directly to the kiln.  The wastewater produced by the
venturi scrubber is typically recycled to the mud washers before
the kiln to recover the lime particulate in the spent scrubbing
fluid.  Additional energy is needed to remove the excess water in
the lime mud filter and to complete evaporation in the kiln.
 (Additional information about venturi scrubbers is provided in
Section 3.1.2.2.)
     The NSPS for kraft lime kilns requires that PM emissions
from gas-fired and oil-fired lime kilns constructed,
reconstructed, or modified after September 24, 1976 be  less than
or equal to 0.15 and  0.30 g/dscm  (0.067 and 0.13 gr/dscf),
respectively.10'11  Based on installation dates, approximately
28 percent  of existing lime kilns are  subject to the NSPS.
     The PM emissions reported by the  industry for lime kiln
ESP's  show  less variability month to month and kiln  to  kiln than
 those  associated with recovery furnace  ESP's.  Point-in-time  PM
data were reported  for nine facilities  with  ESP's  controlling
 lime kilns  subject  to the NSPS;  these  PM data  showed outlet
 concentrations  ranging  from 0.0057  to  0.059  g/dscm (0.0025  to
 0.026  gr/dscf).15
     These  reported data  are  confirmed by monthly  PM emission
 data  from the State of Washington for  two gas-fired  lime kilns
 with  ESP's  at Mills C and D.13   Both kilns  are subject  to the
 NSPS;  the ESP's at  Mills  C and D were  installed in 1982 and 1985,
 respectively.15
      As shown in Figure 3-5,  the PM emission data from the kiln
 at Mill C vary from 0.0025 to 0.0519 g/dscm (0.0011  to
                                3-16

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0.0227 gr/dscf) during the period from November 1988 to
April 1996.  The SCA of the ESP on this lime kiln is
90 m2/(m3/sec)  (460 ft2/l,000 acfm).15  The data for Mill C
confirm that ESP's on existing lime kilns can readily meet the
NSPS limit of 0.15 g/dscm  (0.067 gr/dscf) on a long-term,
continuous basis.
     The lime kiln at Mill D  (shown in Figure 3-6)  consistently
emitted PM at or below 0.018 g/dscm (0.008 gr/dscf)  during the
7-year period from March 1989 to April 1996.  The SCA for the
lime kiln ESP at Mill D is 220 m2/(m3/sec)  (1,120 ft2/
1,000 acfm) .15  The monthly PM emission data from Mill D
demonstrate that new ESP's on lime kilns can achieve a maximum
outlet concentration of 0.023 g/dscm  (0.010 gr/dscf) on a long-
term, continuous basis.
3.1.2  Wet Scrubbers
     The following discussion focuses on the control of gaseous
HAP emissions using packed-bed scrubbers and PM HAP emissions
using venturi scrubbers.  Section 3.1.2.1 discusses packed-bed
scrubbers as the primary mechanism of HC1 control;  the control of
gaseous organic HAP's by packed-bed systems will also be
discussed.  Section 3.1.2.2 discusses venturi scrubbers as a
means of controlling PM emissions.  In addition to venturi
scrubbers, the pulp and paper industry uses other types of wet
scrubbers, such as impingement plate, cyclone, flooded disc, and
packed-bed, to control PM emissions from lime kilns and SDT's.
However, venturi scrubbers are the most prevalent type of wet
scrubber used to control PM from these sources, and the other
scrubber types do not control PM emissions more effectively than
venturi scrubbers.
     3.1.2.1  Packed-Bed Scrubbers.  Test data indicate that both
NDCE and DCE kraft recovery furnaces emit HC1 in the furnace
exhaust gas at concentrations as high as 100 parts per million by
volume  (ppmv), corrected to 8 percent 02.19'20  These exhaust
streams also contain SO0 at concentrations as high as 979 ppmv,
                       &
corrected to 8 percent O2.1/19  Typically, facilities that use
add-on control measures for acid gas emissions use packed-bed wet
                               3-18

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scrubbers.  Although the packed-bed scrubbers on kraft recovery
furnaces are not specifically designed to reduce HC1 emissions,
HC1 control can be achieved as an ancillary benefit.
     This section focuses on control of gaseous HC1 emissions
with packed-bed scrubbers.  Packed-bed systems have been
installed to a limited extent on kraft recovery furnaces for a
variety of reasons, including acid gas (i.e., SO2) control and
hot-water generation  (i.e., to recover heat from the flue
gas),21/22  They have also been demonstrated to achieve high
levels of HC1 control on other combustion systems.  The remainder
of the section describes packed-bed scrubbing systems, presents a
brief summary of the basic operating principles of packed-bed
systems and their theoretical performance for both HC1 and SO2
emission reductions, examines packed-bed scrubber performance
data for kraft recovery furnaces and for other combustion
sources, and discusses existing packed-bed scrubber applications
for recovery furnaces.
    . 3.1.2.1.1  Description.  As illustrated in Figure 3-7, the
recovery furnace exhaust gases are ducted to the acid gas control
system after PM has been removed in the ESP.  Acid gas scrubbers
control HC1 and S02 emissions by mass transfer of these
pollutants from the exhaust gas stream to a liquid scrubbing
solution, typically either water or a caustic solution with
water.  Packed-bed scrubbers are the most frequently used
absorption device because they provide excellent liquid-gas
contact, leading to efficient mass transfer.23'24
     Schematics of two standard types of packed-bed scrubbers,
the counter-flow design and the cross-flow design, are shown in
Figures 3-8 and 3-9.  Typically, the gases pass through a quench
section before entering the scrubber to saturate the gas stream.
The gases then enter  the inlet plenum, which is designed to
distribute the gases  uniformly across the bed cross-section.   As
the gases flow through the bed, they contact a liquid film
created by a flowing  liquid that is distributed evenly throughout
the bed.  After the gas stream exits the bed, it passes through a
mist eliminator to remove entrained droplets that may contain
                               3-20

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                              3-22

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alkaline salts  (generated as the acid gases are scrubbed from the
exhaust gas), residual absorbed acids, and PM that was not
removed by the ESP or the packed bed.  The paragraphs below
describe the role of the packing and the scrubbing liquid in more
detail.
     A packed-bed scrubber is filled with packing material that
is used to produce a large liquid film surface area for contact
between the gas stream and scrubbing liquid.  Packing materials
are available in a variety of forms and materials, each having
specific characteristics with respect to surface area, pressure
drop, weight, corrosion resistance, and cost.25  Specific packing
"materials are selected by the manufacturer to conform with the
gas and liquid  stream properties of a particular application.
The gas stream  moves through the packed bed, contacting the
liquid film on  the surface of the packing.  In the counterflow
configuration,  the gas moves upward, while the liquid moves
downward through the packed-bed section.  In a cross-flow
configuration,  the gas moves in a horizontal direction,
perpendicular to the liquid stream, which moves downward through
the packing.  The countercurrent system is more efficient for
acid gas removal, but height limitations or particle loadings
that can lead to plugging sometimes dictate use of the  cross-flow
              *? P,
configuration.  °
     An aqueous scrubbing solution, which may be  either water or
an alkaline solution,  is used  in acid gas scrubbers.  Because HC1
is highly  soluble in water, adequate  control can  often  be
achieved with water alone.  However,  because the  exhaust from
kraft  recovery  furnaces  also  contains S02,  alkaline  solutions are
expected to be  used  for  this  source.  In addition to providing
substantially better  S02  control and  somewhat better HC1 control,
an alkaline solution  typically is  used  to maintain a constant
scrubber liquid pH  at  or slightly  below 7.0 to prevent  both scale
buildup and corrosion of scrubber  components.  The scrubbing
liquid that is  expected  to  be  used for  acid gas  control is
caustic  solution  (sodium hydroxide [NaOH]),  although sodium
carbonate  (Na2CO3)  and calcium hydroxide  (Ca[OH]2)  (slaked  lime)
                               3-24

-------
also can be used.  When the acid gases are absorbed into the
scrubbing solution, they react with alkaline compounds to produce
neutral salts.  The rate of absorption of the acid gases is
dependent on the solubility of the acid gases in the scrubbing
liquid.  The neutralization reactions are essentially
stoichiometric, i.e., the stoichiometric ratio of alkaline
compounds added to the system to that required for complete
neutralization of the acid absorbed into the scrubber solution is
essentially 1:1 in packed-bed scrubbers.26
     3.1.2.1.2  Theoretical, performance of packed-bed scrubbers.
Packed-bed scrubbers are chemical engineering unit operations
that provide mass transfer between a soluble gas component  (in
the case of kraft recovery furnaces, HC1, S02/ and possibly some
organic HAP's) and.a solvent liquid scrubbing solution (water or
an alkaline solution).  The driving force for absorption is the
difference between the partial pressure•of the soluble compound
in the gas mixture and the vapor pressure of the solute gas in
the liquid film in contact with the gas.     The performance of
the system is a function of the mass transfer rate of the
pollutant from the gas to the liquid solute and of the contact
time between the gas and the liquid.  These properties form the
basis for the design equations that are typically used to
characterize the theoretical performance of gas absorption
systems like packed-bed scrubbers.
     Because the pollutant concentration in the gas stream is
very dilute, several assumptions that simplify these design
equations considerably are reasonable.  The waste gas is assumed
to operate as an ideal gas; the scrubbing solution is assumed to
be an ideal solution; heat effects associated with absorption are
assumed to be negligible; and the reaction of the HC1 and S02
with the alkaline material in the scrubbing solution is assumed
to be fast compared to the rate-limiting absorption step.  Also,
because equilibrium characteristics of a counterflow scrubber are
much less complex mathematically than the characteristics of a
cross-flow tower,  the theoretical analyses focus on the
counterflow tower.
                              3-25

-------
     The design and performance equations for counterflow packed-
bed scrubbers are based on the Whitman two-file theory,  which is
described in detail in reference 28.28  The key element of this
theory for the analysis of kraft recovery furnace packed-bed
scrubbers is that the system is considered to be gas-film
controlling or liquid-film controlling, depending on the
pollutant to be controlled and the scrubbing liquid.  For the
recovery furnace exhaust stream, HC1 absorption is liquid-film
controlling, while both the liquid film and the gas film provide
appreciable resistance to S02 absorption.28  These system
properties simplify the theoretical assessment of the performance
of the system for HC1 in that only gas-phase transfer needs to be
considered.  They also partially explain the difference in
performance of packed-bed scrubbers for S02 and HC1.
     An estimate of the theoretical performance of a packed-bed
scrubber for HC1 emissions can be developed by manipulating the
system design equations.29"31  For a specific set of inlet
conditions, these design equations can be modified to obtain the
following expression  for the efficiency of a packed-bed scrubber:

                       Eff = 1-Yo/Yi
                           = 1 -exp-(Z/HOG)

where yo is the outlet gas mole fraction, y.j_ is the inlet gas
mole fraction, Z is the packing height, and HQG is the height  of
a gas transfer unit.
     These  theoretical analyses have two important implications
for the performance of packed-bed scrubbers in controlling HC1
emissions from kraft  recovery  furnaces.  First, the theoretical
efficiency  of the system is limited by the concentration  that  can
be achieved in the exhaust gas  from the scrubber when it  is  in
equilibrium with the  scrubber  liquor feed.  At the concentrations
found in kraft furnace recovery exhaust gases and scrubbers, the
                                              1         "5 O
Henry's Law coefficient is of  the order of 10"J or less.     If
the scrubber liquor feed is maintained at  a pH of 6.5 or  greater,
the molar concentration of HC1  in the  feed is on the order  of
                               3-26

-------
6 x 10" .  Theoretically, the limiting HC1 concentration in the
exhaust gas is well below 1 ppm.  However, this theoretical limit
is based only on ideal mass transfer considerations and does riot
address nonuniformities in gas and liquid flows that may be found
in operating systems.
     Second, if for a given system, the height of a transfer unit
changes between pollutants by a factor of k, the penetration
(i.e, 1 - efficiency) for the two pollutants changes
exponentially with 1/k.  The reported range of manufacturer's HQG
for plastic packings is 0.18, to 0-.33 meters (m) (0.6 to 1.1 feet
[ft]) for water as a scrubbing liquid and 0.15 to 0.31 m (0.5 to
0.7 ft) for caustic as a scrubbing liquid.    Note that the same
reference reports a range of 0.15 to 0.61 m (0.7 to 2.0 ft) for
scrubbing S02 with caustic.  These data indicate that the height
of a transfer unit for SC>2 is 2 to 3 times that for HCl, so that
the penetration for S02 will be the square root or the cube root
of that for HCl or, equivalently, that the penetration for HCl
will be the square or the cube of the penetration for SOo.  For
example, if a system achieves 99 percent control for HCl,  (i.e.,
the penetration is 0.01), the control efficiency for SC>2 would be
expected to be in the range of 78 to 90 percent.
     3.1.2.1.3  Performance of HCl scrubbers for kraft recovery
furnaces.  To provide a basis for subsequent analyses of HCl
performance potential, a typical sample of emission test data on
HCl concentrations and kraft recovery furnace combustion gas
characteristics is compiled in Table 3-3.  The emission test data
are taken from tests conducted in 1992-93 by the National Council
of the Paper Industry for Air and Stream Improvement, Inc.
(NCASl).1^  A complete compilation of available HCl emission test
data for kraft recovery furnaces is presented in a separate
memorandum.33  The data in Table 3-3 reflect two factors that
complicate the design, operation, and characterization of
performance of packed-bed scrubbing systems--the relatively large
flue gas flow rates generated by these systems and the relatively
low and variable concentrations of both HCl and SC^ generated by
these systems.  Because of the large flow rates, either large-
                               3-27

-------
TABLE 3-3. SUMMARY OF DATA ON KRAFT RECOVERY FURNACE COMBUSTION GAS
CHARACTERISTICS19
Flue gas concentrations8 ||
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 diameter scrubbers or parallel systems are needed to maintain
 proper flow conditions in the scrubber.   The low HC1
 concentrations such as those in Table 3-3 are reported to affect
 the ability of the scrubber to achieve high removal efficiencies
 because of limitations on the.outlet concentrations that can be
 achieved with the systems."'
      Only limited test data on acid gas control with packed-bed
 scrubbers are available for kraft recovery furnaces.  However,
 packed-bed scrubbers are used widely on waste combustion systems,
 and a substantial body of information is available on their
 performance for these systems.  These.data show that these
 scrubbers can achieve removal efficiencies of 99 percent or
 greater with relatively high concentrations of HC1.  Efficiencies
 of this order are confirmed'by scrubber manufacturer representa-'
 tives,  who indicate that properly designed and operated
 packed-bed scrubbers can achieve HC1 emission reductions of at
 least 99 percent or an HC1 outlet concentration not exceeding
 5 ppmv for recovery furnace exhaust streams.23'34
      Available data on scrubber performance are presented in
 Table 3-4 for seven kraft DCE and NDCE recovery furnaces and five
 medical waste incinerators  (MWI's).15/21'22'35f36  With one
 exception, the data in Table 3-4 indicate that packed-bed
 scrubbers on waste combustion systems can achieve HC1 removal
 efficiencies of 98.8 percent or greater.  The one exception is  a
 cross-flow scrubber, which manufacturers indicate are less
 efficient than counterflow systems.  The high HC1 removal
 efficiencies with packed-bed scrubbers are supported by a summary
 of trial bum data for hazardous waste incinerators (HWI's).37
' This study contains limited data on HC1 control efficiencies for
 10 HWI's based on feed rates of organic chlorine to the system
 and outlet HC1 measurements.37  Because the reported HWI data are
 insufficient to characterize inlet concentrations or scrubber
 characteristics,  they were excluded from Table 3-4.  However,
 efficiencies for all 10 systems are greater than 98 percent,  and
 6 of the 10 systems showed efficiencies of substantially greater
 than 99 percent.37  More detailed data on two of these systems
                               3-29

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that used a caustic scrubbing solution showed outlet
concentrations of 1.3 and 13 ppmv, with removal efficiencies of
>99.9 percent and 98.2 percent, respectively.38  Taken together,
the data in Table 3-4 and the HWI data show that a properly
designed and operated packed-bed scrubber can achieve HC1 removal
efficiencies in the range of 99 percent.
     For two MWI systems in Table 3-4, outlet HC1 concentrations
of less than 1.5 ppmv were obtained with HC1 inlet concentrations
of greater than 1,000 ppmv.  This same type of reduction appears
to have been achieved.by the one HWI system with an outlet
concentration of 1.3 ppmv.  These MWI and HWI data support the
results from the theoretical analyses on the ability of these
systems to achieve low outlet concentrations.  Also, systems with
caustic scrubbing solution are able to achieve outlet
concentrations not exceeding 5 ppmv.23'34
     3.1.2.1.4  Performance data--gaseous organic HAP's.  Data
were presented in Chapter 2 on levels of gaseous organic HAP
emissions expected from recovery furnaces.  While there are no
available gaseous organic HAP emission test data that would allow
the determination of the performance of packed-bed scrubbers in
controlling HAP emissions from recovery furnaces, packed-bed
scrubbers designed primarily for HC1 control would be expected to
control emissions of the water-soluble gaseous organic HAP's
(such as methanol and formaldehyde) to a limited degree.
However, because of the low concentrations of gaseous organic
HAP's expected in the furnace exhaust streams, absorption of
these pollutants may be limited in packed-bed scrubbers designed
for HC1 control due to the small concentration gradient  (driving
force}  between the gas and scrubbing liquid.
       In providing design and cost information for packed-bed
scrubbers for HC1 control, vendors were asked to provide
estimates of the degree to which the HAP's methanol,
formaldehyde, and acetaldehyde would be controlled with the same
equipment.  One vendor estimated removal efficiencies of
50 percent for methanol and formaldehyde and 20 percent for
acetaldehyde but would not offer a performance guarantee for the
                               3-31

-------
 three pollutants.34   While  the  packed-bed  scrubber may remove
 some gaseous  organic  HAP's  from the  gas  stream, a portion of the
•pollutants  absorbed into the  scrubbing fluid may volatilize back
 into the  atmosphere from the  wastewater  treatment process, which
 would decrease the overall  system removal  efficiencies.
 Currently,  data are insufficient to  determine  whether the
 blowdown  of the scrubber liquor is sufficient  to maintain low
 levels  of HAP's in the scrubber water to maintain the
 concentration gradient and  to prevent stripping.
     3.1.2.1.5  Existing applications of packed-bed  scrubbers.
 Currently,.two NDCE recovery  furnaces, both at the same  kraft
 pulp mill,  are each equipped  with a  cross-flow packed-bed
 scrubber  that operates downstream from an  ESP.  For  other
 recovery  furnace applications,  the packed-bed  scrubber also would
 be installed downstream from  the PM  control device,  which would
 remove  over 99 percent of the PM from the  emission stream before
 scrubbing.
     One  of the packed-bed scrubbers currently in operation on an
 NDCE recovery furnace was designed for  S02 control and hot-water
 generation (i.e., to  recover  heat from  the flue gas).21'22  Fresh
 water  is  used as the  scrubbing medium,  with some added  caustic.
 Although  no HC1 emission data are available for the  recovery
 furnaces  at this mill, S02  scrubber  design criteria  are  available
 for this  recovery furnace.  As shown in Table  3-4,  the  design
 inlet  S02 concentration was 150 ppmv, while the design  outlet S02
 concentration was 2.5 ppmv, for a design S02  emission reduction
 of 98  percent.35  Because HC1 is more soluble  in water  than S02
 and based on the theoretical  discussion presented  earlier,  HC1
 emission reductions greater than 98  percent would be expected for
 this packed-bed scrubber.    s
     While only one facility has installed packed-bed scrubbers
 on NDCE recovery furnaces,  three other facilities  have reported
 that packed-tower systems are .being used to control  emissions
 from five DCE recovery furnaces.15  Although no information is
 available on the control of HC1 achieved by these  systems,  the
 available data indicate that they achieve S02 outlet
                                3-32

-------
concentrations -ranging from <1 to about 60 ppmv.1^  Furthermore,
the data indicate that the three packed-tower systems handle flow
rates in the range of 7,360 to 14,800 actual cubic meters per
minute  (acmm)  (260,000 to 522,000 acfm).15  These systems show
that counterflow packed-tower systems are compatible with both
DCE and NDCE recovery furnace exhaust streams and provide a
viable technology for control of HC1 emissions from these
furnaces,
     3.1.2.2  Venturi Scrubbers.  Venturi scrubbers are a
demonstrated control.technology for reducing PM emissions and,
therefore, PM HAP emissions from lime kilns and SDT's.
Particulate matter emissions from approximately 86 percent of
lime kilns and 35 percent of SDT's are controlled using venturi
scrubbers.^  However, • venturi scrubbers are used on only one
existing recovery furnace (an NDCE recovery furnace) as the sole
PM control device.12  Venturi scrubbers may also provide, to a
more limited extent, control of gaseous HAP emissions.  This
section briefly describes venturi scrubbers and presents PM HAP
performance data.
     3.1.2.2.1  Description.  Venturi scrubbers are designed to
remove PM primarily by impaction through high-energy contact
between the scrubbing liquid and suspended PM in 'the gas
stream.26  A schematic of a venturi scrubbing system is shown in
Figure 3-10.  A venturi scrubbing system typically consists of a
venturi scrubbing vessel and cyclonic separator.  The venturi
scrubbing vessel has a converging section, a throat section, and
diverging section.
     The exhaust gas enters the converging section and, as the
cross-sectional area of the scrubber vessel decreases, gas
velocity increases.  Scrubbing liquid is introduced either at the
entrance to the converging section or at the throat.39   The
exhaust gas, which is pulled through the venturi vessel by the
system's induced draft fan and forced to move at extremely high
velocities in the throat,  shears the scrubbing liquid from the
walls,  atomizing the liquid.26,39  Particulate matter and gaseous
pollutants are transferred from the gas stream to the liquid
                               3-33

-------
                                        Cyclonic
                                        separator
        Flooded
         elbow
Figure  3-10.  Schematic of a  venturi scrubber.
                       3-34

-------
 droplets via impaction and diffusive mass transfer in the throat
 section as the exhaust stream turbulently mixes with the atomized
 scrubbing liquid.   The throat .'section may be constructed so that
 the  size of the throat opening is adjustable.   With an
 adjustable-throat  (or variable-throat)  venturi,  the gas  velocity
 across  the throat  can be maintained at a constant  speed  as the
 gas  flow rate changes,  thereby maintaining the  desired PM
 collection efficiency.   From the throat section,, the exhaust
 stream  passes through the diverging section of  the venturi
 scrubbing vessel,  where the velocity decreases.  Diffusion,  which
 is an effective collection mechanism for fine particles  and also
 the  primary mechanism of gaseous pollutants transfer,  usually
 occurs  in the diverging section,  where  the velocities  of the gas
 stream  and liquid  droplets are  almost equal.  Collection of  fine
 particles by the.liquid droplets is possible because the path of
 fine particles is  influenced primarily  by Brownian motion rather
 than by the path of  the gas stream.40
     An entrainment  separator,  typically a cyclonic separator, is
 needed  to collect  the PM entrained  in the droplets  because the
 high velocity of the exhaust stream from the venturi scrubbing
 vessel  would have  a  tendency to exhaust the droplets.39
     3.1.2.2.2   Performance data--PM HAP's.  Available
 information indicates that control  systems  that  achieve  the
 greatest  total  PM  collection efficiencies  also achieve the best
 performance for PM HAP  emissions.8   Thus,  although  the following
 information is  presented in terms of  total  PM, the  relative
 performance of  the different  systems  is  applicable  to that
 portion of  the  total  PM that  is  comprised  of PM  HAP's.
     The performance  of  the  scrubber  in  terms of PM collection is
 strongly affected by  the' pressure drop across the scrubber
 throat,  the liquid-to-gas  (L/G) ratio, and  the particle size
distribution.   Particulate matter collection efficiency generally
 increases as the throat velocity and  turbulence  of  the gas stream
 increase, as indicated by an  increased pressure drop across the
scrubber.
                               3-35

-------
     Typical venturi scrubber L/G ratios for PM control range
from 0.4 to 1.3 liters per actual cubic meter (L/acm)  (3 to
10 gallons per 1,000 actual cubic feet  [gal/103 acf]).  While L/G
ratios up to 2.7 L/acm  (20 gal/103 acf) can be used, increasing
the L/G ratio beyond 1.3 L/acm  (10 gal/103 acf)  usually does not
significantly improve PM collection efficiency.   However, venturi
scrubbers with L/G ratios ranging from 2.7 to 5.3 L/acm  (20 to
40 gal/103 acf) are used where absorption of gaseous pollutants
in addition to PM control is desired.  Liquid-to-gas ratios below
0.4 L/acm  (3 gal/103 acf) are usually not sufficient to cover the
throat section.39
     For lime kiln applications, PM collection efficiencies for
venturi scrubbers average 99 percent.39  These results are
supported by data reported for  four lime kiln scrubbers.15'41
One scrubber provided a removal efficiency of 98 percent with a
pressure drop of 26 millimeters of mercury  (mm Hg)  (14 inches of
water  [in. H20]).41  The other  three scrubbers provided  removal
efficiencies of greater than 99.5 percent with scrubber  pressure
drops  in the range of 37 to 45  mm Hg  (20 to 24 in.  H20).15
     Variable-throat venturi scrubbers  with pressure drops  that
range  from 19 to 56 mm  Hg  (10 to 30 in. H20) and average 37 mm Hg
 (20 in. H20) are typically used for controlling PM  emissions from
lime kilns.1'40  Typical L/G ratios are between 1.3 and  2.7 L/acm
 (10 and 20 gal/103 acf).40  Particle size distribution data,
based  on limited lime kiln test data,  show that approximately
17 percent of the particles entering the scrubber are less  than
10 micrometers  (/zm)  in  diameter, while 98 percent of particles
exiting the  scrubber are less than 10  /zm in diameter.42  Lime mud
with a high  soda content, which results from  inefficient washing
of the lime  mud, can produce a  large quantity of PM in the  0.1 to
1.0 /zm size  range.40 Particles in this size  range  are the  most
difficult  to remove  and may require  increased  scrubber pressure
drops  or process modifications  to improve lime mud  washing.
     The NSPS  for kraft lime kilns requires that PM emissions
 from gas-fired and  oil-fired lime kilns constructed,
 reconstructed,  or modified after  September  24,  1976 be less than
                                3-36

-------
or equal to 0.15 and 0.30 g/dscm  (0.067 and 0.13 gr/dscf ) ,
respectively.10'11  Based on installation dates, approximately
28 percent of existing lime kilns are subject to the NSPS.1
     Long-term PM data are available for two gas -fired lime kilns
with venturi scrubbers that are subject to the NSPS PM limit of
0.15 g/dscm (0.067 gr/dscf).  Figures 3-11 and 3-12 present
monthly PM emission data from the State of Washington for lime
kilns at Mills A and B over a 6-year period from 1988 to 1994. 13
The lime kilns at Mills A and B were installed in 1980 and 1979,
respectively.1^  The data demonstrate that existing venturi
scrubbers on lime kilns can readily meet the NSPS PM level of
0.15 g/dscm (0.067 gr/dscf) on a long-term, continuous basis.
     For SDT applications, reported PM removal efficiencies for
venturi scrubbers range from 97 to greater than 99
percent. 40,42,43  The average pressure drop for SDT venturi
scrubbers is 15 mm Hg (8 in. I^O).1  Liquid-to-gas ratios range
from 1.0 to 1.3 L/acm (8 to 10 gal/103 acf).40  Weak wash (from
the lime mud washer) is the scrubbing fluid for the majority of
SDT venturi scrubbers.
     The NSPS for kraft pulp mills require that PM emissions from
SDT's that are constructed, modified, or reconstructed after
September 24,  1976 be less than 0.10 kg/Mg (0.20 Ib/ton)  of BLS
fired in the recovery furnace.10'11  Based on installation dates,
approximately 29 percent of existing SDT's are subject to the
NSPS.12
     No long-term PM data are available for SDT's with venturi
scrubbers that are subject to the NSPS limit of 0.10 kg/Mg
(0.20 Ib/ton)  BLS.  However, long-term data are available for two
SDT's equipped with packed-bed scrubbers designed to meet a more
stringent PM permit limit of 0.06 kg/Mg (0.12 Ib/ton) BLS; high-
efficiency venturi scrubbers are expected to achieve equivalent
control.  Figures 3-13 and 3-14 present monthly PM emission data
from the State of Washington for two SDT's with packed-bed
scrubber systems at Mill B over a 6 -year period from 1988 to
1994.13  Figure 3-15 presents monthly PM emission data from the
State of Washington for a new SDT with a combination venturi and
                               3-37

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packed-bed scrubber system at Mill C over a 2-year period from
1992 to 1994.13  These data demonstrate that high-efficiency wet
scrubbers on SDT's can achieve a maximum outlet PM level of
0.06 kg/Mg (0.12 Ib/ton) BLS on a long-term, continuous basis.
3.1.3  BLO Control
     As explained in Chapter 2, BLO systems that use pure oxygen
instead of air to oxidize black liquor do not need a system vent
because all of the oxygen is consumed in the oxidation reaction.
As a result,  there are no emission points for the molecular 02
BLO unit.  Black liquor oxidation systems that use air to oxidize
black liquor require vents for each oxidation tank.  Add-on
controls currently used to reduce gaseous organic HAP emissions
from air-sparging BLO units collect and incinerate exhaust gases
from the BLO vents.  This section describes the add-on controls
and presents the reductions in gaseous organic HAP emissions that
can be achieved with the add-on controls.
     '3.1.3.1  Description.  Of the estimated 42 kraft mills with
air-based BLO systems, two mills reduce gaseous organic HAP
emissions from air-sparging BLO vents with vent gas collection/
incineration systems.  The BLO vent gas collection/incineration
method used by one mill involves ducting the vent gases to two
condensers in series  (to remove water from the gases),  reheating
the gases, and then ducting the dry gases to a power boiler for
incineration.44'45  The control method used by the second mill is
identical except that a mesh-pad mist eliminator is used in place
of the condensers to remove water from the vent gas. "'    Both
mills incinerate their BLO vent gases in order to reduce TRS
emissions.  Because gaseous organic HAP's such as methanol,
acetaldehyde, and methyl ethyl ketone•are also emitted from BLO
vents, emissions of these HAP's would also be reduced by the
incineration of BLO vent gases.  Particulate HAP's and acid gases
(e.g., HC1) are not emitted from BLO vents.
     Before the BLO vent gases can be incinerated, they must
first be captured and transported to the incineration device.
Vent gases from a BLO unit can be hard-piped to the combustion
control device.  The type of duct material that can be used is
                               3-43

-------
determined by the characteristics of the gas in the vent
stream.48  Two materials commonly used in the construction of
vent ducts in the pulp and paper industry are fiberglass and
stainless steel.  Fiberglass ducts have the advantages of
relatively low cost, light weight, and corrosion resistance, but
are unable to be electrically grounded to prevent the buildup of
static charge and the absorption of hydrocarbons in its
fiberglass resin.48  Stainless steel is the preferred material of
construction for NCG cransport systems.49  Stainless steel has
the advantage of resisting corrosion by water and sulfur
compounds but is susceptible to corrosion by chlorides that may
be present in a vent gas control system that includes other vents
besides the BLO vent  (e.g., bleach plant vent).50
     The BLO vent gas may be conditioned to alter the moisture
content and/or the temperature of the stream before it is" vented
to the combustion control device.  Condensers, knockout drums, or
entrainment separators may be used to condition the gas in  the
                     AR
gas transport system.^0
     Vent gases are preheated only when emissions are controlled
with a combustion device.  Preheating is generally only practiced
on high-volume, low-concentration  (HVLC) streams, where the risk
of explosion is sufficiently low.51  The vent gases from BLO
units can be classified as HVLC streams.  Power boilers and
stand-alone thermal oxidizers are generally the preferred
combustion devices for incinerating HVLC streams.  Power boilers,
which include coal, natural gas, oil, wood waste, or combination
fuel-fired boilers, are designed to produce heat, steam, and
electricity for pulp mill operations.48  A thermal oxidizer is a
refractory-lined chamber containing a burner or burners used  to
oxidize vent streams  containing volatile organic compounds
 (VOC's).48  Both combustion devices have been demonstrated  in the
                                                              A p
pulp and paper  industry as control devices for vent emissions.
     Combustion control devices, such as power boilers and
thermal oxidizers, destroy the chemical structure of organic
compounds by oxidation at elevated temperatures.  These devices
operate on the principle that any VOC heated to a high enough
                               3-44

-------
 temperature in* the presence of sufficient oxygen will oxidize to
 predominantly C02 and H20.52  Combustion devices such as power
 boilers and thermal oxidizers-can achieve VOC/HAP destruction
 efficiencies of 98 percent or greater.53'54  Therefore, a net
 removal efficiency of 98 percent was assumed for all HAP's for
 the BLO incineration control system.
      3-1-3.2  Performance data--gaseous organic HAP's.  Because
 neither of the two vent gas collection/incineration systems
 currently existing has undergone emissions testing, the gaseous
 organic HAP emission reductions associated with a BLO vent gas
 control system were estimated based on gaseous organic HAP
 emission data available from uncontrolled air-sparging BLO
 systems, assuming a 98 percent destruction efficiency.55  The
 gaseous organic-HAP emission -reductions resulting from BLO
 control are presented in Table 3-5.   For a BLO unit with a BLS
 firing rate of 700,000 kilograms of  BLS per day (kg BLS/d)
 (1.5 million pounds of BLS per day [Ib BLS/d])  and 351 operating
 days per year (d/yr),  controlling emissions from the BLO vent
 could reduce average gaseous organic HAP emissions by about
 47 Mg/yr (54 ton/yr),  of which methanol accounts for about
 85 percent.
 3.2  EQUIPMENT CHANGES/MODIFICATIONS
      This section describes equipment changes/modifications that
 could be applied•to recovery furnaces at kraft pulp and paper
 mills to reduce gaseous organic HAP  emissions.   The two equipment
_changes/modifications  are elimination of black liquor or HAP-
 contaminated process water from ESP  control  systems and
 conversion from a DCE  recovery furnace system  to an NDCE recovery
 furnace,  which are discussed in Sections 3.2.1  and 3.2.2,
 respectively.
 3-2.1  Elimination of  Black Liquor used in NDCE Recovery Furnace
        ESP Control Systems
      "When hot  recovery furnace flue  gases come  in contact with
 ESP control  systems, gaseous organic  HAP's  (primarily methanol)
may be  stripped from any black liquor or HAP-contaminated process
water present  in  the system and emitted to the  atmosphere.
                               3-45

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TABLE 3-5. HAP EMISSIONS FOR BLO UNITS55
Hazardous air pollutant
Total organic HAP'sb
Acetaldehyde
Benzene
Formaldehyde
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Toluene
Xylenes
Uncontrolled BLO unit
Emission factor,
mass/mass BLS
2.03 x 10"4
1.48 x 1(T5
1.21 x 1CT6
2.89 x 10"7
1.73 x 1CT4
4.24 x ID"6
1.77 x 1CT6
1.93 x 10-6
1.44 x KT6
4.28 x ID"6
Mass rate, kg/yr
(lb/yr)a
48,500
(107,000)
3,530
(7,790)
289
(637)
69
(152)
41,300
(91,100)
1,010
(2,230)
423
(932)
461
(1,020)
344
(758)
1,020
(2,250)
Controlled BLO unit
Emission factor,
mass/mass BLS
4.06 x 10T6
2.96 x 10'7
2.42 x 10'8
5.78 x 10'9
3.46 x W6
8.48 x 10'8
3.54 x 10'8
3.86 x KT8
2.88 x 10'8
8.56 x 10'8
Mass rate,
kg/yr (lb/yr)a
969
(2,140)
70.7
(156)
5.78
(12.7)
1.38
(3.04)
826
(1,820)
20.3
(44.6)
8.45
(18.6)
9.22
(20.3)
6.88
(15.2)
20.4
(45.1)
aMass rates are based on a BLS firing rate of 700,000 kg BLS/d (1.5 million Ib BLS/d) and 351 operating
 d/yr.
kTotal organic HAP's include all gaseous HAP's in this table.  Numbers may not add exactly due to
 rounding.
                                             3-46

-------
 Electrostatic precipitator control systems include the ESP plus
 the PM return system associated with the ESP.   One method of
 controlling gaseous organic HAP emissions from ESP systems is to
 prevent their generation by eliminating the black liquor or
 contaminated process water from the system.  This equipment
 modification for ESP's  used with NDCE recovery furnaces and the
 associated HAP  emission reductions are discussed below»  (This
 equipment  modification  is not  discussed as an  option for reducing
 gaseous organic HAP's from DCE recovery furnaces be'cause,  as
 discussed  in Chapter 2,  no data are available  to determine if
 eliminating the wet bottom ESP's that are typically used with DCE
 recovery furnaces would actually decrease overall gaseous organic
 HAP emissions.)
      3.2.1.1 Description.   Particulate matter emissions from
 approximately 23  percent of all NDCE recovery  furnaces  are
 controlled with wet-bottom ESP's that use either unoxidized black
 liquor  or  process water in the ESP bottom.   The majority
 (77 percent)  of NDCE recovery  furnaces,  however,  are controlled
 with dry-bottom ESP's.1   Unoxidized black liquor is  used in about
 87  percent  of the wet-bottom ESP's on NDCE recovery  furnaces,  and
 water is used in  the remaining 13  percent.
      Since  the  1980's,  the  industry trend has  been toward the  use
 of  dry-bottom ESP's.  Some  mills  that  installed wet-bottom ESP's
 on  NDCE  recovery  furnaces  in the-late  1970's and early  1980's
 experienced difficulties  in meeting the  NSPS TRS  emission limit
 of  5  ppm.   These mills attempted  to comply with the  TRS  emission
 limit through the use of  one of  the following  techniques:
 (1) modifying the bottom of  the ESP to  limit contact between the
 flue  gases and  the, black  liquor  (e.g., using baffles),
 (2)  switching from the use  of black liquor to using water  in the
 ESP bottom,  or  (3) converting  from a wet-bottom ESP  to a dry-
 bottom ESP.  In general,  technique  Nos.  2 and 3 proved to be the
most viable  options  for meeting the TRS  emission  limit on a
 continuous basis.56'57  Because the mechanism for generating TRS
 emissions in the wet-bottom ESP is  the same mechanism for
 generating HAP emissions, technique Nos. 2 and 3 would also
                               3-47

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prevent methanol and any other gaseous organic HAP's from being
generated in the ESP, provided the water used in technique No. 2
is not contaminated with substantial quantities of organic
compounds.
     The major modifications involved in technique No. 3  (i.e.,
converting a wet-bottom ESP to the dry-bottom design) include
(1) removing the existing agitator paddles and liquor piping,
(2) installing a perpendicular drag scraper system, shallow
fallout hoppers, drag chain conveyors, rotary valves, ash mixing
tank, agitator, and associated instrumentation, and  (3) making
                     £- Q CO
piping modifications. °'3y
     The older design dry-bottom ESP control systems sometimes
use black liquor to sluice and transport the PM captured by dry-
bottom ESP's to the saltcake mix tank.  As a result, gaseous
organic HAP's may be stripped from the black liquor as the hot
recovery furnace flue gases are pulled through the ESP by the
induced draft fan.  The gaseous organic HAP emissions could be
controlled by converting to a dry PM return system.  Dry PM
return systems eliminate the use of black liquor in the PM return
system, so that the captured PM does not contact any black liquor
until it reaches the mix tank.  These hewer PM return systems
also are equipped with rotary valves  (through which the dry
captured PM passes) that provide an air lock between the ESP and
the remainder of the PM return system and the mix  tank  (which
contains black liquor).60  According to one ESP manufacturer,
systems that included dry return of the captured PM were
initially installed around 1985.60
     3.2.1.2  HAP Emission Reduction Potential.  As  shown in
Table 3-6, the elimination of black liquor from ESP  control
systems results in substantial reductions for  the  majority of  the
gaseous organic HAP  compounds.   (Note: Although HC1  emissions  are
included  in Table 3-6, HC1 emissions are unaffected by  the
presence  or absence  of black liquor in the ESP system.)   Although
the available data indicate that acetaldehyde  emissions  increase
with the  elimination of black  liquor from ESP  control  systems,
                               3-48

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       TABLE  3-6.    HAP  EMISSIONS  FOR  NDCE  RECOVERY FURNACES55
Hazardous air
pollutant
Total organic
HAP'se
Acetaldehyde
Benzene
Formaldehyde
Methanol
Methyl ethyl
ketone
Methyl isobutyl
ketone
Phenol
Toluene
Xylenes
HC1
ESP control system with black
liquor
Emission factor,
mass/mass
BLSa'b
1.30 x 1CT4
7.50 x 10"6
9.73 x 10'6
2.98 x 10'6
5.04 x 10'5
7.46 x 10'6
9.23 x 10~6
1.50 x 10'5
8.37 x 10~6
1.92 x 10'5
1.20 x 10"4
Mass rate,
kg/yr
0b/yr)c
31,000
(68,400)
1,790
(3,950)
2,320
(5,120)
712
(1,570)
12,000
(26,500)
1,780
(3,930)
2,200
(4,860)
3,580
(7,900)
2,000
(4,410)
4,590
(10,100)
28,700
(63,200)
ESP control system without
black liquor
Emission factor,
mass/mass
BLSb'd
3.67 x 10'5
1.52 x 10'5
1.73 x 1Q-6
1.93 x IOT6
4.93 x W6
1.80 x KT6
2.27 x 10"6
2.05 x 10-6
2.03 x 10"6
4.76 x 10"6
1.20 x KT4
Mass rate,
kg/yr
(lb/yr)c
8,760
(19,300)
3,630
(8,000)
413
(911)
461
(1,020)
1,180
(2,600)
430
(948)
542
(1,200)
490
(1,080)
485
(1,070)
1,140
(2,510)
28,700
(63,200)
Percent
reduction
72
-103
82
35
90
76
75
86
76
75
—
aEmission factors for gaseous organic HAP's are based on the average emission factors for NDCE
 recovery furnaces equipped with wet-bottom ESP's or with dry-bottom ESP's with wet PM return
 systems.
 Emission factor for HCi is based on the average emission factor for all NDCE recovery furnaces.
GMass rates are based on a furnace size of 700,000 kg BLS/d (1.5 million Ib BLS/d) and 351 operating
 d/yr.
 Emission factors for gaseous organic HAP's are based on the average emission factors for NDCE
 recovery furnaces equipped with dry-bottom ESP's and dry PM return systems.
^otal organic HAP's include all gaseous HAP's in this table except HCI.  Numbers may not add exactly
due to rounding.
                                           3-49

-------
the difference in the acetaldehyde levels may be an anomaly of
the limited data on acetaldehyde emissions.55
     Emission data are available for 10 NDCE recovery furnaces
with black liquor in the ESP control system  (i.e., 6 NDCE
recovery furnaces with wet-bottom ESP's and 4 NDCE recovery
furnaces with dry-bottom ESP's and wet PM return systems).55
Emission data are also available for three NDCE recovery furnaces
with dry-bottom ESP's that have dry return of the captured PM.
Figure 3-16 illustrates the differences in methanol emissions
between the two data sets.  The methanol emission data from the
ten NDCE recovery furnaces with black liquor in the ESP control
system are significantly higher than those from the three NDCE
recovery furnaces with dry-bottom ESP's and  dry PM return
systems.
     Based on the available emission test data, eliminating the
black liquor from the ESP control system reduces  total gaseous
organic HAP emissions by approximately 72 percent.55  In addition
to their lower HAP  emission potential, NDCE  recovery  furnaces
with dry-bottom ESP's and dry  PM return also have lower TRS
emissions than NDCE recovery furnaces with black  liquor in  the
ESP control system.15
     For an NDCE recovery  furnace with a  furnace  size of
700,000 kg BLS per  day  (1.5 million Ib BLS per day) and 351
operating d/yr, eliminating black  liquor  from  the ESP control
system has the potential  to reduce  average gaseous  organic  HAP
emissions by  about  22 Mg/yr  (24 ton/yr).  This emission reduction
represents the  difference  in  emissions between NDCE recovery
furnaces with black liquor in the  ESP control  system (i.e., wet-
bottom ESP's  or dry-bottom ESP's with wet PM return systems)  and
NDCE  recovery furnaces  with dry-bottom ESP's and dry PM return
 systems.  Methanol  emission reductions account for most  of the
 estimated HAP emission reduction.
 3.2.2   Conversion from a DCS Recovery Furnace System to an NDCE
        Recovery Furnace
      The conversion from a DCE recovery furnace system to an NDCE
 recovery furnace (often referred to as a "low-odor conversion")
                                3-50

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               3-51

-------
offers significant emission reduction and operational benefits.
This conversion is an effective measure for reducing HAP
emissions from a DCE recovery furnace system because it
eliminates two sources of HAP emissions, the DCE and BLO unit.
Conversion from a DCE recovery furnace system to an NDCE recovery
furnace is a common modification; an estimated 24 percent of
existing NDCE recovery furnaces were originally installed as DCE
recovery furnaces.1'61'62  These conversions have been performed
for several reasons, including compliance with Federal and State
TRS emission standards and increased energy efficiency.  Other
factors influencing the decision to convert a DCE recovery
furnace system to an NDCE design include the age of the existing
DCE recovery furnace, the condition of the system, and whether
additional capacity is needed at the mill.  The following
sections describe the major modifications involved in converting
a DCE recovery furnace system to an NDCE recovery furnace,
including operational benefits, and present the potential HAP
emission reductions.
     3.2.2.1  Description.  The major modifications involved  in
converting a DCE recovery furnace system to an NDCE recovery
furnace are  (1) replacing the DCE with a concentrator and
associated equipment,  (2) extending or  replacing the economizer,
 (3) rebuilding or replacing the ESP, and  (4) removing the BLO
unit.  Removal of the DCE is the driving force behind the latter
three major modifications.
     The DCE is replaced with a  concentrator, which can achieve
the desired black liquor solids  content without direct contact
between recovery furnace exhaust gases  and black liquor.
Eliminating  contact between the  hot exhaust gases and black
liquor is desirable because the  emissions that result  from
stripping are  also  eliminated.   Operational benefits of replacing
the DCE with a low-pressure, steam-driven concentrator  include
the higher solids content achievable,  improved energy
utilization, and  reduced energy  costs.63  The concentrator,  which
may be one of  several  types, including falling  film and  forced
 circulation, is installed as part  of  the  evaporator plant.   With
                               3-52

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current concentrator technologies, the final solids content of
the black liquor before firing is generally limited to
75 percent; however, concentrator technologies that can achieve
or exceed a solids content of 80 percent are currently in
operation.64  For existing DCE recovery furnace systems, the
average solids content of the fired black liquor is 65 percent;
for existing NDCE recovery furnaces, the average solids content
of the fired black liquor.is 68 percent.1  Increasing the solids .
content of the fired black liquor is advantageous because it
reduces the amount of energy required to evaporate residual
moisture from the black liquor solids.
     The economizer is modified to .recover additional heat from
the flue gas that has become available with removal of the DCE.
The additional•heat recovered in the economizer can be used to
produce more low-cost, high-pressure steam. ^  To produce
additional steam, the recovery furnace economizer is either
expanded with the addition of modules or replaced (i.e., with a
long-flow economizer).  The economizer is the last section of the
recovery furnace that absorbs heat from the flue gas for steam
production.  The economizer optimizes the thermal efficiency of
the recovery furnace by lowering the exit temperature of the
exhaust gas as much as possible while minimizing cold-end
corrosion.  Typical design exit temperatures for an NDCE recovery
furnace range from 176° to 190°C  (350° to 375°F).  For a DCE
recovery furnace system, an exit flue gas temperature of 370°C to
430°C  (700°F to 800°F) is required to operate the DCE.S5  The
thermal efficiency of the recovery furnace increases by 1 percent
for every 22°C (40°F) drop in exit gas temperature.  4 "Direct
contact evaporator recovery furnaces typically operate at thermal
efficiencies of 53 to 58 percent, whereas NDCE recovery furnaces
typically operate at thermal efficiencies of 63 to 68 percent."
Auxiliary equipment that is required when expanding an economizer
includes additional soot blowers, hoppers, and conveyors, which
collect and transport the additional ash from the economizer.
     The ESP is modified to handle the greater PM loading that
results from the removal of the DCE.  The DCE acts as a PM
                               3-53

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control device, collecting 20 to 40 percent of PM emissions from
the recovery furnace.7  Thus, removal of the DCE, without
upgrading the ESP, would likely result in increased PM emissions
from the recovery furnace stack.  Because of the increased PM
emissions and a possible change in gas flow rate, the ESP may
need to be either upgraded or replaced.  As discussed in
Section 3.1.1.1, the characteristics of the gas stream for NDCE
recovery furnaces contribute to reduced ESP corrosion rates in
comparison to DCE recovery furnaces.
     With the removal of the DCE, the BLO unit is no longer
needed; therefore, the emissions associated with the air-sparging
BLO units are eliminated.  The operational benefits associated
with removing an air-sparging BLO unit are the elimination of the
high costs associated with operating this unit and the increased
heating value of the black liquor.
     3.2.2.2  HAP Emission Reduction Potential.  As shown in
Table 3-7, the conversion from a DCE recovery furnace system to
an NDCE recovery furnace results in substantial reductions for
all of the gaseous organic HAP compounds.  Based on the available
emission test data, the conversion from a DCE recovery furnace
system to an NDCE recovery furnace reduces total gaseous organic
HAP emissions by approximately 93 percent.55  In addition to a
lower HAP emission potential, NDCE recovery furnaces also emit
lower TRS emissions.
     Figure 3-17 presents methanol emission data for DCE recovery
furnace systems and for NDCE recovery furnaces equipped with dry-
bottom ESP's and dry PM return systems.54  For the DCE recovery
furnace systems presented in Figure 3-17, only the methanol
emission data from mills that measured emissions from both the
DCE recovery furnace and the BLO unit were included.  There are
three cases in Figure 3-17 where more than one DCE recovery
furnace is present at a mill (M01 and M04, MP1/2 and MP3, and PBS
and PB4).  In those cases, a portion of the total BLO methanol
emissions was attributed to each recovery furnace system based on
the BLS firing rates measured for the DCE recovery furnaces
during the emission tests.   (Note:  Emissions for MP1/2 are
                               3-54

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   TABLE  3-7.   HAP EMISSIONS  FOR  DCE RECOVERY  FURNACE SYSTEMS
                         AND NDCE  RECOVERY  FURNACES55
Hazardous air
pollutant
Total organic
HAP's6
Acetaldehyde
Benzene
Formaldehyde
Methanol
Methyl ethyl
ketone
Methyl isobutyl
ketone
Phenol
Toluene
Xylenes
HC1
DCE recovery furnace system
Emission
factor, mass/mass
BLSa'b
s.isx ur4
4.47 x 1CT5
1.57 x lO"5
3.11 x icr6
3.43 x 1CT4
1.28 x 1CT5
1.39x 10"5
4. 14 x 1CT5
1.12x 10'5
2.90 x 1(T5
1.20 x 10-4
Mass rate,
kg/yr (lb/yr)c
123,000
(271,000)
10,700
(23,500)
3,750
(8,270)
742
(1,640)
81,900
(181,000)
3,050
(6,720)
3,310
(7,300)
9,890
(21,800)
2,670
(5,880)
6,920
(15,300)
28,700
(63,200)
NDCE recovery furnace
Emission factor,
mass/mass
BLSb,d
3.67 x 10'5
1.52 x 10'5
1.73 x 10"6
1.93 x ID"6
4.93 x 10'6
1.80 x W6
2.27 x lO"6
2.05 x 10"6
2.03 x ID"6
4.76 x 10"6
1.20 x HT6
Mass rate,
kg/yr
(lb/yr)c
8,760
(19,300)
3,630
(8,000)
413
(911)
461
(1,020)
1,180
(2,600)
430
(948)
542
(1,200)
490
(1,080)
485
(1,070)
1,140
(2,510)
28,700
(63,200)
Percent
reduction
93
66
89
38
99
86
84
95
82
84
—
aEmission factors for gaseous organic HAP's are based on the sum of the average emission factors for
 DCE recovery furnaces and BLO units.
 Emission, factor for HC1 is based on the average emission factor for all recovery furnaces since no
 overall change in HC5 emissions is expected from converting a DCE recovery furnace system to an
 NDCE recovery furnace.
GMass rates are based on a furnace size of 700,000 kg BLS/d (1.5 million Ib BLS/d) and 351  operating
 d/yr.
 Emission factors for gaseous organic HAP's are based on the average emission factors for NDCE
 recovery furnaces equipped with dry-bottom ESP's and dry PM return systems.
^Total organic HAP's include all gaseous HAP's in this table except HC1. Numbers may not add exactly
 due to rounding.
                                          3-55

-------
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                 3-56

-------
actually the combined emissions for DCE recovery furnaces MP1 and
MP2, which have a combined stack.)
 :    As shown in Figures 3-18 and 3-19, DCE recovery furnace
systems have more gaseous organic HAP emission points than NDCE
recovery furnaces (HAP emission points are shaded in the
figures).  In the DCE system, gaseous organic HAP's such as
methanol can be stripped off in the DCE and wet-bottom ESP by
contact between the hot flue gases and the black liquor.  The BLO
vents are also an emission source for methanol and other gaseous
organic HAP's because gaseous organic HAP's can be stripped from
the black liquor and vented as the oxidizing air is forced up
through the black liquor.  As described in Section 3.3.1., the
wet-bottom ESP (commonly associated with DCE recovery furnaces)
can be converted to a dry-bottom ESP with a dry PM return system,
thereby eliminating the ESP system as a source of methanol
emissions.
     For a DCE recovery furnace system with a furnace size of
700,000 kg BLS per day (1.5 million Ib BLS per day)  and 351
operating d/yr, converting the furnace system to an NDCE design
has the potential to reduce average gaseous organic HAP emissions
by about 114 Mg/yr (126 ton/yr).  This emission reduction
represents the difference in emissions between DCE recovery
furnace systems (including the BLO unit) and NDCE recovery
furnaces  (with dry-bottom ESP's and dry PM return systems).
Methanol emissions reductions account for most of the estimated
gaseous organic HAP emission reduction.
                               3-57

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3-58

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3-59

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3.3  REFERENCES FOR CHAPTER 3
 1.  Memorandum from Soltis, V., Nicholson, R.,  and Holloway, T.,
     MRI, to Telander, J., EPA/MICG.  July 29, 1994.  Summary of
     Responses to the NCASI "MACT" Survey--Kraft and Soda Pulp
     Mills.

 2.  APTI Course SI:412B:  Electrostatic Precipitator Plan
     Review, Self Instructional Guidebook.  U. S. Environmental
     Protection Agency.  Research Triangle Park, NC.  Publication
     No. EPA-450/2-82-019.  July 1983.

 3.  Environmental Pollution Control:  Pulp and Paper Industry,
     Part I, Air.  U. S. Environmental Protection Agency.
     Cincinnati, OH.  Publication No. EPA-625/7-76-001.  October
     1976.

 4.  Memorandum from Nicholson, R.,,MRI, to Telander, J.,
     EPA/ISB.  May 28, 1993.  Meeting minutes from the March 30,
     1993 meeting between Environmental Elements Corp. and
     Midwest Research Institute.

 5.  Telecon.  Bullock, K., MRI, with Bringman, L., Environmental
     Elements Corp.  December 16, 1993.  Rigid-electrode ESP's.

 6.  Memorandum from Nicholson, R., MRI, to Telander, J.,
     EPA/MICG.  June 15, 1995.  Meeting minutes from the April
     12, 1993 meeting between Research-Cottrell and Midwest
     Research Institute.

 7.  Review of New Source Performance Standards for Kraft Pulp
     Mills.  U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.  Publication No. EPA-450/3-83-017.
     September 1983.

 8.  Mcllvane, R.  Removal  of Heavy Metals and Other Utility Air
     Toxics.   (Presented at the EPRI Hazardous Air Pollutant
     Conference.  1993.)

 9.  Someshwar, A.  Compilation of  "Air Toxic" Emission  Data for
     Boilers, Pulp Mills, and Bleach Plants.  National Council  of
     the Paper Industry for Air and Stream Improvement,  Inc.  New
     York.  Technical Bulletin No.  650.  June 1993.  128 p.

10.  U.  S. Environmental  Protection Agency.   New Source
     Performance Standards  for Kraft Pulp  Mills.  43 FR  7568.
     Washington, DC.  U.S.  Government Printing Office.
     February 23, 1978.
                               3-60

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11.  U. S. Environmental Protection Agency.  New Source
     Performance Standards for Kraft Pulp Mills.  51 FR 18538.
     Washington, DC.  U.S. Government Printing Office.  May 20,
     1986.

12.  Memorandum from Nicholson, R., MRI, to Telander, J.,
     EPA/MICG.  June 13, 1996.  Addendum to Summary of Responses
     to the 1992 NCASI MACT Survey.

13.  Memorandum from Holloway, T., MRI, to the project file.
     July 16, 1996.. State of Washington PM Data for Kraft
     Recovery Furnaces, Smelt Dissolving Tanks, and Lime Kilns.

14.  Proposed Standards of Performance for Kraft Pulp Mills.  In:
     Standards Support and Environmental Impact Statement.
     Volume 1.  U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.  Publication No. EPA-450/2-76-014a.
     September 1976.  pp. 4-2 through 4-10.

15.  Memorandum from Soltis, V., MRI, to the project file.
     April 3, 1995.  Kraft and Soda.Pulp Mill Combustion Sources
     Data Base.

16.  Telecon.  Wallace, D., MRI, with Prouty, A., James River
     Corp., Camas, WA.  March 24, 1994.  Performance of the James
     River recovery furnace ESP's.

17.  Operation and Maintenance Manual for Electrostatic
     Precipitators.  U. S. Environmental Protection Agency.
   •  Research Triangle Park, NC.  Publication No.
     EPA-625/1-85-017.  September 1985.

18.  Reference 4,  Attachment 9: Sludge lime kiln air pollution
     control equipment.

19.  Someshwar,  A.  A Study of Kraft Recovery Furnace
     Hydrochloric Acid Emissions.  National Council of the Paper
     Industry for Air and Stream Improvement, Inc.  New York.
     Technical Bulletin No. 674.  August 1994.  100 p.

20.  Somesiiwar,  A. and A. Jain.  Emissions of Hydrochloric Acid
     from Kraft Recovery Furnaces.  National Council of the Paper
     Industry for Air and Stream Improvement, Inc.   (Presented at
     the 1992 TAPPI International Chemical Recovery Conference.
     Seattle, WA.   June 18, 1992.)  14 p.

21.  Fact Sheet for Prevention of Significant Deterioration and
     Notice of Construction:  James River Camas Mill Energy and
     Recovery Modernization.  Washington Department of Ecology.
     February 9, 1989.
                               3-61

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 22.




 23.



 24.



 25.




 26.



 27.

• 28.

 29.




 30.

 31.



 32.

 33.



 34.
Telecon.  Soltis, V., MRI, with Bruno, J.,  Airpol Inc.
October 29, 1993.  Information of scrubbers used to control
HC1 emissions from recovery furnaces at pulp and paper
mills.

Telecon.  Soltis, V., MRI, with Bruno, J.,  AirPol, Inc.
July 2, 1993.  Information about scrubbers used to control
HC1 emissions.

Calvert, S. and'H. Englund  (eds.).  Handbook of Air
Pollution Technology.  New York, John Wiley & Sons, Inc.
1984.  p. 137.

OAQPS Control Cost Manual.  4th Edition.  U. S.
Environmental Protection Agency.  Research Triangle Park,
NC.  Publication No. EPA-450/3-90-006.  January 1990.
p. 9-9.
Anderson 2000
Incinerators.
February 1989
Inc.  Emission Control Systems for
Bulletin TR 89-900239.  Peachtree City,  GA.
Reference 24, p. 136.

Reference 24, pp.  147-149.

Buonicore, A.  Absorption.   In: Air Pollution Engineering
Manual, Air and Waste Management Association.  Buonicore, A.
and W. Davis  (eds.).  New York, Van Norstrand Reinhold.
1992.  pp. 23-24.

Reference 25, pp.  9-28,  9-60,  and  9-61.

Memorandum from Randall, D.  and Holloway, T., MRI,  to  the
project file.  October  4, 1994.  Absorber Design and Cost
Algorithm.

Reference 25, p. 9-45.

Memorandum from Randall, D.,  MRI,  to  the project file.
November 8,  1994.   Comparison of EPA  and NCASI HC1  Emission
Factors for  Recovery Furnaces.

Letter and attachments  from Sanders,  D., Andersen 2000,
Inc.,  to Soltis, V.,  MRI.   November 9,  1993.  Preliminary
proposal for three separate quench and packed-tower
absorption systems to control hydrochloric  acid gas
emissions from recovery furnaces at kraft pulp and  paper
mills.
                                3-62

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35.'  Telecon. *Soltis, V., MRI, with Bruno, J.,  AirPol, Inc.
     October 29, 1993.  Information about scrubbers used to
     control HC1 emissions from recovery furnaces at pulp and
     paper mills.

36.  Memorandum from Holloway, T.,  MRI, to the project file.
     July 2, 1993.  Data to Support HC1 Control Technology
     Transfer from MWI's to Kraft Recovery Furnaces.

37.  Handbook:  Permit Writer's Guide to Test Burn Data:
     Hazardous Waste Incineration.   U. S. Environmental
     Protection Agency.  Cincinnati, OH.  Publication No.
     EPA-625/6-86-012.  September 1986.

38.  Trenholm, A., P. Gorman, and G. Junglcaus.   Incinerator
     Performance Evaluation Results.  In:  Performance Evaluation
     of Full-Scale Hazardous Waste Incinerators, Volume II. U. S.
     Environmental Protection Agency.  Cincinnati, OH.
     Publication No. EPA-600/2-84-181b.  November 1984.

39.  APTI Course ST:412C:  Wet Scrubber Plan Review, Self
     Instructional Guidebook.  U. S. Environmental Protection
     Agency.  Research Triangle Park, NC.  Publication No.
     EPA-450/2-82-020.  March 1984.

40.  Kraft Pulp Mill Inspection Guide.  U. S. Environmental
     Protection Agency.  Research Triangle Park, NC.  Publication
     No. EPA-340/1-83-017.  January 1983.

41.  Roy F. Weston, Inc.  Emissions Testing of Combustion
     Processes in a Pulp and Paper Facility:  Champion
     International.Corp., Roanoke Rapids, North Carolina.
     Prepared for U. S. Environmental Protection Agency--Emission
     Measurement Branch.  Research Triangle Park, NC.  EMB Report
     No. 92-KPM-27.  October 1992.   Volume I.

42.  Someshwar, A. and J. Pinkerton.  Wood Processing Industry,
     In: Air Pollution Engineering Manual, Air and Waste-
     Management Association.  Buonicore, A. and W. Davis  (eds.).
     New York, Van Norstrand Reinhold.  1992.  p. 840.

43.  Modetz, H. and M. Murtiff.  Kraft Pulp Mill Industry
     Particulate Emissions: Source Category Report.  U. S.
     Environmental Protection Agency.  Research Triangle Park,
     NC.  Publication No. EPA-600/7-87-006.  February 1987.

44.  Letter and attachments from Black, C., Champion
     International Corp., Courtland, AL, to Crowder, J., EPA/ISB.
     June 10, 1993.  Response to request for information on costs
     for the BLO vent gas control system at the Champion facility
     'in Courtland, AL.
                               3-63

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45.  Memorandum from Soltis, V. and March, D., MRI, to Telander,
     J. ,  EPA/ISB.  May 17, 1993.  Trip Report for Champion
     International Corp., Courtland, AL.

46.  Telecon.  Nicholson, R., MRI, with Porritt, T.,  S.D. Warren
     Co.   May 27, 1993.  The black liquor oxidation air pollution
     control system in use at S.D. Warren.

47.  Memorandum from Nicholson, R. and Holloway, T.,  MRI, to
     Telander, J., EPA/MICG.  September 6, 1995.  Trip Report for
     S.D. Warren Co., Muskegon, MI.

48.  Pulp, Paper, and Paperboard Industry--Background Information
     for Proposed Air Emission Standards, Manufacturing Processes
     at Kraft, Sulfite, Soda, and Semi-Chemical Mills.  U. S.
     Environmental Protection Agency.  Research Triangle Park,
     NC.   Publication No. EPA-453/R-93-050a.  October 1993.

49.  Collection and Burning of Kraft Non-Condensible Gases--
     Current Practices, Operating Experience, and Important
     Aspects of Design and Operation.  National Council of the
     Paper Industry for Air and Stream Improvement.  New York.
     Technical Bulletin No. 469.  August 29, 1985.  p. 40.

50.  An Investigation of Corrosion in Particulate Control
     Equipment.  U. S. Environmental Protection Agency.
     Washington, DC.  Publication No. EPA-340/1-81-002.
     February 1981.  p. 38.

51.  Reference 50, p. 51.

52.  Hazardous Air Pollutant Emissions from Process Units in the
     Synthetic Organic Chemical Manufacturing Industry--
     Background Information for Proposed Standard.  Volume IB,
     Control Technologies.  U. S. Environmental Protection
     Agency.  Research Triangle Park, NC.  Publication
     No.  EPA-453/D-92-0166.  November 1992.  pp. 2-8 and 2-9.

53.  Memorandum from Farmer, Jack R., EPA/CPB, to Ajax, B. ,
     et al., EPA/CPB.  August 22, 1980.  Thermal Incinerators and
     Flares.

54.  Reference 52, p. 2-18.

55.  Memorandum from Randall, D., Jones, R., and Nicholson, R.,
     MRI, to Telander, J., EPA/MICG.  April 25, 1995.  Nationwide
     Baseline Emissions for Combustion Sources at Kraft and Soda
     Pulp Mills.
                               3-64

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56.  Final Environmental Impact Statement:  Kraft Pulp Mills--
     Background Information for Promulgated Revisions to
     Standards.  U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.  Publication No. EPA-450/3-85-020.   May
     1986.

57.  Memorandum from Eddinger, J., EPA/ISB, to Durkee, K.,
     EPA/ISB.  July 8, 1983.  Meeting minutes from the April 14,
     1983 meeting between kraft pulp mill representatives,  the
     National Council of the Paper Industry for Air and Stream
     Improvement, Inc., and the U. S. Environmental Protection
     Agency.  Discussion of problems mills have with TRS pickup
     in wet-bottom ESP's using unoxidized black liquor.
     Attachments.

58.  Letter from Bringman, L., Environmental Elements Corp., to
     Nicholson, R., MRI.  October 12, 1993.  Budgetary pricing to
     convert from wet- to dry-bottom ESP.

59.  RUST Environment & Infrastructure.  MACT Cost Analysis
     Report for NCASI.  Prepared for the National Council of the
     Paper Industry for Air and Stream Improvement, Inc.  RUST
     Contract No. 35-4735.  October 15, 1993.  47 p.

60.  Telecon.  Nicholson, R., MRI, with Bringman, L.,
     Environmental Elements Corp.  November 30, 1994.
     Information about the particulate return systems associated
     with kraft recovery furnace ESP's.

61.  Memorandum from Soltis, V., MRI to Telander, J., EPA/ISB.
     July 14, 1992.  Meeting minutes from the February 24,  1992
     meeting between Gotaverken Energy Systems, Inc., the U. S.
     Environmental Protection Agency, and Midwest Research
     Institute.

62.  Memorandum from Ramsey M. and Nicholson, R., MRI, to
     Telander, J., EPA/ISB.  November 3, 1992.  Meeting minutes
     from the June 24, 1992 meeting between the Babcock & Wilcox
     Co., the U. S. Environmental Protection Agency, and Midwest
     Research Institute.

63.  Barsin, J., The Babcock and Wilcox Co., Barberton, OH; R.
     Johnson, James River Corp., Camas, WA; and C. Rissler, James
     River Corp., St. Francisville, LA.  The St. Francisville
     Recovery Low Odor Conversion and Capacity Upgrade.
     (Presented at the International Chemical Recovery
     Conference.  Ottawa, Ontario, Canada.  April 3-6, 1989.)
     The Babcock and Wilcox Co.  Technical paper BR-1372.  11 p.

64.  Green R. and G. Hough  (eds.).  Chemical Recovery in the
     Alkaline Pulping Process^,,  3rd Edition.  Prepared by the
     Alkaline Pulping Committee of the Pulp Manufacture Division.
     Atlanta, GA, TAPPI Press.  1992.  196 p.
                               3-65

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65.  Garner,  J.,  Jaako Poyry.  Conversion to Low Odor Improves
     Recovery Boiler Efficiency and Life.  Pulp and Paper.
     63(7):91-95.  July 1989.
                              3-66

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     4.0  MODEL PROCESS UNITS, CONTROL OPTIONS, AND ENHANCED
                        MONITORING OPTIONS

     This chapter defines model process units, identifies HAP
emission control options, and discusses enhanced monitoring
options for combustion sources in the chemical recovery area at
kraft pulp and paper mills.  Model process units represent the
types of units that currently exist in the industry and the types
that may be constructed in the future.  The control options
represent demonstrated emission control techniques, and the
enhanced monitoring options are methods of demonstrating
continuous compliance for a particular control option.  The use
of model process units to characterize an industry allows the EPA
to evaluate the environmental and energy impacts and costs of
various control options for each combustion source.  These
impacts and costs are presented in Chapters 5 and 6,
respectively.
4.1  MODEL PROCESS UNITS
     This section presents the model process units that were
developed for recovery furnaces, SDT's, BLO units, and lime
kilns.  The following parameters were evaluated to develop the
process units:  process-specific characteristics, level of PM
emission control, stack gas characteristics, and HAP emission
levels.  The model process unit parameters are typical for
equipment that currently exists or may be constructed in the
kraft pulp industry.
4.1.1  Recovery Furnace Models
     The nine model process units that were developed to
characterize kraft recovery furnaces are presented in Table 4-1.
Two PM emission levels were developed for each of the nine models
                               4-1

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(RF-la and RF-lb, RF-2a and RF-2b, etc.).  Model designations
ending in "a" represent pre-new source performance standards
(NSPS) furnaces with PM emissions above the NSPS PM limit
promulgated in 1978; designations ending in "b" represent
furnaces with PM emissions at or below the NSPS.  Recovery
furnaces have been characterized based on the following
parameters:   (1) type of final-stage black liquor evaporator
(i.e., DCE or NDCE);  (2) size  (i.e., BLS firing rate and pulp
production rate);  (3) type of PM emission control device;
(4) stack gas characteristics  (i.e., flow rate, temperature, and
moisture content); and  (5) HAP emission levels  (i.e., HC1,
methanol as a surrogate for gaseous organic HAP's, and PM as a
surrogate for PM HAP's).  Each of these parameters is discussed
below.
     4.1.1.1  Evaporator Type.  The recovery furnace models were
characterized based on whether a DCE or an NDCE  (i.e.,
concentrator) is used in the final stage of black liquor
evaporation.  Models RF-l through RF-6 represent NDCE recovery-
furnaces, and models RF-7 through RF-9 represent DCE recovery
furnaces.  Separate models were developed for these two types of
evaporators because the type of evaporator affects methanol
emissions.  As discussed in Chapter 2, higher methanol emissions
are associated with DCE recovery furnace systems because methanol
can be stripped  from the black liquor in the DCE and in the BLO
unit, which is only used with the DCE systems.  Approximately
61 percent of existing  recovery furnaces are NDCE recovery
furnaces, and the  remaining 39 percent are DCE  recovery furnace
systems.1  Based on the current trend in the industry, all new
recovery furnace installations are expected to  be of the NDCE
design.
      4.1.1.2  Recovery  Furnace Size.  Model recovery furnaces
were  characterized by size, based on the BLS firing rate and
equivalent unbleached and bleached pulp production rates.  The
BLS firing rates are  expressed in terms  of kg BLS/d  (Ib BLS/d).
Equivalent unbleached pulp production rates are expressed in
terms of air-dried megagrams of unbleached pulp per day  (ADMUP/d)
                               4-4

-------
 (air-dried tons of unbleached pulp per day  [ADTUP/d]).  Similar
units  (air-dried megagrams  of bleached pulp per day  [ADMBP/d] and
air-dried tons of bleached  pulp per day  [ADTBP/d]) are used  to
express the equivalent bleached pulp production rates.  The
equivalent pulp production  rates are based on the BLS firing
rates and conversion  factors of 1,500 kg BLS/ADMUP  (3,000 Ib
BLS/ADTUP) and 1,800  kg BLS/ADMBP  (3,600 Ib BLS/ADTBP).2'3
     The models include three sizes of NDCE recovery furnaces and
three.sizes of DCE recovery furnaces.  For the NDCE recovery
furnace models, the BLS firing rates are 0.7 million  (MM),
1.2 MM, and 1.8 MM kg BLS/d (1.5 MM, 2.7 MM, and 3.9 MM Ib
BLS/d).  Equivalent unbleached pulp production rates are 450,
820, and 1,200 ADMUP/d  (500, 900, and 1,300 ADTUP/d).  Equivalent
bleached pulp production rates are 380, 680, and 1,000 ADMBP/d
 (420, 750, and 1,100  ADTBP/d).  For the DCE recovery furnace
models, the BLS firing rates are 0.4 MM, 0.7 MM, and 1.2 MM  kg
BLS/d  (0.-9 MM, 1.5 MM, and  2.7 MM Ib BLS/d).  Equivalent
unbleached pulp production  rates are 270, 450, and 820 ADMUP/d
 (300, 500, and 900 ADTUP/d).  Equivalent bleached pulp production
rates are 230, 380, and 680 ADMBP/d (250, 420, and 750 ADTBP/d).
     The distributions of BLS firing rates for DCE and NDCE
recovery furnaces are shown in Figures 4-la and 4-lb,
respectively.  The sample populations of DCE and NDCE recovery
furnaces were divided into small, medium, and large model sizes.
The median BLS firing rate within each size range was then
selected as the production rate for the model.  Figure 4-2a  and
4-2b show the BLS firing rate ranges for DCE and NDCE recovery
furnaces,  respectively, for the small, medium, and large size
categories and the corresponding medians for each size.
     As shown in Figures 4-1 through 4-2, DCE recovery furnaces
tend to be smaller than NDCE recovery furnaces.   The difference
in recovery furnace size reflects the fact that in recent years
(i.e., since 1980), mills have installed larger recovery
furnaces,  and the majority of these mills selected the newer NDCE
recovery furnace technology.1'4  Consequently, the six model
recovery furnace sizes reflect the size variation between the DCE
                               4-5

-------
                    ,<=2 ' >2, <=3   >3, <=4  >4, <=5
                     Range of sizes, million Ib BLS/d
                                                   >5
Figure 4-la.   Size distribution  for DCE recovery  furnaces.
   50
           >0.4, <=1  >1.<=2 . >2, <=3  >3, <=4   >4, <=5    >5
                      Range of sizes, million Ib BLS/d
Figure 4-lb.   Size distribution  for NDCE  recovery  furnaces

                               4-6

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I Maximum size
  Figure  4-2a.   DCE  recovery  furnace model size ranges
                Small NDCE       Medium NDCE       Large NDCE

                     NDCE recovery furnace model size
                  I  j Minimum size JHH Median size
Maximum size
 Figure  4-2b.   NDCE recovery  furnace model size ranges.


                                4-7

-------
and NDCE recovery furnaces.  The 0.7 and 1.2 MM kg BLS/d (1.5 and
2.7 MM Ib BLS/d BLS firing rates for the medium (RF-8) and large
(RF-9) model DCE recovery furnaces correspond to the small (RF-1
and RF-4) and medium  (RF-2 and RF-5) model NDCE recovery-
furnaces, respectively.  A separate small DCE recovery furnace
model  (RF-7) with a BLS firing rate of 0.4 MM kg BLS/d (0.9 MM Ib
BLS/d) and large NDCE recovery furnace models  (RF-3 and RF-6)
with a BLS firing rate of 1.8 MM kg BLS/d  (3.9 MM Ib BLS/d) were
also selected to characterize the existing population of kraft
recovery furnaces.
     4.1.1.3  PM Emission Control Device.  The PM emission
control device for all of the model, recovery furnaces is an ESP.
Electrostatic precipitators are the most prevalent PM emission
control device for recovery furnaces, installed on about
99 percent of recovery furnaces.1  The model recovery furnaces
are further characterized by the type of ESP system  (i.e., with
or without black liquor or HAP-contaminated process water  in  the
ESP bottom or PM return system).  The DCE  recovery furnace
systems are represented by models RF-7 through RF-9; NDCE
recovery furnaces with dry ESP  systems  (i.e.,  dry-bottom ESP's
with  dry PM return systems) are represented by models RF-1
through RF-3; NDCE recovery furnaces with  wet  ESP systems  (i.e.,
wet-bottom ESP's or  dry-bottom  ESP's with  wet  PM return systems)
are represented by models RF-4  through RF-6.   Nondirect contact
evaporator recovery  furnaces equipped with wet ESP systems emit
higher quantities of gaseous organic HAP's than those equipped
with  dry ESP systems,  due  to stripping of  HAP's from the black
liquor or HAP-contaminated water  in the  ESP bottom or PM  return
system.  However, new ESP's tend  to have dry  ESP  systems.5  For
NDCE  recovery  furnaces, models  were developed for both  types of
ESP systems.   All of the DCE recovery  furnace models have  wet ESP
systems  because  94 percent of DCE recovery furnaces  are equipped
with  wet-bottom ESP's,  and information is not available to
determine  if  the remaining 6 percent  that are equipped  with  dry-
bottom ESP's  also have dry PM  return  systems.
                                4-8

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     4.1.1.4  Stack Gas Characteristics.  Model recovery furnaces
were characterized by stack gas characteristics (i.e., flow rate
at the ESP exit, temperature, and moisture content).  The gas
flow rates were calculated from the BLS feed rates using
conversion factors of 13.9 MJ/kg BLS  (6,000 Btu/lb BLS) and
0.242 dscm at 0 percent C>2/MJ  (9,000 dscf at 0 percent
O2/106 Btu),3'6
     The exhaust gas temperatures.used for-the model recovery
furnaces are based on ESP inlet gas temperatures from emissions
      p
tests.   Inlet.temperature is an acceptable estimator for outlet
temperature because the temperature does not vary significantly
across an ESP.  For model NDCE recovery furnaces,  the stack gas
temperature is 199°C  (390°F).  For model DCE recovery furnaces,
the stack gas temperature is 160°C  (320°F).
     Stack gas moisture contents for the recovery furnace models
are averages of measurements taken during emission tests of two
NDCE recovery furnaces and two DCE recovery furnaces.   The
average stack gas moisture content based on the two NDCE recovery
furnace emission tests is 26 percent.  The average stack gas
moisture content based on the two DCE recovery furnace emission
tests is 32 percent.
     4.1.1.5  HAP Emissions.  Model recovery furnaces were
characterized by the levels of HC1, methanol, which is a
surrogate for gaseous organic HAP's, and PM, which is a surrogate
for PM Hiy?'s.  The HC1 emission levels for the model recovery
furnaces are based on the HC1 emission factor of 1.20 x 10"4 kg
of HCl/kg of BLS fired (1.20 x 10~4 Ib of HCl/lb of BLS fired)
presented in Chapter 2.  As discussed in Chapter 2, HC1 emissions
from recovery furnace systems are highly variable, and
insufficient data exist to determine the process operating
parameters that significantly influence emissions.  In addition,
the available data on HC1 emissions from NDCE and DCE recovery
furnaces show a significant overlap.  Therefore, the same
emission factor is applied for both NDCE and DCE model recovery
furnaces.
                               4-9

-------
     The methanol emission levels for model recovery furnaces are
also based on emission factors presented in Chapter 2.  Methanol
emissions for the model DCE recovery furnaces are based on an
emission factor of 1.70 x 10'4 kg methanol/kg BLS (1.70 x 10'4 Ib
methanol/lb BLS).  For model NDCE recovery furnaces with wet ESP
systems, methanol emission levels are based on an emission factor
of 5.04 x 10"5 kg methanol/kg BLS  (5.04 x 10"5 Ib methanol/lb
BLS).  For model NDCE recovery furnaces with dry ESP systems,
methanol emission levels are based on an emission factor of
4.93 x 10"6 kg.methanol/kg BLS  (4.93 x 10'6 Ib methanol/lb BLS).
Separate methanol emission levels were developed because DCE
recovery furnaces have higher methanol emissions than NDCE
recovery furnaces due to the stripping of methanol from the black
liquor.  Also, methanol emissions are higher from NDCE recovery
furnaces with wet ESP systems -than from NDCE recovery furnaces
with dry ESP systems, due to the same stripping effects.
     The NSPS for kraft pulp mills establishes a PM emission
limit of 0.1 g/dscm  (0.044 gr/dscf) at 8 percent O2 that is
applicable to recovery furnaces constructed, modified, or
reconstructed after  September 24,  1976.8'9  Available data
indicate only the year, not the month, that recovery  furnaces
were installed.1'2   Consequently,  this analysis assumes that
those recovery  furnaces installed  during or after 1977 are
subject to the  NSPS, and those  recovery furnaces installed before
1977 are not subject to the NSPS.  Also, recovery furnaces
subject to the  NSPS  are assumed to be in compliance with the NSPS
PM standard.
     The  "a" model recovery furnaces shown in Table 4-1
characterize those recovery furnaces with PM emissions above the
NSPS PM emission  limit.  Therefore, the  "a" model PM  emission
levels  were based on the PM emission concentrations for those
recovery  furnaces that are not  subject to the NSPS and that  emit
more than the NSPS PM limit.  Different  PM levels were calculated
for the DCE and NDCE recovery furnaces that are  subject to  these
parameters.  For  NDCE recovery  furnaces, the PM  emission  level  is
                               4-10

-------
 0.27 g/dscm  (0-. 12  gr/dscf) .   For DCE  recovery  furnaces,  the  PM
 emission level  is  0.18 g/dscm (0.08 gr/dscf).10
     The "b" model recovery  furnaces  represent those  recovery
 furnaces with PM emissions at or below the NSPS  PM  limit of
 0.10 g/dscm  (0.044 gr/dscf).   The  "b" model recovery  furnace PM
 emission level  is  equivalent  to the NSPS limit and  represents  the
 maximum emission level for these recovery furnaces.   Although
 only 30 percent of the recovery furnaces are subject  to  the  NSPS,
 the majority  (approximately  80 percent) of all recovery  furnaces
 reportedly are meeting the NSPS PM emission level.1'2 Therefore,
 the "b" models  represent the  majority of existing recovery
 furnaces.
 4.1.2  Smelt Dissolving Tank  Models
     The seven model' process  units  (SDT-1 through SDT-7)  that
 were developed  to  characterize existing SDT's  are presented  in
 Table 4-2.  Model  process units SDT-1 through  SDT-4 are  also
 representative  of  those SDT's  that are expected  to be constructed
 in the future.  The parameters selected to characterize  typical
 SDT's are (l) size (i.e., BLS,firing rate of the associated
 recovery furnace,  equivalent pulp production rate, and smelt
 flow rate),   (2)  PM emission control device, (3)  inlet and outlet
 gas stream characteristics (i.e., flow rate, temperature  and
moisture content), and (4)  HAP emission levels (i.e., PM as  a
 surrogate for PMHAP's).
     4.1.2.1  SDT  Size.  The SDT size is indicated by the BLS
 firing rate and equivalent pulp production rate  of the associated
recovery furnace and the smelt flow rate.  The smelt  flow rate
was calculated based on a conversion factor of 0.37 kg
smelt/kg BLS (0.37 Ib smelt/lb BLS).2  An equivalent  BLS  firing
rate was used as an indicator of SDT size because the SDT is an
integral part of the kraft recovery furnace.  The SDT models
represent the majority of recovery furnace configurations, i.e.,
one SDT per recovery furnace.  Approximately 8 percent of
recovery furnaces have two SDT's.1  The SDT models SDT-1  and
SDT-5  correspond to the small DCE recovery furnace model  (RF-7);
SDT models  SDT-2 and SDT-6  correspond to the medium DCE and  small
                               4-11

-------
4-12

-------
NDCE recovery furnace models  (RF-1, RF-4, and RF-8); SDT models
SDT-3 and SDT-7 correspond to the large DCE and medium NDCE
recovery furnace models  (RF-2,rRF-5; and RF-9); SDT model SDT-4
corresponds to the large NDCE recovery furnace models (RF-3 and
RF-6) .
     4.1.2.2  PM Emission Control Device.  Two types of emission
control devices are predominantly used to control PM emissions
from SDT's--wet scrubbers and mist eliminators.  Wet scrubbers
are used to control PM emissions from about 87 percent of the
SDT's, and mist eliminators are used to control PM emissions from
about 10 percent of the SDT's.11  The type of PM emission control
device will impact PM emission levels because wet scrubbers are
generally more effective than mist eliminators at controlling PM
emissions.  The PM emission control device f or *SDT models SDT-l
through SDT-4 is a wet scrubber.  These SDT models correspond to
all four recovery furnace model sizes and include sizes for both
DCE and NDCE recovery furnaces.  The PM emission control device
for SDT models SDT-5 through SDT-7 is a mist eliminator.  These
SDT models correspond to the three DCE recovery furnace model
sizes and the small and medium NDCE recovery furnace model sizes.
An SDT model with a mist eliminator that corresponds to the large
NDCE recovery furnace model size was not included because less
than 1 percent of recovery furnaces have this configuration.
     4.1.2.3  Inlet and Outlet Gas Stream Characteristics.  The
model SDT stack gas flow rates represent typical gas flow rates
within each size range.  Available recovery furnace BLS firing
rates and corresponding SDT gas flow rates were used to develop a
factor of 1.04 x 10"5 m3/sec/kg BLS/d (0.01 acfm/lb BLS/d).2  The
model gas flow rates calculated with this factor were then
compared to, and found to be consistent with, the gas flow rates
at actual mills with comparable BLS firing rates.
     The model stack temperature of 77°C (170°F) is based on
process information reported by mills and on measurements during
emission tests.1'12'1   The process information shows stack
temperatures range from 49° to 100°C (120° to 212°F).  The
                               4-13

-------
emission test reports listed stack temperatures of 82°C (180°F)
and 76°C (168°F).
     The stack gas moisture content for model SDT's is
36 percent, which is the average moisture content from four
emission tests.7  The average moisture contents of the stack
gases for the four SDT's that were tested are 35.5 percent,
46.7 percent, 25.4 percent, and 38.5 percent.7
     The inlet gas flow rates were calculated from the stack gas
flow rates and estimated inlet temperature and moisture content.
The model inlet temperature of 93°C  (200°F) was estimated based
                                                              *p
on available process information reported by individual mills.
     4.1.2.4  HAP Emissions.  Particulate matter emissions, as a
surrogate for PM HAP emissions, are characterized by the model
SDT's.  The models characterize SDT's with PM emissions above the
NSPS PM emission limit for SDT's, i.e., 0.10 kg/Mg  (0.20 Ib/ton)
BLS.  Therefore, the model PM emission levels were based on the
PM levels for those SDT's that are not subject to the NSPS and
that emit more than the NSPS PM limit.  The PM levels do not
represent the PM emission performance of typical SDT's because
approximately 75 percent of existing SDT's emit, on average, less
than the NSPS.2  The model SDT PM emission levels were selected
so that the  emission reduction potential and control costs for
those SDT's  with PM emission levels higher than the NSPS could be
evaluated.
     Scrubbers are generally more effective at removing PM than
mist eliminators; therefore, different PM levels were calculated
for SDT's with wet scrubbers and SDT's with mist eliminators.
Average PM emissions are 0.18 kg/Mg  (0.37 Ib/ton) BLS if a wet
scrubber is  the  PM emission control  device, and 0.23 kg/Mg
 (0.46 Ib/ton) BLS if a mist eliminator is the  PM emission  control
device.
4.1.3  Black Liquor Oxidation Unit Models
     The three model process units that were developed to
characterize existing BLO  units are  presented  in Table 4-3.  With
the possible exception of  the estimated one kraft pulp mill that
operates DCE recovery furnaces but does not have a  BLO unit, no
                               4-14

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new BLO units are expected to be built.11  The parameters
selected to characterize typical BLO units are (1) equipment
type, (2) size  (i.e., equivalent BLS firing rate and pulp
production rate),  (3) air pollution control device, (4) vent
characteristics  (i.e., flow rate and moisture content), and
(5) HAP emission levels  (i.e., methanol).
     4.1.3.1  Equipment Type.  Two types of BLO units are used at
kraft pulp mills--air-sparging units and molecular 02 systems.
Models were developed only for air-sparging units, which account
for an estimated 94 percent of the BLO units.1'11  The BLO models
were selected to characterize the majority of BLO systems;
therefore, BLO models were not developed for molecular 02
systems.  Also, molecular 02 BLO systems are essentially closed
systems that do-not emit HAP's.
     4.1.3.2  BLO Size.  Three model sizes for BLO systems were
selected to correspond to the DCE recovery furnace model sizes.
Therefore, the BLS firing rates and pulp production rates for the
DCE recovery furnace models were selected as the parameters that
reflect the size of the BLO unit.  The equivalent BLS firing
rates for models BLO-1, BLO-2, and BLO-3 are 0.4 MM, 0.7 MM, and
1.2 MM kg BLS/d  (0.9 MM, 1.5 MM, and 2.7 MM lb BLS/d),
respectively.
     4.1.3.3  Air Pollution Control Device.  Air emissions from
approximately 95-percent of air-sparging BLO systems are
uncontrolled.11  Those few mills  (about 2 mills) that control BLO
emissions incinerate the BLO vent gases in a power boiler.    The
BLO models were  selected to characterize the majority of BLO
systems; therefore, BLO model vent emissions are uncontrolled.
     4.1.3.4  Vent Characteristics.  The vent gas  flow rates,
temperature, and moisture content for the model BLO units are
based on typical process data provided by mills for actual units
within each model  size range.  The vent gas flow  rates for the
three model BLO units are 4.2, 8.5, and 12.7 m3/sec  (8,900,
18,000, and 26,900 acfm).2  The exhaust gas temperature  is 54°C
 (130°F) .1:L  The exhaust  gas moisture content is 35 percent.   '
                               4-16

-------
     4.1.3.5  JHAP Emissions.  As noted in Chapter 2, methanol
emission levels associated with the BLO models were calculated
using an emission factor of 1.73 x 10~4 kg/kg BLS
(1.73 x 10~4 Ib/lb BLS).
4.1.4  Lime Kiln Models
     The six model process units  (LK-1 through LK-6) that were
developed to characterize rotary lime kilns are presented in
Table 4-4.  Current industry trends are  (1) using ESP's rather
than scrubbers to control PM emissions and  (2) longer and larger
diameter lime kilns.11  Therefore, the majority of new lime kiln
installations will likely be represented by the larger models
LK-5 and LK-6.  The parameters selected to characterize lime
kilns are (1) size (i.e., equivalent pulp production rate, lime
production rate, length, and diameter),  (2) PM emission control
device, (3)  stack gas characteristics (i.e., flow rate,
temperature and moisture content), and (4) HAP emission levels
(i.e., PM as a surrogate for PM HAP's).
     4.1.4.1  Lime Kiln Size.  The lime kiln size is indicated by
the equivalent pulp production rate, lime  (i.e., CaO) production
rate, length, and diameter.
     The model sizes for lime kilns were determined using
available lime production rates.   The size distribution, in Mg/d
(ton/d) of lime, for lime kilns is shown in Figure 4-3.  The
sample population of lime kilns was divided into small, medium,
and large model sizes.  The median lime production rate within
each size range was then selected as the lime production rate for
the model.  Based on the data presented in Figure 4-3, the three
lime kiln model sizes are 90, 180, and 270 Mg/d (100, 200, and
300 ton/d) of CaO.  The daily equivalent pulp production rate was
estimated using a conversion factor of 275 kg CaO/ADMP
(550 Ib CaO/ADTP).3
     The length and diameter were determined based on the lime
production rates for the small, medium, and large models and
available data on lime kiln dimensions at similar production
rates.2  Lime kiln lengths range from 37 to 137 m (120 to 450 ft)
and average 82 m (270 ft); lime kiln diameters range from 2.1 to
                               4-17

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            4-19

-------
4.6 m (7 to 15 ft) and average 3.2 m (10.5 ft).11  The model lime
kiln dimensions were selected to cover these ranges.
     4.1.4.2  PM Emission Control Device.  Both wet scrubbers and
ESP's are used by the kraft pulp industry to control PM emissions
from lime kilns.11  Particulate matter emissions from the
majority of lime kilns  (90 percent) are controlled with wet
scrubbers.11  Venturi scrubbers are the most prevalent type of
wet scrubber used  (89 percent of all wet scrubbers.used to
control PM emissions are venturi scrubbers).11  Particulate
matter emissions from the remaining 10 percent of lime kilns are
controlled by ESP's.11  Lime kiln models were developed to
characterize both types of PM emission control devices.  The PM
emission control device for models LK-1 through LK-3 is a venturi
scrubber.  For models LK-4 through LK-6, the PM emission control
device is an ESP.
     4.1.4.3  stack Gas Characteristics.  The stack gas
flow rates for the lime kiln models with scrubbers  represent
typical gas flow  rates within each size range based on available
process data.2  The model gas flow rates for the small, medium,
and large models  are  7.3, 14.2,  and 24.1 m3/sec  (15,500, 30,000,
and 51,000 acfm),  respectively.  The exhaust gas temperature of
71°C  (160°F)  is based on process data provided by mills.  '     The
range of stack temperatures reported is  49° to 102°C  (120°  to
216°F).1:L  The model  exhaust gas moisture content  of  30 percent
is based on test  data.14
     Model  inlet  gas  flow rates  were calculated  from  the  stack
gas flow rates for the  lime kiln models  with scrubbers and
estimated  inlet  temperature and  moisture content.   An inlet
temperature of 250°C  (480°F) was based  on process  data provided
by mills.11   The range  of  inlet  temperatures is  150°  to  315°C
 (300°  to  600°F)-11 An  inlet moisture  content  of 25 percent was
assumed based on the  moisture  content  from test  results  for a
 lime  kiln  with an ESP.2  Because the gas stream temperature and
moisture  content do not vary significantly across the ESP,  the
 inlet and  outlet gas  stream conditions  are the same for  the model
 lime  kilns with ESP's.
                               4-20

-------
     4.1.4.4  .HAP Emissions.  The model lime kilns shown in
Table 4-4 include PM emission levels as a surrogate for PM HAP
emissions.  The PM emission level for model lime kilns with wet
scrubbers  (LK-1 through LK-3) is 0.27 g/dscm  (0.12 gr/dscf) at
10 percent 02.10  This emission level characterizes all lime  .
kilns with PM emission levels above the NSPS PM emission limit
for lime kilns firing natural gas, i.e., 0.15 g/dscm
(0.067 gr/dscf); the emission level represents both natural
gas-fired and oil-fired lime kilns.  The PM level does not
represent the PM emission performance of typical lime kilns
because approximately 64 percent of existing lime kilns emit less
than the NSPS limit for gas-fired lime kilns.2  The model lime
kiln PM emission level was selected so that the emission
reduction potential and control costs for those lime kilns with
PM emission levels higher than the NSPS could be evaluated.
     Electrostatic precipitators are generally more effective at
removing PM than venturi scrubbers; therefore, different PM
levels were calculated for lime kilns with ESP's.  Particulate
matter emission levels for lime kiln models with ESP's (LK-4
through LK-6) are equivalent to the NSPS level, 0.15 g/dscm
(0.067 gr/dscf).  All existing lime kilns equipped with ESP's
reportedly have PM emissions less than or equal to the NSPS PM
limit for gas-fired lime kilns.2
4.2  CONTROL OPTIONS
     Control options for recovery furnaces,  SDT's,  BLO units,  and
lime kilns were developed based on the emission control
information presented in Chapter 3.  This section identifies and
briefly describes these control options.  Controlled emission
levels are presented for each applicable model process unit,
along with model control device parameters,  where applicable.
4.2.1  Recovery Furnace Control Options
     Table 4-5 presents the four control options that have been
evaluated for recovery furnaces.  Table 4-5  also identifies the
recovery furnace type that is affected by the control option and
the pollutants that would be controlled.  The four control
options are (1)  conversion of a DCE recovery furnace system to an
                              4-21

-------
NDCE recovery furnace  (i.e.,  low-odor conversion),  (2) wet to dry
ESP  system conversion,  (3) PM controls, and (4) addition of a
packed-bed scrubber.

            TABLE 4-5.   RECOVERY  FURNACE CONTROL OPTIONS	
   Control option
Affected recovery furnace type
                                                     Pollutants Controlled
   Low-odor conversiona
DCE recovery furnaces
Gaseous organic HAP's and
PM HAP's
   Wet to dry ESP system conversion
NDCE recovery furnaces with wet
ESP systems
Gaseous organic HAP's
(e.g., methanol)
   PM Controls:
   (a) ESP upgrade or replacement in
      order to meet NSPS PM
      emission level of 0.10 g/dscm
      (0.044 gr/dscf)
   (b) ESP upgrade or replacement
      plus addition of packed-bed
      scrubber in order to meet PM
      level of 0.034 g/dscm
      (0.015 gr/dscf).       	
NDCE and DCE recovery furnaces
currently emitting PM in quantities
above NSPS PM emission level

NDCE and DCE recovery furnaces
currently emitting PM in quantities
greater than 0.034 g/dscm
(0.015 gr/dscf).
PM HAP's
PM HAP's
   Packed-bed scrubber
All recovery furnaces
                                                      HC1
  aln addition to the elimination of the BLO unit and the conversion of the evaporator to the noncontact
   design, the low-odor conversion option also includes an ESP upgrade or replacement (including wet to
   dry ESP system conversion) to meet the applicable PM emission limit listed under "PM Controls."

      4.2.1.1   Conversion  of a DCE Recovery Furnace System to an
 NDCE Recovery Furnace.  Converting a DCE recovery furnace system
 to an  NDCE  recovery  furnace  (or  "low-odor conversion")  was
 evaluated as  a control option for reducing gaseous organic HAP
 emissions from DCE recovery furnace systems.   Under  this  control
 option,  the DCE is eliminated from the chemical recovery  process
 and replaced with  a  concentrator, the  BLO unit is eliminated, and
 the wet  ESP system is converted  to a dry ESP  system.  Based  on
 the emission factors presented  in Sections 4.1.1.5 and 4.1.3.5,
 this control option  reduces methanol emissions by 99 percent.
 Because  the DCE provides  some PM control, as  discussed in
 Chapter  3,  conversion to  an NDCE recovery  furnace has the
 •potential  to increase PM  emissions.  Therefore, depending on the
 design characteristics  of the ESP, an  ESP upgrade or replacement
 may be required to achieve compliance  with  PM emission limits.
                                    4-22

-------
Two levels of PM control were included as part of the low-odor
conversion option.  A PM control level of 0.10 g/dscm
(0.044 gr/dscf) at 8 percent 02  (i.e., the NSPS limit) was
evaluated for both "a" and  "b" model recovery furnaces.  Although
"b" model recovery furnaces have a baseline of 0.10 g/dcsm
(0.044 gr/dscf), conversion to an NDCE recovery furnace has the
potential to increase PM emissions above the baseline.
Therefore, PM controls are necessary to maintain a PM level of
0.10 g/dscm  (0.044 gr/dscf) for the "b" model recovery furnaces.
A control level of 0.034 g/dscm  (0.015 gr/dscf) at 8 percent G>2
was also evaluated for both "a" and "b" model recovery furnaces.
Tables 4-6 and 4-7 present the model recovery furnaces that were
evaluated for this control option.  Controlled emission levels
also are included in these tables.
     4.2.1.2  Wet to Dry ESP System Conversion.  Converting wet
ESP systems to dry ESP systems was evaluated as a control option
for reducing methanol and other gaseous organic HAP emissions
from NDCE recovery furnaces.  With this control option, stripping
of methanol from the black liquor or HAP-contaminated water in
the ESP bottom or PM return system is eliminated.  Using the
methanol emission factors presented in Section 4.1.1.5 for wet
and dry ESP systems, methanol emissions are reduced by
72 percent.  The model recovery furnaces used to evaluate the
impact of this option are presented in Table 4-•8.
     4.2.1.3  PM Emission Controls.  One PM emission control
option was evaluated that would reduce PM emissions from existing
NDCE and DCS recovery furnace systems to the NSPS PM limit.  The
control option would involve either an ESP upgrade or an ESP
replacement to meet the NSPS limit of 0.10 g/dscm
(0.044 gr/dscf).  The model recovery furnaces (NDCE and DCE "a"
models) analyzed for this control option are presented in
Table 4-9.
     A second PM emission control option was evaluated that would
reduce PM emissions from NDCE and DCE recovery furnaces to a more
stringent level of 0.034 g/dscm  (0.015 gr/dscf).  The control
option would involve (1) upgrading the existing ESP and
                              4-23

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installing a packed-bed scrubber or (2) installing a new ESP and
a packed-bed scrubber.  The control option would be applicable to
both new and existing recovery furnaces.  The model recovery
furnaces analyzed for this control option are presented in
Table 4-10.
     Note that because the type of ESP bottom or PM return system
does not affect PM emission levels, this parameter was not
considered in evaluating either of the PM control options.
     4.2.1.4  Packed-Bed Scrubber.  The installation of
packed-bed scrubbers was evaluated as an HC1 control option for
existing and new NDCE and DCE recovery furnaces, and for DCE
recovery furnaces that have undergone a conversion to the NDCE
furnace design.  Packed-bed scrubbers are capable of controlling
outlet HC1 emissions by 99 percent or to levels less than or
equal to 5 ppmv.16'17  This emission level  (i.e., 5 ppmv)
corresponds to an emission factor of 6.20 x 10"5 kg HCl/kg BLS
 (6.20 x 10"5 Ib HCl/lb BLS) for the model NDCE recovery furnaces
and converted DCE's.  The corresponding emission factor for the
model DCE recovery furnaces is 6.53 x  10"5 kg HCl/kg BLS
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emissions from the model NDCE recovery  furnaces  (and converted
DCE's) are reduced by 48 percent, and HC1 emissions from the
model DCE's are reduced by 46 percent.  The model recovery
furnaces that were analyzed for this control option are listed  in
Tables 4-11 and 4-12.
4.2.2  SDT Control Options
     One PM emission  control  option was evaluated that would
reduce PM  emissions from existing  SDT's to  the NSPS PM limit.
The control option would involve replacing  the existing mist
eliminator or  existing  scrubber with a new  wet scrubber designed
to meet the NSPS  PM limit.  The model  SDT's analyzed for  this
 control option are presented  in Table  4-13.
     A second  PM emission control  option was evaluated that would
 reduce  PM  emissions to  a more stringent level  of  0.06 kg/Mg BLS
 (0.12  Ib/ton BLS).  The control  option would involve
 (1) replacing  the existing mist  eliminator  or  scrubber with a new
                               4-28

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wet scrubber or  (2) installing a new wet scrubber.  The control
option would be applicable to both new and existing SDT's.  The
model SDT's analyzed for this control option are presented in
Table 4-14.
4.2.3  BLO Unit Control Option
     Two control options,  (1) conversion of a DCE recovery-
furnace system to an NDCE recovery furnace and  (2) incineration
of BLO vent gases, were evaluated for controlling gaseous organic
HAP emissions from air-sparging BLO units.  Converting the DCE
recovery furnace eliminates  the BLO unit from the chemical
recovery process.  Thus, this control option results in a
100 percent reduction in emissions of HAP's, such as methanol,
from BLO units.  As discussed in Section 4.2.1.1, the overall
methanol emission reduction  for the recovery furnace system is
approximately 99 percent.  The model BLO units  were not used to
assess the impact of this  control option; the economic and
environmental impacts, such  as cost for equipment removal and the
associated emission reduction, were included in the impacts for
the DCE recovery furnace models.
     The second  control option to reduce gaseous organic  HAP
emissions from BLO units is  to incinerate the BLO emissions, most
likely in a power boiler.  This control option  reduces' methanol
emissions from the BLO unit  by 98 percent and from the DCE
recovery furnace system by 49 percent.  The model BLO units
analyzed for this  control.option are presented  in Table 4-15.
4.2.4  Lime Kiln Control Options
     One PM emission  control option was evaluated that would
reduce PM  emissions from existing lime kilns to the NSPS  PM
limit.  The  control option would involve  replacing the existing
scrubber with a  new ESP.   Because lime kilns with ESP's are
already achieving  the NSPS PM level,  they are not included under
this  control  option.  The  model  lime  kilns  analyzed  for this
control option are presented in Table  4-16.
      A second PM emission  control option  was evaluated that would
reduce PM emissions  from lime kilns  to a  more  stringent level of
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                               4-34

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(1)  replacing the existing scrubber with an ESP, (2)  upgrading
the existing ESP, or (3) installing a new ESP.  The more
stringent PM control option is applicable to both new and
existing lime kilns.  The model lime kilns that were analyzed for
this control option are presented in Table 4-17.
4.3  ENHANCED MONITORING OPTIONS
     The practice of enhanced.monitoring allows a facility to
demonstrate continuous compliance with the emission limits
established by the emission standard.  The most direct means of
monitoring compliance is the use of continuous emission monitors
(CEM's) to measure the emissions of each pollutant on a
continuous basis.  In the event that CEM's for specific
pollutants are not applicable because of cost and/or technology
constraints, alternative approaches to ensure continuous
compliance can be adopted.  The best alternative approach is to
use CEM's to monitor surrogate pollutants with emission profiles
that closely match those of the pollutants of concern.  Where
CEM's  are not applicable for  surrogate pollutants, the next best
option is to use process monitors to measure  those process or
add-on control device operating parameters that impact emissions
of the pollutants of concern.  In some cases, the very presence
of specific processing  equipment will ensure  continuous
compliance with  the emission  standard.   Pollutant emissions  can
also be tested on a periodic  basis  (e.g.,  semiannually).
     The following  sections describe how the  approach described
above  was used to develop  the enhanced monitoring options  for
combustion  sources  in  the  pulp and  paper industry.   Table  4-18
summarizes  the enhanced monitoring  options for  recovery  furnaces,
SDT's, BLO  units, and  lime kilns, based  on the  control  options
presented in Section  4.2.   Enhanced monitoring  options  were  not
developed for control  options other than those  developed in
Section 4.2;  if  a CEM is not  applicable, facilities that choose
 to meet the emission limits through the  application of  other
 control options  must  develop an enhanced monitoring plan that
 demonstrates the ability of the selected parameter to gauge  a
 change in emissions.
                               4-38

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 4.3.1  Recovery  Furnace  Enhanced Monitoring
     Enhanced monitoring options that  can be used to demonstrate
 compliance with  recovery furnace emission limits for PM or PM
 HAP's, total gaseous  organic HAP's, and HC1 are presented in the
 following sections.
     4.3.1.1  Enhanced Monitoring for  PM or PM HAP's Controlled
 with an ESP.  Because opacity is the surrogate measurement that
 best characterizes the level of recovery furnace PM emissions,
 installation of  an opacity monitor after the ESP is one option
 being considered as a means of demonstrating compliance with a PM
 or PM HAP emission limit for recovery  furnaces.  For those
 recovery furnaces with a wet scrubber  following the ESP, an
 opacity monitor  must  be  located after  the ESP but prior to the
 scrubber.  Method 5,  Method 29, or Method 17 compliance tests
 could be performed periodically as a substitute for an opacity
 monitor.
     Another option being considered is for the facility to
 develop a monitoring  plan that specifies ESP operating parameters
 to be monitored.  Operating parameters for the ESP would be site-
 specific and would be based on the parameters measured during a
 three-run, EPA Method 5, Method 29, or Method 17 compliance test
 that showed the  facility to be in compliance with the applicable
 PM or PM HAP emission limit.  Under this option, operation
 outside the ranges of the ESP operating parameters would not
 represent noncompliance  with the applicable emission limit but
 instead would require the facility to take corrective actions, if
 necessary, to return  the ESP parameters to the levels established
 during the compliance test.  The corrective action procedures
 would be documented in the facility's startup,  shutdown, and
 malfunction plan.
     4.3.1.2  Enhanced Monitoring for PM or PM HAP's Controlled
with a Wet Scrubber.  For those recovery furnaces that can comply
 with a PM or PM HAP emission limit with existing wet scrubbers,
 the use of an opacity monitor to demonstrate compliance with the
 PM or PM HAP emission limit may be inappropriate.   The exhaust
 from the recovery furnace wet scrubber will have a high moisture
                              4-41

-------
content and will interfere with the readings from an opacity
monitor.  Monitoring scrubber operating parameters (i.e.,
pressure drop and scrubber liquid flow rate) is an alternative
enhanced monitoring option for showing compliance with a PM or PM
HAP emission limit for recovery furnaces.  The pressure drop and
liquid flow rate are indirect measurements of the performance of
the scrubber.  Pressure drop and scrubber liquid flow rate levels
would be site-specific and would be based on the operating
parameters measured during a three-run, EPA Method 5, Method 29,
or Method 17 compliance test that showed the facility to be in
compliance with the applicable PM or PM HAP emission limit.
Method 5, Method 29, or Method 17 compliance tests could also be
performed periodically as a substitute for monitoring scrubber
operating parameters.
     4.3.1.3  Enhanced Monitoring for Gaseous Organic HAP's.
Control of gaseous organic HAP emissions from recovery furnaces
can be achieved by using NDCE recovery furnaces equipped with dry
ESP systems.  Therefore, enhanced monitoring for recovery  furnace
gaseous organic HAP emissions can be achieved simply by
confirming that the recovery furnace is an NDCE recovery furnace
with a dry ESP system.  If the recovery furnace is a DCE recovery
furnace or an NDCE recovery furnace equipped with a wet  ESP
system, the  facility  could measure methanol emissions with a
methanol CEM (e.g., a fourier transform infrared  [FTIR]
spectroscopy monitoring system).
     4.3.1.4 Enhanced Monitoring  for HC1.  Hydrochloric acid
emissions  can be measured  directly using an HC1 CEM.  An HC1 CEM
could be installed after the packed-bed scrubber to  demonstrate
continuous  compliance with an HC1  emission  standard.  An HC1 CEM
could also be used after  the ESP for  those, recovery  furnaces, that
could comply with an HC1  emission limit without a packed-bed
scrubber.   The  feasibility of using HC1  CEM's  to demonstrate
compliance with an HC1 standard has not been  determined.   The  low
HC1  concentrations and high moisture  content  associated with the
recovery furnace flue gas  may make the use  of  HC1  CEM's more
                                4-42

-------
 difficult.   However,  additional  information is  needed before  an
 HC1  CEM can be definitively ruled out  for  recovery furnaces.
      Because HC1  emissions  can be controlled with a packed-bed
 scrubber, monitoring  scrubber operating  parameters is another
 monitoring  option being considered for those recovery furnaces
 that comply with  an HC1 emission limit using a  packed-bed
 scrubber.   The scrubber operating parameters to be monitored  are
 the  scrubber liquid pH and  scrubber liquid flow rate.   Scrubber
 liquid  flow rate  and  pH levels would be  site-specific and would
 be based on the operating parameters measured during a three-run,
 EPA  Method  26 HC1 compliance test that showed the facility to be
 in compliance with an HC1 emission limit.
      Alternative  enhanced monitoring options are  also available
 to demonstrate compliance for those recovery furnaces that could
 comply  with an HC1 emission limit without  a  packed-bed scrubber.
 One  option  would  require the facility  to develop  a monitoring
 plan that specifies operating parameters to  be  monitored.  The
 operating parameters  would  be site-specific  and would be based on
 the  parameters measured during a  three-run,  EPA Method 26 HC1
 compliance  test that  showed the  facility to  be  in compliance with
 an HC1  emission limit.   Under this option, operating  outside  the
 ranges  of the operating parameters would not represent
 noncompliance with the  applicable emission limit  but  instead
 would require the facility  to take corrective actions,  if
 necessary,   to return  the parameters  to the levels  established
 during  the  compliance test.   The  corrective action procedures
 would be documented in  the  facility's  startup,  shutdown, and
 malfunction plan.  A second  option would require periodic
Method  26 HC1  compliance tests to  demonstrate compliance.
 4.3.2   Smelt  Dissolving  Tank  Enhanced Monitoring
     This section presents the enhanced monitoring options that
 can be used to  demonstrate compliance with an SDT  emission limit
 for PM  or PM  HAP's.
     4.3.2.1  Enhanced Monitoring  for PM or PM HAP's Controlled
with a Wet  Scrubber.  Because the exhaust from the SDT wet
 scrubber will have a high moisture content and will interfere
                               4-43

-------
with the readings from an opacity monitor, the use of an opacity
monitor to demonstrate compliance with a PM or PM HAP emission
limit for SDT's may be inappropriate.  Monitoring scrubber
operating parameters  (i.e., pressure drop and scrubber liquid
flow rate) is an alternative enhanced monitoring option for
showing compliance with a PM or PM HAP emission limit for SDT's.
The pressure drop and liquid flow rate are indirect measurements
of the performance of the scrubber.  Pressure drop and scrubber
liquid flow rate levels would be site-specific and would be based
on the operating parameters measured during a three-run, EPA
Method 5, Method 29,  or Method 17 compliance test that showed the
facility  to be  in compliance with the applicable PM or PM HAP
emission  limit.  Method 5, Method 29, or Method 17 compliance
tests could also be performed periodically as a substitute for
monitoring scrubber operating parameters.
4.3.3  Black Liquor Oxidation Unit Enhanced Monitoring
     This section presents the enhanced monitoring options that
can be used to  demonstrate compliance with a total gaseous
organic HAP emission  limit for DCE recovery furnace  systems
 (which include  the BLO unit).
     One  control option presented  for the BLO unit involves  the
removal of  this piece of  equipment from  the chemical  recovery
process by  converting a DCE  recovery furnace  to an NDCE  recovery
furnace equipped with a dry  ESP  system.   Demonstrating  that  this
conversion  has  been  completed assures  compliance  with the
applicable  total gaseous  organic HAP emission limit.
     A second control option involves  incineration  of the  BLO
 emissions.   Enhanced monitoring  for  BLO  incineration could be
 achieved simply by affirming that the  BLO control equipment  is in
place.   Another enhanced monitoring  option would be for the
 facility to monitor the temperature  of the power boiler or other
 incineration device.
 4.3.4  Lime Kiln Enhanced Monitoring
      Enhanced monitoring options that  can be used to demonstrate
 compliance with a lime kiln emission limit for PM or PM HAP's are
 presented in the following sections.
                               4-44  ,

-------
      4.3.4.1  Enhanced Monitoring for PM or PM HAP's Controlled
 with an ESP.  Because opacity is the surrogate measurement that
 best characterizes the level of lime kiln PM emissions,
 installation of an opacity monitor after the ESP is one  option
 being considered as a means of demonstrating compliance  with a PM
 or PM HAP emission limit for lime kilns controlled with  ESP's.
 For those lime kilns with a wet scrubber following the ESP,  an
 opacity monitor must be located after the ESP but prior  to the
 scrubber.  Method 5,  Method 29,  or Method 17 compliance  tests
 could be performed periodically as a substitute for an opacity
 monitor.
      Another option being considered is for the facility to
 develop a monitoring plan that specifies ESP parameters  to be
 monitored.   Operating parameters for the ESP would be  site-
 specific and would be based on the parameters measured during a
 three-run,  EPA Method 5,  Method 29,  or Method 17 compliance  test
 that showed the facility to be in compliance with the  applicable
 PM or PM HAP emission limit.   Under this option,  operation
 outside the ranges of the ESP  operating parameters would not
 represent noncompliance with the applicable emission limit but
 instead would require the facility to  take  corrective  actions,  if
 necessary,  to return  the ESP parameters to  the  levels  established
 during  the  compliance test.  The corrective action procedures
 would be documented in the facility's  startup,  shutdown,  and
 malfunction plan.
      4.3.4,2   Enhanced Monitoring  for  PM or PM  HAP's Controlled
 with a Wet  Scrubber.   For those  lime kilns  that  can comply with a
 lime kiln PM or PM HAP emission  limit  with  existing wet
 scrubbers,  the use  of  an  opacity monitor to demonstrate
 compliance with a  PM  or PM HAP emission limit may be
 inappropriate.  The exhaust  from the lime kiln wet  scrubber will
 have  a high moisture  content and will  interfere with the  readings
 from an  opacity monitor.  Monitoring scrubber operating
parameters  (i.e., pressure drop  and scrubber liquid flow  rate) is
an alternative enhanced monitoring option for showing compliance
with  the applicable PM or PM HAP emission limit for lime kilns.
                               4-45

-------
The pressure drop and liquid flow rate are indirect measurements

of the performance of the scrubber.  Pressure drop and scrubbing
liquid flow rate levels would be site-specific and would be based

on the operating parameters measured during a three-run, EPA
Method 5, Method 29, or Method 17 compliance test that showed the

facility to be in compliance with the applicable PM or PM HAP
emission limit.  Method 5, Method 29, or Method 17 compliance
tests could also be performed periodically as a substitute for

monitoring scrubber operating parameters.

4.4  REFERENCES FOR CHAPTER 4

 1.  Memorandum from Nicholson, R., MRI, to Telander, J.,
     EPA/MICG.  June 13,  1996.  Addendum to Summary of Responses
     to the 1992 NCASI MACT Survey.

 2.  Memorandum from Soltis, V., MRI, to the project  file
     April 3,  1995.  Kraft and Soda Pulp Mill Combustion Sources
     Data Base.

 3.  Someshwar, A.  Compilation of  "Air Toxic" Emission Data  for ,
     Boilers,  Pulp Mills, and Bleach  Plants.  National  Council  of
     the Paper Industry  for Air and Stream Improvement, Inc.,
     New York.  Technical Bulletin No.  650.  June  1993.  128  p.

 4.  Green, R. and  G.  Hough,  (eds.).   Chemical Recovery in the
     Alkaline Pulping  Process.   3rd Edition.  Prepared  by_the_
     Alkaline Pulping  Committee  of the  Pulp Manufacture Division.
     Atlanta,  GA, TAPPI  Press.   1992.   196 p.

 5.  Telecon.  Nicholson, R.,  MRI,  with Bringman,  L,
     Environmental  Elements  Corp.   November 30,  1994.      _
      Information about the particulate return  systems associated
     with kraft' recovery furnace ESP's.

  6.  Memorandum from Soltis,  V.,  MRI,  to the project file.
      October 20,  1994.  Calculation of Recovery Furnace Stack Gas
      Flow Rate.

  7.   Proposed Standards of Performance for Kraft Pulp Mills.   In:
      Standards Support and Environmental Impact Statement.
      Volume 1   U.  S.  Environmental Protection Agency.   Research
      Triangle Park, NC.   Publication No. EPA-450/2-76-014a.
      September 1976.

  8   U. S. Environmental Protection Agency.  New Source
      Performance Standards for Kraft Pulp Mills.  43 FR 7568.
      Washington,  DC.   U.S. Government Printing Office.
      February 23, 1978.
                                4-46

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10
11.
  9.  U.  S.  Environmental  Protection Agency.   New Source
     Performance  Standards  for Kraft Pulp Mills.   51  FR 18538.
     Washington,  DC.   U.S.  Government Printing  Office.   May 20,
     1986.

     Memorandum from Holloway,  T.,  MRI,  to the  project  files.
     June 14,  1996.  Summary  of PM  and HAP Metals Data.

     Memorandum from Soltis,  V., Nicholson, R.,  and Holloway, T.,
     MRI, to Telander, J.,  EPA/MICG.   July 29,  1994.  Summary of
     Responses  to the  NCASI "MACT"  Survey--Kraft  and  Soda  Pulp
     Mills  (Data  Base  Summary Memo).

12.  Roy F. Weston, Inc.  Texas Emissions  Speciation  Study
     Emission Test Results: Champion International
     Corp.--Sheldon, Texas.   Prepared for  Texas Paper Industry
     Environmental Committee.   Report No.  06848-001-001.
     January 1993.  Volume  3.

13.  Roy F. Weston, Inc.  Texas  Emissions  Speciation  Study
     Emission Test Results: Simpson-Pasadena--Pasadena, Texas.
     Prepared for Texas Paper Industry Environmental  Committee.
     Report No. 06848-001-001.   January  1993.  Volume 5.

14.  Environmental Pollution  Control,  Pulp and Paper  Industry,
     Part I, Air.   U. S. Environmental Protection Agency.
     Cincinnati,  OH.  Publication No.  EPA-625/7-76-001.
     October 1976.

15.  Roy F.  Weston, Inc.  Emissions Testing of Combustion
     Processes in a Pulp and  Paper Facility: Champion
     International Corp.- -Roanoke Rapids, NC.  Prepared for U. S.
     Environmental Protection Agency--Emission Measurement
     Branch.  Research Triangle Park, NC.  EMB Report
     No. 92-KPM-27.  October  1992.   Volume I.

16.  Telecon.   Soltis,  V., MRI, with Bruno, J.,  AirPol,  Inc.
     July 2, 1993.  Information about scrubbers  used to control
     HC1 emissions.

17.  Telecon.   Soltis,  V., MRI, with Sanders,  D., Andersen 2000,
     Inc. August  11,  1993.   Cost and efficiency information
     about HC1  control  for recovery furnaces.
                              4-47

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     5.0  MODEL PROCESS UNIT ENVIRONMENTAL AND ENERGY IMPACTS

      This chapter discusses the environmental and energy impacts
 of controlling HAP emissions from new and existing combustion
 sources at kraft  and soda pulp and paper mills.   The
 environmental and energy impacts of each control option discussed
 in Chapter 4 are  presented for the individual model combustion
 process units.  The total nationwide environmental and  energy
 impacts associated with each control option  are  presented in a
 separate memorandum.^
     Section 5.1  of this  chapter discusses the general  approach
 used to determine the environmental and  energy impacts  associated
 with each control option.   Sections 5.2  through  5.5 present  the
 environmental and energy  impacts of each control option for  model
 process units representing recovery furnaces, BLO units,  SDT's,
 and lime  kilns.   Section  5.6 contains  the references cited in
 this chapter.
 5.1  GENERAL APPROACH
     This section introduces the types of environmental  and
 energy  impacts associated  with  the  control options  and discusses
 how these impacts  were determined for each of the model  process
 units.  The  types  of  impacts discussed include air  pollution,
 energy  consumption, water  pollution, solid waste disposal, and
 other impacts (i.e.,  noise, visual, odor, and irreversible and
 irretrievable commitment of resources).   Impacts were calculated
 for each model process unit on an annual basis.  In  calculating
 the annual impacts, all process units were assumed  to operate
 24 hr/d for 351 d/yr, which is equivalent to 8,424 operating
hr/yr.   This operating time accounts for 14 days of scheduled
 shutdown annually for maintenance and repair.
                               5-1

-------
     The procedure for estimating air pollution'impacts is
described in the following section.  The general approaches used
to develop energy impacts, water pollution impacts, solid waste
disposal impacts, and other impacts are provided in
Sections 5.1.2, 5.1.3, 5.1.4, and 5.1.5, respectively.
5.1.1  Air Pollution Impacts
     This section presents the methodology used to determine both
primary and secondary air impacts.
     5.1.1.1   Primary Emissions.  For this impact analysis,
primary air impacts include the reduction of emissions directly   •
attributable to the control option  (i.e., the reduction of
emissions due  to the use  of APCD's  or process modifications).
Primary emissions of PM,  PM HAP's,  gaseous organic HAP's, HC1,
and  S02 were estimated based  on model concentrations  and  emission
factors at baseline and at control  levels.  Gaseous organic  HAP's
include acetaldehyde, benzene, formaldehyde, methanol, methyl
ethyl  ketone,  methyl  isobutyl ketone, phenol,  toluene, and
xylenes.
     As discussed  later  in this  chapter,  PM  is used as a
surrogate measure  for PM HAP's,  i.e,  trace metals, such as
antimony  (Sb), arsenic (As),  beryllium (Be),  cadmium  (Cd),
chromium (Cr), cobalt (Co),  lead (Pb),  manganese (Ma), mercury
 (Hg),  nickel  (Ni),  and selenium (Se).   The primary emission
estimates for PM were derived for each model recovery furnace and
lime kiln by multiplying the model PM concentration  by the model
     flow rate corrected to dry conditions at standard temperature
                                                           HC1.
gas
and by 351 operating d/yr.
     Primary emission estimates of gaseous organic HAP's
and S02 from model recovery furnaces and PM from model SDT's were
determined by multiplying their respective model emission factors
by the model BLS firing rates and by 351 operating d/yr.
     Primary emission estimates of PM HAP's were determined as
a percentage of PM for each model recovery furnace, SDT, and lime
kiln; the percentages were derived based on a comparison of PM
and PM HAP emissions for kraft and soda recovery furnaces, SDT's,
and lime kilns.  The percentages of PM were estimated  to be
                               5-2

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 0.2 percent for recovery furnaces,  0.06 percent for SDT's,  and
 1.4 percent for lime kilns.2
      The control level HC1 emission factor was derived from an
 outlet HC1 emission concentration of 5 ppmv guaranteed by packed-
 bed scrubber manufacturers for inlet HC1 concentrations less than
 500 ppmv.3'4  However,  the actual outlet HC1 emission level
 achieved at a particular mill will  be site-specific.   The
 baseline HC1 emission estimates (and percent HC1 reduction)  in
 this impact analysis may be underestimated because the baseline
 HC1 emission factor includes emissions data from recovery
 furnaces with HC1  emissions at or below 5 ppmv.
      The S02 emission reduction obtained with the packed-bed
 scrubber was estimated for each model recovery furnace by
 applying a percent S02  reduction to average uncontrolled S02
 emission estimates.   Uncontrolled S02 emission factors for
 recovery furnaces- have  already been developed and are presented
 in  the Air Pollution Engineering Manual.5  As shown in the
 manual,  the average  uncontrolled S02  emission factor  for NDCE
 recovery furnaces  is 2.1  kilograms  per air-dried megagram of pulp
 (kg/ADMP)  (4.2 pounds per air-dried ton of  pulp  [lb/ADTP]).5
 Using a  conversion factor of  1,700  kg BLS/ADMP  (3,400  Ib
 BLS/ADTP)  (the average  for both bleached and unbleached pulp
 mills),  the average  uncontrolled S02  emission factor  for NDCE
 recovery  furnaces  is  equivalent to  1.24  x 10"3 kg/kg  BLS  (1.24  x
 10~3 Ib/lb  BLS).6  The  average  uncontrolled SO2  emission factor
 for DCE recovery furnaces  is  1.8  kg/ADMP  (3.5 lb/ADTP),  which is
 equivalent  to 1.03 x 10"3  kg/kg BLS  (1.03 x 10"3  Ib/lb  BLS).5
 Based on  information  from individual mills, at least 50 percent
 S02 control was assumed to be achievable with packed-bed
          rj
 scrubbers.   The control  level  S02 emission estimates were
determined using the uncontrolled emission  factors and  the
 50 percent SO2 control.
     To estimate the incremental reduction in emissions for  each
primary pollutant  (i.e., PM, PM HAP's, gaseous organic HAP's,
HC1, and S02), the control level emission estimate for each
                               5-3

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primary pollutant was compared to its corresponding baseline
emission estimate.
     5.1.1.2  Secondary Emissions.  Secondary air impacts include
the indirect or induced impacts resulting from implementing a
control option.  These indirect or induced impacts include the
following:
      (1)  changes in power boiler emissions of criteria
pollutants such as PM, S02, nitrogen oxides  (NOX), and carbon
monoxide  (CO) resulting from the generation of energy required to
operate APCD's or other equipment included in the control
options; and
      (2)  changes in power boiler emissions of S02 resulting from
the incineration of TRS compounds present in the BLO vent gases
routed  to the power boiler to  control gaseous organic HAP
emissions.
      The power boiler  secondary  emissions of PM, SO2/ NOX, and CO
resulting from the generation  of electricity to  operate  APCD's or
other equipment were estimated based on emission factors related
to electricity usage.  The emission factors used are
0.23  kilograms of PM per  megawatt-hour  (kg PM/MWh)  (0.15 pounds
of PM per million Btu  [Ib PM/MM  Btu]) ,  1.1 kg S02/MWh
 (0.73 Ib  S02/MM Btu),  0.45 kg  NOx/MWh  (0.29  Ib NOX/MM Btu),  and
0.85  kg CO/MWh (0.55  Ib  CO/MM  Btu).8  The  secondary emission
estimates were calculated as a product  of  these  emission factors
and  the model process  unit  electricity  impacts  discussed in the
next section.
      Secondary SO2  emissions  can be  generated under  the BLO vent
gas  control option when TRS  compounds present in the vent gases
are  incinerated in a power boiler or other incineration device.
All  of the TRS from the BLO unit is  assumed to  be routed to a
power boiler or other incineration device;  none is "lost"  as
 condensate along the way.  In deriving the chemical  equation for
 the conversion of TRS to SO2,  the TRS was assumed to be in the
 form of H2S.  During combustion, the H2S would be combined with
 02 to produce S02 and H20.   The chemical equation is as follows:
                                5-4

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SO
                                        H2O
 As  shown in this equation,  one mole of S02 is formed for each
 mole of H2S combusted.   This molar ratio was used in the
 following equation to estimate the mass ratio of S02 to TRS:
           (1 kg-mole SO2  formed/'l kg-mole H2S combusted) x
       (1 kg-mole H2S/34.08 kg H2S)  x (64.06 kg SO2/kg-mole SO2)
                         ~ 1.88 kg S02/kg H2S

 The English unit equivalents for  this equation are the same  as
 the metric unit  values presented  in the equation.   To determine
 the secondary  S02 emission  estimates,  the ratio of SO2 to TRS was
 multiplied by  the estimate  of TRS  emissions incinerated by the
 BLO control system.   These  secondary S02  emission estimates
 represent  worst-case  estimates because some control of S02
 emissions  is likely to be achieved through the application of wet
 scrubbers  on incineration devices  such as power boilers and  lime
 kilns  that could be used to incinerate BLO vent gases.
     To estimate  the  change in emissions  for each secondary
 pollutant  (i.e.,  PM,  S02, NOX/  and CO),  the control level
 emission estimate for each  secondary pollutant was compared  to
 its  corresponding baseline  emission estimate.
 5.1.2   Energy  Impacts
     The energy  impacts  of  the combustion source control  options
 include  changes  in electricity and steam  requirements.  The
 increases  in electricity requirements  from the operation  of
 APCD's were calculated using electricity  cost  equations from  the
 EPA's Office of Air Quality Planning and  Standards (OAQPS)
 Control  Cost Manual.9  These electricity  requirements  are divided
 into fan,  pump, and operating  electricity requirements and were
 calculated assuming 8,424 operating  hr/yr.   The  electricity
 requirements to operate  a BLO vent gas  control  system were
 calculated based  on information from a kraft pulp  mill.10  The
methods used, to calculate the BLO  control  system energy impacts
are described in  Section 5.3.2.
                               5-5

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     The fan electricity requirement  (applicable to ESP's and
scrubbers) is equal to a numerical factor  (0.00018) times the
product of the gas flow rate, pressure drop, and operating
hr/yr>9  The gas flow rate varies with each model process unit.
The pressure drop is based on information  from individual mills.
Although the pressure drop is not the sole parameter that
determines PM collection efficiency for lime kiln scrubbers, for
the purposes of estimating impacts, the pressure drop was used as
an indicator of PM collection efficiency for lime kiln scrubbers.
 (Note: A different scrubber  design, rather than a higher pressure
drop, was used to improve the PM collection efficiency for SDT
scrubbers.)
     The gas flow rate and pressure drop do not change for ESP's
relative to current  operation when the ESP's are upgraded or
replaced to improve  PM collection.  Therefore, the  fan
electricity requirements  for ESP's do not  change relative to
current operation.   However, if a scrubber is  added after an ESP,
the gas flow rate would be  reduced, thereby reducing the fan
electricity requirements  for the ESP.
     The pump  electricity requirement (applicable  to packed-bed
 scrubbers)  is  equal  to a  numerical  factor  (0.000188)  times  the
product of  the liquid flow rate, amount  of head pressure, and
 operating hr/yr divided by the  pump-motor  efficiency.9   The
 liquid flow rate varies with each model  process unit.  A head
 pressure  of  18 m (60 ft)  and a  pump-motor  efficiency of
 70 percent  were assumed.
      The  operating electricity requirement (applicable to ESP's)
 is  equal  to a numerical  factor  (0.00194)  times the product  of  the
 ESP plate area and operating hr/yr.9   The  ESP plate area is
 calculated as a product of the exhaust gas flow rate and the ESP
 SCA.   The gas flow rate varies with each model process unit,  and
 the SCA is based on information from individual mills.    Although
 the SCA is not the sole parameter that determines PM collection
 efficiency for ESP's, for the purposes of estimating impacts,  the
 SCA was used as an indicator of PM collection efficiency.
                                5-6

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      Steam energy savings result from the increased steam flow
 that occurs with the gaseous organic HAP control  option of
 converting the DCE recovery furnace system to an  NDCE recovery
 furnace.11  With NDCE recovery furnaces,  more heat  is available
 for steam production than with DCE recovery furnaces because
 combustion gases are not  used to concentrate black  liquor.  The
 increased steam production resulting from converting the DCE
 recovery furnace system to the NDCE design reduces  the power
 boiler steam production requirements.  A fuel savings can be
 realized from this steam  energy savings  because the amount  of
 fuel required for steam production in the power boiler decreases.
 The steam energy savings  are partially offset by  low-pressure
 steam requirements for the concentrator,  which is a part of the
 NDCE recovery furnace system.   The low-pressure steam would be
 used to concentrate the black liquor.  These  concentrator steam
 requirements  were determined based on the low-pressure steam flow
 rate and the  change in enthalpy between  the  entering feedwater
 and the steam leaving the  superheater.1^
      Another  energy savings  from converting  the DCE  recovery
 furnace system to an NDCE  recovery furnace is  the electricity
 saved by removing the BLO  unit.   The BLO  operating  energy savings
 were  determined by dividing  the  BLO electricity cost  savings
 presented in  Chapter 6  by  the unit  cost of electricity  in the
 U.  S.  EPA Handbook:  Control  Technologies  for Hazardous Air
 Pollutants.13
      The  exact methods  used  to determine  the energy  impacts of
 converting DCE  recovery furnace  systems to NDCE recovery  furnaces
 are presented  in  Section 5.2.3.2 and corresponding tables.
 5.1.3  Water Pollution  Impacts
      Some of the  control options for recovery furnaces, SDT's,
and lime kilns may have a significant impact on the amount of
wastewater generated, treated, and disposed.  If lime kilns
reduce PM emissions by replacing the existing scrubber with a new
ESP,  the existing scrubber discharge would be completely
eliminated.  On the other hand, if recovery furnaces reduce HC1
emissions by adding a packed-bed scrubber, a new scrubber
                               5-7

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discharge  would be generated.   If SDT's reduce  PM emissions by
replacing  the existing PM control device with a new scrubber, the
wastewater discharge may be increased because of the increased
amount  of  PM in the scrubber liquid.  The additional discharge
from  the recovery furnace and SDT scrubbers may simply be
recycled and used elsewhere in the plant.  Alternatively, the
scrubber discharge may require treatment and disposal.  The
wastewater disposal impacts and the exact methods used to
estimate them are discussed for each of these  control options in
their respective sections.
5.1.4  Solid Waste Disposal Impacts
      The recovery furnace and lime kiln PM  control options
include ESP's for PM  control and, therefore,  will generate  a PM
catch.   The PM  catch  from the ESP may  simply be recycled back
into the process.   Potential solid waste  disposal impacts  are
discussed for each  of these control options in their  respective
sections.
5.1.5  ni-.her Impact
       Dther  impacts <
                                 r—.—*  4-Vi <-*' ci c-s-n+- -vr^n f"\7"\t~ n OT1 W
        Impacts,  visual impacts,  odor impacts,
                                                     -WJ.J.a  a..u.v~.i.u.v*>_
aoise :  _
Irretrievable c
                            •x-P  -v~A« /"M T T~f"«O G
       doise  impacts may occur  as  a :



  :o accommodate the new or i
  jccur as  a result of 2
  i.e.,
        steam)  <
                            j  CLO Q. J- *—• *-* *•*••*- « *»* •*• —•———	^j — ^f
                            T-irr-raded APCD's.  Visual impacts may
                             .-,  _he amount of PM and moisture
                             •u— -.-i—i /-.IT-    ririi-it- n Trrna fl~s mav c

 i result of  i
 .mpacts i
                        ^ir^oY-rmQ TT?S emissions.
                                                    , U. S3 AtltAjr ^s^^*\*.^. V*.*-'
                ,= o,ari nn
                         __j_ \^\^^\^ j« -^^ WLkv' ^ —i™ —	
                         -.r^,-; i =v>i o fpc! om-i ssions  data.
                                                                V^VriL^S J-
  rere  ea:
  nformation v
       sily  estimated quantitatively.


                                 ^< +- -t rv»r^ +- /= V» r> T C! d
                                                  ^  O.J_\^»^J-*—
           jj^ VVcto ctv&.J.a.cix/j-^s *-^-* %—i-f **—«.— '- —	  .
           aantitatively;  therefore, only a qualitative c
                                                           ,\JL \^\^*+\mf*-
 mpacts q
 .f these impacts was done  for e
 pplicable.
,i j_ y  t-t *^ wfc»p^p—w •« »"»-P •-- — - —  — --

	j_ _——. n  ^.*-vi— -I r-N'M  T.rln ^ Y*O
        1DJ.6 .
        ior impacts  were determined for  the  gaseous organic I

                                 T"* O *-*»vi T r^ f^ *i ^^Vl C!  3
   ontrol options by comparing 1
   ontrol levels for those control options.
   CE and NDCE recovery furnaces were  d
                                                t baseline and  at
                                        .	•	J  & v.-.wt rpTD O earm C! C! T OT1 C!
                                     O

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 data (in parts per million [ppm]  as H2S)  provided by individual
 pulp and paper mills.6  These TRS concentrations were converted
 to annual TRS emissions using the ideal gas law and the model BLS
 firing rates, assuming 351 operating d/yr.   Total reduced sulfur
 emissions from BLO units are generally emitted in the range of
 0.04 to 0.06 kg/ADMP (0.08 to 0.13 lb/ADTP).14  A mid-range value
 of 0.05 kg/ADMP (0.10 lb/ADTP)  was used to  calculate the annual
 TRS emissions from model BLO units based on the model pulp
 production rates,  assuming 351 operating d/yr.   The mid-range
 value for BLO units was used because the only data available for
 BLO TRS emissions  were the bounds of the range.
 5.2  RECOVERY FURNACE CONTROL OPTIONS
      The following sections discuss the model environmental and
 energy impacts of  implementing control options  designed to reduce
 emissions of PM (as a surrogate for PM HAP's),  methanol (as a
 surrogate for gaseous organic HAP's),  and HC1.   These control
 options include PM controls (Section 5.2.1),  wet to dry ESP
 system conversion  (Section 5.2.2),  conversion of a DCE recovery
 furnace system to  an NDCE  recovery furnace  (Section 5.2.3),  and
 addition of  a packed-bed scrubber (Section  5.2.4).   Table  5-1
 presents the model  recovery furnace sizes and operating
 parameters.
 5.2.1   PM Controls
     Two PM  control  options were  evaluated  for model  NDCE
 recovery furnaces RF-1  through  RF-6  and model DCE  recovery.
 furnaces  RF-7  through RF-9.   The  control  options apply to  both
 new and existing recovery  furnaces  and are  described  below.
     One  PM  control  option that was  evaluated would reduce PM
 emissions from existing  recovery  furnaces to  the NSPS  level  of
 0.10 g/dscm  (0.044 gr/dscf).  The PM control option evaluated
would involve  replacing  or upgrading the  recovery  furnace  ESP.
     A  second  PM control option that was  evaluated  would reduce
PM emissions from existing recovery  furnaces to 0.034  g/dscm
 (0.015  gr/dscf).  This more stringent  PM  control option would
involve replacing or upgrading the recovery furnace ESP and
adding a packed-bed scrubber.  The second PM control option also
                               5-9

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applies to new recovery furnaces; the option could be used to
evaluate the impact on new sources subject to a more stringent
standard (0.034 g/dscm  [0.015 gr/dscf])  than the current NSPS.
     The PM control impacts for model NDCE recovery furnaces with
dry ESP systems  (i.e., RF-1 through RF-3) are assumed to be
identical to the PM control impacts for model NDCE recovery
furnaces with wet ESP systems  (i.e., RF-4 through RF-6) because
PM emissions are not affected by whether or not black liquor is
used in the ESP system.  The environmental and energy impacts
associated with the PM  control options are presented for the
model NDCE and DCE recovery furnaces in the following sections.
     5.2.1.1  air Pollution Impacts.  This section presents the
primary and secondary air  impacts  resulting from implementing PM
controls.
     5.2.1.1.1   Primary emissions.  Although  emission test data
from recovery furnace ESP's on PM  HAP performance are limited,
data collected  from  other  combustion sources  on the  relative
performance of  APCD's for. PM  and PM HAP's  indicate that systems
that achieve the greatest  PM  removal also  provide the best
performance for the  HAP portion  of the  PM.15   Therefore,  PM
performance can be used as a  surrogate  for PM HAP's.   Because
emission test  data  from recovery furnace ESP's indicate that  PM
emissions are  reduced with PM controls,  PM HAP emissions would
also be reduced.6  As stated in Section 5.1.1.1,  PM HAP emissions
 from recovery furnaces  were estimated to be 0.2 percent of  PM
based on a comparison of PM and PM HAP emission data for recovery
 furnaces.
      Tables 5-1 and 5-2 present the operating parameters for
 model NDCE and DCE recovery furnaces,  respectively.   Tables 5-3
 and 5-4 present PM concentrations and PM HAP emission factors for
 model NDCE and DCE recovery furnaces,  respectively.   Table 5-5
 presents the annual PM and PM HAP emission estimates.
 Figures 5-1 and 5-2 illustrate the annual PM emission estimates
 for model NDCE and DCE recovery furnaces, respectively.
      The baseline PM concentration for model NDCE recovery
 furnaces RF-la through RF-6a is 0.27 g/dscm  (0.12 gr/dscf).2  By
                                5-10

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 controlling PM emissions from baseline to the NSPS level
 (0.10 g/dscm [0.044 gr/dscf]),  PM emissions would be reduced by
 63 percent.  On an annual basis,  PM emissions would be reduced by
 about 227 to 593 Mg/yr (250 to 654 ton/yr); PM HAP emissions
 would be reduced by about 0.5  to 1.2 Mg/yr (0.5 to 1.3 ton/yr).
 By controlling PM emissions from baseline to a more stringent PM
 control level of 0.034 g/dscm  (0.015 gr/dscf),  PM emissions would
 be reduced by 88 percent.  On  an annual basis,  PM emissions would
 be reduced by about 313 to 818  Mg/yr (345 to 902 ton/yr);  PM HAP
 emissions would be reduced by  about 0.6 to  1.6  Mg/yr (0.7  to
 1.8 ton/yr).
      The baseline PM concentration for model NDCE recovery
 furnaces RF-lb through RF-6b is the NSPS PM level (0.10  g/dscm
 [0.044  gr/dscf]).   By controlling PM emissions  from the  NSPS
 baseline to 0.034 g/dscm (0.015 gr/dscf), PM emissions would be
 reduced by 66 percent.   On an annual basis,  PM  emissions would be
 reduced by about 86 to 225 Mg/yr  (95 to 248  ton/yr);  PM  HAP
 emissions would be reduced by about 0.2 to  0.4  Mg/yr (0.2  to
 0.5  ton/yr).
      The baseline PM concentration for  model  DCE recovery
 furnaces RF-7a  through RF-9a is 0.18 g/dscm  (0.08  gr/dscf).2   By
 controlling PM  emissions  from baseline  to the NSPS  level,  PM
 emissions  would be reduced by 45  percent.  On an annual basis,  PM
 emissions  would be reduced by about  65  to 194 Mg/yr  (71 to
 214  ton/yr);  PM HAP emissions would  be  reduced  by about 0.1  to
 0.4 Mg/yr  (0.1  to  0.4  ton/yr).   By controlling  PM emissions  from
baseline  to a more  stringent control  level of 0.034, g/dscm
 (0.015 gr/dscf}, PM emissions would  be  reduced  by 81 percent.   On
an annual basis, PM emissions would  be  reduced  by about 117 to
350 Mg/yr  (129  to  386 ton/yr);  PM HAP emissions would be reduced
by about 0.2 to  0.7 Mg/yr  (0.3  to  0.8 ton/yr).  The PM emission
reductions at both  PM control levels are lower  for model DCE
recovery furnaces than for model NDCE recovery  furnaces because
the baseline PM concentration for model DCE recovery furnaces  is
lower than that for model NDCE  recovery furnaces.
                              5-11

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     The baseline PM concentration for model DCE recovery
furnaces RF-7b through RF-9b is the NSPS PM level (0.10 g/dscm
[0.044 gr/dscf]).  By controlling PM emissions from the NSPS
baseline to 0.034 g/dscm  (0.015 gr/dscf), PM emissions would be
reduced by 66 percent.  On an annual basis, PM emissions would be
reduced by about 52 to 156 Mg/yr  (57 to 172 ton/yr) ; PM HAP
emissions would be reduced by about 0.1 to 0.3 Mg/yr  (0.1 to
0 . 3 ton/yr) .
     5.2.1.1.2  Secondary emissions.  Secondary emissions of PM,
S02, NOX, and CO generated under  the PM control options were
estimated for model NDCE  and DCE  recovery  furnaces.  Table 5-6
presents the annual secondary emission estimates.  As  shown in
the table, the secondary  emissions generated under the PM control
options are small.  The increases in secondary PM emissions are
especially insignificant  compared to the reductions  in primary PM
emissions.  The more  stringent  PM control  option includes both an
ESP upgrade and  the addition  of a packed-bed  scrubber.  The
increases  in  secondary S02  emissions under the more  stringent PM
control  option are insignificant compared  with  the  large
reductions  in primary S02 emissions  that result  from adding  the
packed-bed scrubber.   The reductions  in primary S02  emissions
using a packed-bed scrubber are presented
discussed in Section 5.2.4.1.1
                                           in Table 5-12 and
      5.2.1.2
                      Impacts.  The energy requirements of the PM
 control options were estimated for model NDCE and DCE recovery
 furnaces.  The energy requirements were estimated based on model
 SCA values for the ESP.  Tables 5-1 and 5-2 present the baseline
 and control level SCA values for model NDCE and DCE recovery
 furnaces, respectively.  Table 5-7 presents the annual energy
 requirements
 requirements
               As  shown  in the  table, the annual energy
              of  the  PM control  options are small,
 on a
      5.2.1.3  Water Pol.ini-.ion  Impacts.  Because the ESP operates
      dry basis,  no water pollution impacts  are associated with an
 ESP replacement or upgrade used to improve PM collection
 Section 5.2.4.3 presents a discussion of the water pollution
                                5-12

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 impacts resulting from adding a packed-bed scrubber (which is
 included in the more stringent PM control option).
      5.2.1.4  Solid Waste Disposal Impacts.   As mentioned in
 Chapter 2,  the PM catch from the recovery furnace  ESP is
 primarily Na2S04 (i.e.,  saltcake)  andNa2C03.  These chemicals
 are subsequently added to the concentrated black liquor in a mix
 tank (i.e.,  recycled back into the process)  in order to conserve
 chemicals.   Approximately 95 percent of the  Na2SO4  is recovered.
 The Na2S04  recycled back to the recovery furnace is reduced to
 Na2S,  a cooking liquor chemical,  in the reducing zone of the
 furnace.  Reprocessing of the Na2S and Na2CO3 into  cooking liquor
 continues in the SDT.   The recovery process  was assumed to have
 sufficient  capacity to absorb the  additional PM resulting from
 the ESP replacement or upgrade.  Thus,  no solid waste  disposal
 impacts are  expected with an ESP upgrade or  replacement.   Also,
 no  solid waste  disposal  impacts are expected with the  addition of
 a packed-bed scrubber (which is included in  the more  stringent PM
 control option).
     5.2.1.5  Other Impacts.   Limited  information was  available
 to  estimate  quantitatively impacts  such as noise, visual,  odor,
 and irreversible  and irretrievable  commitment of resources.
 Beneficial visual impacts  are  expected  to result from  the  reduced
 PM  emissions  coming  out  of  the recovery furnace  stack.  However,
 there also may be negative  visual impacts under  the more
 stringent PM  control option.   The more  stringent PM control
 option  would  involve adding a  packed-bed scrubber,  which would
add to  the moisture  (i.e.,  steam) coming out of the stack.
Adding a packed-bed  scrubber also would require additional
equipment (i.e., larger  fans to overcome pressure drops and
pumps)  that would increase  noise levels.  However,  these
incremental noise increases are expected to be small compared  to
the typical background noise levels at pulp and paper mills.  The
other impacts, if any, are  expected to be minimal as a result of
implementing the recovery furnace PM control  options.
                              5-13

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5.2.2  Wet to Dry ESP System Conversion
     Two control options were evaluated for reducing emissions of
gaseous organic HAP's such as methanol from existing NDCE
recovery furnaces.  These control options are (1) converting an
ESP system that uses unoxidized black liquor or HAP-contaminated
process water in the ESP bottom or PM return system  (referred to
as a wet ESP system) to an ESP system that uses  "clean" water
 (i.e., water uncontaminated with methanol and other gaseous
organic HAP's) in the ESP bottom or PM return system; and
 (2) converting a wet ESP system to a dry-bottom  ESP with a dry PM
return system  (referred to as a dry ESP system).  With these two
control options, the potential stripping of methanol and other
gaseous organic HAP's from the black liquor or HAP-contaminated
process water  in the ESP system would be eliminated.
     Only the  impacts for the second control option, converting
 from a wet  to  a dry ESP system, were evaluated.  This decision
was based on (1) the lack of emissions data from ESP systems  that
use  "clean"  water  in the ESP bottom or PM  return system; and
 (2) the fact that  very  few mills use water in the ESP system.
     The wet to dry ESP system  conversion  control option applies
 to model NDCE recovery  furnaces RF-4  through RF-6,  which
 represent existing NDCE recovery  furnaces  with wet  ESP  systems.
 These  models represent  existing NDCE  recovery  furnaces  only,
 because no  wet ESP systems  are  expected  to be  installed on new
 NDCE recovery furnaces.   The environmental and energy  impacts
 associated with this  control option are  presented in the
 following sections.
      5.2.2.1  Air Pollution Impacts:  Primary Emissions.  This
 section presents the primary air impacts for model  NDCE recovery
 furnaces RF-4 through RF-6 resulting from a wet to dry ESP system
 conversion.  As discussed below in Section 5.2.2.2, no additional
 electricity requirements are expected in order to operate a dry
 ESP system.  Therefore, no additional secondary emissions are
 expected to be generated from operation of a dry ESP system.
      The impact of the wet to dry ESP system conversion on
 emissions of gaseous organic HAP's was evaluated.  Table 5-3
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 presents the gaseous organic HAP emission factor for the model
 NDCE recovery furnaces.  Table 5-8 and Figure 5-3 present the
 annual gaseous organic HAP.emission estimates for model NDCE
 recovery furnaces.
      Gaseous organic HAP emissions are reduced by about
 72 percent with a wet to dry ESP system conversion.   On an annual
 basis,  gaseous organic HAP's are reduced by about 22 to 58 Mg/yr
 (25 to 64 ton/yr).   Approximately 49 percent of these reductions
 result from the reduction of methanol emissions.
      5-2-2.2  Energy Impacts.   The tradeoff in horsepower
 requirements between the wet and dry ESP systems  is  expected to
 be approximately equal.  For example,  a wet-bottom ESP design
 requires four agitators and  a recirculation pump,  whereas a
 dry-bottom ESP design requires four drives  for the drag system.16
 Therefore,  additional energy requirements are not  expected in
 order to operate dry ESP systems.
      5-2.2.3  Water  Pollution Impacts.   The conversion to wet ESP
 systems  that use "clean" water in the  ESP bottom or  PM return
 system was  not considered as a control  option for  the  reasons
 cited in Section 5.2.2.   Therefore,  no  water impacts are  expected
 for the  wet  to dry ESP system  conversion control option.
      5-2.2.4  Solid  Waste Disposal  Impacts.   The wet to dry ESP
 system conversion control option  is  not  expected to have  an
 effect on PM control  by the  ESP.  Furthermore, the PM  catch from
 the  ESP  is recycled back into  the process,  and the recovery
 process  is assumed to have sufficient capacity to absorb  the
 additional PM.  Therefore, no  solid  waste disposal impacts  are
 expected for this control option.
     5.2.2.5  Other Impacts.    Limited information was available
 to estimate  impacts such  as noise, visual, and irreversible and
 irretrievable commitment  of resources.  The impacts,  if any, are
 expected to be minimal under this control option.
     Odor impacts were determined for the wet to dry ESP system
 conversion control option by comparing TRS emissions  before and
after the ESP conversion.  Wet ESP systems are different from dry
ESP systems in that they have the capability of increasing TRS
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18
emissions in the furnace gas stream by stripping TRS from the
black liquor.17  Table 5-9 and Figure 5-4 present the annual TRS
emission estimates.
     The TRS emission estimates were derived from TRS emissions
data  (in ppm as H2S) provided by individual pulp and paper
mills.6  Baseline TRS emissions were estimated based on the
10 percent trimmed mean TRS concentration  (2.2 ppm) for NDCE
recovery furnaces assumed  to be equipped with wet ESP systems.
This  trimmed mean is a compromise between  the mean and 'the
median.  Using a trimmed mean with a moderate trimming
proportion, such as 10 percent, yields a measure which is neither
as sensitive to outlying values as the mean  (since any small
number  of outlying values  will be deleted  before averaging) nor
as insensitive as the median.  The 10 percent trimmed mean was
estimated by eliminating the  smallest 10 percent and the largest^
10 percent of the sample and  then averaging  what was left over.
Control level TRS emissions were estimated based on the available
TRS  concentration data  (1  ppm)  for an NDCE recovery furnace known
to be equipped with a dry  ESP system.6  Using these baseline  and
control level numbers,  it  was estimated that TRS emissions would
be reduced by approximately 55 percent  under the wet to dry ESP
system conversion  control  option.   On  an  annual basis,  the TRS
emissions  for models RF-4  through RF-6  would be reduced by about
3.0  to 7.8 Mg/yr (3.3  to 8.6  ton/yr).
 523  Conversion of a DCE Recovery Furnace  System to  an  NDCE
        Recovery Furnace
      Converting a DCE recovery furnace system to an NDCE  recovery
 furnace (or "low-odor conversion")  was evaluated as a control
 option for reducing emissions of gaseous organic HAP's from DCE
 recovery furnace'systems.   The conversion of a DCE recovery
 furnace system to an NDCE design involves removing the DCE and
 BLO unit,  adding a concentrator, and extending or replacing the
 boiler economizer.  Additional upgrades are included in the
 low-odor conversion control option, i.e., an ESP upgrade to
 improve PM collection and a wet to dry ESP system conversion to
 reduce gaseous organic HAP emissions.
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     At  stated in Chapter 3,  the DCE provides  some  PM control.
 Therefore,  with the  removal  of  the  DCE,  the  recovery  furnace  ESP
 often must  be  upgraded or replaced  during a  low-odor  conversion
 in  order to meet applicable  PM  emission  limits.   For  the purposes
 of  this  impact analysis,  an  ESP upgrade  PM control  option  that
 would maintain or reduce' PM  emissions to the NSPS level of
 0.10 g/dscm (0.044 gr/dscf)  has been evaluated for  existing DCE
 recovery furnaces that have  baseline PM  emissions at  or above the
 NSPS level.  This PM control  option applies  to model  DCE recovery
 furnaces RF-7a/7b through RF-9a/9b.   These models represent
 existing sources only,  because  no new DCE recovery  furnaces are
 expected to be built.
     A PM control option  that would reduce PM  emissions to
 0.034 g/dscm (0.015  gr/dscf)  has  also been evaluated  for DCE
 recovery furnaces that have  PM  emissions  at  or below  the NSPS
 level but greater than 0.034  g/dscm (0.015 gr/dscf).  This PM
 control  option includes an ESP  upgrade coupled with the addition
 of  a packed-bed scrubber  and  applies  to model  DCE recovery
 furnaces  RF-7b through RF-9b.
     The  environmental and energy impacts  associated  with  the
 low-odor  conversion  control option  are presented  for  model DCE
 recovery  furnaces  in the  following  sections.
     5-2.3.1   Air Pollution Impacts.   This section presents the
 primary and  secondary  air  impacts resulting  from  implementing the
 low-odor  conversion  control option.
     5.2.3.1.1   Primary emissions.  The impact on emissions of
 gaseous organic  HAP's  from converting  a DCE  recovery  furnace
 system to an NDCE  design and  converting the wet ESP system to a
 dry ESP system was evaluated.  The  impact  on PM and PM HAP
 emissions from upgrading the  ESP was also  studied.  Table  5-2
presents  the operating parameters, and Table 5-4 presents  the
model concentrations and emission factors  for the model DCE
recovery  furnaces.  Table  5-5 and Figure 5-2 present the annual
emission estimates for PM and PM HAP's; Table 5-8 and Figure 5-3
present the annual emission estimates  for gaseous organic HAP's.
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     The PM and PM HAP emission reductions achievable by
upgrading the ESP for the model DCE recovery furnaces were
discussed in Section 5.2.1.1.1.
       With a low-odor conversion, gaseous .organic HAP emissions
from model DCE recovery furnace systems  (including BLO units)
would be reduced by about 93 percent; on an annual basis,
emissions would be reduced by  69 to 206 Mg/yr  (76 to 227 ton/yr).
Approximately 70 percent of these reductions result from the
reduction of methanol emissions.
     5.2.3.1.2  Secondary emissions.  Secondary emissions
generated under the low-odor conversion  control option were
estimated for model DCE recovery furnaces.  Table 5-10 presents
the annual secondary emission  estimates.  The  secondary emission
reductions resulting from the  removal of the BLO unit and the
secondary emission increases resulting from the implementation  of
the low-odor conversion PM controls are  discussed separately
below.
     As a result  of the removal of the BLO unit, secondary
emissions are reduced  for model DCE recovery furnaces RF-7
through RF-9.  The secondary PM emission estimates  range  from
-567 to  -1,100 kg/yr  (-1,250 to  -2,430 Ib/yr); the  secondary S02
emission estimates range from  -2,770  to  -5,350 kg/yr  (-6,110 to
-11,800  Ib/yr);  the secondary  NOX emission estimates  range  from
-1,100  to  -2,130  kg/yr (-2,430 to -4,700 Ib/yr); and  the
secondary  CO emission  estimates  range from  -2,090 to  -4,050 kg/yr
 (-4,600  to -8,920 Ib/yr).
     The procedures  for estimating secondary  emissions  associated
with the PM control  options  were presented previously in Section
5.2.1.1.2  and are the  same for both converted and unconverted
model  DCE recovery furnaces;  therefore,  only  the differences
between the converted and unconverted models  that  impact
 secondary emissions are discussed below.  The model SCA values
 for upgraded ESP's on DCE recovery furnaces  converted to the NDCE
 design are higher than the model SCA values  for ESP's on
 unconverted DCE recovery furnaces.  Removal  of the DCE, which
 removes a portion of the PM prior to the ESP,  is the primary
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 reason for increasing the existing ESP's SCA after the low-odor
 conversion.   The increased SCA results in an increase in the
 electricity requirements,  and,  subsequently,  an increase in
 secondary emissions.   Although the gas flow rates from converted
 DCE's  are lower than  the gas  flow rates from unconverted DCE's
 (which reduces the fan electricity requirements),  the associated
 decrease  in electricity requirements  is more than offset by the
 larger increase in electricity requirements due to the higher
 SCA.   Therefore,  the  secondary emission estimates presented in
 Table  5-10 for converted DCE  recovery furnaces  are higher than
 those  presented in Table 5-6  for unconverted DCE recovery
 furnaces.   For example,  the incremental PM secondary  emissions
 for model  RF-7a for the NSPS  PM control option  are equal to  90
 kg/yr  (199 Ib/yr)  for a converted DCE recovery  furnace and
 45 kg/yr  (100  Ib/yr)  for an unconverted DCE recovery  furnace.
 Although  secondary PM emissions  are higher when the PM control
 options are  applied to the  converted  DCE recovery furnaces than
 to the unconverted DCE recovery  furnaces,  the secondary emissions
 are insignificant  when compared  to the  primary  PM emission
 reductions achieved with the  PM  control options.
     5-2-3-2   Energy  Impacts.    Energy  impacts  for the low-odor
 conversion control  option were estimated for model DCE recovery
 furnaces.  The  energy impacts include electricity  impacts from
 both the elimination  of  the BLO  unit  and the PM controls and
 steam  energy impacts  from the furnace conversion.  Table 5-2
 presents the baseline  and control  level  SCA values used  to
 estimate the PM control  electricity impacts for each model DCE
 recovery furnace.  Table 5-11 presents  the  annual estimates of
 the energy impacts.
     5.2.3.2.1  Electricity impacts.  The incremental  electricity
 impacts from the elimination of  the BLO unit and the low-odor
conversion PM controls are discussed separately below.
     With  the elimination of the BLO unit, the BLO operating
electricity savings were estimated to range from -2,450 to
 -4,750 MWh/yr for models RF-7 through RF-9.  The operating
electricity savings were estimated by dividing the annual BLO
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operating cost savings by the unit cost of electricity.  The
annual BLO operating cost savings are discussed in Chapter 6 and
range from $147,000/yr to $285,000/yr for models RF-7 through
RP-9.  The unit cost of electricity is $0.06/kilowatt-hour
(KWh).13  Most of the BLO operating costs  (about 60 percent) is
for power to operate the blowers and pumps.  The remaining
40 percent is for operating the reheater.
      The procedures for estimating the electricity requirements
associated with the PM control options were presented previously
in Section 5.2.1.1.3 and are  the same for  both converted and
unconverted model DCE recovery furnaces; therefore, only the
differences between the converted and unconverted models that
impact  electricity requirements are discussed below.  As
discussed in Section 5.2.3.1.2, the model  SCA values for upgraded
ESP's on converted DCE recovery furnaces are higher than the
model SCA values  for ESP's  on unconverted  DCE recovery furnaces.
The  increased  SCA results  in  an increase  in the  electricity
requirements.  Although  the gas flow  rates from  converted  DCE
recovery furnaces are  lower than  the  gas  flow rates  from
unconverted DCE  recovery furnaces  (which  reduces the  fan
electricity requirements),  the  associated decrease in electricity
requirements  is  more than offset  by the larger'increase in
electricity requirements due  to the higher SCA.   Therefore, the
electricity requirements for the  PM control  options are higher
 for the converted DCE recovery furnaces shown in Table 5-11 than
 for the unconverted DCE recovery furnaces shown in Table 5-7.
 For example,  the electricity requirements for model RF-7a for the
 NSPS PM control option are equal to 391 MWh/yr for a converted
 DCE furnace and 191 MWh/yr for an unconverted DCE recovery
 furnace.  Although electricity requirements are higher when the
 PM control options are applied to the converted DCE recovery
 furnaces than to the unconverted DCE recovery furnaces, these
 requirements are insignificant when compared to the energy
 savings obtained from removing the BLO unit or the energy
 requirements of'pulp and paper mills.
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      5.2.3.2.2   Steam energy  impacts.   Implementing  the  low-odor
 conversion  control  option may increase  steam energy  production.11
 Table 5-11  presents the  estimates  for steam energy production  for
 unconverted DCE  recovery furnaces  and the net  increase in steam
 energy production after  a low-odor conversion.  The  increased
 steam energy production  for model  DCE recovery furnaces  RF-7
 through RF-9 ranges from 1.97 x 108 megajoules per year  (MJ/yr)
 (1.87 x 105 million Btu  per year  [MM Btu/yr])  to 5.91 x  108 MJ/yr
 (5.61 x 105 MM Btu/yr).
      The net increase in steam energy production was estimated to
 be equal to the  steam production from a low-odor conversion minus
 the steam requirements to operate  the concentrator.
      To determine the steam production from a  low-odor
 conversion, the  increase in the thermal efficiency that  results
 from  the low-odor conversion  was estimated.  The heat input to
 the system  was calculated using a  BLS heat content of
 13,900 kJ/kg (6,000  Btu/lb) of BLS fired.19  The increase in the
 thermal efficiency  that  results from a low-odor conversion was
 estimated to be  10 percentage points, based on average thermal
 efficiencies of  56 percent for DCE recovery furnaces and
 66 percent  for NDCE  recovery  furnaces.20'21  Therefore, the
 increase in the  amount of heat input that can be converted to
 steam with  a low-odor conversion was estimated by multiplying  the
 heat  input  by the 10  percentage point increase in thermal
 efficiency.  The heat  input value was divided by the thermal
 efficiency  for a power boiler  (about 85 percent)  to determine  the
 required energy  input  for a power boiler.   The required energy
 input is equivalent  to the increased steam production.   The
 increased steam production was converted to annual steam
production  estimates  for each model DCE recovery furnace,
assuming 351 operating d/yr.   The energy input for the power
boiler can be converted to fuel savings by using the heat
contents for specific power boiler fuels.
     To determine the concentrator steam requirements,  the steam
flow for each model DCE recovery furnace was multiplied by the
change in enthalpy between the entering feedwater (439.8  kJ/kg
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[189.2 Btu/lb])  and the steam leaving the superheater
(3,095.0 kJ/kg  [1,331.5 Btu/lb]).12  The model steam flows were
based on a steam flow of approximately 4,500 kg/hr (10,000 ib/hr)
of low-pressure steam for a 1.1 million kg BLS/d
(2.4 million Ib BLS/d) furnace.22  The steam flow was
extrapolated for each model DCE recovery furnace size, assuming
that steam usage is proportional to the amount of black liquor
concentrated.
     5.2.3.3  Water Po3 int-.i on Impacts.  The conversion to ESP
systems that use "clean" water in  the ESP bottom or PM return
system was not  evaluated as a control option for the reasons
cited in Section'5.2.2.  Therefore, no water impacts are expected
from the wet  to dry ESP system conversion included under the
low-odor conversion control option.  The water pollution impacts
resulting from  adding a packed-bed scrubber  (included under the
more stringent  PM  control  option)  are discussed in
Section 5.2.4.3.
     5.2.3.4  Solid Waste  Disposal Impacts.  -As noted  in
Section 5.2.1.4, the  PM catch from the  ESP  is  recycled back  into
the process.  The  recovery process was  assumed to have sufficient
capacity  to absorb the additional  PM resulting from upgrading the
ESP.   Therefore, no  solid waste  impacts are expected to be
associated with the  low-odor conversion PM control  options.
      5.2.3.5  nt-.her Impacts.   Odor impacts  were determined for
 the low-odor conversion control  option by comparing TRS  emissions
before and after the low-odor conversion.   Table 5-9 presents the
baseline TRS emission estimates  for unconverted model DCE
 recovery furnace systems  (which include BLO units)  and the TRS
 emission reductions for converted model DCE recovery furnaces.
 Figure 5-4 illustrates the annual TRS emission estimates.
      In order to determine the baseline TRS emissions from DCE
 recovery furnace systems, the baseline TRS emissions from DCE
 recovery furnaces and BLO units were combined.  The DCE recovery
 furnace baseline TRS emission estimate was derived from TRS
 emissions data  (in ppm as H2S) provided by individual pulp and
 paper mills.6  Based on the available TRS emissions data, the
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 10  percent  trimmed mean TRS concentration for DCE recovery
 furnaces  is approximately 12 ppm.6  The BLO unit TRS emission
 estimate  was derived from the pulp and paper NSPS supporting
 document.14  Based on the bounds of TRS values given in the
 supporting  document,  a median.value of 0.05 kg/ADMP
 (0.10  Ib/ADTP)  was used as the baseline TRS emission estimate for
 BLO units.   The control level TRS emission estimate (1  ppm)  for
 converted DCE recovery furnaces was derived from TRS emissions
 data provided for  an NDCE recovery furnace known to be  equipped
 with a dry  ESP system.6  Emissions of  TRS compounds are expected
 to  be  reduced by approximately 94 percent under the low-odor
 conversion  control option.   On an annual basis,  the TRS emission
 reductions  would be 22 to 67 Mg/yr (25- to 74  ton/yr).
     Limited information was available to estimate  quantitatively
 impacts such as noise,  visual,  and irreversible and irretrievable
 commitment  of resources.   Beneficial visual impacts are expected
 under  the low-odor conversion control  option.   The  beneficial
 visual impacts  include the  reduction in PM emissions, the
 elimination of  the BLO vent gas stacks,  and the reduction  in the
 amount of moisture (i.e.,  steam)  coming out of  the  stack with  the
 elimination of  the DCE.   This reduction in moisture content  could
 be  completely eliminated if the more stringent  PM control  option
 is  implemented.  The more stringent PM control  option includes a
 packed-bed  scrubber, which  would increase  the moisture  content in
 the stack.  Adding a packed-bed scrubber also requires  additional
 equipment (i.e., larger fans  to overcome pressure drops and
 pumps)  that would  increase  noise levels.   However,  these
 incremental noise  increases are expected to be  small compared to
 the typical background  noise  levels at pulp and paper mills.  The
 other impacts,  if  any,  are  expected to be minimal as a  result of
 implementing the low-odor conversion control option.
 5.2.4  Addition of  Packed-Bed Scrubber
     The addition  of a packed-bed scrubber  downstream of the ESP
 is included in  two  of the control options examined  for  recovery
 furnaces.   These control  options are (1) the use of an ESP plus a
packed-bed scrubber to meet an  outlet PM emission level of
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0.034 g/dscm (0.015 gr/dscf); and (2) the use of a packed-bed
scrubber to reduce HC1 emissions from recovery furnaces.
     The impacts of combining an ESP upgrade or ESP replacement
with a packed-bed scrubber to control PM emissions to
0.034 g/dscm (0.015 gr/dscf)  are presented in Section 5.2.1.  The
impacts presented in the sections below are based on the use of a
packed-bed scrubber to control HC1 emissions from recovery
furnaces.  The applicable model recovery furnaces for the packed-
bed scrubber HC1 control option are model NDCE and DCE recovery
furnaces RF-1 through RF-9.  The model DCE recovery furnaces
include both DCE recovery furnaces converted to the NDCE design
and unconverted DCE recovery furnaces.  Tables 5-1 and 5-2
present the sizes and operating parameters for model NDCE and DCE
recovery furnaces, respectively.
     5.2.4.1  Air Pollution  Impacts.  This section presents the
primary and secondary air impacts resulting from adding a
packed-bed scrubber to control HC1 emissions from model recovery
furnaces.
     5.2.4.1.1  Primary  emissions.   The impact of the packed-bed
scrubber control option  on emissions of HC1 and another acid gas,
S02, was evaluated for model recovery furnaces.  Tables 5-3 and
5-4  present the HC1 and  S02  emission factors for model  NDCE and
DCE  recovery furnaces, respectively.  Table 5-12 presents the
annual  emission estimates  for  HC1 and S02; Figures  5-5  and  5-6
illustrate  the annual emission estimates  for HC1 and S02,
respectively.
     The incremental  HC1 emission reductions for model  NDCE and
converted model DCE  recovery furnaces RF-1 through  RF-9 range
from 8.3 to 36 Mg/yr (9.1 to 40 ton/yr).   The  incremental HC1
emission reductions  for the  unconverted model  DCE  recovery
 furnaces RF-7  through RF-9 are slightly lower  because  of
different furnace characteristics  (i.e.,  higher model  gas  flow
 rates).  The HC1  emission reductions for unconverted models RF-7
 through RF-9  range from 7.8  to 24 Mg/yr (8.6  to 26  ton/yr).
      The incremental S02 emission reductions  for model NDCE and
 converted model DCE recovery furnaces RF-1 through RF-9 range
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 from 59  to 384 'Mg/yr (65  to 423  ton/yr).  'The incremental S02
 emission reductions  for the unconverted model DCE recovery
 furnaces RF-7 through RF-9  are slightly higher because the
 control  level S02  emission  factor associated with DCE  recovery
 furnaces is lower  than the  control level  SO2 emission  factor
 associated with  NDCE recovery furnaces.   The SO2  emission
 reductions for unconverted  models RF-7  through RF-9  range from 74
 to 221 Mg/yr (81 to  244 ton/yr).   Overall,  the S02 emission
 reduction achievable with a packed-bed  scrubber is approximately
 10 times greater than the HC1 emission  reduction.
      Based on information from a  scrubber manufacturer, emissions
 of gaseous HAP's such as  methanol,  formaldehyde,  and acetaldehyde
 may be reduced with  a packed-bed  scrubber,  but no emissions data
 were available to  estimate  potential reductions for  these
 HAP's.23  Therefore,  HC1  and S02  were assumed to  be  the only
 gaseous  pollutants reduced  with a packed-bed scrubber.
      5.2.4.1.2   Secondary emissions.  Secondary emissions
 generated under  the  packed-bed scrubber control option were
 estimated for model  recovery furnaces.  The  baseline secondary
 emissions for the  packed-bed scrubber control  option are  equal  to
 zero (i.e.,  no packed-bed scrubber at baseline).   Table 5-13
 presents the incremental  secondary emissions  relative  to  baseline
 for  each model recovery furnace.
      The increases in  secondary PM emissions  from operating a
 recovery furnace packed-bed  scrubber are  insignificant compared
 to the reductions  in primary PM emissions from  implementing the
 recovery furnace PM  control  options.  The secondary PM emission
 estimates  for model NDCE  and converted DCE recovery furnaces RF-1
 through  RF-9  range from 138  to 594 kg/yr  (304 to  1,310 Ib/yr).
 The  secondary PM emission estimates for unconverted model DCE
 recovery  furnaces RF-7  through RF-9 range from  145 to 435 kg/yr
 (320  to  960  Ib/yr).
     The  increases in secondary S02 emissions from operating a
 recovery  furnace packed-bed  scrubber are insignificant compared
 to the reductions in primary S02 emissions from operating a
packed-bed scrubber.   For model NDCE/converted DCE recovery
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furnaces RF-1 through RF-9, the secondary S02 emission estimates
for the packed-bed scrubber control option range from 671 to
2,900 kg/yr  (1,480 to 6,390 Ib/yr) .  The secondary SO2 emission
estimates for unconverted model DCE recovery furnaces RF-7
through RF-9 range from 708 to 2,120 kg/yr (1,560 to
4,670 Ib/yr) .
     For model NDCE and converted DCE recovery furnaces RF-1
through RF-9, the secondary NOX emission estimates range from 266
to 1,150 kg/yr  (587 to 2,540 Ib/yr).  For unconverted model DCE
recovery furnaces RF-7 through RF-9, the secondary NOX emission
estimates range from 281 to 844 kg/yr  (619 to 1,860 Ib/yr).
     For model NDCE and converted DCE recovery furnaces RF-1
through RF-9, the secondary CO emission estimates range from 503
to 2,190 kg/yr  (1,110 to 4,820 Ib/yr).  For unconverted model DCE
recovery furnaces RF-7 through RF-9, the secondary CO emission
estimates range from 531 to 1,600 kg/yr  (1,170 to 3,520 Ib/yr).
     5,2.4.2 Kngray Impacts.  The  increases  in  energy impacts
 for the  packed-bed scrubber control  option  were  determined for
 model  recovery furnaces.   The baseline  energy level  for  the
 packed-bed scrubber control option is equal to zero  (i.e., no
 packed-bed scrubber at baseline).   Table 5-14 presents the
 incremental energy impacts relative to  baseline.
     The energy impacts for the packed-bed  scrubber  control
 option range from 593 to 2,570 MWh/yr for NDCE/ converted DCE
 models RF-1 through RF-9 and 625 to 1,870 MWh/yr for unconverted
 DCE models RF-7 through RF-9.
      5,2.4.3  Water Pollution Impacts.   Adding a packed-bed
 scrubber creates a new wastewater stream for recovery furnaces,
 thereby affecting the water balance at  the  mill.  Whether there
 are any significant wastewater disposal impacts  for this option
 depends on whether or not the scrubber discharge could be
 recycled and reused elsewhere in the mill.   Wastewater impacts
 were estimated for model recovery furnaces  assuming there was no
 prior recycle or reuse.  Tables 5-1 and 5-2 present the model
 wastewater flow rates used to estimate wastewater impacts for
 model NDCE and DCE recovery  furnaces,  respectively.  The baseline
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 wastewater impacts for the packed-bed scrubber control option are
 equal to zero (i.e.,  no packed-bed scrubber at baseline).
 Table 5-15 presents the incremental wastewater impacts relative
 to baseline.
      Information was  available from two sources to determine the
 amount of wastewater  generated by the packed-bed scrubber  control
 option.   Wastewater flow rate values were estimated using
 procedures in the OAQPS Control Cost Manual and using wastewater
 flow rate values provided by a scrubber manufacturer.9'23   The
 wastewater flow rate  values calculated using the OAQPS Control
 Cost Manual are presented in Chapter 6 in Table 6-23.   A scrubber
 manufacturer  provided wastewater flow rate values of 21.24,
 53.07,  and 84.79 liters per minute (L/min)  (5.61,  14.02, and
 22.40 gallons per minute [gpm])  for three model recovery furnaces
 with scrubber inlet gas flow rates of 47.2,  118,  and 189 m3/sec
 (100,000,  250,000,  and 400,000  acfm),  respectively.23   The
 wastewater flow rates from the  scrubber manufacturer were
 corrected to  correspond to the  model sizes used in this impact
 analysis  and  then were averaged with the wastewater flow rates
 obtained  using the OAQPS Control Cost Manual  to determine the
 average wastewater impacts for  the packed-bed scrubber control
 option.   The  increased wastewater impacts  presented below for  the
 recovery  furnace packed-bed scrubber control  option are
 insignificant  compared to the reduced wastewater impacts
 presented in  Section  5.5.1.3 for the  lime  kiln PM control option,
 which involves replacing existing wet  scrubbers  with ESP's.
      The  wastewater impacts  for  NDCE/converted DCE models RF-1
 through RF-9  range  from 6.1  to 26  million  liters per year  (L/yr)
 (1.6  to 7.0 million gallons per  year  [gal/yr]).  The wastewater
 impacts for unconverted DCE models  RF-7  through RF-9 range from
 6.3 to 19 million L/yr  (1.7 to 5.0 million gal/yr).
      5.2.4.4  Solid Waste Disposal  Impacts.  No solid waste
disposal  impacts are  expected from adding a packed-bed  scrubber.
      5.2.4.5  Other Impacts.  Adding a packed-bed scrubber
requires additional equipment (i.e., larger fans to  overcome
higher pressure drops and pumps) that would increase, noise
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levels.  However, these incremental noise increases are expected
to be small compared to the typical background noise levels at
pulp and paper mills.  Limited information is available to
estimate quantitatively the visual, odor, and other impacts.
However, because adding a packed-bed scrubber increases the
moisture  (i.e., steam) coming out of the stack, there may be
negative visual impacts.  Beneficial odor impacts may result from
the reduction in acid gas emissions.  The other impacts, if any,
are expected to be minimal as a result of implementing this
control option.
5.3  BLACK LIQUOR OXIDATION UNIT CONTROL OPTION
     Two  control options,  (1) conversion of a DCE recovery
furnace system to an NDCE recovery  furnace and  (2) incineration
of BLO vent gases, were evaluated for controlling gaseous organic
HAP emissions from air-sparging BLO units.  The environmental and
energy  impacts of the  first option--converting DCE recovery
furnace systems  to NDCE recovery furnaces--were presented in
Section 5.2.3.   The  following sections present the environmental
and energy  impacts of  the  second BLO  control  option--incineration
of BLO vent gases.   This BLO  control  option applies  to  model  BLO
units  BLO-l through  BLO-3, which represent existing  BLO units
associated  with  DCE  recovery  furnaces.   These models represent
only  existing BLO units because no new DCE recovery  furnace
systems with  BLO units are expected to be installed.
5.3.1  Air  Pollution Impacts
      This section presents the primary  and secondary air impacts
 for model BLO units  resulting from implementing the  BLO vent  gas
 control option.
      5.3.1.1  Primary Emissions.   The impact of the  BLO vent  gas
 control option on emissions of  gaseous  organic HAP's is discussed
 below for the model BLO units.   Table 5-16 presents  the operating
 parameters, as well as the model emission factors,  for each model
 BLO
unit.  Table 5-17 and Figure 5-7 present the gaseous organic
 HAP annual emission estimates for model BLO units
      Gaseous organic HAP
                     emissions are assumed to be reduced by
 about 98 percent from the model BLO units with the incineration
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 of  BLO  vent  gases  in a power boiler or other incineration device.
 For models BLO-1 through BLO-3,  gaseous organic  HAP  emissions  are
 estimated to be reduced by 29 to 86 Mg/yr (31 to 94  ton/yr).
 Approximately 85 percent of these reductions result  from the
 reduction of methanol emissions.
      5.3.1.2  Secondary Emissions.   The secondary emissions
 generated under the  BLO vent gas control option  were estimated
 for the model BLO  units.   The baseline secondary emissions for
 the BLO vent gas control option  are equal to zero (i.e.,  no BLO
 control at baseline).   Table 5-18 presents the incremental
 secondary emissions  relative to  baseline.
      For  models BLO-1 through BLO-3, the secondary PM emission
 estimates range from 400  to 1,210 kg/yr (883  to  2,670 Ib/yr);  the
 secondary NOX emission estimates  range from 776  to 2,340  kg/yr
 (1,710  to 5,160 Ib/yr);  and the  secondary CO  emission estimates
 range from 1,470 to  4,440  kg/yr  (3,240 to 9,780  Ib/yr).
     The  secondary SO2  emission  estimates associated with
 controlling  BLO vent  gas  emissions  range from 9,710  to
 29,200  kg/yr (21,400  to 64,300 Ib/yr)  for models  BLO-1 through
 BLO-3.  As discussed  in Section  5.1.1.2,  the  secondary SO2
 emissions associated  with  the  BLO vent gas  control option include
 (1) S02 emissions  resulting from  the generation of energy
 required  to  collect and incinerate  the BLO vent gases and (2)  S00
                                                                £
 emissions generated when the TRS  in the  BLO vent  gases is
 combusted.   All of the  TRS  collected is  assumed to be combusted.
Also,  all of  the S02  that  is formed from the  combustion of TRS
 compounds is  assumed  to be  emitted  to  the atmosphere; this
assumption is a worst-case  assumption  since many power boilers
are equipped with scrubbers  for S02 control.
5-3.2   Energy Impacts
     The energy impacts for the BLO vent gas  control option were
estimated for the model BLO units.  The baseline energy impacts
for the BLO vent gas control option are equal to zero (i.e.,  no
BLO control at baseline).  Table 5-19 presents the incremental
energy impacts relative to baseline.
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     The model energy impacts were estimated based on the
information provided by an individual mill regarding the total
horsepower requirements to operate the mill's BLO vent gas
control equipment.10  The energy requirements for the BLO control
system at this mill were scaled for the model BLO units, assuming
a direct relationship between BLO vent gas flow rate and energy
requirements.  The mill has a BLO vent gas flow rate of
7.7 m3/sec  (16,327 acfm).6  Based on information supplied by the
mill, 980 kilowatts  (kW)  (100 horsepower  [hp]) are required to
operate the mill'water booster pump motor, 29 kW  (3 hp) to
operate the BLO condenser condensate pump motor, and 3,900 kW
 (400 hp) to operate  the BLO off gas. blower motor.10  The annual
energy requirements  were estimated assuming  the BLO system
operates 8,424 hr/yr and range from 1,720 to 5,210 MWh/yr for
models BLO-1  through BLO-3.
5.3.3  Water  Pollution  Impacts
     Although some condensate is  collected  from the BLO vent
gases,  the  quantity is  negligible.24   Therefore,  the water
 impacts  for the  BLO control  option are expected to be  negligible.
 5.3.4   Solid Waste Disposal  Impacts
     No solid waste impacts  are  expected to be associated with
 the BLO control  option.
 5.3.5   Otiher Impacts
      Beneficial  odor impacts are expected to result from
 implementing the BLO vent gas control option and are discussed
 below for the model BLO units.  Table 5-20 and Figure 5-8 present
 the annual TRS emission estimates.
      As discussed in Section 5.1.5,  a mid-range value of
 0.05 kg/ADMP  (0.10 Ib/ADTP)  was used to calculate the baseline
 TRS emissions from BLO units.14  The baseline TRS emissions are
 assumed to be reduced by about 98 percent with the incineration
 of BLO vent gases in a power boiler or other incineration device.
 On an annual basis, the TRS emissions were  estimated to be
 reduced by about 4.1 to 12 Mg/yr (4.6 to 14 ton/yr) for models
 BLO-1 through BLO- 3.
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      Beneficial visual impacts are expected to result from the
 elimination of BLO vent gas stacks.   Limited information was
 available to estimate impacts such as noise and irreversible and
 irretrievable commitment of resources.  The impacts,  if any, are
 expected to be minimal as a result of implementing the BLO vent
 gas control option.
 5.4  SMELT DISSOLVING TANK CONTROL OPTIONS
      This section discusses the environmental and energy impacts
 resulting from implementing the SDT PM control options.   Two PM
 control options that would reduce PM emissions from SDT's have
 been evaluated.  The first option would reduce PM emissions from
 existing SDT's to the NSPS level of  0.10 kg/Mg (0.20  Ib/ton)  of
 BLS.   The second option would reduce PM emissiqns from existing
 SDT's to a more stringent level of 0.06 kg/Mg (0.12 Ib/ton)  of
 BLS;  scrubbers installed on new SDT's would also  be required to
 meet  a PM level of 0.06 kg/Mg (0.12  Ib/ton)  BLS.
      For mills with existing SDT scrubbers,  the environmental
 impacts of both PM control options were estimated based  on
 replacing the  existing scrubber with a new scrubber.   These
 impacts were estimated for SDT models SDT-1  through SDT-4.   The
 environmental  impacts  of  installing  scrubbers  on  new  SDT's under
 the second, more  stringent PM control option also apply  to SDT-1
 through SDT-4.
      For mills  with existing  SDT mist eliminators, the
 environmental  impacts  of both PM control options  were estimated
 based on replacing the  existing  mist  eliminator with a new
 scrubber.   These  impacts were  estimated for  SDT models SDT-5
 through SDT-7.  The  impacts of  installing new mist eliminators
were  not  examined  because mist eliminators are not assumed  to be
 installed on new SDT's.
 5.4.1   PM Controls
     Table  5-21 presents the model SDT sizes and  operating
parameters  for the PM control options.  The environmental and
energy  impacts associated with the control options are discussed
in the  following sections.
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     5.4.1.1  Air Pollution Impacts.  This section presents the
primary and secondary air impacts for model SDT's resulting from
the implementation of the PM control options.
     5.4.1.1.1  Primary emissions.  Although emission test data
from SDT's on PM HAP performance are limited, available
information indicates that APCD's that achieve the greatest PM
removal also provide the best performance for the HAP portion of
the PM.15  Therefore, PM performance can be used as a surrogate
for PM HAP's.  Because emission test data from SDT scrubbers
indicate that PM emissions are reduced with PM controls, PM HAP
emissions would also be reduced.6   As stated in Section  5.1.1.1,
PM HAP emissions from SDT's were estimated to be 0.06 percent of
PM based on a comparison  of PM and  PM HAP emission data  for
SDT's.
     Table 5-21 presents  the model  PM emission factors for models
SDT-1  through SDT-7.  The baseline  PM emission factor  is
0.18 kg/Mg  (0.37  Ib/ton)  BLS  for model  SDT's with  scrubbers
 (models  SDT-1 through SDT-4).2  The baseline PM  emission factor
is 0.23  kg/Mg  (0.46 Ib/ton)  BLS  for model  SDT's  with mist
eliminators  (models SDT-5 through SDT-7).2   The  control  level PM
emission factors  are 0.10 kg/Mg (0.20  Ib/ton)  BLS  and
 0.06 kg/Mg (0.12  Ib/ton)  BLS.
      Table 5-22 and Figure 5-9  present the annual  PM and PM HAP
 emission estimates.  By controlling PM emissions from a baseline
 of 0.18 kg/Mg (0.37 Ib/ton)  BLS to a control level of  0.10 kg/Mg
 (0.20 Ib/ton)  BLS, PM emissions would be reduced by 46 percent
 from models SDT-1 through SDT-4.   On an annual basis,  PM
 emissions would be reduced by 'about 12 to 53 Mg/yr  (13 to
 58 ton/yr); PM HAP emissions would be reduced by about 0.007 to
 0.03 Mg/yr (0.008 to 0.03 ton/yr)-.
      By controlling PM .emissions from 0.18 kg/Mg  (0.37 Ib/ton)
 BLS to a more stringent  control level of 0.06 kg/Mg (0.12 Ib/ton)
 BLS, PM emissions would  be reduced by 68 percent from models
 SDT-1 through SDT-4.  On an annual basis, PM emissions would be
 reduced by about  18 to 78 Mg/yr  (20 to 86 ton/yr);  PM HAP
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 emissions  would be reduced by about  0.01  to 0.05  Mg/yr (0.01  to
 0.05  ton/yr).
      By  controlling PM emissions  from a baseline  of  0.23  kg/Mg
 (0.46 Ib/ton)  BLS  to a control level of 0.10 kg/Mg  (0.20  Ib/ton)
 BLS,  PM  emissions  would be reduced by 57  percent  from models
 SDT-5 through  SDT-7.   On an annual basis,  PM emissions would  be
 reduced  by about 19 to 56 Mg/yr (21  to 62 ton/yr); PM HAP
 emissions  would be reduced by about  0.01  to 0.03  Mg/yr (0.01  to
 0.04  ton/yr).
      By  controlling PM emissions  from 0.23  kg/Mg  (0.46 Ib/ton)
 BLS to a more  stringent control level of  0.06 kg/Mg  (0.12 Ib/ton)
 BLS,  PM  emissions  would be reduced by 74  percent  from models
 SDT-5 through  SDT-7.   On an annual basis,  PM emissions would  be
 reduced  by about.24 to 73 Mg/yr (27  to 81 ton/yr); PM HAP
 emissions  would be reduced by about  0.01  to 0.04  Mg/yr (0.02  to
 0.05  ton/yr).
      5.4.1.1.2   Secondary emissions.   As  discussed in the
 following  section,  there is only  a small  increase in  energy
 requirements from  implementing PM controls  for SDT's.  The
 increases  in energy requirements  from a scrubber  replacement  were
 considered negligible;  because the secondary emissions were
 estimated  based on the increase in energy requirements, they  were
 also  considered negligible and are not presented  in this  impact
 analysis for models SDT-l through SDT-4.  A different  scrubber
 design,  rather  than a  higher pressure drop,  is used in this
 impact analysis  to estimate the impacts for improved  PM control
 for SDT  scrubbers.
     Although small, the difference  in pressure drop between  the
 existing mist eliminator and the  new design scrubber  replacing it
 was considered  large enough to justify estimating the  increase in
APCD energy requirements for those model  SDT's replacing  existing
mist  eliminators with  new wet  scrubbers (models SDT-5  through
 SDT-7).  The increases  in secondary  emissions were then estimated
 for those  SDT models based on  the  increase  in APCD energy
 requirements.  Table 5-23  presents the annual secondary emission
estimates  for models SDT-5  through SDT-7.   As shown in the table,
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the increases in secondary emissions associated with replacing an
existing mist eliminator with a new scrubber are small; the
increases in secondary PM emissions are especially insignificant
compared to the reductions in primary PM emissions associated
with the SDT PM control options.
     5.4.1.2  Knerov Impacts.  For those SDT's replacing existing
scrubbers with new scrubbers, the resulting increases in energy
requirements are not included in this impact analysis; the
increases are considered negligible.  The pressure drop for the
existing scrubber design, i.e., 12 mm Hg  (6.5 in. of H2O), is
only slightly lower than the pressure drop for the new scrubber
design, i.e., 13 mm Hg  (7 in. H20),6'25  A different scrubber
design, rather than a higher pressure drop, is used in this
impact analysis to estimate the impacts for improved PM control
for SDT scrubbers.  Therefore, no  energy  impacts are presented
for models SDT-1 through SDT-4.
     As discussed in the previous  section, the difference  in
pressure drop between the existing mist eliminator and the new
design scrubber replacing it was  considered large enough to
justify estimating the  incremental APCD energy requirements for
models SDT-5 through SDT-7.  Based on  information from mills, the
baseline pressure drop  for  existing  mist  eliminators  is  1.3 mm Hg
 (0.7  in. H20); the pressure drop  for the  new  scrubber design  is
estimated  to be 13 mm Hg  (7 in. H20).6'25 .The increase  in.
pressure drop  from  1.3  to  13 mm Hg (0.7 to  7  in. H2O)  was  used  to
estimate the  incremental  energy requirements.  Table  5-24
presents the  annual  energy requirements for models  SDT-5  through
SDT-7.  As shown  in the table,  the incremental energy
requirements  associated with replacing an existing  mist
eliminator with a new scrubber are small.
      5.4.1.3   water Pollution Impacts.  By increasing the amount
 of PM removed from the exhaust gases,  the SDT PM control options
would increase the amount of PM in the blowdown.   Slowdown rates
would have to increase because of the greater amount of  PM,
 thereby increasing the amount of wastewater generated.  Because
 wastewater from SDT scrubbers and mist eliminators would
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 typically be  allowed to drain into the  SDT to  react  with the
 smelt,  the additional wastewater generated under this  control
 option  is expected  to be reused.   The SDT  is assumed to  have
 sufficient capacity to absorb the additional wastewater  and PM
 resulting from implementing the  PM control options;  therefore,  no
 wastewater impacts  are expected.
      5.4.1.4   Solid Waste Disposal Impacts.  No  solid  waste
 disposal  impacts are expected from implementation of the PM
 control options for SDT's.
      5.4.1.5   Other Impacts.   Beneficial visual  impacts  are
 expected  from the reduced PM emissions  coming  out of the stack.
 Replacing an  existing mist  eliminator with an  SDT scrubber  that
 has a higher  pressure drop  would  require a larger fan  to overcome
 the higher pressure drop.   The larger fan  would  increase noise
 levels.   However, these  incremental noise  increases  would be
 small compared to typical background noise levels at pulp and
 paper mills.   Limited information is available to determine the
 other impacts;  however,  the impacts, if any, are  expected to be
 minimal as  a  result of implementing the SDT PM control options.
 5.5   LIME  KILN CONTROL OPTIONS
      This  section discusses the environmental and energy impacts
 resulting  from implementing control options designed to  reduce PM
 emissions  from lime kilns.  Two PM control options were  evaluated
 for existing  and new lime kilns.   These control options  are
 described below.
      One PM control  option  that has been evaluated for existing
 lime  kilns would reduce PM  emissions to the NSPS  level of
 0.15  g/dscm (0.067  gr/dscf).   For  existing lime kilns with wet
 scrubbers,  the  control option would involve replacing the
 existing scrubber with an ESP.  The actual control device (i.e.,
 ESP or high-efficiency scrubber)  selected by a particular mill
would actually be site-specific.   The impacts for this PM control
 option were estimated  for model lime kilns LK-1 through LK-3,
which represent existing lime kilns controlled with wet
 scrubbers.
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     Based on PM emissions data supplied by mills,  lime kilns
controlled with ESP's already achieve a PM level of 0.15 g/dscm
(0 067 gr/dscf).6'25  Therefore, the impacts for the control
option reducing PM emissions to.0.15 g/dscm  (0.067 gr/dscf) were
not estimated for lime kilns controlled with ESP's  (represented
by models LK-4 through LK-6).
     A second PM control option that was evaluated for new and
existing lime kilns would reduce PM emissions to 0.023 g/dscm
(0.010 gr/dscf).  For existing lime kilns with wet scrubbers, the
control option would involve replacing the existing scrubber with
an ESP; impacts would be estimated for model lime kilns LK-1
through LK-3.  For  existing lime kilns with  ESP's,  the control,
option would involve upgrading  the existing  ESP.  For new  lime
kilns, the  control  option would involve  installing  a new ESP
capable of  achieving the  0.023  g/dscm (0.010 gr/dscf)  PM level.
The  impacts for upgrading or installing  an ESP  were estimated  for
model lime  kilns  LK-4  through LK-6.   The actual control device
selected  by a  particular mill would  actually be site-specific.
5.5.1  PM Controls
      Table 5-25 presents  the model  lime  kiln sizes  and operating
parameters used in estimating the impacts of the lime  kiln PM
 control options.   The  environmental  and energy impacts associated
 with the control  options  are presented in the following sections.
      5.5.1.1  A-iy Pollution Impacts.  This section presents the
 primary and secondary air impacts estimated for each model lime
 kiln.
      5.5.1.1.1  P-rimarv emissions.   Emission test data from lime
 kiln ESP's on PM HAP performance are limited.  As mentioned in
 Section 5.4.1.1.1, PM performance can be used as a surrogate for
 PM HAP's,  and because emission test data from lime kiln ESP's
 indicate that PM emissions  are reduced with PM controls,  PM HAP
 emissions  would also be reduced.6  As stated in Section 5.1.1.1,
 PM HAP emissions from lime kilns were estimated to be 1.4 percent
 of PM based on a comparison of PM and PM HAP emission data  for
 lime kilns.
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      Table 5-25 presents the PM emission concentrations for the
 PM control options.  Table 5-26 and Figure 5-10 present the
 annual PM and 'PM HAP emission estimates.
      The baseline PM concentration is 0.27 g/dscm  (0.12 gr/dscf)
 for model lime kilns with wet scrubbers (models LK-1 through
 LK-3).    By controlling PM emissions from a baseline of
 0.27 g/dscm (0.12 gr/dscf)  to an NSPS control level of
 0.15 g/dscm (0.067 gr/dscf), PM emissions would be reduced by
 44 percent from models LK-1 through LK-3.   On an annual basis, PM
. emissions would be reduced by about 16 to 53 Mg/yr (18 to
 58 ton/yr);  PM HAP emissions would be reduced by about 0.2 to
 0.7 Mg/yr (0.2 to 0.8 ton/yr).
      By controlling PM emissions from 0.27 g/dscm  (0.12 gr/dscf)
 to a more stringent control level of 0.023 g/dscm
 (0.010  gr/dscf),  PM emissions would be reduced by 92  percent from
 models  LK-1  through LK-3.   On an annual basis,  PM emissions would
 be reduced by  about 33  to 110 Mg/yr (37 to 121 ton/yr); PM HAP
 emissions would be reduced  by about 0.5 to 1.5 Mg/yr  (0.5  to
 1.7 ton/yr).
      The baseline PM concentration for model  lime kilns with
 ESP's (models  LK-4 through  LK-6)  is the NSPS  PM level
 (0.15 g/dscm [0.067 gr/dscf]).   By controlling PM emissions from
 0.15  g/dscm  (0.067 gr/dscf)  to  a control level  of 0.023 g/dscm
 (0.010  gr/dscf),  PM emissions would be reduced by 85  percent from
 models  LK-4  through LK-6.   On an annual  basis,  PM emissions would
 be  reduced by  about 17  to 57  Mg/yr (19  to  63  ton/yr);  PM HAP
 emissions would be reduced  by about 0.2  to  0.8  Mg/yr  (0.3  to
 0.9 ton/yr).
      5.5.1.1.2  Secondary emissions.   The incremental  secondary
 emissions were  estimated based  on  the  difference  between the
 baseline  and control level APCD  energy requirements for lime
 kilns.  Table 5-27  presents the annual secondary  emission
 estimates associated with the PM control options.
     Less energy is needed to operate ESP's than  to operate
 scrubbers.  Therefore,  if the existing scrubber is  replaced with
an ESP to improve PM control, APCD  energy requirements  would be
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reduced.  Because the secondary emissions were estimated based on
the APCD energy requirements, they would also be reduced.  As
shown in Table 5-27, the reductions in secondary emissions are
small; the reductions in secondary PM emissions are especially
small compared to the reductions in primary PM emissions under
the lime kiln PM control options.  The reductions'are smaller
under the more stringent PM  control option since that option
would require a larger ESP with more energy requirements.
     If the existing ESP is  upgraded to reduce PM emissions to a
more stringent level, secondary emissions would be increased
because the upgraded ESP would have higher energy requirements.
As shown in Table 5-27, the  increases in secondary emissions
resulting from the  ESP upgrade are small; the increases  in
secondary PM  emissions are especially insignificant  compared  to
the reductions in primary PM emissions associated with  this more
stringent PM  control  option.
      5.5.1.2  Knar-ay  Impacts. Table  5-28 presents the  annual
APCD  energy requirements associated with the  lime kiln  PM control
options.
      Because  ESP's  require  less  energy  to operate than  scrubbers,
energy requirements are  reduced for  lime kilns  that  reduce PM
emissions by  replacing the  existing  scrubber with an ESP.  The
baseline energy requirements for the existing scrubber  were
determined  based on a baseline pressure drop of 39 mm Hg
 (21 in. H20) for
                 lime  kiln scrubbers.6  The  energy  requirements
 for ESP's
          controlling PM emissions  to 0.15  g/dscm (0.067  gr/dscf)
 were
     determined based on an SCA of 90  m2/(m3/sec)
  (460 ft2/!,000 acfm) from an ESP with long-term PM emission data
 below 0.15 g/dscm  (0.067 gr/dscf).6'25  The energy requirements
 for ESP's controlling PM emissions to 0.023 g/dscm
  (0.010 gr/dscf) were determined based on an SCA of
 220 m2/(m3/sec)  (1,120 ft2/!,000 acfm) from an ESP with long-term
 PM emission data at or
                       below 0.023 g/dscm (0.010 gr/dscf)
                                                           6,25
      As shown in Table  5-28, the reductions in energy
   •quirements associated with  replacing an existing scrubber with
             small.   The reductions  are even  smaller when baseline
an ESP are
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 PM emissions  are  controlled even further,  to  a  level  of
 0.023  g/dscm  (0.010  gr/dscf);  additional  energy is  required  for
 the ESP,  thereby  reducing  the  energy  savings  from replacing  the
 existing  scrubber with  an  ESP.
     Energy requirements are increased  if  existing  ESP's are
 upgraded  to improve  PM  control.   An increase  in SCA from
 90  m2/(m3/sec)  (460  ft2/!,000  acfm) to  220 m2/(m3/sec)
          A
 (1,120  ft^/1,000  acfm)  was  used  to estimate the increase in
 energy  requirements  associated with an  ESP upgrade.   As shown in
 Table 5-28, the increases  in energy requirements  associated  with
 an  ESP  upgrade are small.
     5.5.1.3  Water  Pollution  Impacts.  If a  wet  scrubber is
 replaced  with an  ESP to improve  PM control, the wastewater stream
 from the  scrubber would be  eliminated,  thereby  affecting the
 water balance at  the mill.   Whether there  would be  any
 significant reduction in wastewater disposal  for  this option
 would depend  on whether or  not the scrubber discharge was
 previously recycled  and reused.  Wastewater impacts were
 estimated for model  lime kilns assuming there was no prior
 recycle or reuse.
     The  wastewater  impacts were estimated based  on a factor of
 2,250 kilograms of wastewater per oven-dried megagram of pulp (kg
 wastewater/ODMP)  (4,500 pounds of wastewater per  oven-dried  ton
 of pulp [Ib wastewater/ODTP]) for lime kiln scrubber blowdown.21
 This factor was converted to annual wastewater  impacts using
 conversion factors of 1.0 kg H20/L (8.345  Ib H20/gal)  and
 0.9 ODMP/ADMP (0.9 ODTP/ADTP) and multiplying by  the product of
 the model ADMP/d  (ADTP/d)  and 351 operating d/yr.  Table 5-29
presents  the annual wastewater impacts for model  lime kilns LK-1
 through LK-3.   With the replacement of existing wet scrubbers
with ESP's,  the wastewater discharge would be reduced; the
reductions in wastewater impacts were estimated to range from
 -226 to -709 million L/yr (-60  to -187 million gal/yr).
     Because ESP's operate on a dry basis, no water pollution
impacts are associated with lime kiln PM control if the control
involves an ESP upgrade.
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     5.5.1.4  Solid Waste Disposal Impacts.  Dry PM catch would
be generated if the existing scrubber is replaced with an ESP to
improve PM control.  Also, a larger PM catch would be generated
if the existing ESP is upgraded to improve PM control.  As stated
in Chapter 2, existing lime kilns with ESP's return the PM catch
directly to the lime kiln.  The lime kiln  is expected to have
sufficient capacity to absorb the PM catch resulting from
implementing the lime kiln PM control options.
     5.5.1.5  nt-.her Impacts.  Beneficial visual impacts are
expected as a result of  the reduced PM emissions and reduced
moisture  (i.e., steam) coming out of the stack.  The moisture
content in the stack is  lower with an ESP  as the control device
than with a scrubber.  If the existing scrubber is replaced with
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to overcome the higher pressure drop would be eliminated,  thereby
reducing noise impacts.   However, the reduction in noise is not
expected to be noticeable due to  the high  background  noise levels
typically associated with pulp  and paper mills.  Limited
information  is available to  determine the  other impacts, but  the
impacts,  if  any,  are  expected to  be minimal as a result of
implementing  the  lime  kiln  PM control options.
                                5-40

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TABLE  5-7.    ENERGY  IMPACTS  FOR  PM  CONTROL FOR  MODEL  RECOVERY
                                        FURNACESa
Model
recovery
furnaces
NDCE
RF-1a/4a
RF-1b/4b
RF-2a/5a
RF-2b/5b
RF-3a/6a
RF-3b/6b
DCE
RF-7a
RF-7b
RF-8a
RF-66
RF-9a
RF-9b
Baseline
energy impacts,
MWh/yr
1,700
2,030
3,070
3,650
4,430
5,270
829
. 1,020
1,380
1,700
2,490
3,070

Control
option
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.015 gr/dsd) (c)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.01 5 gr/dscf) (c)
PM controls-0.034 g/dscm (0.01 5 gr/dscf) (c)
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.10 g/dscm (0.044 gr/dscf) (b)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
PM controls-0.034 g/dscm (0.015 gr/dscf) (c)
Control level
energy impacts,
MWh/yr
2,030
2,850
2,850
3,650
5,120
5,120
5,270
7,410
7,410
1,020
1,640
1 1,640
1,700
2,730
2,730
3,070
4,920
4,920
Incremental
energy impacts,
MWh/yr (c)
330
1,150
820
580
2,050
1,470
840
2,980
2,140
191
811
620
320
1,350
1,030
580
2,430
1,850
  (a) Numbers in parentheses represent negative values, indicating that energy impacts are reduced by that amount
   PM control energy impacts at baseline and at 0.044 gr/dscf = [0.00018 x model gas flowrate x 1 in. H2O pressure
   drop x 8,424 hr/yr x 1 MWh/1,000 kWh] + [0.00194 x model gas flow rate x SCA x 8,424 hr/yr x 1 MWh/1,000 kWh].
   PM control energy impacts at 0.015 gr/dscf = [0.00018 x model gas flow rate x 4 in. H2O pressure drop x 8,424 hr/yr
   x 1 MWh/1,000 kWh] + [0.00194 x model gas flow rate x SCA x 8,424 hr/yr x 1 MWh/1,000 kWh] + [0.746 kW/hp x
   Equid flow rate x 60 ft head x spec. grav. H2O x 1/70% pump motor effici. x 8,424 hr/yr x 1 MWh/1,000 kWh].
  (b) Impacts were estimated for ESP upgrade/replacement
  (c) Impacts were estimated for ESP upgrade/replacement plus packed-bed scrubber.
                                           5-63

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                                           5-75

-------
TABLE 5-14.   ENERGY IMPACTS FOR HCL CONTROL FOR MODEL RECOVERY
                               FURNACES51
Model
recovery
furnaces
NDCE/con-
verted DCE
RF-1/4/8
RF-2/5/9
RF-3/6
RF-7
Unconverted
DCE
RF-7
RF-8
RF-9

Control
option


Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber


Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
Incremental
energy impacts,
MWh/yr

AQQ
yoo
1,770
2,570
593


625
1,040
1,870
        (a) Baseline energy impacts are equal to zero.  Packed-bed
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           gravity H2O x hp/3,960 gal x 1/(70% pump motor effic.) x
           1 MWh/1,000 kWh x 8,424 hr/yr].
                                   5-76

-------
TABLE 5-15a (METRIC).   WASTEWATER  IMPACTS  FOR HCL CONTROL FOR
                     MODEL RECOVERY FURNACES3-

Model
recovery
furnaces
NDCE/con-
verted DCE
RF-1/4/8
RF-2/5/9
RF-3/6
RF-7
Unconverted
DCE
RF-7
RF-8
RF-9


Control
option

Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber

Packed-bed scrubber
Packed-bed Scrubber
Packed-bed scrubber
Incremental
wastewater
impacts,
million L/yr

10
18
26
6.1

6.3
10
19
        (a) Metric equivalents in this table were converted from the
          calculated English unit values given in Table 5-15b. See
          Table 5-15b for footnotes, which include calculations.
                                5-77

-------
TABLE 5-15b  (ENGLISH) .   WASTEWATER IMPACTS FOR HCL CONTROL FOR
                     MODEL RECOVERY FURNACESa

Model
recovery
urnaces
vIDCE/con-
verted DCE
RF-1/4/8
RF-2/5/9
RF-3/6
RF-7 	
Unconverted
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RF-7
RF-8
RF-9 	
, 	 — 	
Control
	 option 	

Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
..

Packed-bed scrubber
Packed-bed scrubber
Packed-bed scrubber
	 	 — 	 	 	
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wastewater
impacts,
million gal/yr
__ 	 	 " ~~

2.7
4.8
7.0
1.6
_ 	 1 — 	 	

1.7
2.8
5.0
	 . — 	 	 	 	
           (a) Wastewater impacts are zero at baseline; therefore,
             control level and incremental wastewater impact numbers
             are the same. Control level wastewater impacts =
             wastewater flow rate (gpm) x 60 min/hr x 8,424 hr/yr.
                                  5-78

-------
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-------
 TABLE  5-18a  (METRIC).   SECONDARY  EMISSIONS  FOR  MODEL BLACK
                         LIQUOR  OXIDATION UNITSa
Mode!
BLO
units
BLO-1
BLO-2
BLO-3
Control
option
BLO vent gas control
BLO vent gas control
BLO vent gas control
Incremental emissions, kg/yr
PM
400
807
1.210
SO2
9,710
16,900
29,200
NOx
776
1,560
2,340
CO
1,470
2,970
4,440 -.
    (a) Metric equivalents in this table were converted from the calculated English unit values
      given in Table 5-18b. Refer to Table 5-18b for footnotes.
TABLE 5-18b  (ENGLISH).   SECONDARY  EMISSIONS FOR  MODEL  BLACK
                         LIQUOR OXIDATION UNITSa
Model
BLO
units
BLO-1
BLO-2
BLO-3

Control
option
BLO vent gas control
BLO vent gas control
BLO vent gas control

Incremental emissions, Ib/yr
PM
883
1,780
2,670
SO2
21,400
37,200
64.300
NOx
1,710
3,450
5,160
CO
3,240
6,540
9,780
    (a) Secondary emissions are zero at baseline; therefore, control level and incremental
      secondary emission numbers are the same. Secondary emissions for PM, NOx, and CO
      were estimated based on energy and emission factors for PM, NOx, and CO. Secondary
      emissions for SO2 were estimated based on (1) energy requirements and the emission
      factor for SO2 and (2) 1.88 Ib of SO2 generated for each Ib of TRS combusted.
      Calculations for energy impacts are presented in Table 5-19. Emission factors =
      0.15 Ib PM/MM Btu; 0.73 Ib SO2/MM Btu; 0.29 Ib NOx/MM Btu; and 0.55 Ib CO/MM Btu.
                                     5-81

-------
TABLE 5-19.   ENERGY IMPACTS  FOR MODEL BLACK  LIQUOR
                    OXIDATION  UNITS
Model
BLO
units
BLO-1
BLO-2
BLO-3
Control
option
BLO vent gas control
BLO vent gas control
BLO vent qas control
Incremental
energy impacts,
MWh/yr
1,720
3,480
5,210
    (a) BLO control energy impacts = 503 hp x 0.746 kW/hp x
      8,424 hr/yr x 1 MWh/1,000 kWh x model vent gas flow
      rate/16,327 acfm. The hp requirements and vent gas
      flow rate were provided by an individual mill that
      controls vent gas emissions.
                             5-82

-------
 TABLE  5-20a (METRIC).   TOTAL  REDUCED SULFUR COMPOUND EMISSIONS
               FOR MODEL  BLACK  LIQUOR OXIDATION UNITSa
Model
BLO
units
BLO-1
BLO-2
BLO-3
Baseline
emissions,
Mg/yr
4.2
7.0
13
Control
option
BLO vent gas control
BLO vent gas control
BLO vent gas control
Control level
emissions,
Mg/yr
0.08
0.14
0.25
Emission
reduction,
Mg/yr
4.1
6.9
12
Emission
reduction,
%
98
98
98
   (a) Metric equivalents in this table were converted from the calculated English unit values
     given in Table 5-20b. Refer to Table 5-20b for footnotes.
TABLE 5-20b  (ENGLISH).   TOTAL  REDUCED  SULFUR COMPOUND EMISSIONS
               FOR MODEL  BLACK LIQUOR OXIDATION  UNITS
Model
BLO
units
BLO-1
BLO-2
BLO-3
Baseline
emissions,
ton/yr (a)
4.6
7.7
14
Control
option
BLO vent gas control
BLO vent gas control
BLO vent gas control
Control level
emissions,
ton/yr (b)
0.09
0.15
0.28
Emission
reduction,-
ton/yr
4.6
7.6
14
Emission
reduction,
' %(b)
98
98
98
  (a) The baseline TRS emissions for BLO units are based on an average TRS emission factor
    of 0.10 to/ADTP (assuming an average 3,400 Ib BLS/ADT of bleached and unbleached pulp).
  (b) The control level TRS emissions for BLO units are based on 98 percent TRS control.
                                    5-83

-------
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TABLE 5-24.   ENERGY REQUIREMENTS  FOR MODEL SMELT DISSOLVING TANKS
Model
SDT's
SDT-5
SDT-6
SDT-7
Baseline
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MWh/yr (a)
10
17
30
Control
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PM control (c)
PM control (c)
PM control (c)
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150
270
  (a) Baseline mist eliminator energy impacts = 0.00018 x model inlet gas flow
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  (b) Incremental energy impacts = (control level scrubber energy impacts) -
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  (c) Impacts were estimated based on replacement of existing mist eliminator with
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                                   5-89

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-------
 TABLE  5-29a  (METRIC).   WASTEWATER IMPACTS FOR MODEL LIME KILNSa
Model
lime
kilns
LK-1
LK-2
LK-3

Control
option
,PM control (b)
PM control (b)
PM control (b)
Incremental
wastewater impacts,
million L/yr
(226)
(484)
(709)
               (a) Metric equivalents in this table were converted
                 from the calculated English unit values given in
                 Table 5-29b.  Refer to Table 5-29b for footnotes,
                 which include calculations.
               (b) Impacts were estimated based on replacement of
                 the existing scrubber with a new ESP.
TABLE 5-29b  (ENGLISH).   WASTEWATER IMPACTS  FOR MODEL LIME KILNS*
Model
lime
kilns
LK-1
LK-2
LK-3

Control
option
PM control (b)
PM control (b)
PM control (b)
Incremental
wastewater impacts,
million gal/yr
(60)
(128)
(187)
               (a) Control level wastewater impacts are zero. Therefore,
                 incremental impacts are equal to baseline. Numbers
                 in parentheses represent negative values, indicating
                 that wastewater impacts are reduced by that amount.
                 Wastewater impacts = 4,500 Ib/ODTP x 0.9 ODTP/ADTP
                 x ADTP/d x 351 d/yr x gal/8.345 Ib
               (b) Impacts were estimated based on replacement of
                 the existing scrubber with a new ESP.
                                    5-97

-------
5.6  REFERENCES FOR CHAPTER 5

 1.  Memorandum from Holloway, T. and Nicholson, R., MRI, to
     Telander, J., EPA/MICG.  October9, 1996.  Nationwide Costs,
     Environmental Impacts, and Cost-Effectiveness of Regulatory
     Alternatives for Kraft, Soda, Sulfite, and Semichemical
     Combustion Sources.

 2.  Memorandum from Holloway, T., MRI, to the Project file.
     June 14, 1996.  Summary of PM and HAP Metals Data.

 3   Telecon.  Soltis, V., MRI, with Sanders, D.,_Andersen 2000,
     Inc.  August 11, 1993.  Cost and efficiency information
     about HC1 control for recovery furnaces.

 4.  Telecon.  Soltis, V., MRI, with Bruno, J., AirPol,  Inc.
     July 2,  1993.  Information about scrubbers used to  control
     HC1 emissions.

 5   Someshwar, A. and J.  Pinkerton.  Wood Processing  Industry.
     In: Air Pollution Engineering Manual, Air  & Waste Management
     Association.  Buonicore, A.  and W. Davis (eds.).  New York,
     Van Norstrand Reinhold.  1992.  pp. 835-849.

     Memorandum  from  Soltis,  V.,  MRI, to  the  project file.
     April  3,  1995.   Kraft and  Soda Pulp  Mill Combustion Sources
     Data Base.

     Memorandum  from  Holloway,  T., MRI, to the project file.
     May  3,  1995-  Sulfur Dioxide Control by  Recovery  Furnace
     Scrubbers.

     Memorandum  from  Holloway,  T., MRI, to the project file.
     May  21, 1996.  Secondary Emission Calculations.

     OAQPS  Control  Cost Manual.   4th Edition.  U.  S.
     Environmental  Protection Agency.   Research Triangle Park,  NC
     Publication,No.  EPA-450/3-90-006.   January 1990.

     Letter and attachments from Black,  C.,  Champion
      International Corp., Courtland,  AL,  to  Crowder,  J., EPA/ISB.
     June 10, 1993.   Response to request  for information on costs
      for the BLO vent gas control system at  the Champion facility
      in Courtland,  AL..

 11   Kirby, M.  Economic and Process Considerations in the Use of
      Oxvaen for Black Liquor Oxidation.  Union Carbide Canada
      Limited.  Ontario, Canada.  (Presented at the 21st Pulp and
      Paper ABCP Annual Meeting.  Sao Paolo,  Brazil.
      November 21-25,  1988.)  10 p.
 6.
 7.
 8.
 9.
10,
                                5-98

-------
15.
16.
 12.   Stultz,  S.  and J. Kitto (eds.).   Steam:  Its Generation and
      Use.   40th Edition.   Babcock & Wilcox Co.   New York.   1992.
      Chapter 26,  pp. 3-7.
                                       e
 13.   Handbook:  Control Technologies for Hazardous Air Pollutants.
      U.  S.  Environmental  Protection Agency.   Cincinnati,  OH.
      Publication No. EPA-625/6-91-014.   June  1991.   Chapter 4.

 14.   Proposed Standards of Performance  for Kraft Pulp Mills.   In:
      Standards  Support and Environmental Impact Statement.
      Volume 1.   U.  S.  Environmental Protection  Agency.  Research
      Triangle Park,  NC.  Publication No. EPA-450/2-76-014-a.
      September  1976.  p.  2-9.

      Mcllvane, R.   Removal of Heavy Metals and  Other Utility  Air
      Toxics.   (Presented  at the EPRI  Hazardous  Air Pollutant
      Conference.   1993.).

      Letter from Hurt,  R.,  Radian Corp.,  to Holbrook,  J. and
      Bringman, L.,  Environmental Elements Corp.   July 23, 1985.
      Facsimile cover letter discussing utility  and  maintenance
      costs  for wet-  vs. dry-bottom ESP designs.

 17.   Memorandum  from Eddinger,  J.,  EPA/ISB, to  Durkee, K.,
      EPA/ISB.  July 8,  1983.  Meeting minutes from  the April  14,
      1993 meeting between  kraft pulp  mill representatives,  the
      National Council  of the Paper Industry for Air and Stream
      Improvement, Inc., and the U.  S. Environmental  Protection
      Agency.  Discussion of problems  mills have  with TRS pickup
      in wet-bottom  ESP's using  unoxidized black liquor.
      Attachments.

 18.   Devore, J.  Probability and Statistics for  Engineering and
      the Sciences.   Brooks/Cole Publishing Co.   Monterey,
      California.  1982.  pp. 15-17.

 19.   Someshwar, A.   Compilation of  "Air  Toxic" Emission Data  for
      Boilers, Pulp Mills, and Bleach  Plants.  National Council of
      the Paper Industry for Air and Stream Improvement, Inc.  New
      York.  Technical Bulletin  No. 650.   June 1993.   128 p.

20.   Garner, J., Jaako Poyry.   Conversion to Low Odor Improves
      Recovery Boiler Efficiency and Life.  Pulp  and  Paper.
      63(7):91-95.  July 1989.

21.  Green,  R. and G. Hough (eds.).  Chemical Recovery in the
     Alkaline Pulping Process.    3rd Edition.  Prepared by the
     Alkaline Pulping Committee  of the Pulp Manufacture Division.
     Atlanta, GA, TAPPI Press,   1992.  196 p.

22.  Telecon.  Soltis, V.,  MRI,  with Oscarsson,  B., Gotaverken
     Energy Systems, Inc.   December 16,  1993.   Concentrator steam
     costs.
                              5-99

-------
23
24,
25
Letter and attachments from Sanders, D., Andersen 2000,
Inc   to Soltis, V., MRI.  November 9, 1993.  Preliminary
proposal for three separate quench and packed-tower
absorption systems to control hydrochloric acid gas
emissions from recovery furnaces at kraft pulp and paper
mills.

Memorandum from Nicholson, . R. and Holloway, T., MRI, to
Slander, J., EPA/MICG.  September 6, 1995.  Trip Report for
S.D. Warren Co., Muskegon, MI.

Memorandum from Holloway,  T.,_MRI, to the project file.
July 16, 1996.  State of Washington PM Data for Kraft
Recovery Furnaces, Smelt Dissolving Tanks, and Lime Kilns.
                                5-100

-------
   6.0  MODEL PROCESS UNIT CONTROL AND ENHANCED MONITORING COSTS

      This chapter discusses the costs of controlling HAP
 emissions from new and existing combustion sources at kraft and
 soda pulp and paper mills.   The costs of each control option
 discussed in Chapter 4 are  presented for the  individual  model
 combustion process units.   Also presented are the  costs  of the
 enhanced monitoring options discussed in Chapter 4.   The enhanced
 monitoring options are methods  of demonstrating continuous
 compliance with the control options.   The total nationwide costs
 associated with each control option  are  presented  in a separate
 memorandum.1
      Section 6.1 of this  chapter presents the capital and annual
 costs  for each  control option for model  process units
 representing recovery furnaces,  BLO  units,  SDT's,  and lime kilns.
 Section  6.2  discusses the costs  of the enhanced monitoring
 options.   Section 6.3 contains  the references  cited  in this
 chapter.
 6.1  CONTROL OPTION COSTS
     This  section discusses  the  general  costing approach  used to
develop  capital  and annual  costs  for each control  option  and
presents  the  estimated capital and annual costs of each control
option as  applied to the model process units.    Section 6.1.1
describes  the general  costing approach.   Section 6.1.2 provides
the capital and  annual  costs associated with each  recovery
furnace control  option  and model recovery furnace.
Sections 6.1.3,  6.1.4,  and 6.1.5 provide  the capital and annual
costs applicable  to  the control options for model BLO units,
SDT's and lime kilns, respectively.
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6.1.1
               Posting Approach
     A number of assumptions were made in deriving the costs for
the control options.  The year 1991 was used as the base year for
all costs.  Capital costs were adjusted to 1991 dollars using the
Chemical Engineering Plant Cost Index or the Consumer Price
index, whichever was applicable.2'3  Operating and maintenance
personnel were assumed to work 3 shifts per day, 8 hours per
shift, for 365 d/yr, which is equivalent to 8,760 operating
hr/yr.  All process units were assumed to operate 24 hr/d, for
351 d/yr, which is equivalent to 8,424 operating hr/yr.  This
operating time accounts  for  14 days of scheduled shutdown
annually for maintenance and repair.  These 14 days could be
combined into a single 2-week annual  shutdown period to provide
sufficient time for  the  modifications and upgrades both to
existing equipment  and APCD's needed  to  comply with the control.
options.   If  the  scheduled 2 -week  shutdown did not provide
sufficient time  for the  modifications and upgrades, then  pulp
production losses were  calculated  for the number  of days  beyond
 the 2-week shutdown that were needed to finish the work,
      The procedure used for estimating pulp production :
 described in the following section.  The general approaches
 to develop capital and annual control costs are provided in
 Sections 6.1.1.2 and 6.1.1.3, respectively,
                                                      losses is
                                                           used
      6.1.1
          .1  estimation of  Pulp  Production Losses.   Pulp
 production
           losses were
                        calculated for each pulp type as a product
 of the
       pulp loss value and the total quantity of  lost  pulp
 production.
      Assuming
              the kraft pulp mills achieve an earnings margin of
 25 percent, the pulp loss value was estimated to be equal to
 approximately 25 percent of the total market value.   The 1989
 market values of bleached and unbleached kraft pulp were
 estimated  to be approximately $712 and  $423, respectively, per
 ADMP  ($646 and $384, respectively, per  ADTP).  The market values
       .djusted to 1991  dollars using the Consumer Price  Index.
          estimate for each model recovery  furnace the  total
              lost pulp  production  associated with the  extended
were a
     To
quantity
of
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 recovery furnace downtime, the number of days of shutdown beyond
 the scheduled 2-week shutdown were multiplied by the appropriate
 model pulp production rate.  Model pulp production rates were
 determined for kraft bleached and unbleached pulp mills by
 multiplying model BLS firing rates by the appropriate correlation
 factor.  A correlation factor of 1,800 kg BLS/ADMP (3,600 Ib
 BLS/ADTP)  was used for bleached pulp; a correlation factor of
 1,500 kg BLS/ADMP (3,000 Ib BLS/ADTP) was used for unbleached
 pulp.4
      6.1.1-2  Development of Capital Cost-.a.   The following
 sources of cost information were used to develop capital costs
 (i.e.,  total capital investment [TCI])  for the control options
 being considered for kraft and soda pulp mill combustion sources:
      1. Actual installed capital costs  provided by individual
 kraft and  soda pulp  and paper mills;
      2. Cost equations and quotes supplied  by ESP and scrubber
 manufacturers;
      3. Information supplied by recovery furnace manufacturers;
      4. The U.  S. EPA Handbook:  Control Technologies  for
 Hazardous Air Pollutants;5 and
      5. The U.S. EPA's OAQPS Control Cost Manual.6
      Whenever possible,  actual  cost  information  from individual
 mills was used  to develop the capital cost estimates.  Because
 many  combustion sources  are subject  to the NSPS  for PM emissions
 from  kraft and soda pulp mills, actual mill-specific PM  control
 costs were already available  for all  of  the  control options
 involving control of PM HAP's.  For those control options where
 actual  costs  were not available from  individual mills  or were
 only available from one mill, or where mill-specific costs varied
widely, the EPA reference books  (sources 4 and 5, above) were
used.
     In most  cases,  cost algorithms were developed, relating
costs to the model process unit parameters (e.g., gas flow rate).
In a few cases where a direct relationship between the capital
cost and the model process unit was not apparent, the  "six-tenths
rule" was used to extrapolate costs from one model to another.
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The "six- tenths rule" assumes a direct relationship between
capital cost and capacity taken to the six- tenths power  (i.e.,
C /C2 -  (Qi/Qa)0-6' where c and Q are caPital cost and caPacity
parameter, respectively) .  The capital costs were extrapolated
using either gas flow rate or BLS firing rate as the capacity
parameter.
     6.1.1.3  Dftvelotaneni-- of Annual Costs.  Incremental  total
annual costs  (ITAC) were  derived using  the annual  cost model
described  in  the  OAQPS  Control  Cost Manual.6   Incremental  total
annual costs  refer to the incremental increase of  total  annual
costs  (TAG) over  current  operation.  Total annual  costs  include
both direct annual costs  (DAC)  and indirect annual costs (IAC) .
The  cost components that  comprise  the DAC and IAC  are discussed
in the following  sections.
     6.1.1.3.1 nirect  annual costs.  The DAC include operating
labor  costs,  maintenance  labor and material  costs, utility costs,
and  wastewater treatment  costs.6   Operating  and maintenance labor
costs  were calculated as  a product of  the number of working hr/d
to perform the required task, the number of  operating d/yr, and
the  hourly wage.   Operating and maintenance  labor costs were
 calculated assuming 365 operating d/yr.  The hourly wage and
number of working hr/d vary with each control option and are
based on information from the U.  S. EPA' s Handbook: Control
 Technologies for Hazardous Air Pollutants and the OAQPS Control
 Cost Manual.5'6  The maintenance hourly wage is equal to
 approximately 1.5 times the  operating hourly wage.  The
 supervisory  labor cost is approximately 15 percent of the
 operating labor  cost..  With  the exception of ESP's, the
 maintenance  materials  cost is  estimated as approximately
 100 percent  of the maintenance labor cost.6  The  maintenance
 materials cost for ESP's  is  estimated  as 1 percent of the  flange-
 to-flange purchased  equipment  cost  (PEC) for  ESP's,  and the PEC
 is  estimated as  0.6  times  the  TCI.
      Utility costs were  broken down into electricity costs and
 water costs. Electricity costs were calculated as a product  of
 the electricity  unit cost and  the electricity requirement. The
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 electricity unit cost was assumed to be $0.06/kWh.5  Electricity
 requirements were divided into fan, pump,  and operating
 electricity requirements and were calculated assuming
 8,424 operating hr/yr.
      The fan electricity requirement (applicable to ESP's and
 scrubbers)  is equal to a numerical factor  (0.00018)  times the
 product of  the gas flow rate,  pressure drop,  and operating
 hr/yr.6  The gas flow rate varies with each model process unit.
 The pressure drop is based on information  from mills.4  Although
 the pressure drop is not the sole parameter that determines PM
 collection  efficiency for lime kiln scrubbers,  for the purposes
 of estimating costs,  the pressure drop was used as an indicator
 of PM collection efficiency for lime kiln  scrubbers.   Note:  A
 different scrubber design,  rather than a higher pressure drop,
 was used to improve the PM collection efficiency for  SDT
 scrubbers.
      The gas flow rate and pressure drop do not change for ESP's
 relative to current operation  when the  ESP's  are upgraded or
 replaced to improve PM collection.   Therefore,  the fan
 electricity requirements for ESP's do not  change relative to
 current  operation.  However, if a scrubber is added after an ESP,
 the gas  flow rate would be  reduced,  thereby reducing  the fan
 electricity requirements for the ESP.
      The  pump electricity requirement (applicable  to  packed-bed
 scrubbers)  is equal to a numerical  factor  (0.000188)  times the
 product  of  the liquid  flow  rate,  amount of head pressure, and
 operating hr/yr divided by  the  pump-motor  efficiency.6   The
 liquid flow rate  varies  with each model process  unit.  A head
 pressure  of  18 m  (60 ft)  and a  pump-motor efficiency  of
 70 percent were assumed.
     The  operating electricity  requirement (applicable to ESP's)
 is equal  to a  numerical  factor  (0.00194) times  the product of the
 ESP plate area and operating hr/yr.6  The ESP plate area  is
 calculated as  a product  of the  exhaust gas flow  rate and the  ESP
SCA.  The gas  flow rate varies with each process unit, and the
SCA is based on information  from mills.4  Although the SCA is not
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the sole parameter that determines PM collection efficiency for
ESP's, for the purposes of estimating costs, the SCA was used as
an indicator of PM collection efficiency.  The cost analysis does
not consider increasing the SCA to account for single-chamber ESP
operation at reduced gas flow during maintenance situations.
Instead, the regulation will allow for PM emission excursions
during maintenance situations as part of the "Startup,^Shutdown,
Malfunction Plan" described in the General Provisions.
     Water costs were  calculated as a product of the water unit
cost and the water requirement.  The water unit cost was assumed
to be $0.05/m3  ($0.20/1,000 gal).5  The water requirement is
equal to a numerical factor  (0.060) times the product of the gas
flow  rate and operating hr/yr.6  The gas flow rate varies with
each model process unit.
      For some control  options  (e.g., PM  controls that include
upgrading or replacing an existing  recovery furnace  ESP or
replacing an existing  SDT scrubber  with  a new scrubber), the
labor and maintenance  costs  are  not expected to increase
significantly,  and,  therefore,  the  ITAC.is  represented  by  the  IAC
plus  the difference  in electricity  costs before and  after
implementation of  the  control  options.
      6.1.1.3.2   indirect annual  costs.   The IAC include overhead
costs,  administrative  charges,  property taxes,  insurance costs,-
 and capital recovery costs.  Overhead costs are
                                             approximately
 60
percent of all labor and maintenance material costs
 Overhead costs are not applicable when labor and maintenance
 costs
   do not increase significantly.  Administrative, insurance,
 and property tax costs are approximately 4 percent of the TCI
 Capital recovery costs are equal to a capital recovery factor
 (CRF) multiplied by the TCI.  The CRF is estimated using the
 equation CRF -  [id + i)n]/td + Dn - U , where i = interest
 rate  (assumed to be 7 percent) and n = equipment life of the
 device being installed or modified.
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 6.1.2  Recovery Furnace Control Options
      The following sections discuss the model costs of four
 control options evaluated for recovery furnaces.  These control
 options include PM controls (Section 6.1.2.1), wet to dry ESP
 system conversion (Section 6.1.2.2), conversion of a DCE recovery
 furnace system to an NDCE recovery furnace (Section 6.1.2.3), and
 addition of a packed-bed scrubber (Section 6.1.2.4).
      6.1.2.1  PM Controls.  Two PM control options were evaluated
 for model NDCE recovery furnaces RF-1 through RF-6 and model DCE
 recovery furnaces RF-7 through RF-9.  The control options apply
 to new and existing recovery furnaces and are described below.
      One PM control option that was  evaluated would reduce PM
 emissions from existing recovery furnaces to the NSPS level of
 0.10 g/dscm (0.044 gr/dscf).   The PM control option evaluated
 would involve (1)  replacing the recovery furnace ESP or
 (2)  upgrading the recovery furnace ESP.   The control equipment
 selected by a particular mill  would  be  site-specific.
      A second PM control option that was evaluated would reduce
 PM emissions from existing recovery  furnaces  to  0.034  g/dscm
 (0.015  gr/dscf).   This  more  stringent PM control option would
 involve replacing or upgrading the recovery  furnace ESP and
 adding  a packed-bed scrubber.   The second PM control option also
 applies to  new recovery furnaces;  the option  could be  used  to
 evaluate the cost  to new sources  subject  to a more stringent
 standard (0.034  g/dscm  [0.015  gr/dscf])  than  the current NSPS.
      The  PM control costs  for  existing recovery  furnaces with
 baseline  PM emissions above the NSPS level were  estimated for
 model NDCE  recovery furnaces RF-la through RF-6a and model DCE
 recovery  furnaces RF-7a  through RF-9a.  The PM control  costs  for
 new and existing recovery furnaces with baseline PM emissions at
 or below the NSPS level were estimated for model NDCE recovery
 furnaces RF-lb through RF-6b and model DCE recovery furnaces
RF-7b through RF-9b.
     The PM control costs for model NDCE recovery  furnaces with
dry ESP systems  (i.e.,  RF-1 through RF-3) are assumed to be
identical to the PM control costs for model NDCE recovery
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furnaces with wet ESP systems (i.e., RF-4 through RF-6)  because
PM emissions are not affected by whether or not black liquor is
used in the ESP bottom or PM return system.  The capital and
annual costs to replace or upgrade ESP's are presented for the
model NDCE and DCE recovery furnaces in the following sections.
The capital and annual costs to install a new packed-bed scrubber
are presented in Section 6.1.2.4.
     Based on the costs presented below, it is more expensive to
replace an existing ESP than to upgrade: it.  However, a
replacement may be necessary, depending on the age and condition
of the existing ESP,  in order to effectively control PM
emissions.  Site-specific  conditions often dictate the cost-
effectiveness of replacing or upgrading an ESP.
      6.1.2.1.1  ESP replacement;   capital  costs.  The ESP
replacement costs  for models RF-la through RF-9a  were calculated
based on  recent ESP replacement  costs  provided by individual  pulp
and paper mills  (i.e.,  costs  for ESP's replaced during  or  after
1989).4   The  cost  to  dispose  of  the existing ESP  was assumed  to .
be included in  the new ESP costs provided by the  individual
mills.   New ESP costs average $420/m2  ($39/ft2)  of  ESP  plate  area
 for NDCE and DCE  recovery furnaces.4  The ESP  plate area for  the
 new  ESP was derived from the model exhaust gas flow rates  for
 RF-la through RF-9a and the SCA for the replacement ESP.
      For NDCE recovery furnaces, an SCA of approximately
 100  m2/(m3/sec)  (530 ft2/!,000 acfm) was assumed based on ESP SCA
 information from NDCE recovery furnaces subject to the NSPS
 (i.e.,  furnaces installed or replaced during or after 1977 and
 required to have outlet PM emissions of 0.10 g/dscm
 [0.044 gr/dscf] or lower).4  Because dry-bottom ESP's are used to
 control PM emissions from approximately 80 percent of NDCE
 recovery furnaces, it was assumed  that all replacement ESP's for
 NDCE recovery furnaces would be of  the dry-bottom design.   The
 ESP replacement costs for the three model NDCE recovery furnaces
 are presented in Table 6-1.  The  total capital costs range from
 $4.12 million to  $10.7 million  for RF-la  through RF-6a.
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      For DCE recovery furnaces,  an SCA of approximately
 90 m2/{m3/sec)  (430 ft2/!,000 acfm)  was assumed based on ESP SCA
 information from DCE recovery furnaces subject to the NSPS (i.e.,
 furnaces installed or replaced during or after 1977 and required
 to have outlet  PM emissions of 0.10  g/dscm [0.044 gr/dscf]  or
 lower).4  Because wet-bottom ESP's are used to control PM
 emissions from  approximately 90  percent of DCE recovery furnaces,
 it was  assumed  that all new replacement ESP's for DCE recovery
 furnaces would  be of the wet-bottom  design.8   The ESP replacement
 costs for the three model DCE recovery furnaces are presented in
 Table 6-1.   The TCI costs range  from $2.01 million to
 $6.03 million for RF-7a through  RF-9a.
      Installing a new fan and stack  typically comprises
 approximately 20  percent of the  total capital costs of installing
 a  new ESP.9   Because the fan and stack usually do not need to be
 replaced when an  ESP is replaced,  the ESP replacement costs
 stated  above are  estimated  to be 80  percent of the cost of  a
 completely new  ESP.   The costs to replace the fan and stack due
 to the  addition of the packed-bed scrubber are presented in
 Section 6.1.2.4.2.
      In some cases,  installation of  a replacement ESP can be
 achieved using  a  "roll-in"  procedure,  in  which the ESP is erected
 adjacent to  its final  location and then rolled into position
 using roller assemblies  or  rubber-tired dollies.   The roll-in
 technique has been used  for a  number of years  on  a wide  range of
 equipment sizes.9  However,   the  roll-in technique probably  cannot
 be used  for  the majority of  recovery furnaces  due to  the  location
 of the ESP  (e.g.,  an elevated  position  relative to  the recovery
 furnace).  Because the ESP  replacement  costs were based  on  actual
 ESP replacement costs provided by  individual pulp and paper
mills, it was assumed  that  they were based  on  recovery furnaces
 that  cannot do  ESP roll-ins.   Therefore, no contingency factor is
needed to adjust ESP replacement costs  to account  for the
 furnaces being unable to do ESP roll-ins.  However, without the
ESP roll-in, an ESP replacement probably could not be completed
within the scheduled 2-week shutdown for maintenance.  Because no
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information is available on the time needed to complete an ESP
replacement, the maximum time estimated to complete an ESP
upgrade, as described in Section 6.1.2.1.3, was used.  The
estimated maximum time is 30 days.  Therefore, pulp production
losses for replacing the ESP were calculated for that period of
time minus the 2-week  (14-day) scheduled mill shutdown.  Pulp
production losses for the 16-day period are presented in
Table 6-2.
     For mills producing bleached pulp, the pulp production
losses range from $1.19 million to $3.12 million for RF-la
through RF-6a and $710,000 to $2.13 million for RF-7a through
RF-9a.  For mills producing unbleached pulp,  the pulp production
losses range from $844,000 to $2.19 million for RF-la through
RF-6a and $506,000  to  $1.52 million for RF-7a through RF-9a.  The
unbleached pulp production losses are lower for each model
recovery furnace because unbleached pulp has  a lower market value
than bleached pulp.
     6.1.2.1.2  ESP replacement:  incremental annual costs.
Labor and maintenance  requirements and costs  are assumed  to be
unchanged when  the  ESP is  replaced.  However, because  the ESP
replacement option  includes  an  increase  in ESP plate area, .
electricity costs are  increased.  The  increase  in  ESP  electricity
costs resulting from the  ESP replacement is based  on an increase
in the  SCA.
      For NDCE and DCE recovery  furnaces,  the  baseline  SCA values
are approximately 90 m2/(m3/sec)  (430  ft2/l,000  acfm)  and
 70 m2/(m3/sec)  (330 ft2/!,000 acfm),  respectively.  These SCA
values  are the  average values common to  ESP's on NDCE  and DCE
 recovery furnaces installed prior to 1977 (i.e.,  installed prior
 to the  NSPS and not subject to the NSPS  PM standard of
 0.10 g/dscm [0.044 gr/dscf]) that also have PM emissions greater
 than 0.10 g/dscm (0.044 gr/dscf).4  As a result of the ESP
 replacement, the baseline SCA would be increased to a value of
 approximately 100 m2/(m3/sec)  (530 ft2/!,000 acfm) for NDCE
 recovery furnaces and 90 m2/(m3/sec)  (430 ft2/l,000 acfm) for DCE
 recovery furnaces.   These SCA values are the average values
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 common to ESP's  on NDCE and DCE recovery furnaces  installed
 during or after  1977 (i.e.,  installed after the  NSPS  and subject
 to  the NSPS  standard of 0.10 g/dscm [0.044  gr/dscf])  that also
 have  PM emissions  less  than or equal  to  0.10 g/dscm
 (0.044 gr/dscf)  but greater than 0.034 g/dscm (0.015  gr/dscf)
 (the  more stringent PM  control level).4
      The incremental annual  costs for ESP replacements  include
 the difference in  electricity costs plus the indirect costs
 affected by  the  TCI,  which  include the administrative,  property
 tax,  and insurance costs plus the capital recovery cost.   The
 lifetime of  dry-bottom  ESP's typically ranges  from 12 to
 15  years.9   Therefore,  an average 13.5-year life span was assumed
 when  calculating the capital recovery cost  for dry-bottom ESP's
 installed on NDCE  recovery  furnaces.   The lifetime of wet-bottom
 ESP's  is  typically 10 years.9  Therefore, an average  10-year life
 span was  assumed when calculating the capital  recovery  cost for
 wet-bottom ESP's installed on DCE recovery  furnaces.
     The  ITAC for  the model  NDCE  and  DCE recovery  furnaces,
 excluding annualized pulp production  losses  (i.e.,  capital
 recovery  costs for the  pulp  production losses),  are presented  in
 Table  6-1.  -The  incremental  annual  costs  range from $666,000/yr
 to  $1.73  million/yr for RF-la through RF-6a  and  $378,000/yr to
 $1.14 million/yr for RF-7a through  RF-9a.  The ITAC for  the model
 NDCE and  DCE recovery furnaces, including annualized  bleached and
 unbleached pulp  production losses,  are presented in Table 6-2.
 The incremental  annual  costs,  including annualized bleached pulp
 production losses,   range from $805,000/yr to $2.09 million/yr for
 RF-la through RF-6a and $764,000/yr through  $1.99 million/yr for
 RF-7a through RF-9a.  The incremental annual costs, including
annualized unbleached pulp production losses, range from
 $764,000/yr to $1.99 million/yr for RF-la through RF-9a and
 $451,000/yr to $1.36 million/yr for RF-7a through RF-9a.
     6.1.2.1.3   ESP upgrade  (to 0.10 g/dscm  TO.044 gr/dscf1):
 capital costs.  The ESP upgrade costs for existing NDCE and DCE
recovery furnaces are based on May 1993 ESP upgrade costs
supplied by an ESP manufacturer.9  The ESP manufacturer supplied
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costs for a model NDCE recovery furnace with an exhaust gas flow
rate of 109 m3/sec (230,000 acfm) and a model DCE recovery
furnace with an exhaust gas flow rate of 160 m3/sec
(340,000 acfm).9  According to the ESP manufacturer, the proposed
upgrade would result in an ESP size adequate to meet an outlet PM
level of 0.10 g/dscm  (0.044 gr/dscf).9
     The ESP manufacturer supplied ESP upgrade costs for two
different ESP upgrade schedules  (Schedules 1 and 2} .  Schedule 1
is a 21-day, 7-day/week ESP upgrade schedule, including about
14 days of recovery furnace outage and about 3 or 4 days of
partial load on both  sides of the outage.9  Three days of partial
load before and after the outage were assumed, for  a total of
6 days of partial load.  Assuming a 50 percent load for 6 days,
there would be 3 days of downtime during the period of partial
load.  Added to the 14 days of recovery furnace outage, there is
a total downtime of 17 days, which  is 3 days of downtime beyond
the annual 2-week shutdown for maintenance.  Schedule 2 is a
30-day, 6-day/week upgrade schedule and has no periods of partial
load.  There would be 30 days of recovery  furnace  outage.
Schedule  2 would have 16 days of downtime  beyond the annual
2-week shutdown.  For the model  NDCE  recovery  furnace, the cost
for  Schedule 1  is $1,292,000, and  the cost for Schedule 2  is
$1,259,000.9   For the model DCE  recovery  furnace,  the  cost for
Schedule  1 is  $1,504,750,  and the  cost  for Schedule 2  is
$1,466,500.9
      The  nature of  the  ESP upgrades is  identical  for Schedules  1
and 2.  A brief summary of the  required modifications  is
presented in Table  6-3.   The  ESP upgrades for these schedules
 include  replacing the weighted  wire design with  a rigid electrode
 design.9   Rigid electrode ESP's generally operate at a higher
voltage than weighted wire ESP's and, in some cases,  may require
 replacement of the transformer and other controls.  However,  the
 ESP upgrade cost estimate does  not include those costs that vary
 widely based on site-specific conditions, such as the need for
 transformer replacement.
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      The only difference between the two ESP upgrade schedules is
 that Schedule 2 allows a longer downtime because major
 modifications to the furnace would be performed at the same time.
 The costs of the recovery furnace modification are not included
 because they are not associated with the ESP upgrade.   The ESP
 upgrade work for Schedule 2 would be extended over the 30-day
 shutdown period.
      The ESP upgrade costs were adjusted to 1991 dollars and then
 scaled using the six-tenths power rule described in
 Section 6.1.1.2 to derive costs for the model NDCE and DCE
 recovery furnaces.   The model ESP upgrade costs,  without pulp
 production losses,  for Schedules 1 and 2 are presented in Tables
 6-4 and 6-5,  respectively.   The ESP upgrade capital costs for
 Schedule 1 range from $1.20 million to $2.12 million for RF-la
 through RF-6a and $811,000  to $1.57 million for RF-7a  through
 RF-9a.   The ESP upgrade capital costs  for Schedule 2 range from
 $1.16  million to $2.07 million for RF-la through RF-6a and
 $791,000 to $1.53 million for RF-7a through RF-9a.
     The pulp production losses associated with shutting down the
 mill to upgrade the  ESP were calculated using the method
 described in  Section 6.1.1.1.   The  ESP upgrade  costs that include
 bleached and  unbleached pulp production losses  are presented  in
 Tables  6-6  and 6-7,  respectively.   The pulp production losses  for
 Schedules  1 and 2 are  presented for the model recovery furnaces
 in  Tables  6-6  and 6-7,  respectively.
     The bleached pulp production losses  for Schedule  1  range
 from $224,000  to  $585,000 for RF-la through RF-6a  and  $133,000 to
 $399,000 for RF-7a through RF-9a.   The  unbleached pulp production
 losses  for Schedule  1  range  from $158,000 to  $411,000  for RF-la
 through EF-6a and $94,900 to $285,000  for RF-7a through RF-9a.
 The pulp production  losses for mills producing unbleached pulp
 are lower than  for mills producing bleached pulp because
 unbleached pulp has  a lower market value than bleached pulp.
     Because Schedule 2 is longer than Schedule 1, the pulp
production losses are higher for Schedule 2 than for Schedule 1.
The bleached pulp production losses for Schedule 2 range from
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$1.19 million to $3.12 million for RF-la through RF-6a and
$710,000 to $2.13 million for RF-7a through RF-9a.  The
unbleached pulp production losses for Schedule 2 range from
$844,000 to $2.19 million for RF-la through RF-6a and $506,000 to
$1.52 million for RF-7a through RF-9a.
     6.1.2.1.4  ESP upgrade  (to 0-10 a/dsnm  FO.04* gr/dsef1):
incremental annual costs.  Labor and maintenance costs are
assumed to be unchanged when the ESP is upgraded to achieve.a PM
level of 0.10 g/dscm  (0.044 gr/dscf).  Therefore, the incremental
annual costs for the  ESP upgrade include only  the electricity
costs and the TCI-based indirect annual costs, which include
administrative, property tax,  insurance, and capital recovery
costs.  The capital recovery cost for NDCE recovery furnace ESP's
is based on an  average 13.5-year life span for dry-bottom ESP's.
The  capital recovery  cost  for  DCE recovery furnace ESP's  is based
on an average 10-year life span for wet-bottom ESP's.9  Although
the  ESP plate area is not  increased with an  ESP  upgrade,  there
will be additional electricity costs  associated  with  the  new  ESP
design.  The actual increase in electricity  costs with an ESP
upgrade  is  not  currently known. Therefore,  it was assumed that
 the  incremental increase in electricity costs  for an  upgraded ESP
would be  the  same as for a replacement  ESP.   Because  the
 electricity cost increases for the  replacement ESP  in
 Section 6.1.2.1.2 were based on an increase in SCA from baseline
 to control levels, the electricity cost increases for the
 upgraded ESP were calculated in the same manner.4  The ITAC for
 the model recovery furnaces are presented in Tables 6-4 through
 6-7.
      Table 6-4 presents the ITAC for the Schedule 1 ESP upgrade
 for each model recovery furnace,  without accounting for
 annualized pulp production losses.   As shown  in the table,  the
 ITAC for the Schedule 1 ESP upgrade, without  annualized pulp
 production losses, range  from $207,000/yr to  $383,000/yr for
 RF-la through RF-6a  and $159,000/yr to $322,000/yr for RF-7a
 through RF-9a.  Table 6-5 presents the ITAC for  the Schedule 2
 ESP upgrade for each model recovery furnace,  without accounting
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 for annualized pulp production losses.   As  shown in the table,
 the ITAC for the Schedule 2  ESP upgrade,  without annualized pulp
 production losses,  range from $202,000/yr to  $375,000/yr for
 RF-la through RF-6a and $156,000/yr to  $314,000/yr  for RF-7a
 through RF-9a.
      Table 6-6  presents the  ITAC for the Schedule 1 ESP upgrade
 for each model  recovery furnace and includes  estimated production
 losses associated with bleached and unbleached pulp.   As shown in
 the table,  the  ITAC for the  Schedule 1  ESP  upgrade,  including
 bleached pulp production losses,  range  from $233,000/yr to
 $452,000/yr for RF-la  through RF-6a and $178,000/yr to
 $379,000/yr for RF-7a  through RF-9a.  The ITAC for  the Schedule  1
 ESP upgrade,  including unbleached pulp  production losses, range
 from $226,000/yr to $431,000/yr for RF-la through RF-6a and
 $173,000/yr to  $363,000/yr for RF-7a through  RF-9a.
      Table  6-7  presents the  ITAC for the  Schedule 2  ESP upgrade
 for each model  recovery furnace and includes  estimated production
 losses associated with bleached and unbleached pulp.   As  shown in
 the table,  the  ITAC for the  Schedule  2  ESP upgrade,  including
 bleached pulp production losses,  range  from $341,000/yr to
 $740,000/yr for RF-la  through RF-6a and $257,000/yr  to
 $617,000/yr for RF-7a  through RF-9a.  The ITAC for the Schedule 2
 ESP upgrade, including unbleached pulp  production losses, range
 from $300,000/yr to $631,000/yr for RF-la through RF-6a and
 $228,000/yr to  $530,000/yr for RF-7a  through RF-9a.
      6.1.2.1.5   ESP upgrade  (to 0.034 a/dscm  TO. 015 crr/dscf 1 ) :
 capital  costs.   Control  costs  have  been determined for those new
 and existing recovery  furnaces  controlling PM emissions from the
NSPS  level  of 0.10  g/dscm  (0.044  gr/dscf) to 0.034 g/dscm
 (0.015 gr/dscf).  These  costs would include an ESP upgrade cost
and  a packed-bed scrubber cost.  Because no actual ESP upgrade
costs were available for controlling PM emissions to 0.034 g/dscm
 (0.015 gr/dscf), the upgrade  cost for the recovery furnace ESP
was  instead based on the incremental cost difference between an
ESP  capable of achieving a PM level less than or  equal to
0.10 g/dscm  (0.044 gr/dscf) but greater than 0.034 g/dscm
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(0.015 gr/dscf) and an ESP capable of achieving a PM level less
than or equal to 0/034 g/dscm  (0.015 gr/dscf).  This section
presents the ESP upgrade costs; the packed-bed scrubber costs are
presented in Section 6.1.2.4.
     The ESP upgrade capital costs were based on recent ESP costs
provided by individual pulp and paper mills  (i.e., costs for
ESP's installed or replaced during or after  1989).4  The ESP
costs average  $420/ra2  ($39/ft2) of ESP plate area for recovery
furnaces.4  To determine the ESP upgrade  cost, this cost per ESP
plate area was multiplied by the increase in ESP plate area
assumed to reduce PM emissions from  0.10  g/dscm  (0.044 gr/dscf)
to  0.034 g/dscm  (0.015 gr/dscf).
     The ESP plate area  for NDCE recovery furnace ESP's achieving
a PM level less than or  equal  to 0.10 g/dscm (0.044 gr/dscf) but
greater than 0.034 g/dscm  (0.015 gr/dscf)  is based on an average
SCA of approximately 100 m2/(m3/sec)  (530 ft2/l,000 acfm),  as
discussed  in Section 6.1.2.1.2.  The ESP  plate area for DCE
recovery furnace  ESP's achieving a PM level  less than or  equal  to
0.10 g/dscm  (0.044 gr/dscf)  but  greater than 0.034 g/dscm
 (0.015 gr/dscf)  is based on an average  SCA of  approximately
90  m2/(m3/sec)  (430  ft2/!,000  acfm), as discussed in
Section  6.I.2.I.2.4  The ESP plate area for recovery  furnace
ESP's  achieving a PM level less than or equal to 0.034  g/dscm
 (0.015  gr/dscf)  is based on an SCA of approximately
 120 m2/(m3/sec)  (620 ft2/!,000 acfm).  This is the SCA value for
 an ESP achieving a PM emission level of 0.034 g/dscm
 (0.015 gr/dscf)  on a long-term basis.4'1
      The capital cost attributable to the control option to
 install new recovery furnace  ESP's capable  of achieving a PM
 level of 0.034 g/dscm (0.015  gr/dscf) would not be the cost of a
 new ESP,  but only that portion associated with controlling PM
 emissions from 0.10 g/dscm  (0.044 gr/dscf)  to 0.034 g/dscm
 (0.015 gr/dscf), which is the same as the cost to upgrade
 existing recovery furnace ESP's to achieve  the same PM level of
 0.034 g/dscm  (0.015 gr/dscf).
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      The  capital  costs  of  the  ESP upgrade  used to  achieve  the
 0.034 g/dscm (0.015  gr/dscf) PM level  are  lower than  the capital
 costs of  the ESP  upgrade used  to achieve the  0.10  g/dscm
 (0.044 gr/dscf) NSPS PM level  discussed in Section 6.1.2.1.3.
 The  capital  costs for this more stringent  ESP upgrade control
 option, excluding pulp  production losses,  are presented in
 Table 6-8 and range  from $644,000 to $1.67 million for RF-lb
 through RF-6b and $387,000 to  $1.16 million for RF-7b through
 RF-9b.
      There are no pulp  production losses for  new recovery
 furnaces  to  install  an  upgraded ESP because the ESP is upgraded
 prior to  installation.  No information is  currently available for
 existing  recovery furnaces on  the amount of time required  to
 complete  an  ESP upgrade that would allow PM control to
 0.034  g/dscm (0.015  gr/dscf).   However, it was  assumed that the
 pulp  production losses  could be as high as those for  Schedule 1
 of the  ESP upgrade control option discussed in  Section 6.1.2.1.3.
 The pulp production  losses are  presented in Table  6-9.
      6.1.2.1.6  ESP  upgrade  (to 0.034  cr/dscm  TO.015 ar/dscf 1 ) :
 incremental  annual costs.  Labor and maintenance costs are
 assumed to be unchanged when the ESP is upgraded to achieve a PM
 level of  0.034 g/dscm (0.015 gr/dscf).  Therefore,  the
 incremental  annual costs for the ESP upgrade  include  only the
 electricity  costs and TCI-based indirect annual  costs, which
 include administrative,  property tax,  insurance, and  capital
 recovery costs.   The capital recovery  cost  for NDCE recovery
 furnace ESP's is based  on  an average 13.5-year life span for
 dry-bottom ESP's.   The  capital  recovery cost  for DCE  recovery
 furnace ESP's is based  on  an average 10-year  life span for
wet-bottom ESP's.   The  PM  control  electricity costs would include
both ESP upgrade and packed-bed  scrubber electricity  costs.  The
ESP upgrade electricity costs are presented in this section;
Section 6.1.2.4  presents the packed-bed scrubber electricity
costs.  The ESP  upgrade electricity costs are based on an
increase in SCA from approximately 100 m2/(m3/sec)   (530 ft2/
1,000 acfm)  for  NDCE recovery furnaces and 90 m2/(m3/sec)
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(430 ft2/!,000 acfm)  for DCE recovery furnaces to approximately
120 m2/(m3/sec) (620 ft2/!,000 acfm)  for all recovery furnaces.4
     The electricity costs presented in this section are based on
gas flow rates and pressure drops in the absence of a packed-bed
scrubber.  If a packed-bed scrubber was added after the ESP, the
fan electricity costs for the ESP would change slightly from
those presented in this section.  However, because the total
electricity costs are only a small fraction  (approximately
10 percent, of the ITAC, a slight change in fan electricity costs
would have a negligible effect on the ITAC.
     The ITAC  for the model recovery furnaces, excluding
annualized pulp production losses, are presented in Table 6-8 and
range from $117,000/yr to  $304,000/yr for RF-lb through RF-6b and
$80,300/yr to  $241,000/yr  for RF-7b through RF-9b.  The ITAC for
the model recovery furnaces, including annualized pulp production
losses, are presented in Table  6-9.  The  incremental annual
costs,  including annualized bleached pulp production losses,
range from $143,000/yr to  $373,000/yr for RF-lb through RF-6b and
$99,000/yr to  $298,000/yr  for RF-7b through  RF-9b.  The
incremental annual  costs,  including annualized unbleached pulp
production losses,  range  from $l36,000/yr to $352,000/yr for
RF-lb through RF-6b and  $94,000/yr to  $282,000/yr  for RF-7b
through RF-9b.
      6.1.2.2   Wgfc  to Dry ESP  System  Conversion.  Two  control
options were  evaluated  for reducing  emissions of gaseous organic
HAP's  such as methanol  from existing NDCE recovery furnaces.
These  control options are (1)  converting an ESP  system that uses
black liquor or HAP-contaminated process water in  the ESP  bottom
 or PM return system (referred to as  a  wet ESP system)  to an ESP
 system that  uses "clean" water (i.e.,  water uncontaminated with
methanol and other gaseous organic HAP's)  in the ESP bottom or PM
 return system; and  (2)  converting a wet ESP system to a dry-
 bottom ESP with a dry PM return system (referred to as a dry ESP
 system).  With these two control options, the potential stripping
 of methanol and other gaseous organic HAP's from the black liquor
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 or  contaminated process  water  in the  ESP  system would be
 eliminated.
     Only  the  costs  for  the  second  control option,  converting
 from a wet to  a dry  ESP  system,  were  evaluated.  This decision
 was based  on  (1)  the uncertainty associated with the available
 cost estimates for converting  to an ESP system that uses  "clean"
 water in the ESP  bottom  or PM  return  system; and  (2) the  fact
 that very  few  mills  use  water  in the  ESP  system.
     A cost estimate is  available for converting a wet-bottom ESP
 that uses  black liquor in the  ESP bottom  to one that uses  "clean"
 water in the ESP  bottom.  This cost estimate is significantly
 lower than the cost  estimates  available for converting to a
 dry-bottom ESP, but  the  accuracy of this  cost estimate is
 questionable.  According to  a  1985  EPA estimate for a 900 ADMP/d
 (1,000 ADTP/d) mill, the capital  cost to  convert a wet-bottom ESP
 to  one that uses  water in the  ESP bottom  is $154,000.  The annual
 cost is $67,000/yr.11  These costs  are lower than the wet- to
 dry-bottom conversion costs  presented below.  Several pulp and
 paper industry representatives commenting on the estimate
 indicated  that the costs to  evaporate the added water should be
 higher.  They  also noted that mills may experience a loss of
 production to  evaporate  the  extra water if excess capacity was
 not available  in  the evaporators.12
     The wet to dry ESP  system conversion control option applies
 to model NDCE  recovery furnaces RF-4 through RF-6, which
 represent  existing NDCE  recovery  furnaces with wet ESP systems.
 These models represent existing NDCE recovery furnaces only,
 because no wet ESP systems are expected to be installed on new
 NDCE recovery furnaces.
     The model costs for the wet  to dry ESP system conversion
 control option are based on  costs to convert NDCE recovery
 furnace wet-bottom ESP's to  dry-bottom ESP's.   For the purposes
 of this cost analysis,  these wet- to dry-bottom ESP conversion
 costs are assumed to apply also to those NDCE recovery furnaces
with dry-bottom ESP's and wet PM return systems.   The ESP
 conversion costs may be lower than those presented if an ESP
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upgrade to improve PM collection is also performed at the same
time.  However, no information is currently available on the
extent of the cost reduction.  The capital and annual costs for
the wet to dry ESP system conversion control option are presented
in the following sections for existing model NDCE recovery
furnaces.
     6.1.2.2.1  Capital  costs.  The wet to dry ESP system
conversion capital costs are based on 1993 conversion costs from
an ESP manufacturer.13   These costs were adjusted to 1991 dollars
and then scaled, using the  six-tenths power rule, to derive costs
for the three model NDCE recovery furnaces.  The ESP model used
by the manufacturer to develop the conversion costs was stated as
being three  fields in length and two chambers in width, each
6.1 m  (20 ft) wide.  The cost to remove the existing agitator
paddles and  liquor piping and install a perpendicular drag
scraper system, shallow  fallout hoppers, drag chain conveyors,
and rotary valves was estimated to be $560,000  for the material
and  $285,000 for  installation.  The  cost estimate does not
include the  cost  associated with  (1) any removal of asbestos,  if
applicable;  (2) any piping  beyond  the rotary valves; or  (3) any
equipment beyond  the  rotary valves,  such as an  ash mixing  tank
with associated instrumentation.   The ESP  conversion costs  from
the  ESP manufacturer  are based  on  working  two  10-hour  shifts  for
about  10  days and converting both  ESP  chambers  simultaneously.
Therefore,  no downtime would be necessary  beyond  the annual
2-week shutdown,  which means no pulp production losses would  need
 to be  included in the model ESP conversion costs  presented below.
     The recovery furnace size used by the ESP manufacturer in
 calculating the wet-bottom ESP conversion costs was  stated to be
 about  600 to 900 ADMP/d (700 to 1,000 ADTP/d)13.   A size of
 800  ADMP/d  (900 ADTP/d)  (the size for the mid-size model NDCE
 recovery furnace RF-5)  was used to scale the costs.   The capital
 costs  for the three model NDCE recovery furnaces are presented in
 Table 6-10.  The wet to dry ESP system conversion costs range
 from $596,000 to $1.06 million for RF-4 through RF-6.
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      6.1.2.2.2  Incremental annual costs.  Direct annual costs
 are not assumed to increase as a result of the wet to dry ESP
 system conversion.  Although there may be some extra maintenance
 costs,  they are expected to be small compared to the increases in
 capital recovery and other indirect costs.  Past dry-bottom ESP
 designs were associated with higher maintenance costs.   Changes
 in designs have eliminated many of those problems.14  The costs
 from the ESP manufacturer used to develop the model costs are
 based on the modern design.   Furthermore, because wet-bottom ESP
 designs are associated with greater corrosion,  switching to dry-
 bottom ESP designs results in a longer life span for the ESP.
 Utility costs (i.e.,  electricity)  also do not change
 significantly because of an equal trade-off in horsepower
 requirements between the wet and dry ESP system designs.14
      Based on these assumptions,  the ITAC for wet to dry ESP
 system  conversions should only include those indirect annual
 costs affected by the TCI (i.e.,  administrative,  property tax,
 insurance,  and capital recovery costs).   Similar to the  ESP
 replacement costs,  the capital recovery cost is  also based on  an
 average  13.5-year life for dry-bottom ESP's operating on NDCE
 recovery furnaces.   The ITAC for  the model  NDCE  recovery furnaces
 are presented in  Table 6-10  and range from $93,500/yr to
 $166,000/yr for RF-4  through RF-6.
      6.1.2.3   Conversion of  a DCE Recovery  Furnace  System to an
 NDCE  Recovery Furnace.   Converting a DCE  recovery furnace  system
 to an NDCE  recovery furnace  (or "low-odor conversion") was
 evaluated as  a  control  option for reducing  gaseous  organic  HAP
 emissions from DCE  recovery  furnace  systems.  The conversion of  a
 DCE recovery  furnace  system  to  an NDCE design involves removing
 the DCE  and BLO unit, adding  a  concentrator, and extending  or
 replacing the boiler  economizer.  Capital and annual  costs have
been evaluated for  these three  tasks.  Additional upgrades are
 included in the low-odor conversion  control option, i.e., an ESP
upgrade to improve  PM collection and a wet to dry ESP system
conversion to reduce  gaseous organic HAP emissions.  Separate
capital and annual  costs were developed for the ESP upgrade and
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the wet to dry ESP system conversion.  The ESP conversion costs
may be lower if an ESP upgrade is also performed at the same time
as the ESP conversion.  However, no information is currently
available on the extent of the cost reduction.  Therefore, the
costs were developed in the same way as those developed for
recovery furnaces in Sections 6.1.2.1 and 6.1.2.2.
     Often other upgrades are performed at the same time as a
low-odor conversion.  These upgrades usually provide additional
cost savings because of increased efficiency, increased process
capacity, and improved performance and safety.  Possible upgrades
include combustion air system improvements, composite tubing, and
emergency drain and flame safety systems.15  The  capital costs
and annual cost savings associated with these additional upgrades
have not been evaluated as part of the low-odor conversion
control option.  The pulp production credits associated with
increased process capacity were not  included  in the low-odor
conversion total annual cost estimate because the additional
capacity increases may  require  significant modifications  (e.g.,
expanding the recovery  furnace  bed or modifying the air system),
which  would  require  additional  capital expenses.
     The low-odor  conversion  total annual cost estimates  also do
not  include  (1)  DCE  maintenance cost savings,  (2) ESP maintenance
 cost savings,  and  (3)  higher  solids  firing cost benefits  for the
 reasons described  below.
     Maintenance requirements associated with the DCE are
 eliminated with the removal of this  piece of equipment during a
 low-odor conversion.   The lower maintenance requirements
            with an NDCE recovery furnace increase furnace
               which allows for higher utilization of recovery
associated
availability
furnace capacity without additional costs.  The DCE maintenance
cost savings were not included in the low-odor conversion cost
estimates because sufficient data are not available to quantify
the cost savings.
     Lower corrosion rates are associated with NDCE recovery
furnace ESP's than with DCE recovery furnace ESP's.  The lower
corrosion rates for NDCE recovery furnace ESP's are the result of
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a higher-temperature, lower-moisture content gas stream from NDCE
recovery furnaces  compared to DCE recovery furnaces, as well as
from the predominant use of dry-bottom ESP's.  Therefore,
converting to an NDCE design would eliminate the need for more
frequent ESP replacement resulting from ESP corrosion.  The ESP
maintenance cost savings were not included in the low-odor
conversion cost estimates because sufficient data are not
available to quantify the cost savings.
     Because concentrators can achieve higher BLS concentrations
than DCE's (i.e.,  75 to 80 percent .vs. 65 percent), converting to
an NDCE recovery furnace provides the mill with an opportunity to
increase the solids content of the black liquor fired in the
furnace.4'16  However, increasing the solids content of the black
liquor to the upper limits requires additional capital expenses,
such as modifications to the fuel delivery system to handle a
more viscous liquid.  Neither the potential cost credits nor the
additional capital expenses and any associated maintenance costs
associated with higher solids firing are included in the low-odor
conversion cost estimates.
     Particulate matter control costs are included in the low-
odor conversion cost estimates.  With the removal of the DCE,
which provides some PM control, as stated in Chapter 3, the ESP
often must be upgraded or replaced during a low-odor conversion
in order to meet applicable PM emission limits.  For the purposes
of this cost analysis, an ESP upgrade PM control option that
would maintain or reduce PM emissions to the NSPS level of
0.10 g/dscm (0.044 gr/dscf)  has been evaluated for those existing
DCE recovery furnaces that have PM emissions at or above the NSPS
level.   This PM control option applies to model DCE recovery
furnaces RF-7a/7b through RF-9a/9b.   These models represent
existing sources only, because no new DCE recovery furnaces are
expected to be built.
     A PM control option that would reduce PM emissions to
0.034 g/dscm (0.015 gr/dscf)  has also been evaluated for DCE
recovery furnaces that have PM emissions at or below the NSPS
level.   This  PM control option includes an ESP upgrade coupled
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with the addition of a packed-bed scrubber and applies to model
DCE recovery furnaces RF-7b through RF-9b, which, as cited above,
represent only existing sources.
     The capital and annual costs for low-odor conversions are
presented in the following sections for model DCE recovery
furnaces.
     6.1.2.3.1  Capital costs:  jnt-.roduction.  The total capital
cost of  the low-odor conversion control option includes purchase
and installation costs of the  extended economizer with associated
soot blowers and ash handling  equipment;  demolition  costs for the
DCE and  BLO unit; purchase and installation  costs of the black
liquor concentrator; ESP upgrade  capital  costs;  and  wet to dry
ESP system conversion  capital  costs.
     6 1.2.3.2  Capital costs;  economizer expansion, demolition,.
and concentrator.   The cost  of economizer expansion  and
demolition has  been estimated  at  $6.5 million for a  mid-size
recovery furnace.   The cost  estimate  is based on cost  data  from
three  sources--two  recovery  furnace manufacturers and  one kraft
pulp mill, at which three  low-odor conversions were  completed
over a 3-year period.   A 20  percent contingency  factor was  added
to the supplier costs  to  account  for site-specific  tie-in work.
Where  applicable,  the  available cost  data were adjusted  to  1991
dollars and scaled for a 0.7 million kg BLS/d (1.5  million  Ib
BLS/d)  furnace using the six-tenths power rule.   The $6.5 million
 cost  estimate is the average of the adjusted costs  from the three
 sources--$6 million,  $4.8 million, and $8.6 million. '  '
      The concentrator costs are based on cost information from a
 concentrator manufacturer.  The equipment costs for a falling
 film concentrator range from $1.5 to $3 million.  Total capital
 costs, including installation, are approximately two times the
 equipment cost.19  Based on this information, the average total
 capital cost estimate for a concentrator is approximately
 $4.5 million.  The concentrator capital  cost estimate does not
 include liquor storage and piping costs  or  the  cost for the
 addition of a cooling tower cell.
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      The  total  economizer expansion,  demolition,  and concentrator
 cost  for  the mid-size model  DCE  recovery  furnace  (i.e.,  RF-8)  is
 approximately $11 million, equal to  the sum of  the  $6.5  million
 for the economizer  expansion and demolition and the $4.5 million
 for the concentrator.  The six-tenths power rule  was used  to
 calculate the capital costs  for  the  small and large model  DCE
 recovery  furnaces  (i.e.,  RF-7 and RF-9).  The low-odor conversion
 capital costs  (excluding  the pulp production losses)  are
 presented in Table  6-11.   The capital costs, excluding the ESP
 upgrade and wet to  dry ESP system conversion costs,  range  from
 $8.09 million to $15.7 million for model  DCE recovery furnaces
 RF-7  through RF-9.
      6.1.2.3.3   Capital costs:   ESP  upgrade.  Electrostatic
 precipitator upgrade costs to achieve total  outlet  PM emissions
 of 0.10 g/dscm  (0.044 gr/dscf) have  been  determined for  the
 applicable DCE  recovery furnace  models.   The ESP  upgrade capital
 costs to  control PM to NSPS  levels for model DCE  recovery
 furnaces  RF-7a  through RF-9a are derived  from the Schedule 1 ESP
 manufacturer costs  discussed in  Section 6.1.2.1.3 and presented
 in Table  6-4.9   The Schedule 1 costs  were chosen  because the ESP
 upgrade could be completed within the scheduled time for the
 low-odor  conversion.  The  six-tenths  power rule was  used to
 calculate the capital costs  for  the model DCE recovery furnaces.
 The ESP upgrade  costs to control  PM  emissions to  NSPS levels for
 the model DCE recovery furnaces  are presented in  Table 6-11,
 excluding pulp production losses.  The ESP upgrade  costs range
 from $881,000 to $1.70 million for RF-7a through  RF-9a.  The
 bleached and unbleached pulp production losses are presented in
 Table 6-12.  Although NSPS PM emission levels are associated with
 model DCE recovery  furnaces  RF-7b through RF-9b at baseline, once
 they are converted  to NDCE recovery furnaces, the ESP's must be
 upgraded in order to maintain PM emissions at NSPS levels.  The
 ESP upgrade costs presented  above for model  furnaces RF-7a
 through RF-9a were  applied,  as a worst-case  cost  estimate,  for
model DCE recovery  furnaces  RF-7b through RF-9b.
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     Control costs to achieve total outlet PM emissions of
0.034 g/dscm (0.015 gr/dscf) have been determined for the
applicable DCE recovery furnace models.  These PM control costs
would include both ESP upgrade costs and packed-bed scrubber
costs.  This section presents the ESP upgrade costs; the packed-
bed scrubber costs are presented in Section 6.1.2.4.  The capital
costs for an ESP upgrade to control PM emissions to 0.034 g/dscm
(0.015 gr/dscf) were estimated by summing the Schedule 1 ESP
upgrade costs presented above and the ESP upgrade costs presented
in Table 6-8 and discussed  in Section 6.1.2.1.5.  These costs
apply to model DCE recovery furnaces RF-7a through RF-9a.  The
ESP upgrade costs for model DCE recovery furnaces are presented
in Table 6-13, excluding pulp production losses, and range from
$9.80 million to $19.4 million for RF-7a through RF-9a.  The
bleached and unbleached pulp production losses are presented in
Table 6-14.  Using the same reasoning stated in the previous
paragraph, the ESP upgrade  costs presented above for model
recovery furnaces RF-7a through RF-9a were applied, as a worst-
case cost estimate,  for model DCE recovery furnaces RF-7b through
RF-9b.
     6.1.2.3.4  Capital costs:  wet to dry ESP system  conversion.
The wet to dry ESP system conversion costs for model DCE recovery
furnaces RF-7 through RF-9  are based on ESP manufacturer costs
presented in Table 6-10 and discussed  in Section 6.1.2.2.1  for
converting NDCE recovery furnace wet ESP systems to the dry ESP
system design.13  The ESP manufacturer costs were  converted to
1991 dollars and  then scaled  for the model DCE recovery furnaces
using the six-tenths power  rule.   The  conversion costs include
the  costs to remove  the  existing agitator paddles  and  liquor
piping and  install a perpendicular drag  scraper  system,  shallow
fallout hoppers,  drag  chain conveyors, and  rotary  valves  but  do
not  include  the  costs  for asbestos removal  or  equipment  or  piping
beyond the  rotary valves  (e.g.,  an ash mixing  tank and associated
equipment).13  The  ESP  system conversion costs  for the model  DCE
recovery  furnaces are presented in Table 6-11  and  range  from
 $439,000  to  $849,000 for RF-7 through RF-9.
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      6.1.2.3.5   Capital  costs:  total  costs.  The total  capital
 costs for  the low-odor conversion  option are equal to the sum of
 the economizer expansion,  demolition,  and  concentrator  costs plus
 the ESP upgrade  and wet  to dry  ESP system  conversion costs.
 These costs, excluding pulp production losses, are presented in
 Table 6-11 and range'from  $9.41 million to $18.2 million for
 RF-7a/7b through RF-9a/9b.
      6.1.2.3.6   Capital  costs:  pulp production losses.  The
 production losses attributed to a  low-odor conversion are
 site-specific and depend on factors such as liquor storage
 capacity,  liquor trade or  sell  options, and coordination with
 scheduled  mill shutdowns.15 Pulp  production losses were
 calculated assuming an average  additional  shutdown period of
 11 days beyond the scheduled 2-week shutdown period  (i.e., a
 total  of 25 days of downtime).  The pulp production losses were
 calculated using the market values of  bleached and unbleached
 pulp  discussed in Section  6.1.1.1  and  an earnings margin of
 25 percent.3
      The average 25-day  shutdown was estimated based on the
 following  information:
      1.  A time  frame for  completion of 21 to 30 days with proper
 pre-shutdown planning and prefabrication;15
      2.  A case study where one mill completed three low-odor
 conversions over a 4-week outage (i.e.., 31 days);20 and
      3.  A case study that  involved two shutdowns;  the first
 shutdown was for several days to relocate ductwork, and the
 second was for approximately 10 days to tie in the new systems.21
     The total capital costs that include pulp production losses
associated with the low-odor conversion are presented in Tables
 6-12 and 6-14.   For mills producing bleached pulp,  the pulp
production losses associated with a low-odor conversion range
from $488,000 to $1.46 million for RF-7a/7b through RF-9a/9b.
For mills producing unbleached pulp, the pulp production losses
associated with a low-odor  conversion range from $348,000 to
$1.04 million for RF-7a/7b through RF-9a/9b.
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     6.1.2.3.7  Incremental annual costs: introduction.  The ITAC
estimate includes the following six primary components:
     1.  Capital recovery;
     2.  Administrative costs, taxes, and insurance;
     3.  Steam production credits;
     4.  Operating cost savings for the BLO;
     5.  Concentrator steam costs; and
     6.  Operating electricity costs for the ESP.
     The annual costs of these six primary components were
estimated for the three model DCE recovery furnaces and summed to
determine the ITAC.  As discussed in Section 6.1.2.3, certain
other potential cost savings were not quantified.  These
potential cost savings include  (1) maintenance cost savings
resulting from eliminating the DCE;  (2) -ESP replacement cost
savings resulting from a less corrosive exit gas stream
associated with NDCE recovery furnaces; and  (3) pulp production
credits for those mills that choose  to provide for additional
capacity during the low-odor conversion.
     6.1.2.3.8  Incremental annual costs: capital recovery.  For
a low-odor conversion, the capital recovery costs for'the model
DCE recovery  furnaces are based on the following:
     1.  An equipment life of 20 years;
     2.  The  model capital costs presented  in Tables 6-11 through
6-14;
     3.  The  model bleached and unbleached pulp  production  losses
incurred during  construction, which  are  presented in Tables 6-12
and 6-14; and
     4.  An interest  rate of  7 percent.
     Total capital recovery costs were calculated for  each  PM
control level for the following three  scenarios:
     1.  Without  annualized pulp  production losses  (Scenario 1);
     2.  With annualized bleached pulp production losses
 (Scenario 2); and
     3.  With annualized unbleached  pulp production losses
 (Scenario 3).
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     Design parameters for each model furnace are presented in
Table 6-15.                        *'
     The low-odor conversion capital  recovery costs for
Scenarios 1, 2, and 3 for model DCE recovery furnaces (including
an ESP upgrade to control PM emissions to NSPS levels) are
presented in Tables 6-16, 6-17, and 6-18, respectively.   For
Scenario 1, capital recovery costs range from $918,000/yr to
$1.78 million/yr for RF-7a/7b through RF-9a/9b.  For Scenario 2,
capital recovery costs range from $964,000/yr to $1.92 million/yr
for RF-7a/7b through RF-9a/9b.  For Scenario 3, capital recovery
costs range from $951,000/yr to $1.88 million/yr for RF-7a/7b
through RF-9a/9b.
     The low-odor conversion capital  recovery costs for
Scenarios 1, 2, and 3 for model DCE recovery furnaces (including
an ESP upgrade to control PM emissions to 0.034 g/dscm
[0.015 gr/dscf])  are presented in Tables 6-19, 6-20, and 6-21,
respectively.  For Scenario 1, capital recovery costs range from
$963,000/yr to $1.91 million/yr for RF-7a/7b through RF-9a/9b.
For Scenario 2, capital recovery costs range from
$1.01 million/yr to $2.05 million/yr for RF-7a/7b through
RF-9a/9b.  For Scenario 3, capital recovery costs range from
$996,000/yr to $2.01 million/yr for RF-7a/7b through RF-9a/9b.
     6.1.2.3.9  Incremental annual costs: administrative, taxes,
and insurance costs.  Administrative, tax,  and insurance costs
were estimated as 4 percent of the TCI and are presented in each
of the low-odor conversion annual cost tables, starting with
Table 6-16.6
     6.1.2.3.10  Incremental annual costs:  steam production
credits.  Steam production credits result from the improved steam
flow that occurs with a low-odor conversion.22  The steam
production credit is assumed to be equal to the cost of the power
boiler fuel that has been displaced by black liquor in steam
generation.  It was assumed that mills would first reduce the use
of higher-cost power boiler fuels, i.e., natural gas or fuel oil.
Therefore, only the reduction in the  use of natural gas and fuel
oil was considered in determining the displaced fuel cost and not
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reductions in the use of lower-cost hogged wood or coal.  To
determine the displaced fuel cost, the increase in the thermal
efficiency that results from a low-odor conversion was estimated.
     The increase in the thermal efficiency that results from a
low-odor conversion is estimated to be 10 percentage points.  The
supporting data for this estimate are as follows:
     1.  Direct contact evaporator recovery furnaces operate at
thermal efficiencies of 53 to 58 percent, whereas NDCE recovery
furnaces operate at thermal efficiencies of 63 to 68 percent;15
and
     2.  The thermal efficiency of a recovery furnace increases
approximately 1 percentage point for every 22 °C  (40°F) drop in
exit temperature.16  The difference in the exit flue gas
temperatures before and after a low-odor conversion is about
200°C  (400°F), which corresponds to a 10 percentage point
increase in thermal efficiency.  For DCE recovery furnaces, the
exit flue gas temperature is 371°C to 427°C  (700°F to 800°F).15
This high temperature range is needed to operate the DCE.   For
NDCE recovery furnaces, the design exit flue gas temperature
range  is 177°C to 357°C  (350°F to 375°F).l6  The exit flue  gas
temperature for NDCE recovery  furnaces is limited by the optimum
operable range for the ESP  (163°C to 204°C  [325°F to 400°F]) and
recovery furnace operating and design parameters  (163°C  [325°F]
minimum).16
     The steam production credit  estimates are presented in each
of  the low-odor conversion annual cost tables, starting with
Table  6-16.  If natural gas is the displaced steam generation
fuel,  the average steam production credit is estimated  to  range
from $758,000/yr to  $2.27 million/yr for RF-7a/7b through
RF-9a/9b.  If oil is  the displaced fuel, the average  steam
production credit is  estimated to range  from $1.19 million/yr  to
$3.58  million/yr for RF-7a/7b  through RF-9a/9b.  These  estimates
are based on the following  information:
     1. A thermal  efficiency  increase  of 10 percentage points
 (from  56  to  66 percent);
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     2.  Model BLS  firing  rates  of  0.7,  1.2, and  1.8 million kg
BLS/d  (0.9,  1.5, and  2.7 million Ib BLS/d), with  a BLS heat
content  of  13,900 kJ/kg  (6,000 Btu/lb);8
     3.  A  natural  gas heat  content of 38,100 kJ/m3
 (1,024 Btu/ft3) and cost of  $0.12/m3  ($3.48/1,000 ft3);23'24
     4.  A  fuel oil heat content of 40,400 kJ/L  (145,000 Btu/gal)
and cost of $0.20/L ($0.77/gal);23'25 and
     5.  A  power boiler thermal  efficiency of 85 percent.21
     6.1.2.3.11  Incremental annual costs; BLO operating cost
savings.  The high  operating costs  associated with air-sparging
BLO units are eliminated with the removal of the BLO unit during
a low-odor  conversion.  Most of  the BLO operating costs  (about
60 percent)  is for  power to operate the blowers and pumps.  The
remaining 40 percent  is for operating the reheater.26  These cost
savings are included  as a  credit in the total annual cost
estimate.   The annual operating  costs of a BLO system that
oxidizes black liquor for  a DCE  recovery furnace range from
$103,000 to $309,000  for RF-7 through RF-9.  The cost savings
from removal of the BLO unit are presented in each of the low-
odor conversion annual cost tables, beginning with Table 6-16.
The cost savings are based on total annual costs of $251,900/yr
for a BLO 'unit that oxidizes black  liquor fired in two DCE
recovery furnaces with a total black liquor firing rate of
1.0 million kg BLS/d  (2.2  million Ib BLS/d)4.
     6.1.2.3.12  Incremental annual costs: concentrator steam
costs.   The concentrator'that replaces the DCE in a low-odor
conversion uses low-pressure steam  to evaporate moisture from the
black liquor.  The  vapor from the concentrator can be used for
additional  evaporation at  lower  black liquor solids levels, or
can be used to heat water.  Concentrator steam costs were
estimated for each  model DCE recovery furnace,  assuming that
steam usage is proportional to the amount of black liquor
concentrated.  The  annual  concentrator steam costs for the model
recovery furnaces range from $57,800 to $173,000 for RF-7 through
RF-9.   The  concentrator steam costs are presented in each of the
low-odor conversion annual cost  tables,  beginning with
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Table 6-16.  Concentrator steam costs are based on the following
information:
     1.  A steam requirement of approximately 4,500 kg/hr
(10,000 Ib/hr) of low-pressure steam for a 1.1 million kg BLS/d
(2.4 million Ib BLS/d) furnace;27 and                          ^
     2.  A cost of $4.02/Mg  ($3.65/ton) for low-pressure steam.
     6.1.2.3.13  Incremental annual costs: electricity costs.
The increase in electricity  costs for upgrading the ESP to
maintain or reduce PM emissions to the NSPS level of 0.10 g/dscm
 (0.044 gr/dscf) was estimated for model DCE recovery furnaces
RF-7a/7b through RF-9a/9b.   The actual increase in electricity
costs for  the  ESP upgrade  is not known.  It was assumed that the
incremental increase  in  electricity costs  for an upgraded ESP
would be the  same as  for a replacement ESP.  Because the
electricity cost increases for the replacement ESP in
Section 6.1.2.1.2 were based on an increase in SCA, the
electricity cost increases for the upgraded ESP were calculated
in the same manner.
                                                -9a, with
 PM
     For DCE recovery furnaces RF-7a through
   emissions above 0.10 g/dscm (0.044 gr/dscf),  the ESP
baseline
 electricity costs were estimated based on an increase in SCA
 values from approximately 70 m2/(m3/sec)  (330 ft2/!,000 acfm)  to
 approximately 100 m2/(m3/sec)  (530 ft2/l,000 acfm).4  For DCE
 recovery furnaces RF-7b through RF-9b, with baseline PM emissions
 less than or equal to 0.10 g/dscm (0.044 gr/dscf)  but greater
 than 0.034 g/dscm (0.015 gr/dscf), the ESP electricity costs were
                       increase in SCA values from approximately
estimated based on an
90 m2/(m3/sec) (430 ft2/!,000 acfm) to
                                        approximately
 100 m2/(m3/sec) (530 ft2/!,000 acfm).4  The increase in ESP
 electricity costs resulting from the maintenance or control of PM
 emissions to the NSPS level are presented in Tables 6-16 through
 6-18 for each of the model DCE recovery furnaces and range from
               $70,000/yr for RF-7a through RF-9a and $ll,700/yr
$23,300/yr to
to $35,000/yr
               for RF-7b through RF-9b.
      The increase in electricity costs resulting from the
 implementation of PM controls to reduce PM emissions to
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0.034 g/dscm  (0.015 gr/dscf) was estimated for model DCE recovery
furnaces RF-7a/7b through RF-9a/9b.  The PM control electricity
costs would include both ESP upgrade and packed-bed scrubber
electricity costs.  The ESP upgrade electricity costs are
presented in this section; Section 6.1.2.4 presents the packed-
bed scrubber electricity costs.
     For DCE recovery furnaces RF-7a through RF-9a, with baseline
PM emissions above 0.10 g/dscm (0.044 gr/dscf), the increase in
ESP electricity costs is based on an increase in the SCA from a
baseline value of approximately 70 m2/(m3/sec) (330 ft2/
1,000 acfm) to approximately 120 m2/(m3/sec)  (620 ft2/
1,000 acfm}.4  For DCE recovery furnaces RF-7b through RF-9b,
with baseline PM emissions less than or equal to 0.10 g/dscm
(0.044 gr/dscf) but greater than 0.034 g/dscm  (0.015 gr/dscf),
the ESP electricity costs were estimated based on an increase in
SCA values from approximately 90 m2/(m3/sec)  (430 ft2/!,000 acfm)
to approximately 120 m2/(m3/sec)  (620 ft2/!,000 acfm).4  The
increase in ESP electricity costs resulting from the control of
PM emissions to 0.034 g/dscm (0.015 gr/dscf) are presented in
Tables 6-19 through 6-21 for each of the model DCE recovery
furnaces and range from $33,100/yr to $99,200/yr for RF-7a
through RF-9a and $21,400/yr to $64,200/yr for RF-7b through
RF-9b.
     As stated in Section 6.1.2.2.2, electricity costs do not
change significantly when a wet ESP system is converted to the
dry ESP system design because of an equal trade-off in horsepower
requirements between the wet and dry ESP system designs.
Therefore, no electricity costs for the wet to dry ESP system
conversion are presented in this cost analysis.
     6.1.2.3.14  Incremental annual costs: total costs.
Incremental total annual costs were estimated for converting
model DCE recovery furnaces to an NDCE design for each of the PM
control levels, each of the scenarios, and each of the displaced
fuels.  The scenarios were discussed in Section 6.1.2.3.8.
Scenario 1 excludes annualized pulp production losses from the
ITAC; Scenario 2 includes annualized bleached pulp production
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losses in the ITAC; and Scenario 3 includes annualized unbleached
pulp production losses in the ITAC.
     The ITAC estimates for Scenario 1 for DCE recovery furnaces
with controlled PM emissions at NSPS levels are presented in
Table 6-16.  For Scenario 1, with natural gas as the. displaced
steam generation fuel, the ITAC range from $520,000/yr to
$170,000/yr for RF-7a through RF-9a and $508,000/yr to
$140,000/yr for RF-7b through RF-9b.  If fuel oil is the
displaced steam generation fuel, the ITAC for Scenario 1 range
from a cost of $90,000/yr for RF-7a to a cost savings of
$1.14 million/yr for RF-9a; for RF-7b through RF-9b, the ITAC for
Scenario 1 range from a cost of $80,000/yr to a cost savings of
$1.17 million/yr.
     The ITAC estimates for Scenario 2 for DCE recovery furnaces
with controlled PM emissions at NSPS levels are presented in
Table 6-17.  For Scenario 2, with  natural gas as the displaced
steam generation fuel, the  ITAC estimates range from $560,000/yr
to $310,000/yr for RF-7a through RF-9a and $548,000/yr to
$280,000/yr  for RF-7b  through RF-9b.  If fuel oil is the
displaced  steam generation  fuel, the ITAC for Scenario 2 range
from  $130,000/yr for RF-7a  to $120,000/yr for RF-7a to a cost
savings  of  $1.00 million/yr for RF-9a; for RF-7b through RF-9b,
the ITAC for Scenario  2  range from a cost of  $120,000/yr to a
cost  savings of  $1.03  million/yr.
      The ITAC estimates  for Scenario 3 for DCE  recovery  furnaces
with  controlled PM emissions  at NSPS levels  are presented  in
Table 6-18.   For Scenario  3,  with natural gas as  the displaced
 steam generation fuel,  the ITAC  range  from  $550,000/yr  to
 $270,000/yr for RF-7a through RF-9a and  $538,000/yr to
 $240,000/yr for RF-7b through RF-9b.   If fuel  oil  is  the
 displaced steam generation fuel,  the ITAC for Scenario  3  range
 from a cost of $120,000/yr for RF-7a to  a cost  savings  of
 $1.04 million/yr for RF-9a; for RF-7b  through RF-9b,  the ITAC' for
 Scenario 3 range from a cost of  $110,000/yr to a cost  savings of
 $1.07 million/yr.
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     The ITAC estimates for Scenario 1 for DCE recovery furnaces
with controlled PM emissions of 0.034 g/dscm (0.015 gr/dscf) are
presented in Table 6-19.  For Scenario 1, with natural gas as the
displaced steam generation fuel, the ITAC range from $590,000/yr
to $380,000/yr for RF-7a through RF-9a and $578,000/yr to
$350,000/yr for RF-7b through RF-9b.  If fuel oil is the
displaced steam generation fuel, the ITAC for Scenario 1 range
from a cost of $160,000/yr to a cost savings of $930,000/yr for
RF-9a; for RF-7b through RF-9b, the ITAC for Scenario 1 range
from a cost of $150,000/yr to a cost savings of $960,000/yr.
     The ITAC estimates for Scenario 2 for DCE recovery furnaces
with controlled PM emissins of 0.034 g/dscm (0.015 gr/dscf) are
presented in Table 6-20.  For Scenario 2, with natural gas as the
displaced steam generation fuel, the ITAC range from $630,000/yr
to $520,000/yr for RF-7a through RF-9a and $618,000/yr to
$490,000/yr for RF-7b through RF-9b.  If fuel oil is the
displaced steam generation fuel, the ITAC for Scenario 2 range
from a cost of $200,000/yr for RF-7a to a cost savings of
$790,000/yr for RF-9a; for RF-7b through RF-9b, the ITAC for
Scenario 2 range from a cost of $190,000/yr to a cost savings of
$820,000/yr.
     The ITAC estimates for Scenario 3 for DCE recovery furnaces
with controlled PM emissions of 0.034 g/dscm (0.015 gr/dscf) are
presented in Table 6-21.  For Scenario 3, with natural gas as the
displaced steam generation fuel, the ITAC range from 620,000/yr
to $480,GOO/yr for RF-7a through RF-9a and $608,000/yr to
$450/000/yr for RF-7b for RF-9b.  If fuel oil is the displaced
steam generation fuel, the ITAC for Scenario 3 range from a cost
of $190,000/yr for RF-7a to a cost savings of $830,000/yr for
RF-9a; for RF-7b through RF-9b, the ITAC for Scenario 3 range
from a cost of $180,000/yr to a cost savings of $860,000/yr.
     6s. 1.2.4  Addition of Packed-Bed Scrubber.   The addition of a
packed-bed scrubber downstream of the ESP is included in two of
the contrpl options examined for recovery furnaces.  These
control options are (1)  the use of an ESP plus a packed-bed
scrubber to meet an outlet PM emission level of 0.034 g/dscm
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(0.015 gr/dscf);  and (2) the use of a packed-bed scrubber to
reduce HCl emissions from recovery furnaces.
     The costs of replacing or upgrading ESP's to control PM
emissions are presented in Sections 6.1.2.1 and 6.1.2.3 for NDCE
and DCE recovery furnaces.  This section discusses the design and
cost of packed-bed scrubbers for nine model recovery furnaces.
The design and cost of packed-bed scrubbers are presented for the
three model DCE recovery furnaces both with and without a low-
odor conversion.  The applicable model recovery furnaces for the
packed-bed scrubber control option are RF-1 through RF-9.
Exhaust gas stream parameters for each model and associated
absorber are shown in Table 6-22.
     6.1.2.4.1  Packed-bed scrubber design.  Because only limited
information was available from a scrubber manufacturer regarding
the design parameters associated with a scrubber used to control
HCl emissions from kraft recovery furnaces, the model packed-bed
scrubbers were designed based on the procedures presented in
Chapter 9 of the OAQPS  Control Cost Manual  for counterflow
towers.6'29  Two assumptions were made to simplify the packed-bed
scrubber design analysis.  First, it was assumed that the gas
stream exiting the ESP  is cooled to saturation by a water spray
before it enters the packed-bed scrubber.   As a result,  the gas
stream flow rates into  and out of the packed-bed scrubber are  the
same.  Insufficient design information was  available  from the
OAQPS  Control Cost Manual and a scrubber manufacturer to include
in the design analysis  a  quench chamber for cooling the  gas
stream.  A second simplifying assumption was  that the diffusivity
of HCl in the gas stream  is approximated by the diffusivity of
HCl in the air.
      Because  the model  gas flow rates are  large and the  inlet HCl
concentrations  are  low  (only  9.7 ppmv for model NDCE  and
converted model DCE recovery  furnaces and  9.2 ppmv  for
unconverted model DCE recovery  furnaces),  the diameters  of  the
model towers  are  11 to  23 times  the height  of the packing.   The
packing  height  was  about  0.60 m (1.54 ft)  for each  model NDCE and
 converted model DCE recovery furnace and  0.43 m (1.41 ft)  for
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each unconverted model DCE recovery furnace.  The tower diameters
ranged from 5.2 to 11 m  (17 to 36 ft) for model NDCE and
converted model DCE recovery furnaces and 5.4 to 9.3 m  (18 to
30 ft) for unconverted model DCE recovery furnaces.  Design and
operating parameters for each model recovery furnace packed-bed
scrubber are shown in Table 6-23.  The algorithm showing the
procedures and equations used to determine the packed-bed
scrubber design parameters is presented in a separate
memorandum.3 ®
     6.1.2.4.2  Capital costs.  Capital costs were calculated
based on procedures presented in the OAQPS Control Cost Manual.^
The unit costs used in calculating the capital and annual costs
were derived from the OAQPS Control Cost Manual and from
background information for the Medical Waste Incinerator
standard.6'31  The unit costs are shown in Table 6-24.  Capital
costs in 1991 dollars are presented in Table 6-25 for each model
recovery furnace.  These costs were compared to those obtained
from a scrubber manufacturer.2^
     Capital costs consist of purchased equipment and
installation costs.  Purchased equipment costs consist of
equipment, instrumentation, sales tax, and freight costs.
Equipment includes a fiberglass reinforced polyester stack,
fiberglass absorber tower, 5-cm (2-in.)  randomly packed ceramic
Raschig rings, a liquid recirculating pump, an induced draft fan,
and a fan motor.
     The addition of a packed-bed scrubber may result in
additional dissolved solids loading to the wastewater treatment
system.  For those mills with restrictive total dissolved solids
(TDS) effluent limitations, the additional solids loading from
the scrubber may require internal process measures to reduce
dissolved loading from other areas of the mill.  These internal
process measures will have associated engineering, equipment, and
construction costs.  However,  because the additional costs are so
site-specific, they cannot be estimated on a model basis and may
even be offset by any heat recovery benefits realized as a result
of adding an HC1 scrubber.
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     All equipment costs were estimated as functions of various
design parameters.  Specifically, the stack cost was based on the
length and diameter of the stack; the packed tower cost was based
on the surface area of the tower; the packing cost was based on
the volume of packing; the fan cost was based on the impeller
diameter; the fan motor cost was based on the horsepower rating;
and the pump cost was based on the design liquid flow rate. '
In most cases, the referenced costing equations were developed
for much smaller equipment.  Thus, the costs for the models in
this analysis were developed by extrapolating well beyond the
largest parameter value for which the equations were developed.3
     Instrumentation, sales tax, and freight were estimated to be
equal to 18 percent of the equipment costs.  Installation was
estimated to be equal to  120 percent of the purchased equipment
costs.6  Total capital costs were estimated for each of the model
recovery furnaces.  The model furnaces include both new and
existing furnaces.  For model NDCE recovery furnaces RF-l  through
RF-6, the total capital costs range from  $1.10 million to
$2.58 million.  For unconverted model DCE recovery  furnaces  RF-7
through RF-9, the  total capital  costs range from  $736,000  to
$1.93 million.  The total capital costs for the model DCE
recovery furnaces  converted  to the NDCE design are  slightly  lower
because  of  the change in  furnace  characteristics  that  occurs
after a  low-odor  conversion.  The total capital costs  for  the
converted model DCE recovery furnaces RF-7 through  RF-9 are
identical to those for comparably sized model NDCE  recovery
furnaces and range from $707,000  to  $1.85 million.
     Capital costs for a  packed-bed  scrubber were also obtained
from a  scrubber manufacturer.  The manufacturer provided packed-
bed scrubber capital  costs of $895,000,  $1.69 million,  and
$2.30 million for three model furnaces with  scrubber inlet gas
flow rates  of 47.2,  118,  and 189 m3/sec   (100,000,  250,000, and
400,000 acfm) ,  respectively.   These  costs include the cost for a
quench,  packed tower,, mist eliminator,  recirculation system
 (including  two recirculation pumps  and recirculation piping),
                                                       7 Q
 instrumentation,  engineering costs,  and exhaust stack.
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Corrected for differences in gas flow rates from the model costs
presented in the previous paragraph, the costs from the scrubber
manufacturer differ by approximately 5 to 25 percent from the
OAQPS costs presented in the previous paragraph for comparably
sized model furnaces.  This cost difference is within the
±30 percent range of accuracy that OAQPS costs should have,
according to the OAQPS Control Cost Manual.6  However, it should
be noted that the OAQPS costs estimated here do not include
quench costs.
     6.1.2.4.3  Annual costs.   Annual costs for the packed-bed
scrubber were also calculated based on procedures presented in
the OAQPS Control Cost Manual.  Unit costs used in the annual
cost calculations are shown in Table 6-24.  Total annual costs in
1991 dollars are presented in Table 6-26 for the model recovery
furnaces.
     Annual costs were developed for labor, maintenance
materials, water, caustic, wastewater disposal, electricity,
overhead, property taxes, insurance, administrative charges, and
capital recovery.  Operator labor and maintenance labor were both
assumed to be 0.5 hr per 8-hr shift, with three shifts per day.
Supervisory labor costs were estimated to be equal to 15 percent
of the operator labor costs.  Maintenance materials costs were
estimated to be equal to 100 percent of the maintenance labor
costs.6  The wastewater flow rate was estimated based on the
assumption that the NaCl concentration in the recirculating water
would be limited to 10 percent by weight.  As a result, blowdown
is approximately 0.08 to 0.09  percent of the recirculating liquid
flow rate.  Makeup water is needed for evaporative cooling before
the packed-bed scrubber and to replace the blowdown losses.  A
stoichiometric amount of caustic is needed to react with all of
the HC1 in the exhaust gas stream; an additional amount of
caustic must be added to react with the S02 also present in the
exhaust gas stream (assuming 50 percent SO2 control).
Electricity usage by the fan was based on the gas flow rate out
of the quench shown in Table 6-22 and the pressure drop and
fan-motor efficiency shown in Table 6-23.  Electricity usage by
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the pump was based on the gas flow rate out of the quench shown
in Table 6-22, the pump-motor efficiency shown in Table 6-23, and
an assumed pressure head of 18 m  (60 ft).   Overhead costs were
estimated to be equal to 60 percent of all labor and maintenance
materials costs.6' Collectively, property taxes, insurance, and
administrative charges were estimated to be equal to 4 percent of
the TCI.6  Capital recovery was estimated to be equal to a CRF
times the TCI.6  The CRF is 0.1098, based on an equipment life of
15 years and an interest rate of  7 percent.
     For model NDCE recovery furnaces RF-1 through RF-6, the TAG
 (as shown in Table 6-26) range from $348,000/yr to $790,000/yr.
For model unconverted DCE recovery furnaces RF-7 through RF-9,
the TAG range from $229,000/yr to $554,000/yr.  The TAG for  the
model DCE recovery furnaces converted to the NDCE design are
slightly higher because of higher costs for caustic, water,  and
wastewater disposal.  The higher  costs  are a result of the higher
S02 emission  factor included in the equations  for those costs.
Based on the  limited  information  available, S02 emissions  are
slightly higher,  on average, from NDCE  recovery furnaces than
from DCE recovery furnaces.32   The TAG  for the converted model
DCE recovery  furnaces RF-7  through RF-9 are identical  to those
 for comparably  sized  model  NDCE recovery  furnaces and  range  from
 $234,000/yr  to  571,000/yr.
 6.1.3   Black  Liquor Oxidation  Unit  Control Options
     Two  control  options,  conversion  of a DCE  recovery furnace
 system  to  an NDCE recovery furnace  and incineration of BLO vent
             evaluated for controlling gaseous  organic  HAP
 gases,  were
 emissions from air-sparging BLO
units.  The cost of the first
 option--converting DCE recovery furnace systems to NDCE recovery
 furnaces--was presented in Section 6.1.2.3.  The following
 section presents the capital and annual costs of the second BLO
 control option--incineration of BLO vent gases.  This BLO control
 option applies to model BLO units BLO-1 through BLO-3, which
 represent existing BLO units associated with DCE recovery
 furnaces.  These models represent only existing BLO units because
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no new DCE recovery furnace systems with BLO units are expected
to be installed.
     6.1.3.1  Capital Costs.  The total capital costs to collect
BLO vent gases and incinerate them in a power boiler or other
incineration device are based on a 1990 BLO control cost estimate
of $4.8 million supplied by industry for a 730 ADMP/d
(800 ADTP/d) kraft pulp mill.33  The 1990 BLO control cost
estimate includes piping, fans, condensers, and safety-related
equipment, such as flame arresters, rupture disks, etc.  No major
power boiler modifications  (such as scrubber modifications) are
included.  The BLO control cost estimate was adjusted to 1991
dollars and then scaled using the six-tenths power rule described
in Section 6.1.1.2 to derive BLO control costs for the model BLO
units.  A conversion factor of 1,700 kg BLS/ADMP  (3,400 Ib
BLS/ADTP) (the average for bleached and unbleached pulp mills
together) was assumed in scaling the cost.  Design parameters for
each model BLO unit are presented in Table 6-27.  The model BLO
control capital costs are presented in Table 6-28.  The BLO
control capital costs range from $2.5 million to $4.83 million
for BLO-1 through BLO-3.  Because the BLO collection and
incineration system for one mill was installed within a 1-week
maintenance shutdown, it was assumed that no downtime would be
necessary beyond the annual 2-week shutdown used in determining
costs.34  As a result, no pulp production losses are included in
these costs.
     6.1.3.2  Annual Costs.  Annual costs were estimated for
operating and supervisory labor, maintenance labor and materials,
electricity, steam, and indirect costs (e.g., overhead,
administrative, taxes, insurance, and capital recovery).  The BLO
control annual costs were estimated for each model BLO unit based
on the following sources:
   "  1.  Annual operating requirements provided by one mill (Mill
A) for its BLO vent gas control system;2^
     2.  Operating labor costs from the U. S. EPA Handbook:
Control Technologies for Hazardous Air Pollutants;5 and
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     3.  Supervisory labor and maintenance costs and indirect
costs from the OAQPS Control Cost Manual.6
     The operating labor costs were estimated assuming 0.5 hours
per shift per condenser for two condensers for three 8-hour
shifts per day.5  The operating labor hourly rate was assumed to
be $17/hr.5  The annual operating labor hours were assumed to be
365 d/yr.  The supervisory labor costs were assumed to be
15 percent of the operating labor costs.6  The maintenance labor
costs were estimated at 1.5 times the operating labor costs.
The maintenance materials costs were estimated at 100 percent of
the maintenance labor costs.6
     Electricity costs were estimated based on the total kW  (hp)
requirements to operate the BLO vent gas control equipment at
Mill A and scaled for the model BLO units assuming a direct
relationship between BLO vent gas flow rate and electricity
costs.  For Mill A, with a BLO vent gas flow rate of 7.7 m3/sec
 (16,327 acfm), 980 kW  (100 hp) are required to operate the mill
water booster pump motor, 29 kW  (3 hp) to operate the BLO
condenser condensate pump motor, and 3,900 kW  (400 hp) to operate
the BLO off gas blower motor.26  The model electricity costs were
estimated assuming 8,424 operating hr/yr and $0.06/kWh.
     Steam costs were estimated based on the steam requirements
and unit steam cost for the BLO off-gas reheater at Mill A--
730 kg steam/hr  (1,600 Ib steam/hr) and $7/Mg of steam
 ($3/1,000 Ib of steam), respectively--and scaled for the model
BLO units assuming a direct relationship between BLO vent gas
flow rate and steam costs.26  The model steam costs were
estimated assuming 8,424 operating hr/yr.
     Indirect costs were estimated using assumptions in the  OAQPS
Control Cost Manual.  Overhead  costs were estimated as 60 percent
of labor and maintenance costs.  Administrative, taxes, and
 insurance costs were estimated  as 4 percent of  the TCI.   Capital
recovery costs were calculated  as the product of the CRF  and the
TCI.6  The CRF is  0.1424, based on a  10-yr equipment life for the
                                                          5  24
 ductwork and condenser and  an  interest  rate of  7 percent.  '
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     Total annual costs are presented in Table 6-28 and range
from $681,000/yr to $1.32 million/yr for BLO-1 through BLO-3.
6.1.4  Smelt Dissolving Tank Control Options
     Two PM control options that would reduce PM emissions from
SDT's have been evaluated.  The first option would reduce PM
emissions from existing SDT's to the NSPS level of 0.10 kg/Mg
(0.20 Ib/ton) BLS.  The second option would reduce PM emissions
from existing SDT's to a more stringent level of 0.06 kg/Mg
(0.12 Ib/ton) BLS; the second option also applies to new SPTs;
the option could be used to evaluate the cost to new sources
subject to a more stringent standard (0.06 kg/Mg [0.12 Ib/ton]
BLS) than the current NSPS.
     For mills with existing SDT scrubbers, the costs of both PM
control options were estimated based on replacing the existing
scrubber with a new scrubber.  These-costs were estimated for SDT
models SDT-1 through SDT-4.  For mills with new SDT scrubbers,
the costs of installing scrubbers under the second, more
stringent PM control option also apply to SDT-1 through SDT-4.
For the purposes of this cost analysis, the capital cost to
install a new SDT scrubber capable of meeting 0.06 kg/Mg
(0.12 Ib/ton) BLS was assumed to be the same as the cost to
replace an existing scrubber with a new scrubber capable of
meeting 0.06 kg/Mg (0.12 Ib/ton)  BLS.   However, that may be an
overestimate because the capital cost that would be attributable
to the 0.06 kg/Mg (0.12 Ib/ton)  BLS control option would only be
that cost associated with controlling PM emissions from the
current NSPS level of 0.10 kg/Mg (0.2 Ib/ton) BLS to 0.06 kg/Mg
(0.12 Ib/ton) BLS.  Such a cost is more similar to a scrubber
modification cost than a scrubber replacement cost.
     For mills with existing SDT mist eliminators,  the costs of
both PM control options were estimated based on replacing the
existing mist eliminator with a new scrubber.  These costs were
estimated for SDT models SDT-5 through SDT-7.  The costs of
installing new mist eliminators were not examined because mist
eliminators are not,assumed to be installed on new SDT's.
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     Note: For at least one scrubber type (wetted-wheel
scrubbers), the scrubber replacement capital and annual costs
would be approximately equal to the cost of replacing a mist
eliminator with a scrubber.  Similar to mist eliminators, the
total capital costs would be based on replacement of the entire
scrubber system.  Also similar to mist eliminators, the
incremental annual costs would include electricity costs based on
replacing an existing scrubber that has a low pressure drop with
another that has a significantly higher pressure drop, as well as
indirect costs based on a capital cost of replacing the entire
scrubber system.  The capital and annual costs to replace wetted-
wheel scrubbers will not be presented in this cost analysis
because there is insufficient information to estimate the costs
and because only 13 percent of SDT's have wetted-wheel
scrubbers.4
       The following sections present the capital and annual
costs to  replace existing wet scrubbers and mist eliminators with
new wet scrubbers under the SDT PM control options.
     6.1.4.1  Replacement of Existing Scrubber with New  Scrubber:
Capital Costs.  The conditions under which replacing a scrubber
is more cost-effective than modifying an existing scrubber are •
very site-specific.  To be conservative, only the cost to replace
a scrubber was  evaluated.  The cost to dispose of the existing
scrubber  was assumed to be included in the scrubber replacement
costs.  The  capital costs  to replace the scrubber are based  on
recent  costs provided by a pulp and paper mill for an SDT
scrubber.4   The available  long-term PM emissions  data for the
scrubber  show  that  it  is capable  of consistently meeting both of
the SDT PM emission limits--0.10  kg/Mg  (0.20 Ib/ton) BLS and
0.06 kg/Mg (0.12  Ib/ton) BLS.10   The SDT scrubber is  a packed-
tower  scrubber with a  gas  flow rate of 3.8 m3/sec  (8,071 acfm) at
60 to  70  percent  of recovery  furnace capacity.  The  costs
provided  by the pulp  and paper mill are packed-tower  scrubber
     Hs  and scrubber modification  costs.  The  packed-tower scrubber
      is $280,000  (1988  dollars);  the scrubber'modification  cost
     50,000 (1991  dollars).4   The  1988  scrubber  cost  was  adjusted
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to 1991 dollars using the Chemical Engineering Plant Cost Index
and then summed with the scrubber modification costs to obtain
the total capital cost in 1991 dollars.  The six-tenths rule was
used to extrapolate the total capital cost for each of the model
SDT's.  Based on information from a scrubber manufacturer, the
on-site work time to replace a scrubber is about 2 days.35
Therefore, no downtime beyond the annual 2-week shutdown is
necessary for the scrubber replacement, which means that no pulp
production losses are expected for this control option.
     The model scrubber replacement costs are presented in
Table 6-29.  Total capital investment costs for the SDT models
SDT-1 through SDT-4 range from $292,000 to $706,000.
     6.1.4.2  Replacement of Existing Scrubber with New Scrubber:
Incremental Annual Costs.  The ITAC for each SDT model include
the indirect costs associated with the TCI of the new scrubber
(i.e., administrative, property tax, and insurance costs plus the
capital recovery costs).  The administrative, taxes, and
insurance costs were estimated to be equal to 4 percent of the
TCI.6  A properly designed and maintained venturi scrubber can
operate for 20 years. 5  Other types of scrubbers may have
different life spans.  To be conservative, a 15-year life span
for replacement scrubbers was assumed.  The capital recovery cost
was estimated based on a 15-year scrubber life and a 7 percent
interest rate.  The increase in electricity costs from the
scrubber replacement is not included in the ITAC estimate because
it is not significant relative to the total annual cost.'  The
average pressure drop for existing SDT scrubbers with PM
emissions greater than 0.10 kg/Mg (0.20 Ib/ton) BLS (i.e.,
baseline pressure drop) is approximately the same as the average
pressure drop for those SDT scrubbers capable of meeting both SDT
PM emission limits (0.10 kg/Mg [0.20 Ib/ton]  BLS)  and 0.06 kg/Mg
[0.12 Ib/ton]  BLS)  on a long-term basis.4'10  The baseline and
control level pressure drops are 12 mm Hg (6.5 in. H20) and 13 mm
Hg (7 in. H20') ,  respectively.4  All other direct costs (i.e.,
costs for operating labor,  maintenance, water, and wastewater
treatment)  are assumed to be the same as those incurred by the
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existing scrubber and, therefore, are not included in the ITAC
estimate.
     The ITAC for the four model SDT's are presented in
Table 6-29.  The ITAC estimates range from $43,800/yr to
$106,000/yr for SDT-1 through SDT-4.
     6.1.4.3  Replacement of Existing Mist Eliminator with New
Scrubber: Capital Costs.  The capital costs to replace an
existing mist eliminator with a new scrubber include the costs
for the new scrubber and all auxiliary equipment  (i.e., fans,
ductwork, etc.) that would be required at a new source.  Based on
information from a scrubber manufacturer, a completely new
scrubber system would cost about twice as much as replacing only
the scrubber, as described in Section 6.1.4.I.35  The cost to
dispose of the existing mist eliminator was assumed to be
included in these replacement costs.  Therefore,  the capital
costs for the three model SDT's  are equal to twice the scrubber
replacement costs for the three  corresponding size model SDT's
presented in Section  6.1.4.1.  It  is assumed that no downtime
beyond the annual 2-week shutdown  is necessary for replacing a
mist eliminator with  a scrubber.
     The design parameters for the three SDT models are presented
in Table 6-30.  Capital costs for  replacing a mist eliminator
with a new scrubber are presented  in Table 6-31.  Total capital
investment costs for  the SDT models SDT-5 through SDT-7 range
 from $584,000  to $1
      6.1.4.4   Repl
                     } million
                  acement (
Existing Mist Eliminator with New
 for each SDT
Scrubber: Incremental Annual Costs.  Incremental total annual
costs were estimated for each of the three model SDT's.  The ITAC
             model include both direct and indirect annual costs,
with the exception of operating labor.  No changes in operator
and supervisor personnel were assumed to be required.  The
increase in maintenance labor costs was estimated, assuming
3 hr/d at a wage rate of $25/hr.6  Maintenance materials were
estimated at 100 percent of maintenance labor costs.   As
discussed in Section 6.1.1.3.1, for the purposes of calculating
costs, pressure drop is used as an indicator of PM collection
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efficiency.  Electricity requirements and costs increase as a
result of increasing the pressure drop to reduce PM emissions to
0.10 kg/Mg  (0.20 Ib/ton) BLS and to 0.06.kg/Mg  (0.12 Ib/ton) BLS.
The average pressure drop is 1.3 mm Hg (0.7 in. H20) for those
SDT mist eliminators with PM emissions above 0.06 kg/Mg
(0.12 Ib/ton) BLS  (i.e., baseline pressure drop); the average
pressure drop is 13 mm Hg (7 in. H2O) for those SDT scrubbers
capable of meeting both PM emission limits (0.10 kg/Mg
[0.20 Ib/ton] and 0.06 kg/Mg [0.12 Ib/ton] BLS) on a long-term
basis.4'10  Therefore, an increase in pressure drop from 1.3 to
13 mm Hg (0.7 to 7 in. H20)  was used to estimate the increase in
electricity requirements and resulting increase in electricity
costs.  The overhead cost was estimated to be equal to 60 percent
of the total maintenance cost.6  The administrative, taxes, and
insurance costs were estimated to be equal to 4 percent of the
TCI.6  The capital recovery cost was estimated to be equal to the
product of a CRF and the TCI.6  The CRF is 0.1098, based on a
15-year scrubber life and a 7 percent interest rate.
     The ITAC for the SDT models SDT-5 through SDT-7 are
presented in Table 6-31 and range from $190,000/yr to
$301,000/yr.
6.1.5  Lime Kiln Control Options
     Two PM control options have been evaluated for existing and
new lime kilns.  One PM control option that has been evaluated
for existing lime kilns would reduce PM emissions to the NSPS
level for gas-fired lime kilns--0.15 g/dscm (0.067 gr/dscf).  For
existing lime kilns with wet scrubbers, the control option would
involve replacing the existing scrubber with an ESP.  However,
the actual control device (e.g., ESP or high-efficiency scrubber}
selected by a particular mill would be site-specific.  The costs
for this PM control option were estimated for lime kiln models
LK-1 through LK-3, which represent existing lime kilns controlled
with wet scrubbers.
     Based on PM emissions data supplied by mills, lime kilns
controlled with ESP's already achieve a PM level of 0.15 g/dscm
(0.067 gr/dscf).4'10  Therefore, costs were not estimated for the
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control option reducing PM emissions to 0.15 g/dscm
(0.067 gr/dscf) for lime kilns controlled with ESP's (represented
by models LK-4 through LK-6).
     A second PM control option that was evaluated for new and•
existing lime kilns would reduce PM emissions to 0.023 g/dscm
(0.010 gr/dscf).  For existing lime kilns with wet scrubbers, the
control option would involve replacing the existing scrubber with
an ESP; costs would be estimated for models LK-1 through LK-3.
For existing lime kilns with ESP's, the control option would
involve upgrading the existing ESP.  For new lime kilns, the
control option would involve installing a new ESP capable of
achieving the  0.023 g/dscm  (0.010 gr/dscf) PM level.  The costs
for upgrading  or installing a new ESP were estimated for models
LK-4 through LK-6.  The actual control device selected by a
particular mill would actually be site-specific.  The capital  and
annual costs for each of  these options are presented in the
following sections.
     6.1.5.1   Replacement of Existing Scrubber with ESP: Capital.
Costs.  The costs  of replacing a scrubber with an ESP were
calculated based on recent  ESP costs provided by individual  pulp
and paper mills.4   The  cost to dispose of the existing  scrubber
was assumed to be  included  in the new ESP costs provided by  the
individual mills.   New  lime kiln ESP  costs  average  $484/m2
 ($45/ft2)  of  ESP plate  area.4  The  ESP plate area  for  each model
lime kiln  was  derived  from the model  gas  flow rate  at  the ESP
inlet  and  the SCA for  the new ESP.   The  SCA for model  lime kiln
ESP's  meeting a PM level  of 0.15  g/dscm (0.067 gr/dscf)  is
estimated  to  be 90 m2/(m3/sec)  (460 ft2/!,000 acfm).4   The SCA
value  is based on the  SCA of an actual  lime kiln  ESP  for which
long-term PM emissions data are available to demonstrate that its
PM emissions  are consistently at or below 0.15 g/dscm
 (0.067 gr/dscf).10  The SCA for model lime  kiln  ESP's meeting a
 PM level of 0.023 g/dscm (0.010 gr/dscf)  is estimated to be  220
m2/(m3/sec)  (1,120 ft2/!,000 acfm).4  The SCA value is based on
 the SCA of an actual lime kiln ESP for which long-term PM
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 emissions data are available to demonstrate that its PM emissions
 are consistently at or below 0.023 g/dscm (0.010 gr/dscf).10
      Installing a new fan and stack typically comprises
 approximately 20 percent of the total capital costs of installing
 a new ESP.   Because the fan and stack usually do not need to be
 replaced when a scrubber is replaced with an ESP,  the cost for
 replacing a scrubber with an ESP is only about 80 percent of the
 cost of a completely new ESP.9  Based on information from an ESP
 manufacturer,  the lifetime of the replacement ESP is about
 15 years.36
      Table  6-32 presents the model replacement costs to control
 PM emissions to 0.15 g/dscm (0.067 gr/dscf).   The costs range
 from $457,000  to $1.50 million for LK-l  through LK-3.   Table 6-33
 presents the model replacement costs to  control PM emissions to
 0.023  g/dscm (0.010 gr/dscf).   The costs range from $1.11 million
 to $3.65 million for LK-l through LK-3.
      It was assumed that installation of the  ESP could be
 completed within the 2-week scheduled shutdown,  and,  therefore,
 pulp production losses were not included in these  cost estimates.
 Further information is needed to determine the validity of  this
 assumption  (e.g.,  the lack of  available  space  complicating  ESP
 installation and thereby increasing  costs).
     6.1.5.2   Replacement of  Existing Scrubber with ESP:
 Incremental  Annual  Costs.   To  determine  the incremental  annual
 costs  of  replacing  the existing scrubber with  a new ESP  for each
 model  lime kiln,  the annual  costs  for operating the existing
 scrubber  were  subtracted from  the  annual  costs  for  operating a
 new  ESP.  To be  conservative,  the  TCI-related  indirect  costs  for
 the  existing scrubber (i.e., the administrative, property tax,
 insurance, and capital  recovery costs) were not  included  in the
 cost comparison.
     The  incremental  annual costs  of replacing  the  existing
 scrubber with  a new  ESP  are presented  in Tables  6-32 and 6-33.
Design parameters and  costs for the existing scrubber at baseline
PM levels are presented  in Tables  6-34 and 6-35, respectively.
Because over 80 percent  of lime kiln scrubbers are venturi
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scrubbers, the scrubber design parameters presented in Table 6-34
are based on a venturi scrubber as the baseline control device.
Design parameters for the new ESP are presented in Table 6-36,
and the ESP costs at the 0.15 g/dscm  (0.067 gr/dscf) and
0.023 g/dscm  (0.010 gr/dscf) PM levels are presented in Tables
6-37 and  6-38, respectively.
     Direct annual costs  (i.e., operating labor costs,
maintenance costs, and utility costs) are reduced significantly
when the  existing scrubber  is replaced with an ESP.  Overhead
costs are also reduced because they are a function  of the labor
and maintenance  costs.  For model lime kilns LK-1 through LK-3
controlling PM emissions  to 0.15 g/dscm  (0.067 gr/dscf), the
reduction in  direct annual  costs and  overhead costs obtained by
switching from a scrubber to an ESP was greater than the
TCI-related indirect annual costs for the new ESP.  As  a result,
the ITAC  are  actually  cost  savings of $l04,000/yr to  $53,000/yr
for LK-1  through LK-3.  The ITAC savings for the model  lime kilns
are presented in Table 6-32.
      For  model  lime kilns LK-1  through LK-3 controlling PM
emissions to  0.023 g/dscm (0.010 gr/dscf),  the  reduction in
direct  annual costs and overhead costs was  less  than  the TCI-
related indirect'costs for  the  ESP.   As  a  result,  there are
annual  costs  associated with  replacing  the  existing scrubber  with
a new ESP,  ranging from $17,400/yr  to $342,000/yr for LK-1
 through LK-3.  The TCI-related indirect  annual  costs  for the  ESP
were strongly influenced by the high SCA value  used to estimate
 the TCI.   The SCA for new ESP's meeting a PM level of
 0.023
     „*.!_ «   dbdkaiM — —• — — 	 — —                 —
      g/dscm (0.010 gr/dscf) is approximately 220 m2/(m /sec)
(1,120 ft2/!,000 acfm).4  The ITAC for the model lime kilns are
presented in Table 6-33.
     Approximately 15 percent of lime kiln scrubbers for which
data are available have pressure drops below 19 mm Hg  (10 in.
H20), or are low-energy, low-pressure, or ejector type
scrubbers.4  These scrubbers operate at a lower pressure drop
than the venturi scrubber used as the baseline control device.
The annual costs to replace these low-pressure drop scrubbers
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with ESP's would be higher than the costs and cost saving
presented above.  The additional annual costs for replacing low-
pressure drop scrubbers were estimated based on the difference in
pressure drop between the low-pressure drop scrubbers and the
venturi scrubber used as the baseline control device.  The
average pressure drop is 7.5 mm Hg  (4 in. I^O) for those low-
pressure drop lime kiln scrubbers with PM emissions greater than
0.15 g/dscm  (0.067 gr/dscf).  The average pressure drop is 39 mm
Hg  (21 in. H2O) for the baseline venturi scrubber.  To estimate'
the incremental annual costs of replacing low-pressure drop lime
kiln scrubbers with ESP's, annual costs of $34,500/yr for LK-1,
$65,700 for LK-2, and $112,000/yr for LK-3 should be added to the
annual costs and cost savings presented above.
     6.1.5.3  Upgrade of Existing ESP: Capital Costs.  Because no
actual ESP upgrade costs were available for controlling PM
emissions from a level of 0.15 g/dscm (0.067 gr/dscf) to a level
of 0.023 g/dscm  (0.010 gr/dscf}, the upgrade cost for the lime
kiln ESP was instead based on the incremental cost difference
between an ESP capable of achieving a PM level of 0.15 g/dscm
(0.067 gr/dscf) and one capable of achieving a PM level of
0.023 g/dscm (0.010 gr/dscf).
     The ESP upgrade capital costs were based on the recent ESP
costs provided by individual pulp and paper mills (i.e., costs
for ESP's installed or replaced during or after 1989).4  The new
lime kiln ESP costs average $484/m2 ($45/ft2)  of ESP plate area.4
To determine the ESP upgrade cost, this cost per ESP plate area
was multiplied by the increase in ESP plate area assumed to
reduce PM emissions from 0.15 g/dscm (0.067 gr/dscf)  to
0.023 g/dscm (0.010 gr/dscf).  The ESP plate area for each model
lime kiln was derived from the model gas flow rate at the ESP
inlet and the ESP SCA.  The model SCA for an ESP meeting a long-
term PM level of 0.15 g/dscm (0.067 gr/dscf)  is approximately 90
m2/(m3/sec)  (460 ft2/!,000 acfm).4'10  The model SCA for an ESP
meeting a long-term PM level of 0.023 g/dscm (0.010 gr/dscf)  is
approximately 220 m2/(m3/sec) (1,120 ft2/!,000 acfm).4'10
                               6-51

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     For new lime kilns installing ESP's to control PM emissiosn
to 0.023 g/dscm (0.010 gr/dscf),  the capital cost attributable to
the control option would not be the cost of a new ESP but only
that portion associated with controlling PM emissions from the
current NSPS level of 0.15 g/dscm  (0.067 gr/dscf) to 0.023 g/dscm
(0.010 gr/dscf).  Such a cost would be the same as the cost to
upgrade existing lime kiln ESP's to achieve the same PM level of
0.023 g/dscm  (0.010 gr/dscf).
     The capital costs, excluding  pulp production losses, for the
ESP upgrade control option for new and existing model lime kilns
are presented  in Table 6-39 and range from $654,000 to
$2.15 million  for LK-4 through LK-6.  No information is currently
available  for  existing lime kilns  on the amount  of time required
to complete an ESP upgrade that would achieve a  PM control level
of 0.023 g/dscm  (0.010 gr/dscf).   As a result, no pulp production
losses were estimated for this ESP upgrade control option.
      6 1.5.4   Upgrade of Existing  ESP: Incremental Annual Costs.
Labor and  maintenance costs are assumed to be unchanged when  the
ESP  is upgraded  to achieve a  PM level of  0.023 g/dscm
 (0.010 gr/dscf).  Therefore,  the  incremental annual  costs for the
ESP  upgrade include  only the  increase in  electricity costs and
the  TCI-based indirect annual costs, which  include
administrative,  property tax,  insurance,  and capital recovery
costs.   The  capital  recovery  cost is based  on  an average  15-year
life span for lime kiln  ESP's.36   The  increased  electricity  costs
are  based on an increase  in SCA from 90 m2/(m3/sec)
 (460 ft2/!,000 acfm)  to  220  m2/(m3/sec)  (1,120  ft2/!,000  acfm) .
The  ITAC for the new and existing model  lime kilns,  without
 taking pulp production losses into account,  are  presented in
 Table 6-39 and range from $112,000/yr to $369,000/yr for LK-4
 through LK-6.
 6.2   ENHANCED MONITORING COSTS
      The following sections present the estimated costs for the
 enhanced monitoring options discussed in Chapter 4.   Table 6-40
 presents a summary of the enhanced monitoring costs, and
 Table 6-41 presents the itemized  capital and annual costs for
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opacity monitors and HC1 CEM's.  Enhanced monitoring costs were
not estimated for control options other than those presented in
Chapter 4; if facilities choose to meet the emission limits
through the application of other control options, and a CEM is
not applicable because of cost and/or technology constraints, the
facilities must develop an enhanced monitoring plan that
demonstrates the ability of the selected parameter to gauge a
change in emissions.
6.2.1  Recovery Furnace Enhanced Monitoring
     The following sections present the costs of enhanced
monitoring options that can be used to demonstrate compliance
with recovery furnace emission limits for PM or PM HAP's, total
gaseous organic HAP's, and HC1.
     6.2.1.1  Enhanced Monitoring for PM or PM HAP's Controlled
with an ESP.  Because opacity is the surrogate measurement that
best characterizes the level of recovery furnace PM emissions,
installation of an opacity monitor after the ESP is one option
being considered as a means of demonstrating compliance with a PM
or PM HAP emission limit for recovery furnaces.  For those
recovery furnaces with a wet scrubber following the ESP, an
opacity monitor must be located after the ESP but prior to the
scrubber.  A computer program distributed by the Emission
Measurement Technical Information Center (EMTIC) of EPA was used
to estimate capital and annual costs for an opacity monitor.
     The capital cost from EMTIC to purchase and install an
in-situ opacity monitor (i.e., an opacity monitor that measures
emissions in the stack or duct)  is approximately $34,800.  The
capital costs include planning,  selecting the type of equipment,
providing support facilities,  PEC,  installing and checking CEM's,
performance specification tests (certification), and preparing
the quality assurance/quality control (QA/QC)  plan required by
appendix F (40 CFR 60).   The PEC includes the cost to purchase a
data acquisition system (DAS)  which includes data reduction and
reporting hardware/software.37
     The annual costs from EMTIC equal $16,500/yr and include
costs for operating and maintenance,  reporting and recordkeeping,
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and annual review and update.37  Administrative, insurance,
property tax, and capital recovery costs were estimated
separately and added to the annual costs from the EMTIC program.
The administrative, insurance, and property tax costs were
calculated as 4 percent of the TCI, based on guidance in the
OAQPS Control Cost Manual.6  The capital recovery cost was
calculated as a product of a CRF and the TCI.6  The CRF was
calculated assuming a 20-year equipment life and 7 percent
interest.  The total annual cost for the opacity monitor is
approximately $2l,200/yr.
     Method  5, Method 29, or Method 17 compliance tests could be
performed periodically  (e.g., semiannually) as  a substitute  for
an  opacity monitor.  The  estimated cost for one three-run, EPA
Method  5  compliance test  is $8,500.37  The estimated  cost  for one
three-run, EPA Method 29  compliance test  is $12,000.3  No costs
are available for a three-run,  EPA Method 17  compliance test.   If
performed semiannually,  the Method 5  tests would  cost $17,000/yr;
the Method 29 tests would cost  $24,000/yr.
      Another option being considered  is  for  the facility  to
develop a monitoring  plan that  specifies  ESP  operating parameters
 to be monitored.   Operating parameters for the ESP would  be  site-
 specific and would be based on the parameters measured during a
 three-run,  EPA Method 5,  Method 29,  or Method 17  compliance  test
 that showed the facility to be in compliance with the applicable
 PM or PM HAP emission limit.   The cost to implement a monitoring
 plan has not been estimated.   The estimated costs for three-run,
 EPA Method 5 or Method 29 compliance tests were discussed in the
 previous paragraph.   No costs are available for a three-run, EPA
 Method 17 compliance test.
      6.2.1.2  Enhanced Monitoring for PM QT- PM HAP's Controlled
 w-it-Ji a Wet Scrubber.  For those recovery furnaces that can comply
 with a PM or PM HAP emission limit with existing wet scrubbers,
 the use  of an opacity monitor  to  demonstrate compliance with the
 PM emission limit may be inappropriate.  The exhaust from the
 recovery furnace wet scrubber  will have a high moisture content
 and will interfere with  the readings  from an opacity monitor.
                                6-54

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Monitoring scrubber operating parameters  (i.e., pressure drop and
scrubber liquid flow rate) is an alternative enhanced monitoring
option for showing compliance with a PM or PM HAP emission limit
for recovery furnaces.  The pressure drop and liquid flow rate
are indirect measurements of the performance of the scrubber.
     The pressure drop across a wet scrubber can be determined by
using a basic magnehelic gauge coupled with the S-type pitot tube
and would require manual reading.  The pressure drop can also be
determined using a similar arrangement with an electronic
magnehelic gauge that produces a digital signal.  The cost for a
manual read-out system would be less than $300.  The additional
cost for the electronic magnehelic gauge is not currently known.
     There are various techniques for measuring liquid flow rate
in a wet scrubber.  These techniques include ultra-sonic
detection mounted externally on the in-flowing water pipe and
turbine devices that are mounted within the pipe, both of which
generate an electrical signal that can be logically displayed in
a control room.  The cost for these flow-measuring techniques can
vary from $2,000 to $25,000, depending on the device sensitivity
and distance from the control room.^7
     Pressure drop and scrubber liquid flow rate levels would be
site-specific and would be based on the operating parameters
measured during a three-run, EPA Method 5, Method 29,  or
Method 17 compliance test that showed the facility to be in
compliance with the applicable PM or PM HAP emission limit.
Method 5, Method 29,  or Method 17 compliance tests could also be
performed periodically (e.g., semiannually)  as a substitute for
monitoring scrubber operating parameters.   The estimated costs
for three-run,  EPA Method 5 and Method 29  compliance tests were
discussed in Section 6.2.1.1.  No costs are available for a
three-run,  EPA Method 17 compliance test.
     6.2.1.3  Enhanced Monitoring for Gaseous Organic HAP's.
Control of gaseous organic HAP emissions from recovery furnaces
can be achieved by using NDCE recovery furnaces equipped with dry
ESP systems.  Therefore,  enhanced monitoring for recovery furnace
gaseous organic HAP emissions can.be achieved simply by
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confirming that the furnace is an NDCE recovery furnace with a
dry ESP system.  No costs are associated with this enhanced
monitoring option.
     If the recovery furnace is a DCE recovery furnace or an NDCE
recovery furnace equipped with a wet ESP system, the facility
could measure methanol emissions with a methanol GEM (e.g, a
fourier transform infrared, or FTIR, spectroscopy monitoring
system) .  The capital and annual costs for an FTIR monitor have
been estimated to be approximately 160,000 and 71,500/yr,
respectively.39
     6.2.1.4  Enhanced Monitoring for HC1.  Hydrochloric acid
emissions can be measured directly using an HC1 GEM.  An HC1 GEM
could be installed after the packed-bed scrubber to demonstrate
continuous  compliance with  an HC1 emission standard.  An HC1 GEM
could also  be used after the ESP for those recovery furnaces that
could comply with an HC1 emission limit without a packed-bed
scrubber.   The capital and  annual costs for an HC1 GEM were
determined  using  the EMTIC  GEM  cost program.
     The capital  cost  from  EMTIC to purchase  and install  an
extractive  HC1 monitor (i.e., an HC1 GEM  that extracts a  sample
and transports the sample through a conditioning system and  into
a gas analyzer)  is approximately $126,900.37  The  capital  costs
include planning,  selecting the type of equipment, providing
support facilities,  PEC,  installing and checking CEM's,
performance specification tests (certification), and preparing
the QA/QC  plan required by  Appendix F  (40 CFR 60).  The  PEC  costs
include the cost for a DAS  for  data reduction and  reporting.   A
performance specification for HC1 monitors is currently  under
development for  the  CFR.   However,  one has already been  developed
by the Northeast States for Coordinated Air Use Management,  or
                                        37
NESCAUM,  and is  being evaluated by EPA.
      The direct  annual costs from EMTIC equal $60,300/yr and
 include costs for operating and maintenance,  reporting and
 recordkeeping, and annual review and update.37  Administrative,
 insurance,  property tax,  and capital recovery costs  were
 estimated separately and added to the program costs.   The
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 administrative,  insurance,  and property tax costs  were  calculated
 as  4  percent  of  the  TCI,  based on guidance  in the  OAQPS Control
 Cost  Manual.6 The capital  recovery  cost was calculated as a
 product  of a  CRF and the  TCI.6  The  CRF was calculated  assuming a
 20-year  equipment life  and  7 percent interest.6  The  total annual
 cost  for the  HC1 CEM is approximately $77,400/yr.
      The feasibility of using  HC1 CEM's to  demonstrate  compliance
 with  an  HC1 standard has  not been determined.  The low  HC1
 concentrations and high moisture content associated with the
 recovery furnace flue gas may  make the use  of  HC1  CEM's more
 difficult.  However,  additional  information is needed before an
 HC1 CEM  can be definitively ruled out  for recovery furnaces.
      Because  HC1 emissions  can be controlled with  a packed-bed
 scrubber, monitoring scrubber  operating parameters is another
 monitoring option being considered for those recovery furnaces
 that  comply with an  HC1 emission limit using a packed-bed
 scrubber.  The scrubber operating parameters to be monitored are
 scrubber liquid  pH and  scrubber  liquid flow rate.  The  cost for a
 pH monitoring system for  scrubber water is  approximately
 $5,000.37  The cost  to  measure scrubber liquid flow rate was
 discussed in  Section 6.2.1.2 and ranges  from $2,000 to  $25,000,
 depending on  the  devices' sensitivity  and distance from the
 control  room.37   Scrubber liquid flow  rate  and pH levels would be
 site-specific and would be based on  the  operating parameters
measured during  a three-run, EPA Method  26A HC1 compliance test
 that  showed the  facility  to be in  compliance with an HC1 emission
 limit.  Method 26A must be used  when the measurement point is
 downstream of a wet  scrubber.   The estimated cost for one three-
 run,  EPA Method  26 HC1  compliance  test  is $9,100 if performed
alone, or $600 if performed in conjunction with EPA Method 5,
Method 29, or Method 17 testing.40  The  $600 would be in addition
 to the cost of the PM or PM HAP  testing.
     Alternative enhanced monitoring options are also available
 to demonstrate compliance for those recovery furnaces that could
 comply with an HC1 emission limit without a packed-bed scrubber.
One  option would require the facility to develop a monitoring
                               6-57

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plan that specifies operating parameters to be monitored.
Operating parameters would be site-specific and would be based on
the parameters measured during a three-run, EPA Method 26 or 26A
HC1 compliance test that showed the facility to be in compliance
with the applicable HC1 emission limit.  Either Method 26 or 26A
could be used if the measurement point does not follow a wet
scrubber.  The cost to implement a monitoring plan has not been
estimated.  The estimated cost for a three-run EPA Method 26 HC1
compliance test would be the same as the estimated cost for a
three-run, EPA Method 26A HC1 compliance test, which was
discussed in the previous paragraph.  A second option would
require periodic  (e.g., annual) Method 26  or 26A HC1 compliance
tests to demonstrate compliance.  The annual cost of EPA
Method 26 or 26A HC1 compliance testing is $9,100/yr if the test
is performed annually and without EPA Method 5, Method 29, or
Method 17 testing.40  The annual cost is $600/yr if performed
annually and in  conjunction with EPA Method 5, Method 29,  or
Method 17 testing.40  The $600 would be in addition to the annual
cost  of the PM or  PM HAP testing.
6.2.2  Black Liquor Oxidation Unit  Enhanced Monitoring
      This  section  presents  the  costs of the enhanced monitoring
options  that  can be used  to demonstrate compliance with  a total
gaseous  organic  HAP emission limit  for  DCE recovery  furnace
 systems  (which include  the  BLO  unit).
      One  control option presented for  the  BLO  unit  involves  the
 removal  of this  piece of  equipment  from the chemical  recovery
 process  by converting a DCE recovery furnace  system equipped with
'a wet ESP system to an NDCE recovery furnace  equipped with a dry
 ESP system.   Demonstrating that this conversion has  been
 completed assures compliance with the applicable total gaseous
 organic HAP emission limit.  No costs are associated with this
 enhanced monitoring option.
      A second control option involves incineration of the BLO
 emissions.  Enhanced monitoring for BLO incineration could be
 achieved simply by affirming that the BLO control equipment is in
 place.  No cost is associated with this enhanced monitoring
                                6-58

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option.  Another enhanced monitoring option would be for the
facility to monitor the temperature of the power boiler or other
incineration device.  The cost of a temperature monitor is
assumed to be zero because temperature monitoring is already
conducted by mills.
6.2.3  Smelt Dissolving Tank Enhanced Monitoring
     This section presents the costs of the enhanced monitoring
options that can be used to demonstrate compliance with an SDT
emission limit for PM or PM HAP's.
     6.2.3.1  Enhanced Monitoring for PM or PM HAP's Controlled
with a Wet Scrubber.  Because the exhaust from the SDT wet
scrubber will have a high moisture content and will interfere
with the readings from an opacity monitor, the use of an opacity
monitor to demonstrate compliance with a PM or PM HAP emission
limit for SDT's may be inappropriate.  Monitoring scrubber
operating parameters (i.e., pressure drop and scrubber liquid
flow rate) is an alternate enhanced monitoring option for showing
compliance with a PM or PM HAP emission limit for SDT's.  The
pressure drop and liquid flow rate are indirect measurements of
the performance of the scrubber.  The costs to monitor pressure
drop and scrubber liquid flow rate were discussed in
Section 6.2.1.2.
     Pressure drop and scrubber liquid flow rate levels would be
site-specific and would be based on the operating parameters
measured during a three-run, EPA Method 5, Method 29, or
Method 17 compliance test that showed the facility to be in
compliance with the applicable PM or PM HAP emission limit.
Method 5, Method 29, or Method 17 compliance tests could also be
performed periodically (e.g., semiannually) as a substitute for
monitoring scrubber operating parameters.  The estimated costs
for three-run, EPA Method 5 and Method 29 compliance tests were
discussed in Section 6.2.1.1.  No costs are available for a
three-run, EPA Method 17 compliance test.
                               6-59

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6.2.4  Lime Kiln Enhanced Monitoring
     The following sections present the costs of the enhanced
monitoring options that can be used to demonstrate compliance
with a lime kiln emission limit for PM or PM HAP's.
     6.2.4.1  Enhanced Monitoring for PM or PM HAP's Controlled
with an ESP.  Because opacity is the surrogate measurement that
best characterizes the level of lime kiln PM emissions,
installation of an opacity monitor is one option being considered
as a means of demonstrating compliance with a PM or PM HAP
emission limit for lime kilns controlled with ESP's.  For those
lime kilns with a wet scrubber following the ESP, an opacity
monitor must be located after the ESP but prior to the scrubber.
The capital and annual costs for the opacity monitor were
discussed in Section 6.2.1.1.  Method 5, Method 29, or Method 17
compliance tests could be performed periodically  (e.g.,
semiannually) as a substitute for an opacity monitor.  The
estimated costs for three-run, EPA Method 5 and Method 29
compliance tests were discussed in Section 6.2.1.1.  No costs are
available for a three-run, EPA Method 17 compliance test.
     Another option being considered is for the facility to
develop a monitoring plan that specifies ESP parameters to be
monitored.  Operating parameters for the ESP would be site-
specific and would be based on the parameters measured during a
three-run, EPA Method 5, Method 29, or Method 17  compliance test
that showed the facility to be in compliance with the applicable
PM or  PM HAP emission limit.  The cost to implement a monitoring
plan has not been estimated.  The estimated costs for three-run,
EPA Method 5 and Method 29 compliance tests were  discussed in
Section 6.2.1.1.  No costs are available for a three-run, EPA
Method 17 compliance test.
     6.2.4.2  Enhanced Monitoring for PM or PM HAP's Controlled
with a Wet Scrubber.  For those lime kilns that can  comply with a
lime kiln PM or PM HAP emission limit with existing wet
scrubbers, the use of an opacity monitor to demonstrate
compliance with a PM or PM HAP emission limit may be
inappropriate.  The exhaust  from the lime kiln wet  scrubber will
                               6-60

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have a high moisture content and will interfere with the readings
from an opacity monitor.  Monitoring scrubber operating
parameters (i.e., pressure drop and scrubber liquid flow rate) is
an alternative enhanced monitoring option for showing compliance
with the applicable PM or PM HAP emission limit for lime kilns.
The pressure drop and liquid flow rate are indirect measurements
of the performance of the scrubber.  The costs to monitor
pressure drop and scrubber liquid flow rate were discussed in
Section 6.2.1.2.
     Pressure drop and scrubber liquid flow rate levels would be
site-specific and would be based on the operating parameters
measured during a three-run, EPA Method 5, Method 29, or
Method 17 compliance test that showed the facility to be in
compliance with the applicable PM or PM HAP emission limit.
Method 5, Method 29, or Method 17 compliance tests could also be
performed periodically (e.g., semiannually)  as a substitute for
monitoring scrubber operating parameters.  The estimated costs
for three-run, EPA Method 5 and Method 29 compliance tests were
discussed in Section 6.2.1.1.  No costs are available for a
three-run, EPA Method 17 compliance test.
                               6-61

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TABLE  6-3
SUMMARY  OF  ASSUMPTIONS  USED  IN ESP UPGRADE  COSTS9
 NDCE Recovery Furnace ESP Characteristics:
SSS=3=S=
 Existing ESP:
 • The existing ESP is assumed to contain 46
 lanes on 10-inch centers (weighted wire design).
 • The existing ESP is 3 fields long, with each
 field 10 feet long and 30 feet tall.

 • The existing ESP has a parallel drag scraper
 arrangement  (dry-bottom).	^	
                              New ESP:
                              • The ESP is rebuilt with 42 lanes on 11-inch
                              centers (rigid electrode design).
                              • The size will be adequate for 99.4 percent PM
                              removal, yielding an outlet PM residual of 0.044
                              gr/dscf at 8 percent oxygen.
                              • The ESP will be 3 fields long, with each  field
                              10 feet long and 30 feet high.	
  DCE Recovery Furnace ESP Characteristics:
  Existing ESP:
  • The existing ESP is assumed to contain 50
  lanes on 10-inch centers (weighted wire design).
  • The existing ESP is 3 fields long, with each
  field 10 feet long and 30 feet tall.

  • The existing ESP has a steel shell design (wet-
  bottom).                              	
                              New ESP:
                              • The ESP is rebuilt with 46 lanes on 11-inch
                              centers (rigid electrode design).
                              • The size will be adequate for 98.8 percent PM
                              removal, yielding an outlet PM residual of 0.044
                              gr/dscf at 8 percent  oxygen.
                              • The ESP will be 3 fields long, with each field
                              10 feet long and 32  feet high.    	
  Modifications:
  • There is single-chamber operation while the other chamber is washed down, the roof removed, and
  the internals gutted.
  • The recovery furnace is taken off line; work continues on rebuild; one chamber is finished.
  • The recovery furnace is at partial load through rebuilt chamber;  the other chamber is finished.
  Other Assumptions:
  « The existing casing is in acceptable condition; only minor replating is needed.
  • Wet- and dry-bottoms are reused "as is," except for minor repairs. Transformers, controls, and
  inlet and outlet ductwork are also reused.
     The roof insulation is replaced, but all other insulation is acceptable.
   • The site location is in the southeast United States.  As such, all field labor is based on merit shop,
   1993 wage rates and work rules.
   • No removal of asbestos or polychlorinated biphenyls (PCB's) is required.
   • The scrap is taken to a site within the plant gates.
   • There are no perforated plates.                 • The ESP is at grade.
   • The ductwork and stack do not obstruct crane    • There is no low voltage.
   mobility.
                                               6-66

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a 
-------
TABLE  6-16.    SCENARIO  1:  ANNUAL  COSTS  OF  LOW-ODOR CONVERSION
        (INCLUDING  ESP  UPGRADE  TO  CONTROL  PM  TO  0.10  G/DSCM
  [0.044   GR/DSCF])   FOR MODEL  DCE RECOVERY FURNACES   (EXCLUDING
                     ANNUALIZED  PULP PRODUCTION  LOSSES)a
Costs
Total Capital Investment (TOO
Direct Annual Costs (DAC)
Steam production credits (b)
Natural gas
Fuel oil
BLO operating cost savings (c)
Concentrator steam costs (d)
ESP operating electricity costs (e)
Total DAC
Natural gas
Fuel oil
Indirect Annual Costs (IAC)
Administrative, taxes, and insurance (t)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Capital recovery (g)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Total tAC
Total Annual Costs
Natural gas
Fuel oil

FIF-7a
$9,410,000

(8758,000)
($1,190,000)
(£103,000)
$57,600
S23.3OO
(5780,000)
($1,210,000)

$324,000
835,200
$17,600
5377,000
8764,000
$103,000
851,300
$91B.OOO
£1,300,000
£520,000
£90,OOO
Model Recovery Furnaces
RF-7b
£9,410,000

($758,000)
(£1,190,000)
($103,000)
£57,800
£11,700
(5792,000)
(£1.220,000)

$324,000
£35.200
$17,600
£377,000
£764,000
$103,000
£51,300
$918.000
£1.300,000
5508.OOO
£80,OOO
RF-8a
£12,800,000

($1.260,000)
(£1,990,000)
(£172,000)
S96.3OO
£38,800
($1.300,000)
(£2.030.OOO)

$440,000
£48,OOO
$23,800
£512,000
£1.040,000
£140,000
£69,700
$1,250,000
£1.760,000
£46O,OOO
(£270. DOO)
RF-Sb
£12.800,000

(£1.260,000)
(£1,990,000)
($172,000)
£96.300
S19.4OO
(£1,320,000)
(£2,050.000)

£440,000
£48,000
£23.6OO
£512,000
£1,040,000
$140.000
£69.700
£1.250.000
£1.760.000
£440.000
(£290.000)

£18,200.000

(£2.270,000)
(£3,580.000)
(£309.000)
£173,000
£70,000
(£2,340.000)
(£3.650.000)

£628,000
$68.000
£34.0OO
£730.000
$1,480.000
5199,000
£99.2OO
£1,780.000
£2.510.000
£170,000
(51,140.000)

£18.200,000

(£2,270,000)
(£3,580,000)
($309.000)
£173,000
£35,000
(£2,370,000)
(£3,680.000)

£626,000
£68.000
£34,OOO
£730,000
£1,480,000
$199,000
$99,200
81,780,000
£2,510.000
£140.000
(£1,170,000)
       (a) All costs in £1991. Numbers in parentheses represent cost savings.
       (b) Steam production credit calculations (either natural gas or fuel oil):
        Natural gas credit = (model BLS firing rate) x (6,000 Btu/lb) x (1 d/24 hr) x (66^56% thermal efficiciency)/(S5% power boiler efficiciency) x
          £1 fan ,024 Btu) x (8,424 hr/yr) x (£3.48/1,000 ft3)
        Fue) oil credit =-- (model SLS firing rate) x (6,000 Btu/lb) x (1 d/24 hr) x (66%.56% thermal efficiency)/(85% power boiler efficiency) x
          (1 gal/144.000 Bto)x (8.424 hrftri} K ($0.77/gal)                               "if             n *
       (c) BLO operating cost savings = $251,900/yr x (model BLS firing rate/2,200.000 Ib BLS/d)
       (d) Concentrator steam costs = S54,OOO/yr x (model BLS firing rate/2,400,000 Ib BLS/d)
       (e) ESP operating electricity cost = 0.00194 x increase in ESP plate area x 8,424 hr/yr x SO.Oe/kWh
       (f) Administrative, taxes, and insurance «= O.O4 x TCI
       (g) For low-odor conversion, capital recovery cost = O.O944 x TCI (based on 20^r remaining service life and 7% interest)
        For ESP upgrade and wet- to dry-bottom ESP conversion, capital recovery cost = 0.1169 x TCI (based on 13.5-yr ESP life and 7% interest)
                                              6-91

-------
TABLE  6-17     SCENARIO 2:  ANNUAL COSTS  OF  LOW-ODOR  CONVERSION
        (INCLUDING ESP  UPGRADE  TO  CONTROL PM TO  0.10  G/DSCM
  [0  044  GR/DSCF])   FOR MODEL  DCE  RECOVERY  FURNACES   (INCLUDING
                       BLEACHED  PULP  PRODUCTION LOSSES)a

Costs
Total Cacrtal Investment (TCI)
Direct Annual Costs (DAC)
Steam production credits (b)
Natural gas
Fuel oil
BUD operating cost savings (c)
Concentrator steam costs (d)
ESP operating electricity costs (d)
Total OAC
Natural gas
Fuel oil
Indirect Annual Costs (1AC)
Administrative, taxes, and insurance (e)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Capital recovery (1)
Low-odor conversion
ESP upgrade
Wet- to dry-Bottom ESP conversion
Production losses
Tota!
Total IAC
Total Annual Costs
Natural gas
Fuel oil 	 _^__^_


59,900,000

($758,000)
(S1.190.000)
($103,000)
$57,800
$23,300
(5760,000)
(51. 21 0.000)

324,000
35,200
17,600
5377,000
5764,000
$103,000
551,300
546,100
5964,000
51.340.000
S560.000
5130,000

$9.900.000

($758,000)
($1.190.000)
(5103,000)
$57,800
511,700
(5792,000)
(51.220.000)

324,000
35,200
17,600
5377,000
5764.000
$103,000
$51,300
- 546,100
5964,000
51,340.000
$548,000
5120.000
RF-8a
513,600.000

($1,260,000)
($1.990,000)
(5172.000)
$96,300
$38,600
(51,300,000)
(52.030.000)

440,000
48,000
23,800
5512.000
51.040.000
5140,000
569,700
577,400
51,330.000
51.640.000
5540,000
(5190.000)

RMb T
513,600,000

($1,260,000)
($1,990,000)
($172,000)
596.300
519,400
(51.320,000)
(52,050.000)

440,000
48.000
23,600
5512.000
$1,040,000
$140,000
$69,700
$77,400
$1,330.000
$1,640.000
$520,000
(S21 0.000)
RF^9a T
$19,700,000

($2.270,000)
($3.580,000)
($309.000)
$173,000
570,000
($2,340,000)
(53.650,000)

628,000
68.000
34,000
5730.000
51,480,000
5199,000
$99.200
$138.000
51,920,000
$2.650.000
$310,000
(51.000.000)
RF-90
$19,700,000

($2,270,000)
(53.580.000)
($309,000)
$173,000
$35,000
($2,370.000)
(53,660,000)

628,000
68,000
34,000
5730.000
51,480.000
5199,000
599,200
5138,000
51,920.000
52.650.000
$280,000
(51.030.000)
         (a) AH costs in S1991. Numbers in parentheses represent cost savings.
         (b) Steam production credit calculations (either natural gas or fuel oil):                                  .,,,..  „.
           Natural gas credit = (model BLS firing rate) x (6,000 Btu/lb) x (1 d/24 hr) x (6S%-56% thermal efficiciency)/(85% power boiler efficiency) x
            0 ft3M.024 Btu) X (8,424 hr/yr) X (53.48/1,000 ft3)                                       ...,„,,
           Fuel wl credit - (model BLS firing rate) x (S.OOO Btu/lb) x (1 d/24 hr) x (6S%-56% thermal efnciency)/(85% power boiler efficiency) x
            (1 gal/144.000 Btu) x (8,424 hr/yr) x (50,77/gal)
         (c) BLO operating cost savings = S251,900/yr x (model BLS firing rate/2,200.000 Ib BLS/d)
         (d) Concentrator steam costs = 554,000/yr x (model BLS firing rate/2,400,000 Ib BLS/d)
         (e) ESP operating elect/icity cost - 0.00194 x Increase in ESP plate area x 8,424 hr/yr X $0.06/kWh
         m Administrative, taxes, and Insurance - 0.04 x TCI                                   ._.,,..,
         la) For low-odor conversion, capital recovery cost - 0.0944 x TCI (based on 2O-yr remaining service Me and 7% Intensl)     .,,„,_„„
           For ESP upgrade and wet-to dry-bottom ESP conversion, capital recovery cost = 0.1169 xTCI (based on 13.5-yr ESP life and 7% Interest)
                                                 6-92

-------
TABLE  6-18.    SCENARIO  3:  ANNUAL  COSTS  OF  LOW-ODOR  CONVERSION
        (INCLUDING  ESP  UPGRADE TO CONTROL  PM  TO  0.10  G/DSCM
  [0.044   GR/DSCF])   FOR MODEL DCE  RECOVERY  FURNACES   (INCLUDING
                     UNBLEACHED  PULP  PRODUCTION LOSSES}a
Costs
Total Capital Investment (TCI)
Direct Annual Costs (DAC)
Steam production credits (b)
Natural gas
Fuel oil
BLO operating cost savings (c{
Concentrator steam costs (d)
ESP operating electricity costs (e)
Total DAC
Natural gas
Fuel oil
Indirect Annual Costs (IAC)
Administrative, taxes, and insurance (f)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Capital recovery (g)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Production losses
Total
Total IAC
btat Annual Costs
Natural gas
Fuel oil

RF-7a
$9,760,000

($758.000)
($1,190,000)
($103,000)
$57,800
$23,300
($760,000)
(81,210,000)

324,000
33,200
17,600
377,000
$764.000
$103,000
$51,300
$32,900
951.000
$1,330.000
$550,000
$120.000
Model Recovery Furnaces
RF-7b
$9.760,000

($758,000)
($1,190,000)
($103,000)
$57,800
$11,700
($792,000)
($1,220.000)

324,000
35,200
17,600
377,000
$764.000
$103,000
$51,300
$32,900
951.000
$1,330.000
$538,000
$110.000
RF-8a
$13.400.000

($1.260,000)
($1.990,000)
($172.000)
$96,300
$38,800
($1,300,000)
($2,030.0001

440,000
48,000
23.800
512,000
$1.040.000
$140.000
$69,700
$54,800
1,300,000
$1.820.000
$520.000
($210.000)
RF-Bb
$13,400,000

($1,260,000)
($1.990,000)
($172,000)
$96,300
$19,400
($1,320,000)
($2.050.000)

440.000
48,000
23,800
512,000
$1,040,000
$140,000
$69,700
$54,800
1,300,000
$1,820.000
$5OO.OOO
($230.000!
RF-9a
$19,200,000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$70,000
($2,340.000)
(S3.650.000)

628,000
68,000
34,000
730,000
$1.480,000
$199,000
$99,200
$98,2OO
1,880,000
$2.610.000
$270,000
(S1.040.OOO)
Rr-9b
$19.200.000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$35,000
($2,370,000)
($3,680,000)

628,000
68,000
34,000
730.OOO
$1,480,000
$199,000
$99,200
$96,200
1,880,000
$2.610,000
$240.000
($1.070.OOO)
     (a) All costs in $1991. Numbers in parentheses represent cost savings.
     (b) Steam production credit calculations (either natural gas or fuel oil):
       Natural gas credit = (model BLS firing rate) x (6.00O Btu/lb) x (1 d/24 hr) x (66%r56% thermal efficiciency)/(85% power boiler efficiciencv) x
        (1 ft3/1,024 8tu) x (8.424 hr/ysS X f£3.48/1,OOO«3!
       fuel oil credit = (model BLS firing rate) x (S.OOO Btu/lb) x (1 d/24 hr) x f.66%-56% thermal efficiency)/(85% power boiler efficiency) x
        (1 gal/144,000 Btu) x (8,424 hrfyi) x ($0.77/gaf)
     (cj BLO operating cost savings = $251,900/yr x (model BLS firing rate/2.200,000 Ib BLS/d)
     (dj Concentrator steam costs = $54,OOO/yr x (model BLS firing rate/2,400,000 Ib BLS/d)
     
-------
TABLE  6-19      SCENARIO  1:  ANNUAL  COSTS  OF  LOW-ODOR  CONVERSION
       (INCLUDING ESP  UPGRADE TO  CONTROL  PM  TO  0.034  G/DSCM
  [0  015  GR/DSCF])   FOR MODEL DCE  RECOVERY  FURNACES   (EXCLUDING
                     ANNUALIZED  PULP  PRODUCTION LOSSES)a

Total Caoital Investment (TCI)

Steam production credits (b)
Natural ga*
Fuel on
iLO operating cost savings (c)
Concentrator stum costs (d)
ESP operating electricity costs (e)
Total DAC
Natural gu
Indirect Annual Costs (1AC)
Admlnittrative. taxes, and insurance (0
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Casual recovery (g)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total

Total Annual Costs
Natural gas

SS.6OO.OOO

($758,000)
{S1.190.000)
(5103,000)
557,800
S33.100
(S770.000)
(S1.200.000)

324,000
50,800
17,600
392,000
$764.000
$148,000
$51,300
963,000
S1.360.000
$590,000
$160.000
S9.8OO.OOO

($758,000)
(51,190,000)
($103,000)
$57.800
S21.400
(8782,000)
($1.210.000)

324,000
50.800
17.600
392,000
$764.000
S148.000
$51,300
963.000
$1,360.000
$578,000
$150.000
RF-Sa
$13,400,000

($1,263,000)
($1,990.000)
($172,000)
$98,300
$55.000
($1,280,000)
($2,010.000)

440,000
73,600
23,800
537,000
$1,040.000
$215,000
$69.700
1,320.000
$1,660.000
$580,000
($150.000)

BF-Sb
$13,400,000

($1,260.000)
(S1.990.0OO)
($172,000)
$96,300
$35.600
(S1,3OO,000)
(52,030,000)

440.000
73.600
23.800
537.000
$1,040,000
$215.000
S69.700
1,320.000
$1.660.000
$560,000
(SI 70.000)

$19.400,000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$99,200
($2,310.000)
(S3.620.000)

628.000
114.000
34,000
776.000
S1, 480.000
$334.000
$99.200
1.910.000
$2.690,000
$380,000
($930.000)

$19.400,000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$64,200
($2,340,000)
($3.650.000)

628,000
114,000
34,000
776.0OO
$1.480,000
$334,000
$99.200
1,910.000
$2.690.000
$350.000
(S960.000)
     (a) AH c«a in S1991. Numbers in parentheses represent cost savings,
     (b! Steam production credit calculations (either natural gas or fuel oil):                                    «•••„-*.
       Natural gas credit - (model BUS firing rate) X (6.000 Btu/lb) x (1 d/24 hi) x (66%-5S% thermal effi=iciency)/(S5% power boiler efficiency) x
        (1 M/1.024 Btuix (8.424 hr/yr)x ($3.48/1,000 ft3)                                            ,
       Fuel 0,1 credit - (model BLS firing rate) x (6.000 Btuilb) x (1 d/24 hi) x (66%-56% thermal efficiency>/(B5% power bo,ler effic.ency) x
        (1 ga!rt44,000 Btu) x (8.424 hr/yr) x (S0.77/gal)
     (c) BUD operating cost savings = S251.900/yrx (model BLS firing rate/2,200,000 Ib BLS/d)
     (d) Concentrator steam costs - S54.OOO/yr x (model BLS firing rate/2,400.000 Ib BLS/d)
     (e) ESP operating electricity cost - 0.00194 x increase In ESP plate area x 8,424 hr/yr x S0.06/KWh
     (ft Administrative, taxes, and insurance « O.O4 x TCI	
     fa) For tew*dor conversion, capital recovery cost - 0.0944 x TCI (based on 20-yr remaining sennce life and T*!"*"*}
      For ESP upgrade and wet-to dry-bottom ESP conversion, capital recovery cost = 0.1169 x TCI (based on 13.5-yr ESP We and 7% interest)
                                                 6-94

-------
TABLE  6-20.    SCENARIO  2:   ANNUAL  COSTS  OF  LOW-ODOR  CONVERSION
        (INCLUDING  ESP UPGRADE  TO  CONTROL  PM  TO  0.034  G/DSCM
  [0.015  GR/DSCF])   FOR  MODEL  DCE  RECOVERY  FURNACES   (INCLUDING
                       BLEACHED  PULP  PRODUCTION  LOSSES)a
Costs
Total Capital Investment (TCI)
Direct Annual Costs (DAC)
Steam production credits (b)
Natural gas
Fuel oil
BLO operating cost savings (c)
Concentrator steam costs (d)
ESP operating electricity costs (d)
Total DAC
Natural gas
Fuel oil
Indirect Annual Costs (IAC)
Administrative, taxes, and insurance (e)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Capital recovery (f)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Production losses
Total
Total IAC
Total Annual Costs
Natural gas
Fuel oil

RF-7a
S10.300.0CX3

($756,000)
($1,190,000)
($103.000)
857,800
$33,100
(S770.000)
(SI. 200,000)

324,000
50.800
17,600
392.000
$764.000
$148,000
551,300
546,100
1,010,000
S1 .400,000
$630,000
S200.000

HF-7b
$10,300.000'

(5758.000)
($1,190,000)
($103.000)
557,800
' $21,400
($782,000)
(S1. 210.000)

324.000
50.8OO
17.6OO
392.000
$764.000
$143,000
551,300
$46.100
1,010.000
S1.4OO.OOO
$618.000
$190.000
Model Recovery Furnaces
RF-8a
$14.200,000

($1,260.000)
($1,990,000)
($172,000)
$96.300
$55,000
(51,280,000)
($2.010.000)

440.OOO
73,600
23.800
537,000
$1.040,000
5215,000
$69,700
$77,400
1,400,000.
$1.940.000
$660,000
($70.000)
RF-Sb
$14.200.000

(S1.260.000)
($1,990.000)
(S172.OOO)
$96.300
535,600
($1,300,000)
(52,030.000)

440.000
73,600
23.800
537,000
S1. 040.000
5215.000
S69.700
577.400
1,4OO.OOO
51.940.000
5640.000
(S90.000I
RF-Sa
$20.900,000

(52.270.000)
($3,580,000)
(5309.000)
S173.000
$99.200
($2,310,000)
(53,620.000)

628,000
114,000
34.000
776.000
$1,480,000
5334,000
599.200
5138.000
2.050.000
$2.830.000
5520.000
(5790.000)
RF-9b
$20,900.000

($2,270.000)
($3,580,000)
($309,000)
S173.000
$54,200
($2,340,000)
($3,650,000)

628.000
114.000
34,000
776,000
51,480,000
$334,000
S99.2OO
5138.000
2,050,000
$2.830.000
S490.OOO
(5820.000)
       (a) All costs in 51991. Numbers in parentheses represent cost savings.
       (b) Steam production credit calculations (either natural gas or fuel oil):
         NituraS gas credit = (model BLS firing rate) x (6,000 Btu/lb) x (1 d/24 hr) x (66%-56% thermal efficiciency)/(85% power boiler efficiciency) x
          p ft3/l,024Btu! x {8,424 hr/yr) x (S3.48/1.000 ft3)
         Fuel oil credit = (model BLS firing rate) x (6.000 Btu/ib) x (1 d/24 hr) x (66%-56% thermal efficiency)/(85% power boiler efficiency) x
          (1 gal/144,000 Btu) x (S.-424 hr;yr) x ($0.77/gal)
       (c) BLO operating cost savings = S251.900ryr x (model BLS firing rate/2.200.000 Ib BLS/d)
       (d) Concentrator steam costs = $54.000/yr x (model BLS firing rate/2.400,000 Ib BLS/d)
       (e) ESP operating electricity cost = O.00184 x increase in ESP plate area x 8,424 hr/yr x $0.06/kWh
       (f) Administrative, taxes, and insurance = 0.04 x TCI
       (g) For low-odor conversion and production losses, capital recovery cost = 0.0944 x TCI (based on 20-yr remaining service life and 7% interest)
        For ESP upgrade and wet- to dry-bottom  ESP conversion, capital recovery cost = 0.1169 x TCI (based on 13.5-yr ESP life and 7% interest)
                                               6-95

-------
TABLE  6-21
      ^I
  [0 015
  L° *
           SCENARIO 3:  ANNUAL COSTS  OF LOW-ODOR  CONVERSION
              ESP  UPGRADE  TO CONTROL  PM TO  0.034  G/DSCM
               )  FOR  MODEL DCE RECOVERY  FURNACES   (INCLUDING
          UNBLEACHED  PULP  PRODUCTION LOSSES) a

Total CacHa] Investment (TCI) 	

Stsam production credits (b)
Natural gas
Fuel oil
BIO operating cost livings (c)
Concentrator steam costs (d)
ESP operating electricity costs (e)
Total DAC
Natural gas
Indirect Annual Costs PAC)
Administrative, taxes, and Insurance (0
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Total
Capital recovery (g)
Low-odor conversion
ESP upgrade
Wet- to dry-bottom ESP conversion
Production losses
Total

Totai Annual Costs
Natura! gas
- edel Recovery
S1 0.100.000

($758,000)
C$1.190,000)
($103,000)
$57,800
$33,100
($770,000)
($1.200.000)

324.000
50,800
17.600
392.000
$764,000
$148.000
$5 1,300
$32,900
-996,000
$1.390,000
$620.000
$190.000
$10.100.000

($758,000)
($1,190.000)
($103,000)
$57,600
$21,400
($782,000)
($1.210.000)

324,000
50,800
17,600
332.000
$764.000
$148.000
$51,300
$32,900
996,000
$1.390,000
$608.000
$180000
RF-8a
$14,000.000

($1,260,000)
($1,990.000)
($172,000)
$96,300
$55,000
($1,280,000)
($2.010,000)

440.000
73,600
23,800
537,000
$1,040,000
$215,000
$69,700
$54.800
1,380,000
$1.920.000
$640.000
($90,000)

RF-Sb
$14.000.000

($1,260,000)
($1,990,000)
($172,000)
$96,300
$35,600
($1,300,000)
(S2.030.OOO)

440.000
73,600
23,800
537,000
$1,040,000
$215,000
$69.700
$54.800
1,380,000
S1.920.000
$620,000
($110.000)

$20.400,000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$99,200
($2,310,000)
($3,620.000)

626,000
114.000
34,000
776,000
$1,480,000
8334,000
$99,2OO
$98,200
2.010.OOO
S2.790.000
S480.0OO
($830.000)

$20,400.000

($2,270,000)
($3,580,000)
($309,000)
$173,000
$64.200
($2,340,000)
(S3.650 OOO)

628,000
114.000
34,000
77.6,000
$1,480,000
$334,000
$99,200
$98,200
2,010.000
$2,790,000
$450.000
($860.000)
(a) AH costs in $1991. Numbers in parentheses represent cost savings.
                                          * ,66^56, therm, efficiency,/,** power bo ..... fT,cM x



   (1 gal/144.000 Btu) X (8.424 hr/yr) x (S0.77/gal)
(c) BLO operating cost savings = $251,900/yr x (model BLS firing rate/2.200,000 Ib BLS/d)
(d) Concentrator steam costs - S54,000/yr x (model BLS firing rate/2.400,000 Ib BLS/d)
(e) ESP operating electricity cost - 0.00194 x Increase In ESP plate area x 8.424 hr/yr x $0.06/kWh
  For ESP upgrade and wet- to dry-bottom ESP conversion, capital recovery cost = 0.1169 x TCI (based on
                                   6-96

-------
  TABLE  6-22a (METRIC).   GAS  AND  LIQUID STREAM PARAMETERS  FOR
                RECOVERY FURNACE MODEL PROCESS UNITSa
Parameters
Gas Stream Prooerties:
ESP Outlet:
Flow rate, m^/sec
Temperature, CC
Moisture content, %
Out of Quench:
Flow rate, m /sec
Temperature, °C
Moisture content, %
Density, kg/m
Molecular weight,
g/gmole
Viscosity, kg/m-hr
HCI concentration, ppmv
HCI emissions, kg/d
Out of Absorber:
HCI concentration, ppmv
Liquid Stream Prooerties:
HCI concentration in
entering liquid, gmole HCI
per gmole pollutant-free
liquid
Density, kg/rn^
Moiecular weight,
g/gmole
Pollutant Properties:
Diffiisivity of HCI in air,
Diffusivitv of HCI in
water, m /hr
Model NDCE/Converted DCE Recovery Furnaces
RF-1/4/8

93
199
26

76
72
33
0.8946
25.3
0.0617
9.7
82

5
0

999
18
0.0673
9.4E-6

RF-2/5/9

168
199
26

136
72
33
0.8946
25.3
0.0617
9.7
147

5
0

999
18
0.0673
9.4-6

RF-3/6

243
199
26

197 .
72
33
0.8946
25.3
0.0617
9.7
212

5
0

999
18
0.0673
9.4E-6

RF-7

56
199
26

45
72
33
0.8946
25.3
0.0617
9.7
49

5
0

999
18
0.0673
9.4E-6

Model DCE Recovery Furnaces
RF-7

56
160
32

48
74
37
0.8762
25.0
0.0607
9.2
49

5
0

999
18
0.0673
9.4E-6

RF-8

93
160
32

80
74
37
0.8762
25.0
0.0607
9.2
82

5
0

999
18
0.0673
9.4E-6

RF-9

168
160
32

144
74 :
37
0.8762
25.0
0.0607
9.2
147

5
0

999
n
0.0673
9.4E-6

aMetric equivalents in this table were converted from the calculated English unit values given in Table 6-22b.
                                    6-97

-------
TABLE  6-22b  (ENGLISH).   GAS AND  LIQUID STREAM PARAMETERS FOR
                    .	 	ii..-»-ii_ ^-M--» <-•*—•  •• ^^-XT-H^-IT-  T^T^ X"\^"*T3 O O  TTKTTT^O

Parameters
— = — ^^^=
Gas Strom Properties:
ESP Outlet:
Flow rate, acfm
Temperature, *F
Moiiture content, %
Out of Quench*:
Flow rate, acfm
Temperature, °F
Moisture content, %
Density, lb/ft3
Molecular weight,
Ib/lbmole
Viscosity, lb/ft-hr
HC1 concentration, ppmv
HCI emissions, Ib/d
Out of Absorber:
HCI concentration, ppmv
Liauid Stream Properties:
HCI concentration in
entering liquid, Ibmole
HCI per Ibmole pollutant-
free liquid
Density, lb/ft3
Molecular weight,
Ib/lbmole
Pollutant Prooerties:
Diffusivity of HCI in air,
fl?/hr
Diffusiviry of HCI in
water, fir/hr
Model NDCE/Converted DCE Recovery Furnaces
RF-1/4/8
=====


198,000
390
26

161,000
161
33
0.05587
25.3

0.0415
9.7
180

5

0



62.4
IS


0.725

1.02E-4
RF-2/5/9
=====


357,000
390
26

289,000
161
33
0.05587
25.3

0.0415
9.7
324

5

0



62.4
18


0.725

1.02E-4
RF-3/6
=====


515,000
390
26

417,000
161
33
0.05587
25.3

0.0415
9.7
468

5

0



62.4
18


0.725

1.02E-4
RF-7
==


119,000
390
26

96,500
161
33
0.05587
25.3

0.0415
9.7
108

5

0



62.4
18


0.725

1.02E-4
Model DCE Recovery Furnaces
RF-7 1
-•'_ ' "-"—


119,000
320
32

102,000
165
37
0.05470
25.0

0.0408
9.2
108

5

0



62.4
18


0.725

1.02E-4
RF-8
=====


198,000
320
32

170,000
165
37
0.05470
25.0

0.0408
9.2
180

5

0



62.4
18


0.725

1.02E-4
RF-9
	 •


357,000
320
32

307,000
165
37
0.05470
25.0

0.0408
9.2
324

5

0



62.4
18


0.725

1.02E-4
«To simplify the packed-bed scrubber design analysis, it was assumed that the gas stream exiting the ESP was cooled to saturation

with water sprays.
                                           6-98

-------
      TABLE  6-23a  (METRIC).   PACKED-BED  SCRUBBER DESIGN AND
                           OPERATING PARAMETERS51
Packed-Bed Scrubber
Parameters
Packed-Bed Scrubber Desien
Parameters:
Cross-sectional area, n?
Vessel diameter, m
Packing height, m
Tower height, m
Surface area, m^
Pressure drop, mm Hg
Auxiliary Equipment:
Stack height, m
Suck diameter, m
Fan impeller diameter, m
Fan motor efficiency,
fraction
Pump motor efficiency,
fraction
Power for fan, k\V
Power for pump, kW
Wastewater flow rate,
L/min
Caustic addition (dry
NaOH), kg/hr
Column Operation:
Minimum wetting rate,
m2/hr
Fraction of flooding gas
velocity
Operating hours per year
Equipment
Labor
Operating labor
requirement, hr/d
Maintenance labor
requirement, hr/d
Model NDCE/Converted DCE Recovery Furnaces
RF-1/4/8
36
6.7
0.47
8.4
249
2.4
30.5
3.1
2.7
0.7
0.7
34.4
28.1
6.25
25.6
0.12
0.7
8,424
8,760
1.5
1.5
RF-2/5/9
64
9.0
0.47
11
433
2.4
30.5
4.1
3.6
0.7
0.7
62.3
50.6
11.2
46.1
0.12
0.7
8,424
8,760
1.5
1.5
RF-3/6
93
11
0.47
13
615
2.4
30.5
5.0
4.1
0.7
0.7
89.5
73.1
16.2
66.6
0.12
0.7
8,424
8,760
1.5
1.5
RF-7
21
5.2
0.47
6.8
155
2.4
30.5
2.4
2.2
0.7
0.7
20.6
16.9
3.75
15.4
0.12
0.7
8,424
8,760
1.5
1.5
Model DCE Recovery Furnaces
RF-7
22
5.4
0.43
6.9
161
2.2
30.5
2.5
2.3
0.7
0.7
20.2
17.7
3.21
13.2
0.12
0.7
8,424
8,760
1.5
1.5
RF-8
37
6.9
0.43
8.5 .
259
2.2
30.5
3.2
2.8
0.7
0.7
33.6
29.5
5.36
22.0
0,12
0.7
8,424
8,760
1.5
1.5
RF-9
67
9.3
0.43
It
452
23.
30.5
43
3.7
0.7
0.7
60.7
53.1
9.65
39.6
0.12
0.7
8,424
8,760
1.5
1.5
"Metric equivalents in this table were converted from the calculated English unit values given in Table 6-23b.
                                     6-99

-------
TABLE 6-23b
(ENGLISH).   PACKED-BED SCRUBBER DESIGN AND
     OPERATING PARAMETERS

Picked-Bed Scrubber
Parameters
=============
Packed-Bed Scrubber Design
Para meters:
CroJt-sectiontI area, ft
Vessel diameter, ft
Packing height, ft
Tower height, ft
Surface area, ft2
Pressure drop, in E^O
Auxiliary Eauioment;
Suck height, ft
Stack diameter, ft
Fan impeller diameter, in
Fan motor efficiency,
fraction
Pump motor efficiency,
fraction
Power for fan, kW
Power for pump, kW
Wastewater flow rate.
gpm
Caustic addition (dry
NaOH), Ib/hr
Column Oneration:
Minimum wetting rate,
f&hr
Fraction of flooding gas
velocity
Operating hours per year
Equipment
Labor
Operating labor
requirement, hr/d
Maintenance labor
requirement, hr/d
Model NDCE/Converted DCE Recovery Furnaces
RF-1/4/8
==


384
22.1
1.54
27.5
2,679
1.3

100
10.1
105
0.7

0.7

34.4
28.1
1.651

56.5


1.3

0.7

8,424
8,760
1.5

1.5

RF-2/S/9 |


690
29.6
1.54
35.2
4,657
1.3

100
13.6
140
0.7

0.7

62.3
50.6
2.971

102


1.3

0.7

8,424
8,760
1.5

1.5

RF-3/6
=====


998
35.6
1.54
41.3
6,624
1.3

100
16.3
160
0.7

0.7

89.5
73.1
4.291

147


1.3

0.7

8,424
8,760
1.5

1.5

RF-7
=====


231
17.1
1.53
22.4
1,672
1.3

100
7.8
85
0.7

0.7

20.6
16.9
0.990

33.9


1.3

0.7

8,424
8,760
1.5

1.5

Model DCE Recovery Furnaces
RF-7
====


242
17.6
1.41
22.7
1,735
1.2

100
8.1
90
0.7

0.7

20.2
17.7
0.849

29.1


1.3

0.7

8,424
8,760
1.5

1.5

RF-8
=


403
22.7
1.41
27.9
2,791
1.2

100
10.4
110
0.7

0.7

33.6
29.5
1.415

48.4


1.3

0.7

8,424
8,760
1..5

1.5

RF-9
===


725
30.4
1.41
35.8
4,864
1.2

100
14.0
145
0.7

0.7

60.7
53.1
2.548

87.2


1.3

0.7

8,424
8,760
1.5

1.5

                          6-100

-------
   TABLE 6-24a  (METRIC).   UNIT COSTS FOR PACKED-BED SCRUBBER
Parameters
Operator wage rate, $/hr
Water cost, $/m3
Electricity, $/kWh
Wastewater disposal, $/m3
Caustic (dry NaOH), $/Mg
Packing material, $/m^
Value
15.64
0.05
0.06
1.0
441
706
 aMetric equivalents in this table were converted from the calculated English unit values
 given in Table 6-24b.
 TABLE 6-24b  (ENGLISH).   UNIT COSTS FOR PACKED-BED SCRUBBERa'b
Parameters
Operator wage rate, $/hr
Water cost, $71,000 gal
Electricity, $/kWh
Wastewater disposal, $71,000 gal
Caustic (dry NaOH), $7ton
Packing material, $/rr
Value
15.64
0.2
0.06
3.8
400
20
fOAQPS Control Cost Manual
Medical Waste Incinerators-Background Information for Proposed Standards and
 Guidelines: Model Plant Description and Cost Report for New and Existing Facilities.
 U. S. Environmental Protection Agency. Research Triangle Park, NC.  Publication
No. EPA-453/R-94-044a.  July 1994. p. 62.
                                  6-101

-------
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                                              6-102

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TABLE  6-28.    CAPITAL  AND ANNUAL  COSTS  OF COLLECTION AND
  INCINERATION  OF  BLO  VENT  GASES  FOR MODEL  BLACK  LIQUOR
                                OXIDATION  UNITSa

Total Capital Investment (TCI) (b)
Direct Annual Costs (DAC)
Operating labor (c)
Operator
Supervisor
Maintenance (d)
Labor
Material
Electricity (e)
Steam (f)
Total DAC
Indirect Annual Costs (IAC)
Overhead (g)
Administrative, taxes and insurance (h)
Capital recovery (i)
Total IAC
Total Annual Costs 	 	 	
Model BLO units
BLO-1
2,500,000

$18,600
$2,790
$27,400
$27,400
$103,000
$22,000
$179,000

$45,700
$100,000
$356,000
$502,000
$681,000
BLO-2
3,390,000

$18,600
$2,790
$27,400
$27,400
$209,000
$44,600
$285,000

$45,700
$136,000
$483,000
$665,000
$950,000
BLO-3
4.830,000

$18,600
$2,790
$27,400
$27,400
$312,000
$66,600
$388,000

$45,700
$193,000
$688,000
$927,000
$1 ,320,000
 (a)  All costs in $1991.
 (b)  TCI = $4.800,000 x [(model BLS rate)/(800 ADTP/d x 3,400 Ib BLS/ADTP)] ~ 0.6 x (361.3 $1991 /3S7.6 $1990)
 (c)  Operating labor ~ 0.5 hr/shifl/condenser x 3 sh'rfts/d x 2 condensers x 365 d/yr x $17/hr
     Supervisor labor - 15% of operator labor
 (d)  Maintenance labor = 0.5 hr/shift/condenser x 3 shifts/d x 2 condensers x 365 d/yr x $25/hr
     Maintenance materials = 100 percent of maintenance labor
 (a)  Electricity costs = Mill A electricity costs x (model vent gas flowrate/Mill A vent gas flowrate)
     Mill A electricity costs = (100 hp + 3 hp + 400 hp) x 0.746 kW/hp x 8,424 hr/yr x $0.06/kWh
     The Mill A electricity costs are based on 100 hp to operate the mill water booster pump motor, 3 hp to
      operate the BLO condenser condensate pump motor, and 400 hp to operate the BLO off gas blower motor.
     The Mill A vent gas flowrate - 16,327 acfm
 (1)  Steam cost = Mill A steam cost x (model vent gas flowrate/Mill A vent gas flowrate)
     Mill A steam cost = 1,600 Ib steam/hr x 8,424 hr/yr x $3/1,000 Ib steam
     The Mill A steam cost is based on steam requirements of 1,600 Ib steam/hr for the BLO off gas reheater.
     The Mill A vent gas flowrate = 16,327 acfm
 (g)  Overhead = 0.6 x (labor + maintenance)
 (h)  Administrative, taxes, and insurance = 0.04 x TCI
 (i)  Capital recovery = 0.1424 x TCI. based on 7% interest and 10-yr equip, life for ductwork and condenser.
                                          6-106

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                                                              6-108

-------
   TABLE  6-30a (METRIC) .   MODEL SDT/SCRUBBER DESIGN PARAMETERS3-
Design parameters
Baseline APCD:

Control option APCD:
Black liquor firing rate, kg BLS/d:
Equivalent ADMP/d:
Bleached pulp
Unbleached pulp
Gas flowrate-APCD inlet (Q), m3/sec:
Existing pressure drop, mm Hg:
New pressure drop, mm Hg:
Operating days per year:
Equipment
. Labor
Operating hours per year:
Equipment
Labor
Model SDT's
SDT-5
mist
eliminator
scrubber
400.000
230
270
4.4
1.3
13
351
365
8,424
8,760
SDT-6
mist
eliminator
scrubber
700,000
380
450
7.4
1.3
13
351
365
8,424
8,760
SDT-7
mist
eliminator
scrubber
1,200,000
680
820
13.4
1.3
13
351
365
8,424
8,760
(a)  Metric equivalents in this table were converted from the calculated English unit values
    given in Table 6-30b.
                                     6-109

-------
TABLE 6-30b  (ENGLISH).  MODEL SDT/SCRUBBER DESIGN PARAMETERS

Baseline APCD:
Control option APCD:
Black liquor firing rate, Ib BLS/d:
Equivalent ADTP/d:
Bleached pulp
Unbleached pulp
Gas flow rate-APCD inlet, acfm:
Existing pressure drop, in. H2O:
New pressure drop, in. H20:
Operating days per year:
Equipment
Labor
Operating hours per year:
Equipment
Labor
Model SDT's
SDT-5
mist
eliminator
scrubber
900,000
250
300
9,400
0.7
7
351
365
8,424
8,760
SDT-6
mist
eliminator
scrubber
1,500,000
420
500
15,700
0.7
7
351
365
8,424
8,760
SDT-7
mist
eliminator
scrubber
2,700,000
750
900
28,300
0.7
7
351
365
8,424
8,760
                             6-110

-------
   TABLE  6-31.    CAPITAL  AND ANNUAL  COSTS  TO  REPLACE MIST
          ELIMINATORS  WITH  SCRUBBERS  FOR  MODEL SDT'Sa
Costs
Total Capital Investment (TCI) (b):
Direct Annual Costs (DAC) :
Operating labor (c):
Operator
Supervisor
Maintenance (d):
Labor
Material
Utilities (e):
Electricity
Water
Wastewater treatment (f) :
Total DAC:
Indirect Annual Costs (IAC):
Overhead (g):
Admin., taxes and insurance (h):
Capital recovery (i) :
Total IAC:
Total Annual Costs (TAC) :
Incremental Total Annual Costs (1TAC) (j):
Model SDT's
SDT-5
$584,000

$37,200
$5,580
$27,400
$27.400
$5,420
$9,500
$0
$1 1 3,000

$32,900
$23,400
$64,100
$120,000
$233,000
$190,000
SDT-6
$796,000

$37,200
$5,580
$27,400
$27,400
$9,050
•$15,900
$0
$123,000

$32,900
$31 ,800
$87,400
$152,000
$275,000
$232,000
SDT-7
$1,130,000

$37,200
$5,580
$27,400
$27,400
$16,300
$28,600
$0
$142,000

$32,900
$45,200
$124,000
$202,000
$344,000
$301 ,000
(a)  All costs in $1991
{b)  New scrubber TCI (models 5-7) = [scrubber replacement TCI (models 1-3)] x 2
(c)  Operator labor = 6 hr/d x 365 d/yr x $17/hr
    Supervisor labor = 15% of operator labor
{d}  Maintenance labor = 3 hr/d x 365 d/yr x $25/hr
    Maintenance materials = 100% of maintenance labor
(e)  Electricity = 0.000181 x inlet gas flowrate x (7 - 0.7 in. H2O) x 8,424 hr/yr x $0.06/kWh
    Water = 0.6 x inlet gas flowrate x 8,424 hr/yr x $0.20/1,000 gal
(f)   Recycled to SDT
(g)  Overhead = 0.6 x maintenance
(h)  Administrative, taxes, and insurance = 0.04 x TCI
(i)   Capital recovery = 0.1098 x TCI (based on 15-yr scrubber life and 7% interest)
(j)   ITAC = TAC - operating labor costs.
                                       6-111

-------
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                                6-115

-------
       TABLE  6-34a  (METRIC).   MODEL LIME  KILN/SCRUBBER DESIGN
                                   PARAMETERS51
Design parameters
 ipiiiiiiiiiHglif*8"'!! ill-'	'-'	.iii-...iiit...=a:^^^g:^s^^s:^^^^^^^^^

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Lime production rate, Mg CaO/d

Equivalent ADMP/d

Gas flowrate-APCD inlet, m3/sec

 Pressure drop, mm Hg

 Operating days per year
     Equipment
     Labor

 Operating hours per year
     Equipment
     Labor        	__

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Model Lime Kilns
LK-1
=—======
scrubber
90
320
10
39
351
365
8,424
8,760
LK-2
s==s^=^=s^^=:^s:
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180
680
20
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351
365
8,424
8,760
LK-3
=====
scrubber
270
1,000
34
39
351
365
8,424
8,760
 (a)  Metric equivalents in this table were converted from the calculated English unit values
     given in Table 6-34b.
                                          6-116

-------
TABLE 6-34b  (ENGLISH).  MODEL LIME KILN/SCRUBBER DESIGN
                       PARAMETERS
Design parameters
Baseline APCD
Lime production rate, ton CaO/d
Equivalent ADTP/d
Gas flowrate-APCD inlet, acfm
Pressure drop, in. H20
Operating days per year
Equipment
Labor
Operating hours per year
Equipment
Labor
Model Lime Kilns
LK-1
scrubber
100
350
22,000
21
351
365
8,424
8,760
LK-2
scrubber
200
750
42,500
21
351
365
8,424
8,760
LK-3
scrubber
300
1,100
72,200
21
351
365
8,424
8,760
                         6-117

-------
TABLE  6-35.   ANNUAL  COSTS  FOR EXISTING LIME  KILN  SCRUBBERS*


costs 	 „_===
Direct Annual Costs (DAG)
Operating labor (b)
Operator
Supervisor
Maintenance (c)
Labor
Material
Utilities (d)
Electricity
Water
Wastewater treatment (e)
Total DAC
Indirect Annual Costs (IAC)
Overhead (f)
Total Annual Costs

LK-1


$37,200
$5,580
$27,400
$27,400
$42,000
$22,200
$0
$162,000

$58,500
$221,000

vlodel Lime Mins
LK-2


$37,200
$5,580
$27,400
$27,400
$81,200
$43,000
$0
$222,000

$58,500
$281,000

LK-3

	
$37,200
$5,580
$27,400
$27,400
$138,000
$73,000
$0
$309,000

$58,500
$368,000
(a)  All costs in $1991
(b)  Operator labor = 6 hr/d x 365 d/yr x $17/hr
    Supervisor labor = 15% of operator labor
(c)  Maintenance labor = 3 hr/d x 365 d/yr x $25/hr
    Maintenance materials = 100% of maintenance labor
(d)  Electricity = 0.00018 x model inlet gas flowrate x pressure drop x 8,424 hr/yr x $0.06/kWh
    Water = 0.06 x model inlet gas flowrate x 8,424 hr/yr x $0.20/1,000 gal
(e)  Recycled to mud washer
(f)  Overhead =  0.6 x (labor + maintenance)
                                       6-118

-------
TABLE  6-36a  (METRIC) .   MODEL LIME  KILN/ESP DESIGN PARAMETERS51
Design parameters
Control option APCD
Lime production rate, Mg CaO/d
Equivalent ADMP/d
Gas flowrate~ESP exit, m3/sec
ESP plate area, m2
PM controls— 0. 1 5 g/dscm
PM controis~0.023 g/dscm
SCA, m2/(m3/sec)
PM controls-0.15 g/dscm
PM controls-0.023 g/dscm
Pressure drop, mm Hg
Operating days per year
Equipment
Labor
Operating hours per year
Equipment
Labor
Model Lime Kilns
LK-1
ESP
90
320
10
' 909
2,210
91
221
2
351
365
8,424
8,760
LK-2
ESP
180
680
20
1,818
4,420
91
221
2
351
365
8,424
8,760
LK-3
ESP
270
1,000
34
3,090
7,514
91
221
2
351
365
8,424
8,760
    (aj Metric equivalents in this table were converted from the calculated English unit values
     given in Table B-3Sb.
                                    6-119

-------
TABLE 6-36b  (ENGLISH).  MODEL LIME  KILN/ESP DESIGN PARAMETERS

Control option APCD
Lime production rate, ton CaO/d
Equivalent ADTP/d
Gas flowrate-ESP exit, acfm
ESP plate area (A), ft2
PM controls-0.067 gr/dscf
PM controls-0.01 gr/dscf
SCA,ft2/1, 000 acfm
PM controls-0.067 gr/dscf
PM controls--0.01 gr/dscf
Pressure drop, in. H20
Operating days per year
Equipment
Labor
Operating hours per year
Equipment
Labor
Model Lime Kilns
LK-1
ESP
100
350
22,000
10,157
24,699
462
1,123
1
351
365
8,424
8,760
LK-2
ESP
200
750
42,500
19,621
47,714
462
1,123
1
351
365
8,424
8,760
LK-3
ESP
300
1,100
72,200
33,332
81,058
462
1,123
1
351
365
8,424
8,760
                              6-120

-------
TABLE  6-37.
ANNUAL  COSTS FOR NEW  LIME KILN  ESP'S CONTROLLING
 PM TO  0.15  G/DSCM  (0.067 GR/DSCF)a
Costs
Total Capital Investment 0"CI) (b):
Direct Annual Costs (DAC):
Operating labor (c):
Operator
Supervisor
Coordinator
Maintenance (d):
Labor
Material
Electricity (e):
Electricity-fan
Electricity-operating
Waste disposal:
Total DAC:
Indirect Annual Costs (IAC):
Overhead (f):
Admin., taxes and insurance (g):
Capital recovery (h):
Total IAC:
Total Annual Costs:
Model Lime Kilns
LK-1
$457,000

$13,100
$1,970
$4,320
$838
$2,740
$2,000
$10,000
$0
$35,000

$13,800
$18,300
$50,200
$82,300
$117,000
LK-2
$883,000

$13,100
$1,970
$4,320
$1,620
$5,300
$3,870
$19,200
$0
$49,400

$15,800
$35,300
$97,000
$148,000
$197,000
LK-3
$1,500,000

$13,100
$1,970
$4,320
$2,750
$9,000
$6,570
$32,700
$0
$70,400

$18,700
$60,000
$165,000
$244,000
$314,000
         (a)  All costs in $1991
         (b)  TCI = ESP plate area x $45/ft2 plate area
         (c)  Operator labor = 3 hr/day x 365 d/yr x $12/hr
             Supervisor labor = 15% of operator labor
             Coordinator labor = 33% of operator labor
         (d)  Maintenance labor = 0.0825 x ESP plate area
            . Maintenance material = 0.01 x (0.6 x TCI)
         (e)  Electricity-fan = 0.00018 x model gas f lowrate x pressure drop x 8,424 hr/yr x $0.06/kWh
             Electricity-operating = 0.00194 x ESP plate area x 8,424 hr/yr x $0.06/kWh
         (f)  Overhead.= 0.6 x (labor + maintenance)
         (g)  Administrative, taxes, and insurance = 0.04 x TCI
         (h)  Capital recovery = 0.1098 x TCI (based on 15-yr ESP life and 7% interest)
                                         6-121

-------
TABLE  6-38.
ANNUAL COSTS  FOR NEW  LIME KILN ESP'S  CONTROLLING
PM  TO  0.023 G/DSCM  (0.010 GR/DSCF)a
Costs
Total Capital Investment (TCI) (b):
Direct Annual Costs (DAC):
Operating labor (c):
Operator
Supervisor
Coordinator
Maintenance (d):
Labor
Material
Electricity (e):
Electricity-fan
Electricity-operating
Waste disposal:
Total DAC:
Indirect Annual Costs (IAC):
Overhead (f):
Admin., taxes and insurance (g):
Capital recovery (h):
Total IAC:
Total Annual Costs:
Model Lime Kilns
LK-1
$1,110,000

$13,100
$1,970
$4,320
$2,040
$6,660
$2,000
$24,200
$0
$54,300

$16,900
$44,400
$122,000
$183,000
$237,000
LK-2
$2,150,000

$13,100
$1,970
$4,320
$3,940
$12,900
$3,870
$46,800
$0
$86,900

$21,700
$86,000
$236,000
$344,000
$431,000
LK-3
$3,650,000

$13,100
$1,970
$4,320
$6,690
$21,900
$6,570
$79,500
$0
$134,000

$28,800
. $146,000
$401,000
$576,000
$710,000
         (a)  All costs in $1991
         (b)  TCI = ESP plate area x $45/ft2 plate area
         (c)  Operator labor = 3 hr/day x 365 d/yr x $12/hr
             Supervisor labor = 15% of operator labor
             Coordinator labor = 33%  of operator labor
         (d)  Maintenance labor = 0.0825 x ESP plate area
             Maintenance material = 0.01 x (0.6 x TCI)
         (e)  Electricity-fan = 0.00018 x model gas flowrate x pressure drop x 8,424 hr/yr x $0.06/kWh
             Electricity-operating = 0.00194 x ESP plate area x 8,424 hr/yr x $0.06/kWh
         (f)   Overhead = 0.6 x (labor + maintenance)
         (g)  Administrative, taxes, and insurance = 0.04 x TCI
         (h)  Capital recovery = 0.1098 x TCI (based on 15-yr ESP life and 7% interest)
                                           6-122

-------

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                                      6-124

-------
          TABLE  6-40.    SUMMARY OF  ENHANCED MONITORING  COSTS
Enhanced monitoring system
Opacity monitor
Methanol CEM (FITR)
HC1 CEM
EPA Method 5 PM compliance test (three runs)
EPA Method 29 PM compliance test (three runs)
EPA Method 26 or 26A HC1 compliance test (three
runs)2
Monitoring plan
Confirmation of NDCE recovery furnace with dry
ESP system
Confirmation of BLO control equipment
Temperature monitor for power boiler or other
incineration device0
pH monitoring system
Flow rate measurement system°>e
Magnehelic gauge, S-rype pitot tube (pressure drop
measurement)"
Cost
Capital cost: $34,800
Annual cost: $21,200/yr
Capital cost: $160,000
Annual cost: $71,500/yr
Capital cost: $126,900
Annual cost: $77,400/yr
Initial compliance test cost: $8,500
Semiannual testing annual cost: $17,000/yr
Initial compliance test cost: $12,000
Seminnual testing annual cost: $24,000/yr
Initial compliance test cost: $9, 100*
$600b
Annual testing annual cost: $9, lOO/y^
$600b
Cost not available
$0
$0
$0
$5,000
$2,000 - $25,000
Manual read-out system: $300
Digital read-out system: Cost not available
aCost assumes EPA Method 26 or 26A HC1 testing is performed alone.
bCost assumes EPA Method 26 or 26A HC1 testing is performed in conjunction with EPA Method 5,
 Method 29, or Method 17 testing.
cCost of monitoring power boiler or incinerator temperature is assumed to be zero because temperature
 monitoring is already conducted by mills.
d Annual costs were not available for monitoring pH and flow rate of scrubber liquid or for monitoring
scrubber pressure drop.
eCost depends on the  device sensitivity and distance from the control room.
                                         6-125

-------
   TABLE  6-41.   OPACITY AND HCL  CONTINUOUS  EMISSION MONITOR
                                      COSTSa

Parameters 	
Capital costs
Planning
Select type of equipment
Provide support facilities
Purchased equipment cost
Install and check CEM's
Performance specification tests (certification)
Prepare QA/QC plan
Total capital investment 	
Annual costs
Operating and maintenance
Annual RATAb
Supplemental RATA
Quarterly CGA's0
Reporting and recordkeeping
Annual review and update
Administrative, insurance, and property taxes
Capital recovery6
Total annual cost 	
CEM costs
Opacity CEM
=======^=

$1,200
$4,000
$100
$21,500
$300
$1,400
$6,300
$34,800

$7,000
$0
$0
$0
$5,900
$3,600
$3,300
$1,400
$21,200
HC1 CEM

$4,600
$10,500
$13,100
$61,500
$11,100
$14,300
$11,800
$126,900

$8,500
$10,000
$9,500
$3,500
$11,600
$17,200
$12,000
$5,100
$77,400
aAll costs are based on EMTIC's CEM program, except for administrative, insurance, property tax, and
 capital recovery costs, which are based on procedures from the OAQPS Control Cost Manual.
^Relative accuracy test audit
cCylinder gas audits
^Administrative, taxes, and insurance = 0.04 x TCI
eCapital recovery = 0.0944 x TCI (based on 20-yr equipment life and 7% interest)
                                        6-126

-------
6.3  REFERENCES FOR CHAPTER 6

 1.  Memorandum from Holloway, T. and Nicholson, R.,  MRI, to
     Telander, J., EPA/MICG.  October 9, 1996.  Nationwide Costs,
     Environmental Impacts, and Cost-Effectivness of Regulatory
     Alternatives for Kraft, Soda, Sulfite, and Semichemical
     Combustion Sources.
 5.
 6.
 7.
 8.
 9.
10.
11
     Economic Indicators--CE Plant Cost Index.
     Engineering (New York).   1960-1993.
                                           Chemical
     Memorandum from Mathias, S.
     EPA/ISB.  February 2, 1994.
     for Kraft Pulp Mills.
                             EPA/CEIS, to Telander, J.,
                             Value of Lost Production days
Memorandum from Soltis, V., MRI, to the project file.
April 3, 1995.  Kraft and Soda Pulp Mill Combustion Sources
Data Base.

Handbook: Control Technologies for Hazardous Air Pollutants.
U. S. Environmental Protection Agency.  Cincinnati, OH.
Publication No. EPA-625/6-91-014.  June 1991.  Chapter 4.

OAQPS Control Cost'Manual.  4th Edition.  U. S.
Environmental Protection Agency.  Research Triangle Park,
NC.  Publication No. EPA-450/3-90-006.  January 1990.

U. S. Environmental Protection Agency.  National Emission
Standards for Hazardous Air Pollutants: General Provisions.
59 FR 12408 et seq.  Washington, DC.  U.S. Government
Printing Office.  March 16, 1994.

Memorandum from Soltis, V., Nicholson, R., Holloway, T.,
MRI, to Telander, J., EPA/MICG.  July 29, 1994.  Summary of
Responses to the NCASI "MACT" Survey--Kraft and Soda Pulp
Mills (Data Base Summary Memo).

Memorandum from Nicholson, R., MRI, to Telander, J.,
EPA/ISB.  May 28, 1993.  Meeting minutes from the March 30,
1993 meeting between Environmental Elements Corp. and
Midwest Research Institute.

Memorandum from Holloway, T., MRI, to the project file.
July 16, 1996.  State of Washington PM Data for Kraft
Recovery Furnaces, Smelt Dissolving Tanks, and Lime Kilns.

Memorandum from Radian Corp. to EPA/ISB.  September 18,
1985.  Meeting minutes from the June  10, 1985 meeting
between kraft pulp mill representatives, the National
Council of the Paper Industry for Air and Stream
Improvement, Inc., the U. S. Environmental Protection
Agency,  and Radian Corp.
                              6-127

-------
12.  Letter and attachments from Eddinger, J., EPA/ISB, to
     Blosser, R., National Council of the Paper Industry for Air
     and Stream Improvement.  May 22, 1985.  Preliminary cost _
     estimates for evaluating the three control options to bring
     wet-bottom ESP's into compliance with the NSPS.

13.  Letter from Bringman, L., Environmental Elements Corp., to
     Nicholson, R., MRI.  October 12, 1993.  Budgetary pricing to
     convert from wet- to dry-bottom ESP.

14.  Letter from Burt, R., Radian Corp., to Holbrook, J. and
     Bringman, L., Environmental Elements Corp.  July 23, 1985.
     Facsimile cover letter discussing utility and maintenance
     costs for wet- vs. dry-bottom ESP designs.

15.  Garner, J., Jaako Poyry.  Conversion to Low Odor Improves
     Recovery Boiler Efficiency and Life.  Pulp and Paper.
     63(7):91-95.  July 1989.

16.  Green, R. and G. Hough  (eds.).  Chemical Recovery in the
     Alkaline Pulping Process.  3rd Edition.  Prepared by the
     Alkaline Pulping Committee of the Pulp Manufacture Division.
     Atlanta, GA, TAPPI Press, 1992.  196 p.

17.  Memorandum from Ramsey, M. and Nicholson, R., MRI, to
     Telander, J., EPA/ISB.  November 3, 1992.  Meeting minutes
     from the June 24, 1992 meeting between The Babcock and
     Wilcox Co., the U. S. Environmental Protection Agency, and
     Midwest Research Institute.

18.  Telecon.  Soltis, V., MRI, with Morgan, P., ABB Combustion
     Engineering Services, Inc.  August 6, 1993.  Information
     about cascade evaporators and low-odor conversion costs.

19.  Telecon.  Soltis, V., MRI, with Blake, J., Goslin-
     Birmingham.  August  27, 1993.  Concentrator costs.

20.  Williamson, F., Chief Power Engineer, Harmac Pulp Division.
     Low Odor Boiler Conversion--By Threes.  In: TAPPI Kraft
     Recovery Operations  Short Course.  TAPPI Press.
     January 3-8, 1993.   pp. 229-247.

21.  Hein, A.  Kraft Recovery Boiler: Conventional to Low-Odor
     Conversion.  Pulp &  Paper Canada.  88(12):223-226.
     December 1987.

22.  Kirby, M.  Economic  and Process Considerations in the Use of
     Oxygen for Black Liquor Oxidation.  Union Carbide Canada
     Limited.  Ontario, Canada.   (Presented at the 21st Pulp and
     Paper ABCP Annual Meeting.  Sao Paolo, Brazil.
     November 21-25, 1988.)  10 p.
                               6-128

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23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
Perry, R., D. Green, and J. Maloney  (eds:).
Chemical  Engineer's Handbook.  6th edition.
pp. 9-16, 9-18.
    Perry's
    1984.
Pulp, Paper, and Paperboard Industry--Background Information
for Proposed Air Emission Standards, Manufacturing Processes
at Kraft, Sulfite, Soda, and Semi-Chemical Mills.  U. S.
Environmental Protection Agency.  Research Triangle Park,
NC.  Publication No. EPA-453/R-93-050a.  October 1993.
National Petroleum News 1991 Fact Book.
June 1991.  p. 114.
Volume 83, No. 7.
Letter and attachments from Black, C., Champion Interna-
tional Corp., Courtland, AL, to Crowder, J., EPA/ISB.
June 10, 1993.  Response to request for information on costs
for the BLO vent gas control system at the  Champion facility
in Courtland, AL.

Telecon.  Soltis, V., MRI, with Oscarsson,  B., Gotaverken
Energy Systems, Inc.  December 16, 1993.  Concentrator steam
costs.

Memorandum from Rovansek, W., Radian Corp., Herndon, VA, to
the record.  September 1, 1993.  Pulp and Paper Operating
Costs.

Letter and attachments from Sanders, D., Andersen 2000,
Inc., to Soltis, V., MRI.  November 9, 1993.  Preliminary
proposal for three separate quench and packed-tower
absorption systems to control HC1 gas emissions from
recovery furnaces at kraft pulp and paper mills.

Memorandum from Randall, D. and Holloway, T., MRI, to the
project file.  October 4, 1994.  Absorber Design and Cost
Algorithm.

Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Model Plant Description
and Cost Report for New and Existing Facilities.  U. S.
Environmental Protection Agency.  Research  Triangle Park,
NC.  Publication No. EPA-453/R-94-044a.  July 1994.  p. 62.

Someshwar, A. and J. Pinkerton.  Wood Processing Industry.
In: Air Pollution Engineering Manual, Air and Waste
Management Association.  Buonicore, A. and  W. Davis (eds.).
New York, Van Norstrand Reinhold. 1992.  pp. 835-849.

RUST Environment & Infrastructure.  MACT Cost Analysis
Report for NCASI.  Prepared for the National Council of the
Paper Industry for Air and Stream Improvement, Inc.  RUST
Contract No. 35-4735.  October 15, 1993.  47 p.
                              6-129

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34.
35.
36.
37.
38.
39.
40.
Memorandum from Nicholson, R. and Holloway, T., MRI, to
Telander, J., EPA/MICG.  September 6, 1995.  Trip Report for
S.D. Warren Co., Muskegon, MI.

Telecon.  Soltis, V., MRI, with Bruno, J., Airpol, Inc.
April 22 and 27, 1993.  Information on scrubbers used to
control particulate matter emissions from lime kilns and
smelt dissolving tanks at pulp and paper  mills.

Memorandum from Nicholson, R., MRI, to Telander, J.,
EPA/MICG   June 15, 1995.  Meeting minutes from the
April 12, 1993 meeting between Research-Cottrell and Midwest
Research Institute.

Memorandum from Toney, M., EPA/EMB, to Telander, J.,
EPA/ISB.  November 24, 1993.  Enhanced Monitoring for Pulp
and Paper Combustion  Sources.

Memorandum from Segall, R. EPA/EMB, to Copland, R., EPA/SDB.
October  14, 1992.  Final  Report on Emission Measurement and
Continuous Monitoring for Medical Waste Incinerator Study.

Memorandum from Toney, M., EPA/EMC, to Telander, J.,
EPA/MICG.  January 13, 1995.  Costs of Enhanced Monitoring
for Pulp and  Paper Combustion Sources.

Telecon   Harris, V.,  MRI-NCO, with Hosenfeld, J. ,  MRI-KCO.
May 26,  1995.  Costs  of EPA  Method 26 stack tests.
                               6-130

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                           APPENDIX A.
           EVOLUTION OF THE TECHNICAL SUPPORT DOCUMENT

     The purpose of this study was to develop a basis for
supporting proposed NESHAP for combustion sources at kraft and
soda pulp and mills.  This study was initiated in June of 1991
and focused on the following combustion equipment:  chemical
recovery furnaces  (including DCE's), SDT's, BLO systems, and lime
kilns.  To accomplish the objectives of this study, the following
technical data were acquired for each type of combustion equip-
ment:  (1) equipment design and operating parameters, (2) types
and quantities of HAP's emitted,  (3) types and costs of emission
control techniques  (including both process changes/controls and
add-on air pollution control devices), and (4) the effectiveness
of these control techniques in reducing HAP emissions.  The bulk
of the information was gathered from the following sources:
     1.  Technical literature;
     2.  Responses to a maximum achievable control technology
(MACT) survey distributed by NCASI to U.S. pulp and paper mills;
     3. Plant visits;
     4. Emission test reports supplied by individual mills, State
agencies, and NCASI;
     5. Recovery furnace manufacturers; and
     6. Manufacturers of ESP's and wet scrubbers.
     Significant events relating to the evolution of the TSD are
listed in Table A-l.
                               A-l

-------
TABLE A-l.  EVOLUTION OF THE TECHNICAL SUPPORT DOCUMENT
Date
7/1/91-
7/31/91
8/1/91
9/17/91
9/23/91
9/24/91
9/25/91
10/28/91
1/10/92
1/14/92
2/7/92
2/24/92
4/9/92
4/30/92
5/30/92
6/24/92
7/2/92
9/22/92
9/23/92
9/30/92
10/8/92-
10/31/92
11/20/92
3/30/93
4/12/93
5/24/93
6/14/93
6/15/93
8/16/93
9/13/93
10/12/93
Event
Contacted State and local agencies to identify well-controlled combustion sources
Initial meeting with NCASI and AFPA regarding combustion sources NESHAP and "MACT"
survey
Site visit to Champion International Corp., Roanoke Rapids, NC
Site visit to Procter and Gamble, Perry, FL
Meeting with Florida Department of Environmental
mills in Florida and obtain copies of permits
Regulation to discuss kraft pulp and paper
Site visit to Packaging Corp., Clyattville, GA
Meeting with NCASI and AFPA to discuss industry
profile
Site visit to Longview Fibre Co., Longview, WA
Site visit to James River Corp., Camas, WA
NCASI MACT survey mailed to industry by NCASI
Meeting with Gotaverken to discuss design and operation of kraft recovery furnaces
Public meeting held in Washington, DC to discuss status of NESHAP and effluent guidelines
for pulp and paper mills
Initial responses to NCASI MACT survey received by EPA, and kraft combustion sources
data base created to tabulate information in these responses
Additional responses to NCASI MACT survey received by EPA
Meeting with Babcock & Wilcox to discuss design and operation of kraft recovery furnaces
Draft summary of responses to NCASI MACT survey prepared
Site visit to MEAD Coated Board, Phenix City, AL
Site visit to Champion International Corp., Courtland, AL
Public meeting in Washington, DC, to discuss status of NESHAP and effluent guidelines for
pulp and paper mills
Source test at Champion International Corp., Roanoke Rapids, NC, to identify HAP's emitted
from a recovery furnace, smelt dissolving tank, black liquor oxidation system, and lime kiln
Meeting with NCASI and industry representatives to discuss NCASI's source test plan for
combustion sources
Meeting with Environmental Elements Corp., Baltimore, MD, to discuss ESP designs,
modifications, and upgrades, and associated costs
Meeting with Research-Cottrell, Somerville, NJ, to
upgrades, and associated costs
discuss ESP designs, modifications, and
First EPA Work Group meeting to discuss status and direction of combustion sources
NESHAP
Monthly particulate matter emission data for kraft recovery furnaces, lime kilns, and SDT's
received from the State of Washington (1989-1992)
Emission test reports for Texas kraft mills received
from NCASI
Letters sent to Andersen 2000, Inc., and AirPol regarding the effectiveness of packed-bed
scrubbers on HC1 removal from kraft recovery furnace flue gas
Completed review and summary of State regulations regarding PM and gaseous HAP
emissions from kraft combustion sources
Meeting with NCASI and industry to discuss methanol emissions and effectiveness of steam
strippers
                           A-2

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TABLE A-l.   (continued)
Date
10/31/93
12/2/93
12/16/93
1/1/94
2/3/94
2/17/94
3/11/94
3/21/94
4/11/94
4/27/94
5/12/94
7/13/94
7/29/94
7/29/94
8/24/94
8/31/94
9/1/94
9/14/94
9/21/94
9/30/94
10/4/94
11/30/94
12/20/94
1/18/95
1/31/95
3/7/95
4/20/95
Event
Review of first draft emission test report from NCASI-sponsored testing at kraft pulp
completed
Mill-specific control costs for MACT floor options submitted to EPA for impact analysis
Meeting with NCASI and industry to discuss status of NCASI source test program,
subcategories, MACT floors, and proposed format of the standard
Preliminary drafts of TSD Chapter 1 through 6 completed
Meeting with NCASI and industry to discuss status and findings of NCASI's test program
Preliminary draft of TSD Chapter 6 (Control Costs) sent to NCASI for review
Mill-specific control costs for beyond-the-floor options submitted to EPA for impact analysis
Industry comments on preliminary draft of TSD Chapter 6 received
Response to industry comments on preliminary draft of TSD Chapter 6 completed
Preliminary draft of Appendix B completed
An updated version of monthly particulate matter emission data for kraft recovery furnaces,
lime kilns, and SDT's received from the State of Washington (1988-1994)
Received and reviewed report from industry summarizing results from an industry survey of
recovery furnace manufacturers regarding time needed for recovery furnace conversions that
included a list of all kraft and soda recovery furnaces valid through December 1994
All HAP emissions data from NCASI's test program received to date compiled into emissions
data base for the project
Preliminary regulatory alternatives developed based on the subcategorization of recovery
furnaces for the source category
Combustion sources data base revised to account for mill-wide and recovery furnace
shutdowns and furnaces installed since the original MACT survey was completed based on an
industry inventory of kraft and soda recovery furnaces
Emissions data received from International Paper Co. compiled and added to emissions data
base for the project
Meeting with industry representatives to discuss the MACT standards under consideration and
the vendor capacity and resource requirements to rebuild/replace recovery furnaces.
Site visit to Federal Paper Board, Augusta, GA
Site visit to S.D. Warren Co., Muskegon, MI
Received and reviewed HC1 study (Technical Bulletin No. 674) conducted by NCASI
Additional mill-specific control costs for MACT floor and beyond-the-floor options submitted
to EPA for impact analysis
Second Work Group meeting to provide technical update
Third Work Group meeting to discuss the preliminary regulatory alternatives, the impacts and
economic analyses of those alternatives, and the EPA recommended regulatory alternative;
examined use of bubble approach to reduce the control costs for particulate control under the
EPA recommended regulatory alternative
Teleconference meeting with OECA on enhanced monitoring
Teleconference meeting with States on issues associated with the bubble approach
Teleconference meeting with OECA on enhanced monitoring protocols
Teleconference meeting with OECA on enhanced monitoring
          A-3

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                           TABLE A-l.    (continued)
Date
                         	Event	
Meeting with industry representatives regarding control options for the Pulp and Paper
NESHAP and the definition of a "clean mill"	
5/22/95
 8/2/95
Meeting with representatives of the Institute of Clean Air Companies to discuss the status of
the NESHAP
2/29/96
Submitted revised mill-specific control costs for new regulatory alternatives to EPA for impact
analysis
2/29/96
Submitted inputs for HC1 risk analysis to EPA to determine applicability of Section 112(d)(4)
of the CAA to HC1 controls for pulp and paper combustion sources
4/12/96
Nationwide environmental impacts inputs submitted to EPA for benefits analysis
6/17/96
Meeting with industry representatives to discuss applicability threshold and PM HAP emisison
limits for new sources		
 7/8/96
Teleconference meeting with OECA on enhanced monitoring
7/26/96
Draft TSD submitted to EPA and industry representatives for review
Teleconference meeting with industry representatives regarding enhanced
approaches	
7/31/96
                                                                          monitoring
          Fourth Work Group meeting to provide update on status of the NESHAP
          NCASI comments on the TSD received
                                            A-4

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                          APPENDIX B.
       EMISSION MEASUREMENT AND CONTINUOUS MONITORING FOR
                PULP AND PAPER COMBUSTION SOURCES
B.1  INTRODUCTION
     Between July 1991 and November 1994, EPA gathered emissions
data from a variety of information sources in support of a NESHAP
for combustion sources in the pulp and paper industry.  Sources
of information included:
     1.  An emissions test program sponsored by NCASI;
     2.  An emissions test program for the Texas Paper Industry
Environmental Committee  (TPIEC);
     3.  An emissions test program sponsored by the International
Paper Company; and
     4.  Selected emissions test reports in state agency
compliance files.
     The industry-sponsored test programs were specifically
designed to provide data to:   (1) determine the mass emission
rates of HAP's from recovery furnaces, BLO units, SDT's, and lime
kilns; and (2) determine control efficiencies of APCD's for
HAP's.
     Emissions testing was performed primarily using manual
methods.  Locations sampled included the inlet and outlet of the
control device(s) where pollution controls were applied, and the
effluent stack where they were not applied.
     This appendix defines the methods used in the test programs
to collect emissions data,  discusses alternatives for monitoring
emissions to indicate continuous compliance with any proposed
                               B-l

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standards, and recommends procedures to demonstrate compliance
with proposed standards.
B.2  MEASUREMENT METHODS USED IN DATA COLLECTION
     This section presents a summary of measurement methods used
to generate emissions data in approximately 29 source test
reports.  The data in these reports were used to support the
development of emissions standards for combustion sources in the
pulp and paper industry.
B.2.1  fi^opp of Test Programs
     The types of samples and data  collected at each test site,
the measurement locations,  and  test methods used are summarized
in Tables B-l through D-a.1"29  Tables B-2 through B-8 summarize
information and data collected  as part of International  Paper
Company's nine-mill emissions test  program.  Table B-l summarizes
information contained in the remaining 20 emission test  reports.
Sample types and  sampling locations are  discussed in Section 2.1.
The  specific test methods used  for  collecting  and analyzing the
samples are discussed in Section  2.2.
     B.2. 1.1 Types of  Samples  and  Data  Collected.  The  samples
collected during  the test programs  were  primarily flue gas
samples before  or after emission  control devices.  Because  a
variety of  source emissions test  reports were  used, a disparity
exists in the number and type  of  pollutants  measured at  each
source .
      The source tests  contained data for the following
pollutants :
      1.  Metals,  including antimony (Sb) ,  arsenic  (As) ,  beryllium
 (Be) ,  cadmium (Cd) ,  cobalt  (Co) ,  chromium (Cr) (total) ,  lead
 (Pb)
 thallium (Tl)
manganese  (Mn), mercury  (Hg),  nickel  (Ni),  selenium  (Se)
          SO.
          H.
     A •
     ,S,  methyl mercaptan, dimethyl sulfide, carbon
 disulfide, sulfuric acid;
      4.  Terpenes, a-terpinol, a,b-pyrene, 3-curene, p-cyrene;
      5.  HC1;
      6.  CO ;
                                B-2

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      7.   NOX;
      8.   Polychlorinated dibenzo-p-dioxins and dibenzofurans
 (PCDD/PCDF);
      9.   Selected organic HAP's,  such as  acrolein,  acetaldehyde,
 acetophenone,  acetone,  methanol,  carbon tetrachloride,
 chloroform,  chlorobenzene,  chloromethane,  bromomethanol,  isobutyl
 ketone, methyl ethyl  ketone,  methylene chloride,  1,2-dichloro-
 methane,  trichlorofluoromethane,  bromodichloromethane,
 formaldehyde,  1,1,1-dichloroethylene,  1,1,2-trichloroethane,
 1,2,4-trichloroethane,  tetrachloroethylene,  styrene,  toluene,
 xylenes,  benzene;  and
      10.  Semivolatile  organics,  such as  acenaphthene, pyrene,
 benzo-a-anthracene, chrysene, benzo-b-fluoroanthene,
 benzo-a-pyrene, dibenzo-a,h-anthracene, benzo-g,h,i-pyrene,
 indeno-1,2,3-pyrene.
      B.2.1.2   Emission  and Process  Sampling Locations.  Flue gas
 stream samples consisted of uncontrolled  gas streams  from BLO
 tanks, SDT's,  and  recovery furnaces,  and  controlled streams from
 ESP outlets and scrubbers  following lime  kilns  and recovery
 furnaces.  Additionally,  one  test report  contained analysis of a
 quench water process  stream.  This  process  stream was analyzed
 for PCDD/PCDF  and metals.
 B.2.2  Sampling and Analytical Methods Used
       Sampling and analysis methods used at each mill are given
 in Tables B-l  and B-2.   The discussion in this  section groups the
 sampling and analytical methods into three  categories:
 (1) organic HAP methods,  (2) metal  HAP methods, and (3) HC1
methods.
     B.2.2.1   Organic HAP Methods.  The methods used to gather
 organic HAP emissions data  included EPA Methods 18 and 23 of 40
 CFR 60 Appendix A; Methods  0010, 0011, and  0030 of SW-846; and
 two methods developed by NCASI.   One of the methods developed by
NCASI and validated by EPA Method 301 made use of a heated summa
 canister source sampling train  (HSCSST) for  collection of the gas
sample for later laboratory analysis by gas  chromatography (GC)
and flame ionization detector (FID)  or mass  selective detector
                               B-3

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(MSD).1/2,30,31  This method is capable of measuring a variety of
organic HAP's.  The HSCSST used a Summa® canister, heated to
130°C,  for collecting gaseous samples.  The system employed for
the analysis of the Summa® canisters was consistent with the
requirements of EPA Method T014, except that the system bypasses
the Nafion® permeation dryer.
     The other method developed by NCASI and validated by EPA
Method 301 made use of a water-filled impinger followed by silica
gel traps for capturing methanol and other water-soluble organics
such as acetaldehyde, acetone, and methyl ethyl ketone.1'32  The
collected samples are later analyzed by GC/FID.   The method is
very similar to EPA's Method 308 for methanol, which is described
in Section 4.4.
     Differences among the methods include the ability to provide
information on multiple pollutants and detection  limits.
Methods 18, 0010, 0030, and the HSCSST provided information on a
greater number of pollutants.  Methods 23  (dioxins), 0011
 (aldehydes) , and 308  (methanol) provided information on a very-
limited number of pollutants.  Detection limits for most of the
methods were generally acceptable.  However, some of the data
gathered using EPA Method 18 did not provide adequate detection
limits because the GC set-up variables were not optimized.
     B.2.2.2  Metal HAP Methods.  At most plants, metal HAP
compounds were collected and analyzed using EPA draft Method 29
 (also known as draft Method  0012 of SW-846, the EPA combined
metals train, or the EPA multimetals  train).  Differences were
noted in  some of the older test reports with respect to blank
correction  procedures and in the treatment  of nondetect data.
These differences were reconciled before  the data were used
further.33'34  The  GARB Method 425 was used at six  plants for
determining hexavalent Cr emissions.16'17'29  At  one plant, EPA
Method  12 and a modified Method 5  train were used to determine  Ni
and Mn, and hexavalent Cr emissions,  respectively.10  At  this
plant,  a  stainless  steel probe was used  instead  of  a  glass  probe.
 For this  reason,   high levels  of  Cr  and Ni were  present  in  the
                                B-4

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blanks.  The Cr and Ni emissions data at this mill were removed
from the NESHAP data pool.
     B.2.2.3  Hydrogen Chloride Methods.  Hydrogen chloride
emissions were determined using EPA Methods 26 and 26A in 40 CFR
Part 60 Appendix A.  The two methods are very similar, except
that in Method 26A the gas sample is collected isokinetically,
whereas in Method 26 a nonisokinetic procedure is used.  Method
26A is preferred at locations downstream of scrubbers where acid-
gas mists are present.
B.3  MONITORING SYSTEMS AND DEVICES
     This section presents the various types of continuous
monitoring systems and monitoring devices, including data
acquisition and data processing systems, readily available on an
"off-the-shelf" basis that could be used to monitor emissions.
The applicability of these systems to the affected facilities or
similar facilities is discussed.  This discussion covers such
factors as the accuracy, precision, repeatability, reliability,
complexity, maintenance, the difficulty of installation and
operation of these systems, and costs (capital and annualized).
Cost estimates include the costs of setting up and operating the
monitoring system, but not the cost of reporting any data
collected.  Performance specifications are provided,  also, if
available.
B.3.1  Opacity Monitoring
     Opacity monitoring equipment has been routinely used to
monitor the opacity of emissions from combustion sources for many
years.  These monitors are comparatively simple and are easy to
install.  They are usually installed in the breeching duct or in
the discharge stack downstream of any particulate control device.
Choice of an appropriate measurement location depends upon
source-specific factors, such as effluent ductwork configuration,
presence of vibration, ease of access to the location, etc.   A
detailed discussion of the accuracy,  precision,  repeatability,
reliability,  and maintenance requirements for these instruments
will not be provided because this monitoring technique is well
established.
                               B-5

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     Estimated initial costs  (purchase,  installation, performance
testing, quality assurance program plan  preparation)  and annual
costs  (operation & maintenance, recordkeeping  and  reporting,
program update, quality assurance) for an  opacity  monitor
installed at a stack  location are $39,600  and  $18,800,
respectively  (all dollar  amounts are  in  1994 dollars).35
     Performance specifications for opacity monitors are
contained in Performance  Specification 1,  Appendix B,  40 CFR
Part 6C.  These requirements  were first  promulgated on October 6,
1975;  substantial revisions were issued  on March 30, 1983.
B.3.2  Hydrogen Chloride  Monitoring
     Emissions monitoring equipment  for  measuring gaseous HC1 is
commercially available; monitoring techniques  include gas filter
correlation (GFC) infrared analyzers, FTIR, ion mobility
spectroscopy  (IMS), ultraviolet  (UV)  spectroscopy, on-line
specific  ion  electrodes  (SIE), and mass  spectrometric techniques.
The mass  spectrometric technique  is  not  included in the
discussion  that  follows  because  of  its high cost.   Detection
limits for  these  instruments  range  from the low part per billion
 (ppb)  range (e.g.,  IMS)  to the low ppm range  (e.g., FTIR).  The
FTIR and  SIE  systems  are fairly complex systems, whereas the GFC
and IMS are not.  All of these systems are comparatively new,
and, therefore,  source-specific installation instructions are not
well developed.   All  systems are prone to difficulties  if
condensed water is  present in the sample delivery lines.  Sample
lines  and other sample delivery components must be  relatively
                 •ri anH should be heated to prevent condensation.
                            • Vio i <~,™ rvr-iTn r-zmap. some HC1 absorption
.nert  to moist I
tor HC1 concentrations in 1
in the sample c
system start up.   However, after an :
                JLCXUJ.WUO -.«. -                 ,
                eliverv system is likely to  occur upon monitoring
                 ii ^ ^ ^fc^^A*4»**^3 W *-* ** V *•—. •— —• — — —	 —             —
                 referred method of moisture removal where
                        iah.  Gas dilution to reduce the moisture
:he  HC1 instrument :
Iryers are' the i
moisture contents are t
:ontent below the dew point of the gas i
lowever, the latter t
spots are present in t
                     padinas should become stable.  Permapure

                       L^^J.1J.L- W A-  U-ii^- 3(-*-l~' *"-*•--——•—• — 	a
                       schnique is not always  successful  if  cold
                       Vio  <3=Tnr>i <= d^liverv  svstem.   The gas
                                  _ c.

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dilution technique will dilute the sample below the HC1
guantitation limit for some of the instrumental methods.
     Limited information can be provided at this time about the
accuracy, precision, repeatability, and reliability of HC1
monitoring systems as applied to gas streams from pulp and paper
mills.  It should be noted that none of the aforementioned
methods were developed for, or have yet been successfully applied
to, measuring HC1 emissions from recovery furnaces at kraft pulp
mills.  However, performance characteristics of GFC monitoring
systems at hazardous waste incineration facilities have been
studied by EPA and have been found to be acceptable.
     The NCASI completed an evaluation of a TECO 15 GFC
monitoring system using the dilution approach for moisture
removal.
        37
Method 26 data were gathered concurrently with the
monitoring data.  The investigators were unable to establish a
good correlation between the GFC monitoring data and the EPA
Method 26 data.  Several factors may have been responsible for
the poor results.  For example, the HC1 content of the gas stream
may have been reduced to levels below the detection limit of the
instrument by the dilution gases.  It is possible to compensate
for the lower gas concentrations by increasing the optical path
length.  However, sufficient details were not provided in the
study to confirm this.  Loss of HC1 in the sampling lines is also
a possibility due to the high moisture contents.  Improved HC1
recoveries may be achieved by using other moisture management
schemes, such as a Nafion® drier at or near the stack.  The
Nafion® drier would remove moisture while the gas stream is still
hot and significantly reduce the potential for water condensation
in the sampling lines.  Furthermore, the use of the Nafion® drier
as an alternative to dilution gases lessens the potential for
reducing the HC1 concentrations below the GFC monitor detection
limits.
     Based on information generated in an EPA study of GFC
monitoring systems, the initial costs (purchase, installation,
performance testing, quality assurance program plan preparation)
and annual costs (operation & maintenance, recordkeeping and
                               B-7

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reporting, program update, quality assurance) for a GFC monitor
installed at a stack location are $144,500 and $68,700,
respectively.35'36  The estimated initial costs and annual costs
associated with an FTIR monitoring system are $162,000 and
$50,000, respectively, and those for an IMS system are
approximately $149,500 and $68,700, respectively.38'39  The SIE
systems have not been costed because their performance
characteristics are not acceptable.
     Performance specifications for HC1 monitoring systems in
stationary sources are contained in Performance Specification 13,
which was proposed on April 19, 1996 along with regulations for
                                   40
hazardous waste combustion systems.
B.3.3  Methanol Monitoring
     Emissions monitoring equipment for measuring vaporous
methanol  is currently commercially available; HAP specific
monitors  include on-line  GC/FID and FTIR.  The methanol
quantitation limit for the GC/FID system  is  2 to 3 ppm.1  If
lower detection limits are needed, an  Entech concentrator can be
used.
     A  GC-based monitoring system, called the hazardous organic •
mass emission  rate  (HOMER) monitor, is another type  of monitoring
system  that combines  EPA Methods 25A and  18  using a  direct
interface.41   A total hydrocarbon  (THC) analyzer provides a.
continuous measurement  of the  THC  concentration, as  propane,  in
an extracted gas  sample.  The  analyzer output  is recorded by  a
personal  computer-based data acquisition  system  (PC/DAS).  A  gas
chromatograph  equipped  with a  FID  is programmed  to  semi-
continuously analyze  the same  gas  sample  stream  every 6 minutes,
with the  GC/FID  results being  recorded by the  PC-DAS.  The HOMER
software  program converts the  continuous  THC signal  to provide  a
continuous  read  out  of  the  speciated VOC  concentrations  (in  this
case, methanol)  in the  gas  stream using  the GC/FID  results.   This
is done by determining  the  relative  response factors  (RRF's)  for
each target VOC  on the  THC analyzer from gaseous standards  of the
 compound at known concentrations.   The GC/FID response determines
 the proportion of each target  VOC in the gas stream. The EPA
                                B-8

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                               41
recently sponsored a demonstration study of this monitoring
system and showed that the HOMER monitor is a viable way to
provide continuous information on speciated organic compounds.'
     For emission sources where the correlation between methanol
emissions and THC emissions can be established, continuous on-
line FID monitors are readily available as surrogate monitors.
     Current technical data indicate that the above monitoring
systems are applicable for monitoring methanol emissions from
SDT's and recovery furnace vents, as well as other pulp and paper
vent streams.1'2  Although no long-term continuous monitoring
data are available, sufficient short-term integrated data have
been gathered to establish that both the GC/FID system and the
FTIR system can successfully measure methanol emissions from the
above sources.1'2'42  Data were recently submitted to EPA to
demonstrate that the techniques can meet EPA Method 301
criteria.30'31'42  It should be noted that none of the monitoring
systems suggested for continuous monitoring of methanol emissions
have been used for long-term monitoring of combustion sources at
kraft or soda pulp mills.  Therefore, long-term studies are
required to determine the accuracy, precision, repeatability, and
costs of setting up and operating the monitoring systems.
     The initial costs (purchase, installation, performance
testing, quality assurance program plan preparation) and annual
costs (operation & maintenance, recordkeeping and reporting,
program update, quality assurance) for a HOMER monitoring system
installed at a stack location are $135,300 and $64,500,
respectively.39  The estimated costs associated with an THC
monitoring system would be approximately $115,300 and $59,800,
respectively,33  The estimated costs associated with a FTIR
monitoring system would be approximately $162,000 and $50,000,
respectively.39
     Performance specification 8A for THC systems can be found in
the background information document which supports proposed
regulations for hazardous waste combustion systems.43  Additional
performance specifications for THC systems and GC systems were
proposed on October 22,  1993 in 58 FR 54648.44  The FTIR sampling
B-9

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and analysis protocols for measuring gaseous organic compounds,
such as methanol, can be found in EPA Method 318.45'46
B.3.4  Parametric Monitoring Systems
     Scrubber performance is easily monitored with off-the-shelf
monitoring equipment for pH and liquid flow rate.  There are
various techniques for measuring liquid flow rate in a wet
scrubber including ultra sonic detection mounted externally on
the inflowing water pipe and turbine devices that are mounted
within the pipe, both of which generate an electrical signal that
can be logically displayed in a control room.38  For liquid
streams containing less than 1 percent solids, a paddle wheel
sensor can be used to measure the flow rate.  If the solids
content of the  liquid flow stream is greater than 1 percent, an
insertion type  of sensor must be used to determine flow rate.
     The cost of the liquid flow rate monitoring equipment  can
vary from $2,000 to $25,000 depending on the device sensitivity
and device location from the control room.35  A  complete paddle
wheel flowrate  monitoring system will cost approximately
$1,200.38  The  initial  cost of  a flow rate monitoring  system with
an insertion type sensor is approximately $3,750.38  The  initial
cost for a pH monitoring system is  estimated to  be  $5,000.
B.4  PERFORMANCE TEST METHODS
     The following  subsections  discuss  the  test  methods
 recommended for measuring emissions of particulates,
 Dpacity,  methanol,  and HC1.
                              TTK-! n  A^ omioa-i on  (
                                                     netal  HAP's,
         H^ l^Jtid*,LV^*i» /  t**.XA^A J.AX-*.*- •    • ••—.».  —	— —— —
         >rocedures and  analytical  techniques.   Costs  to conduct
 sampling ]
 Derformance testing using
                                -
                                        -
 rhese costs :
              nclude nreoaration of the final test report.

       «7here alternate test methods or procedures
:ases '
evaluated,  comments  are ]
lata obtained by the c

                          rovided on the relationships between the
                                                   r _ ._ i_ «. u»« 4— ti —% 4—
 :he proposed reference methods.  As appropriate,
 :ould prevent the use of the reference methods to determine
 :ompliance are identified.
                                i_ T n

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B.4.1  Particulate Matter and Metal HAP Emissions
     Emissions of HAP metals and PM can be measured
simultaneously using EPA Method 29.47/48  Because of potential
losses of Hg during sample desiccation, it is recommended that PM
and Hg not be measured simultaneously.  If these two species must
both be measured, one of the two following options should be
used:
     1.  Method 549 or Method 1749 for PM and Method 2948 for Hg
and other trace metals of interest, or
     2.  Method 101A48 for Hg and Method 2948 for PM and other
trace metals of interest.
     Method 3, using the integrated sampling techniques, or
Method 3A are recommended for measuring 02 and C02.49  The
concentrations of these gases are necessary for correcting the
particulate matter emission rate to a standard basis.
     The sampling and analytical cost for three Method 5 runs
with associated Method 3 testing is estimated to be $8,500 (all
dollar amounts are expressed in 1994 dollars),47  Method 17 may
be used as an alternative to Method 5 if a constant value of
0.009 g/dscm  (0.004 gr/dscf) is added to the results of Method 17
and the stack temperature is no greater than 205°C (400°F).49  No
sampling and analytical cost is available for Method 17 test
runs.  If a three-run Method 29 test for all trace metals and Hg
is run in conjuction with a Method 5 test for PM,  the additional
cost of the Method 29 test would be approximately $8,750.47  The
estimated cost for three Method 29 runs for PM and trace metals
with associated Method 3 testing is $12,000.47  The additional
cost for three Method 101A runs in conjunction with PM/metals
testing is estimated at $5,500.47
B.4.2  Opacity
     Method 9 should be used to determine the opacity of
emissions.49  The estimated cost for conducting three Method 9
observations in conjunction with PM emissions testing is
$1,060.47
                              B-ll

-------
B.4.3  Hydrogen Chloride Emissions
     Methods 26 or 26A should be used to determine the HC1
emissions.49  If the measurement point is downstream of a wet
scrubber, Method 26A must be used.  The estimated cost to conduct
a three-run performance test using Method 26 or 26A is $9,100.
However, if the Method 26A test is run in conjunction with a
Method 5 test, the additional cost for the Method 26A test would
be approximately $600  (above the cost of a Method 5 test) for
analyzing the HC1 impingers after the PM filters.50
B.4.4  Methanol Emissions
     Method 308 or the Methanol Sampling Train  (MST) should be
used to determine methanol emissions.32'51  The Method 308
sampling train consists of an unheated Teflon® line, two
30-milliliter  (mL) water-filled midget impingers in an ice bath,
and one glass adsorbent tube packed in two sections containing
520 milligrams  (mg) and 260 mg of silica gel, respectively.  The
gas sample is nonisokinetically extracted from the sampling point
in the stack, and methanol is collected in deionized distilled
water and adsorbed on  silica gel.  The sample is returned to the
laboratory, where the methanol in the water fraction is separated
from other organic compounds with a GC and is then measured by an
FID.  The fraction adsorbed on the silica gel is extracted with
an aqueous solution of n-propanol and is then separated and
measured by GC/FID.  The analytical limit of guantitation  (LOQ)
in the water  impinger  samples is  0.50 nanograms  (ng)  (equivalent
to about 0.5  ppm methanol in a 20-liter  (L) sample of source
gas).  The overall LOQ for the method is 1.6 ppm of methanol for
a 20-L sample of source gas.51
     The MST  consists  of a glass-lined heated probe, two
condensate knockout traps in an  ice bath, and three sorbent
cartridges packed with Anasorb®  747.  A 1:1 mixture of carbon
disulfide  (CS2) and N,N-dimethylformamide  (DMF) is used  to desorb
methanol from the Anasorb® samples.  The condensate traps also
collect  a significant  amount of  methanol, if water  is present.
Condensate and desorption samples are analyzed  by GC/FID.  The
analytical LOQ in the  CS2/DMF samples is 0.69 ng  (equivalent  to
                               B-12

-------
about 0.5 ppm methanol in a 20-L sample of source gas).   The
overall LOQ for the MST is 3 ppm of methanol for a 20-L sample of
source gas.51
     The estimated cost to conduct a three-run performance test
using Method 308 in conjunction with other"performance testing is
$9,500.35  A three-run performance test using the MST in
conjunction with other performance testing should cost about
$9,500 and offers the additional advantage that other chemical
compounds can be measured simultaneously using the same sampling
train, if desired.5   Compounds in the emission matrix can be
identified by mass spectral library matching if the desorbed
samples are analyzed on a GC equipped with an MSD and appropriate
computer software.
                              B-13

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Test run-averace oneratine conditions:


^t "n^
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Recovery firing rate:
1.62 million Ib BLS/day
Scrubber makeup flow rate: N/A
No. 2 tank:
Recovery firing rate:
2.89 million Ib BLS/day
Scrubber makeup flow rate:
377 gal/min






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capacity: 250,000 Ib/hr. PM emissions co
Flakt electrostatic precipitator (maximum o
0.023 gr/dscf; inlet loading: 10 gr/dscf; ma
opacity: 10% © 182,000 ACFM; specific (
area = 28 ft2 CA/KACFM; gas velocity ••
ft/sec; treatment time = 1 1 .82 seconds). C
gas exhausted to atmosphere through radial
height = 249;', internal diameter = 7' - 1<
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Two sources tested for same pollutants: •
1) Babcock & Wilcox NDCE Recovery F
bottom ESP, firing rate = 5,4 million poi
BLS/day. BL at 73 % solids is fed to pro
tank, then to furnace.
Representative operating parameters:


1 .. ,
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BLS Production: 3600 Ib BLS/ODTP
Liquor sulfidity: 25%-30%
Soda and sulfur makeup:
Saltcake from R8 C1O2 generator, added
mix tank
No. of liquor guns: 4
Auxiliary fuel: Natural gas or No. 1 fuel
Combustion air: 4 levels of combustion ai
BLS firing rate: 237,000 Ib BLS/hr
BL temp: 252°F
ESPO,: 1.5 %
Stack TRS: Ippm








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2) Lime kiln; can use either natural gas o
receives NCG's; PM emissions controlled
chamber, 3-field ESP followed by wet sci
8% caustic for SO2 removal.
Test run-specific operating parameters (a\


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Kiln throughput: 553 tons CaO/day
Cold end temp: 1210"F
Hot end temp: 2535°F
Exit TRS concentration: 3.9 ppm
Exit VOC concentration: 8.7 ppm
Exit SO2 concentration: 56 ppm







                                  B-29

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1) No. 2 recovery furnace, DCE (cyclone) with
bottom ESP; BLS firing rate: = 1 .6 million Ib B
BLS content = 65%.
Test run-specific operating parameters (average):
L*

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Stack temperature: 351°F
Stack flow rate: 99,255 DCFM
02 concentration: 8.4%
2) No. 3 recovery furnace, NDCE with dry-bott
ESP; BLS firing rate =4.65 million Ib BLS/d;
BLS content = 65%.
Test run-specific operatinE parameters (average)












































Stack temperature: 356°F
Stack flow rate: 175,414 DCFM
O9 concentration: 9.2%









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Test run-specific operating parameters (average)

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Pulp production: 858 tons/d
BL firing rate: 106 gal/min
BL solids concentration: 70%
Stack temperature: 262° F
02 concentration: 6%
Stack gas flow: 51,000 dscfm
Average total PM emissions: 0.0069 gr/dscf




CO
                                             B-30

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mud clarifierj foul condensate from evaporatoi
steam stripped, and gases from steam stripper
the kiln; all other NCG's burned in NCG ther
oxidizer. Kiln design firing rate: 400 tons Ca
PM emissions from kiln are controlled with at
Ooeratine conditions durine samnlinc (average

fr 1
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3-05/15/93
2 ^
IMoss Point Mill,
Test dates: 04/28











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3-07/23/93
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Test dates: 07/09






























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B-35

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                                     B-42

-------
      TABLE B-4.  METALS ANALYZED BY EPA METHOD 29 IN TESTING AT
                      INTERNATIONAL PAPER MILLSa
Metals
Antimony
Arsenic
Beryl lium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury-
Nickel
Selenium
Silver
Millsb
Moss Paint
and Mobile
/
S
S
S
s
s

s
s
s
s
s

Pine Bluff
/
/
/
/
^
^
/
/

^
/
/
/
Georgetown
/
/
/
/
^
/

/
/
/
/
S

Natchez
/
S
S
s
s
s
s
s

s
s
s

aThe same metals were analyzed for in all samples at a particular
 mill, regardless of the process unit.
bNo metals testing was conducted at the Androscoggin, Erie, and
 Riversdale Mills.  At Ticonderoga, the metals compounds were not
 identified.
                                 B-43

-------
TABLE B-5.
VOLATILE ORGANIC COMPOUNDS SPECIATED BY METHOD 18 IN
  TESTING AT INTERNATIONAL PAPER MILLS5




Ac«on«Mcrolemb





Chlorobenzene



Cumene
1,2-Dichlorethane
1 ,2-DichloroethyIene
Dimethyl disulfide
Dimethyl sulfide
Ethano!
Ethyl benzene
Ethyl benzene/
m.p-cresor
Hexichlorocyelopentadiene
Hexachloroethane
Hexachloroethane/
m,p-cresolb
n-Hextne
Isopropyl alcohol
Isopropyl alcohol/acrolein
Methano!
Melhanol/acetaldehyde
Methly chloroform
Melhylene chloride
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl mercaptan
Napthalene/a-terpineol"
Phenol
a-Pinene
b-Pinene
a-Terpineol
Mills

/
/

/

/
s
s
s
s

s
s
s
s
s
s
s
s

s

s
s
s

s

s
s
s
s
s
s
s




s
s

s
s
s
s

s
s

s
s


s
s
s
s



s
s
s

s

s
s
s
s
s
s
s



Erie
/
/

s
s
s
s

s
s

s
s


s
s
s
s



s
s
s

s

s
s
/
s
s
s
s



Pine Bluff
and Natchez


/
/

/
/

/
/

^



/
/
/

/
/
/

/

/

/
/
/
/
/
/
/




Georgetown


/
s

s
s

s
s

s
s


s
s
s

s
s
s

s

s

s
s
s
s
s
s
s
s
s
s

Ticonderoga

/

/
/
/
/

/
/
/
/

/
s
s
/

/

/
/

s
s

s

s
s
s
s
s

s
/
s
s

Mobile

/

/
s
s
s


s

s
s


s
/
/
/



/
s
s

s

s
s
s
s
s
s
s




Rjverdale
/
/

/
s
s
s

/
/

/
J


s
s
s
s




s
s

s

s
s
s
s
s

/



                               B-44

-------
                                       TABLE B-5.   (continued)
Volatile organic compounds
Tetpenes
Toluene
Trichlorobenzene
1 , 1 ,2-trichloroethane
Trichloroethylene
m,p-Xy!ene
o-Xylene
Mills
Moss Point
/
/
/
/
/
/
/
Androscoggin
s
s

s
s
s
s
Erie
/
s

s
s
s
s
Pine Bluff
tnd Natchez
/
s

s
s
s
s
Georgetown

/

/
/
S
s
Ticonderoga

^
S
s

s
s
Mobile
/
/

/
/
/
/
Riverdale
/
/

S
s
s
s
"All samples analyzed by Method 18 at a particular mill were analyzed for the same compounds, regardless of the process unit from which the sample*
 were collected.
''Compounds listed together were coelutants.
                                                     B-45

-------
TABLE B-6.  VOLATILE ORGANIC COMPOUNDS SPECIATED BY LIQUID
       INJECTION TESTING AT INTERNATIONAL PAPER MILLS

Volatile organic
compounds
Total VOC
Total chlorine

Acetaldehyde
Acetone
Acetone/Acrolein"
Acctophcnone
Acrolein
Benzene
Carbon tetrachloride
Carbon tetrachloride/
benzene'5
Catechol
Catfichol/Naphthaleneb
Chlorobenzene
Chlorofonn
Chloroform/n-Hexane"
m,p-Cresol
o-Cresol
Cumene
Cumene/a-terpineol
1 ,2-Dichloroethane
1 ,2-Dichloroethylene
Dimethyl disulfide
Dimethyl sulfide
Ethanol
Ethyl benzene
Ethyl benzene/
m,p-Cresolb
Hexachlorocyclo-
Hexachloroe thane
Hexachloroethane/
m,p-Cresolb
n-Hexane
Isopropyl alcohol
Mills8
Moss Point



/
/

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/

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/
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/
/
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/
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/
/

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/
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/
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/
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/
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/
/
/


/
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/

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s
s
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/
/

/"
/
/
/



/
/


/

/


/
/
/
/

/

/
/
/
                            B-46

-------
                                    TABLE  B-6.   (continued)
Volatile organic
compounds
Isopropyl alcohol/
Acrolein"
Methanol
Methanol/
Acetaldehyde"
Methyl chloroform
Methylene chloride
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl mercaptan
Naphthalene
Naphthalene/
a-Terpineolb
Phenol
a-Pinene
b-Pinene
a-Terpineol
Terpenes
Toluene
Trichlorobenzene
1 , 1 ,2-Trichloroeihane
Trichloroethylene
m,p-Xylene
o-Xylene
Mills*
Moss Point

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Georgetown
Recovery
furnace &
lime kiln
No. 1





















Smelt
dissolving
tank&
limekiln
No. 2




^
/
/



/
/
/
^


/
/

/
/
Ticonderoga
Smelt
dissolving
tank




/
/
/



/
/
/
/


/
^

/
/
Lime kiln






















Riverdale

/

/
/
/
/
/

/
/



/
/

/
/
/
/
aNo liquid samples were collected from the recovery furnaces, lime kilns, smelt disolving tanks, or black liquor oxidation tanks at the
 Mobile and Erie Mills.
''Compounds listed together were coelutants.
                                                   B-47

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    TABLE B-7.  ALDEHYDE AND KETONE COMPOUNDS ANALYZED BY RTI DNPH
          . PROCEDURE IN TESTING AT INTERNATIONAL PAPER MILLS
Aldehydes and ketones
Acetaldehyde
Acetone
Acetophenone
Acrolein
Benzaldehyde
Crotonaldehyde
Cyclohexanone
Formaldehyde
Methyl ethyl ketone
Methyl isobutyl ketone
Pentanal
Propionaldehyde
Millsa
Moss Point, Pine Bluff,
Natchez, and Mobile
/
/
/
S
/
^
/
/
^
/
/
/
Georgetown
/
/
/
^
/


/
^
S

S
aNo aldehyde and ketone testing was conducted at the Androscoggin,
 Erie, and Riverdale Mills.  The aldehyde and ketone compounds
 analyzed by this method at the Ticonderoga Mill were not identified.
                                 B-48

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   TABLE  B-8.
DIOXIN AND FURAN COMPOUNDS ANALYZED BY METHOD  23 AT
       INTERNATIONAL PAPER MILLSa
                2378
               12378
              123478
              123678
              123789
             1234678
                2378
               12378
               23478
              123478
              123678
              234678
              123789
             1234678
             1234789
       Tetrachlorodibenzo-p-dioxin
       Pentachlorodibenzo-p-dioxin
       Hexachlorodibenzo-p-dioxin
       Hexachlorodibenzo-p-dioxin
       Hexachlorodibenzo-p-dioxin
       Heptachlorodibenzo-p-dioxin
       Octachlorodibenzo-p-dioxin
 (TCDD)
 (PeCDD)
(HxCDD)
(HxCDD)
(HxCDD}
 (HpCDD)
(OCDD)
       Tetrachlorodibenzofuran  (TCDF)
       Pentachlorodibenzofuran  (PeCDF)
       Pentachlorodibenzofuran  (PeCDF)
       Hexachlorodibenzofuran  (HxCDF)
       Hexachlorodibenzofuran  (HxCDF)
       Hexachlorodibenzofuran  (HxCDF)
       Hexachlorodibenzofuran  (HxCDF)
       Heptachlorodibenzofuran  (HpCDF)
       Heptachlorodibenzofuran  (HpCDF)
       Octachlorodibenzofuran  (OCDF)
              Total
              Total
              Total
              Total
              Total
              Total
              Total
              Total
     Tetrachlorodibenzo-p-dioxins (TCDD)
     Pentachlorodibenzo-p-dioxins (PeCDD)
     Hexachlorodibenzo-p-dioxins (HxCDD)
     Heptachlorodibenzo-p-dioxins (HpCDD)
     Tetrachlorodibenzofurans (TCDF)
     Pentachlorodibenzofurans (PeCDF)
     Hexachlorodibenzofurans (HxCDF)
     Heptachlorodibenzofurans (HpCDF)
aThis is a list of congeners from the analysis at the Georgetown Mill.
 At Ticonderoga,  the  congeners  were not identified.
                                 B-49

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B.5  REFERENCES FOR APPENDIX B

 1.  Roy F. Western, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill C.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement, Inc.  Revised
     Draft Final.  October 11, 1993.  Volume 1, Section 4.6.

 2.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill H.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement, Inc.  Draft
     Final.  December  8,  1993.  Volume 1, Sections 4.4-4.6.

 3.  Roy F. Weston, Inc.  Texas Emissions Speciation Study
     Emission Test Results: Champion International Corp., Lufkin,
     Texas.  Prepared  for Texas Paper Industry Environmental
     Committee.  Report No. 06848-001-001.  January 1993.
     Volume 2.

 4.  Roy F. Weston, Inc.  Texas Emissions Speciation Study
     Emission Test Results: Champion International Corp.,
     Sheldon, Texas.   Prepared for Texas Paper Industry
     Environmental Committee.  Report No. 06848-001-001.
     January 1993.  Volume 3.

 5.  Roy F. Weston, Inc.  Texas Emissions Speciation Study
     Emission Test Results: Inland-Orange, Orange, Texas._
     Prepared for Texas Paper Industry Environmental Committee.
     Report No.  06848-001-001.  January 1993.  Volume 4.

 6.  Roy F. Weston, Inc.  Texas Emissions Speciation Study
     Emission Test Results: Simpson-Pasadena, Pasadena, Texas.
     Prepared for Texas Paper Industry Environmental Committee.
     Report No.  06848-001-001.  January 1993.  Volume 5.

 7.  Roy F. Weston, Inc.  Texas Emissions Speciation Study
     Emission Test Results: Temple-Inland, Inland, Texas._
     Prepared for Texas Paper Industry Environmental Committee.
     Report No.  06848-001-001.  January 1993.  Volume 6. .

 8.  Roy F. Weston, Inc.  Hazardous Air Pollutant  Emission
     Inventory  for Mill G.  Prepared for National  Council of the
     Paper Industry for Air and Stream Improvement, Inc.  Draft
     Final.  May 20,  1994.  Volume  1, Section 4.7.

 9.  Roy F. Weston, Inc.  Hazardous Air Pollutant  Emission
     Inventory  for Mill D.  Prepared for National  Council of the
     Paper Industry for Air and Stream Improvement, Inc.  Draft
     Final.  December 13, 1993.   Volume 1, Sections 4.4  and 4.6.
                               B-50

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10.  Letter and attachments from Hershey,  R.,  Potlatch Corp.,  to
     Thorvig,  L., Minnesota Pollution Control  Agency.  July 28,
     1989.  Transmittal of a copy of Interpoll Laboratories
     Report No. 9-2757 containing the results  of the April 1989
     emissions test on the No. 8 recovery furnace at Potlatch
     Corp.'s Cloquet, Minnesota mill.

11.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill J.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement,  Inc.  Draft
     Final.  December 30, 1993.  Volume 1, Section 4.2.

12.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill K.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement,  Inc.  Draft
     Final.  April 19, 1994.  Volume 1, Section 4.3.

13.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill L.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement,  Inc.  Draft
     Final.  March 17, 1994.  Volume 1, Section 4.8.

14.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill M.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement,  Inc.  Draft
     Final.  May 25, 1994.  Volume 1, Section 4.2.

15.  Letter and attachments from McGaughey, J.,  Radian
     Corporation, to Pearson, J., Federal Paper Board Company,
     Inc.  June 11, 1991.  Transmittal of HC1  emissions test data
     for the May 1991 emissions test of the Nos. 2 and 3 recovery
     furnaces at Federal Paper Board's Augusta,  Georgia mill.

16.  Letter and attachments from Reitter,  A.,  Consolidated
     Papers, Inc., to Telander, J., EPA/ISB.  June 22, 1993.
     Transmittal of Interpoll Laboratories Report No. 1-3472E
     containing the results of the December 1991 emissions tests
     on the Nos. P2 and P3 power and Rl recovery boiler stacks at
     the Consolidated Paper Kraft Plant in Wisconsin Rapids,
     Wisconsin.

17.  Letter and attachment from Reimer, D., Boise Cascade Paper,
     to Telander, J., EPA/ISB.  June 13, 1993.  Transmittal of
     Source Test Report: Boise Cascade Paper,  International
     Falls, Minnesota, Recovery Boiler Noncriteria Pollutant
     Tests, February 5-9, 1991, Volume II.

18.  Roy F. Weston, Inc.  Hazardous Air Pollutant Emission
     Inventory for Mill N.  Prepared for National Council of the
     Paper Industry for Air and Stream Improvement,  Inc.  Draft
     Final.  April 26, 1994.  Volume 1, Section 4.2.
                               B-51

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19
Letter and attachments from Morse, T.,  Westvaco Bleached
Board Division to Telander, J., EPA/ISB. September 22, 1993.
Transmittal of the complete emissions test report from the
February 1990 methanol emissions test and the emission test
summaries from the April 1990 to April 1993 methanol
emissions tests for the Nos. 1 and 2 recovery furnaces, the
Nos. 1 and 2 SDT's, the BLO unit, and the lime kiln at
Westvaco's Covington, Virginia mill.
20,
21.
22
23
24,
25
26
27
28,
Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Mississippi.  September 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Mill.  Jay, Maine.  November 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Pennsylvania.  December 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Arkansas.  July 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Carolina.  July 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
York.  April 1993.

Roy F. Weston, Inc.  Hazardous Air
Study.  Prepared for International
Selma, Alabama.  December 1993.
Pollutant Emissions
Paper.  Moss Point,


Pollutant Emissions
Paper.  Androscoggin


Pollutant Emissions
Paper.  Erie,


Pollutant Emissions
Paper.  Pine Bluff,


Pollutant Emissions
Paper.  Georgetown, South


Pollutant Emissions
Paper.  Ticonderoga, New


Pollutant Emissions
Paper.  Riverdale Mill.
Roy F. Weston, Inc.  Hazardous Air Pollutant Emissions
Study.  Prepared for International Paper.  Natchez,
Mississippi.  September 1993.

Roy F. Weston, Inc.  Hazardous Air Pollutant Emissions
Study.  Prepared for International Paper.  Mobile, Alabama.
September 1993.
                               B-52

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29.  Air Toxics Emission Inventory Report, California Kraft Pulp
     Mills.  Prepared for California Air Resources Board.
     Sacramento, California.  Undated.  Appendix B:  Pooled Air
     Toxics Source Test Program for Kraft Pulp Mills.  The
     appendix contains the November 14, 1990 emissions test
     report for Gaylord Container Corp., Antioch, California; the
     November 27, 1990 emissions test report for Simpson Paper
     Company, Anderson, California; the December 10, 1990
     emissions test report for Simpson Paper Company, Fairhaven,
     California; and the December 13, 1990 emissions test report
     for Louisiana Pacific Corp., Samoa, California.

30.  Roy F. Weston, Inc.  Field Evaluation of the Heated Summa®
     Canister Source Sampling Train.  Recovery Furnace, Mill D.
     Prepared for the National Council of the Paper Industry for
     Air and Stream Improvement, Inc.  July 1993.

31.  Roy F. Weston, Inc.  Field Evaluation of the Heated Summa®
     Canister Source Sampling Train.  Smelt Dissolving Tank Vent,
     Mill C.  Prepared for the National Council of the Paper
     Industry for Air and Stream Improvement, Inc.  July 1993.

32.  Environmental Protection Agency. Test Methods, Proposed
     Method 308.  Code of Federal Regulations.  Title 40, Chapter
     I, Subchapter C, Part 63, Appendix A (draft).  December 17,
     1993.

33.  Memorandum from Harris, V., MRI, to the project file.
     July 15, 1996.  Revisions to Champion Sheldon and Champion
     Lufkin Metals Emissions Data.

34.  Memorandum from Harris, V., MRI, to the project file.
     May 16, 1996.  Review Findings of Metals Blank Data.

35.  Memorandum from Toney, M.,  EPA/EMB, to Telander, J. ,
     EPA/ISB.  November 24, 1993.  Enhanced Monitoring for Pulp
     and Paper Combustion Sources.

36.  Shanklin, S., L. Cone., and S. Steinsberger, Entropy
     Environmentalists, Inc.  Report: Evaluation of HC1
     Measurement Techniques at a Hazardous Waste Incinerator.
     Prepared for the U. S. Environmental Protection Agency,
     Research Triangle Park.  EPA Contract No. 68-02-4442.
     EPA/ORD/AREAL.  Undated.

37.  Someshwar, A., A Study of Kraft Recovery Furnace
     Hydrochloric Acid Emissions.  National Council of the Paper
     Industry for Air and Stream Improvement, Inc.  New York.
     Technical Bulletin No. 674.  August 1994.  pp. 11-13.

38.  Memorandum from Toney, M.,  EPA/EMC, to Telander, J.
     EPA/MICG.  January 13, 1995.  Costs of Enhanced Monitoring
     for Pulp and Paper Combustion Sources.
                               B-53

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39.  HAP GEMS Data Base, Emission Measurement Technical
     Information Center Bulletin Board, Office of Air Quality
     Planning and Standards Technology Transfer Network,
     U. S. Environmental Protection Agency, Research Triangle
     Park, North Carolina.

40.  U. S. Environmental Protection Agency.  Proposed Revisions
     to Federal Regulations for Hazardous Waste Combustion
     Devices.  Code of Federal Regulations.  Title 40, Chapter I,
     Subchapter C, Part 264/265, Subpart O and Part 266,
     Subpart H.  April 19, 1996.

41.  Steinsberger, S., W. Buynitzky, W. DeWees, J. Knoll,
     M. Midgett, and M. Hartman, U. S. EPA Evaluation of
     Hazardous Organic Mass Emission Rate  (HOMER) System for
     Measurement of Hazardous Organic NESHAP Emissions.
     Submitted for presentation at the 86th Annual meeting of the
     Air and Waste Management Association.  Unpresented'.
     June 1993.

42.  Leavy, J., Analytical Sciences.  Hazardous Air Pollutant
     Testing at Natchez Mill by Merlab.  International Paper
     Technical Service Report No. 93.558T.  Program/Project
     No. 3271-14.  June 16, 1993.

43.  Draft Technical Support Document for HWC MACT Standards.
     Volume IV: Compliance with the Proposed MACT Standards.
     Appendix G.  Performance Specification 8A--Performance
     Specification for Total Hydrocarbon CEMS.  U. S.
     Environmental Protection Agency.  Office of Solid Waste and
     Emergency Response.  February 1996.

44.  U.S. Environmental Protection Agency.  Test Methods,
     Proposed Performance Specifications 101 and 102.  Code of
     Federal Regulations.  Title 40, Chapter C, Proposed Part 64,
     Appendix A.  October 22, 1993.

45.  U.S. Environmental Protection Agency.  Test Methods,
     Proposed Method 318.  Measurement of Gaseous Formaldehyde,
     Phenol, and Methanol Emissions by FTIR Spectroscopy.  Code
     of Federal Regulations.  Title 40, Chapter C, Part 63,
     Appendix A  (draft).  February 3, 1995.

46.  U.S. Environmental Protection Agency.  Test Methods, EPA
     Protocol for the Use of Extractive Fourier Transform
     Infrared  (FTIR) Spectrometry in Analyses of Gaseous
     Emissions from Stationary Industrial Sources.  Code of
     Federal Regulations.  Title 40, Chapter C, Part  63, Appendix
     A (draft).  February 3, 1995.
                               B-54

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47
48
49
50,
51.
52
Memorandum from Segall,  R.,  EPA/EMB,  to  Copland,  R.,
EPA/SDB.   October 14,  1992.   Final  Report  on Emission
Measurement and Continuous Monitoring for  Medical Waste
Incinerator Study.

U.S.  Environmental Protection Agency.  Test  Methods,  Method
29.   Code  of Federal  Regulations.   Title 40,  Chapter I,
Subchapter C,  Part 60,  Appendix A.  April  25,  1996.

U.  S.  Environmental Protection Agency. Test  Methods.   Code
of  Federal Regulations.   Title 40,  Chapter I,  Subchapter C,
Part  60, Appendix A.   July 1, 1993.

Telecon.   Harris, V.,  MRI-NCO, with Hosenfeld,  J., MRI-KCO.
May 26,  1995.   Costs  of EPA Method 26 stack  tests.

Peterson,  M.,  B. Pate,  E. Rickman,  R. Jayanty,  F. Wilshire,
and J.  Knoll.   Validation of a Test Method for the
Measurement of Methanol Emissions from Stationary Sources.
•Journal of the Air and Waste Management  Association
 (Pittsburgh).   45:3-11.   January 1995.

Telecon.   Harris, V.,  MRI,  with Peterson,  M.,  Research
Triangle Institute.  May 24, 1995.   Costs  of Methanol
Sampling Train  (MST).
                               B-55

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                                   TECHNICAL REPORT DATA
                              (Please read Instructions on reverse before completing)
 1. REPORT NO.
   EPA-453/R-96-012
                                                                 3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
   Technical Support Document:  Chemical Recovery Combustion
 Sources at Kraft and Soda Pulp Mills
                                       5. REPORT DATE
                                          October 1996
                                                                 6. PERFORMING ORGANIZATION CODE
 7. AUTHOR(S)
                                                                 8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS

   Office of Air Quality Planning and Standards
   U. S. Environmental  Protection Agency
   Research Triangle Park, NC 27711
                                                                  10. PROGRAM ELEMENT NO.
                                       11. CONTRACT/GRANT NO.

                                          68-D1-0115
 12. SPONSORING AGENCY NAME AND ADDRESS

   Office of Air and Radiation
   U. S. Environmental Protection Agency
   Washington, D.C.  20460
                                        13. TYPE OF REPORT AND PERIOD COVERED

                                          Interim Final (1991-1996)
                                        14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
 National emission standards for hazardous air pollutants (NESHAP) are being proposed for the pulp and
 paper industry under authority of Section 112(d) of the Clean Air Act as amended in 1990.  This
 technical support document provides technical data and information such as industry and equipment
 descriptions, analyses of effectiveness and costs of emission control systems, and estimates of
 environmental impacts of emission control options,  that were used in the development of the proposed
 NESHAP for chemical recovery combustion sources at kraft and soda pulp mills.  A NESHAP for
 noncombustion sources in the pulp and paper industry is being developed concurrently,  and information
 on these sources is contained in separate documents.	
 17.
                                     KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                 b. IDENTIFIERS/OPEN ENDED TERMS
                                                          c. COSATI Field/Group
 black liquor
 black liquor oxidation
 chemical recovery
 combustion scarce
 hazardous air pollutants
 kraft pulp mill
lime kiln
particulate matter
recovery furnace
smelt dissolving tank
soda pulp mill
NESHAP
air pollution control
pulp and paper mills
 18. DISTRIBUTION STATEMENT

    Unlimited
                       19. SECURITY CLASS (Report)
                         Unclassified
                                  21. NO. OF PAGES
                                    471
                                                 20. SECURITY CLASS (Page)
                                                   Unclassified
                                                                                    22. PRICE
EPA Form 2220-1 (Rev. 4-77)
                         PREVIOUS EDITION IS OBSOLETE

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