Pulp And Paper NESHAP Plain English Description

A Plain English Description
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Disclaimer
J" This document was furnished to the U.S. Environmental Protection Agency by Eastern Research
Group, Inc. This document is final and has been reviewed and approved for publication. The
^ opinions, findings, and conclusions are those of the authors and not necessarily those of the
U.S. Environmental Protection Agency.

When using this document, remember that it is not legally binding and does not replace the
National Emission Standard for Hazardous Air Pollutants (NESHAP)for Source Category:
7*""" Pulp and Paper Production (April 15, 1998, 63 FR 18504) for purposes of application of the rule
^. -,' to any specific mill.

^ This document is not intended, nor can it be relied upon, to create any rights enforceable by any
„-> party in litigation with the United States. The EPA may change this document at any time
Zf- without public notice.

&
<-_; Amendments to the Cluster Rule are being drafted and will be posted on the Technology Transfer
~* Network (TTN) at www.epa.gov/ttn/uatw/pulp/pulppg.html. You should periodically check
<=^> this website for amendments and/or other relevant information.
11
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Chapter 1 -
Introduction
Chapter 2 -
Description of
the Pulping and
Bleaching
Processes
Contents
Page
1.1 What does this document do? 1

1.2 Why do I need this document? 2

1.3 How should I use this document? 3

1.4 What are the Pulp and Paper "Cluster Rules"? 4

Figure 1. Types of Mills Covered Under the Cluster
Rules 4

Figure 2. Comparison of the Revised Final
Subcategories with Previous Subcategories .... 7

1.5 What is the purpose of the Pulp and Paper NESHAP? 8

Figure 3. Highest Emitted Hazardous Air Pollutants
from Pulp and Paper Mills 8

1.6 How many sources does the NESHAP affect? 10

Figure 4. Location of Pulp and Paper Mills 10

1.7 What if I have questions? 11

1.8 How do I get additional copies of this document? 11

1.9 Where can I find additional information about this NESHAP? 12

1.10 Where can I find additional information on the pulp and paper industry? . 14

2.1 What distinguishes the types of mills that manufacture pulp and paper? .. 15

Figure 5. Chemical Pulping Process Differences 16

2.2 What is the kraft pulping process? 17
Kraft digesting process 17

Figure 6. Example Overview of a Kraft Pulping Mill with
a Papermaking System 18
in
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Contents (Continued)

Page

Kraft pulp processing steps 19

Figure 7. Brown Stock Washing System (Rotary Vacuum) . 20

Evaporator system 21
Oxygen delignification system 21
Gas collection systems 22

Figure 8. Typical Oxygen Delignification System
(Medium Consistency) 23

Condensate stripping 24

2.3 What is bleaching? 25

Figure 9, Example Bleaching Line 26

Bleaching chemicals 27
Bleaching mixers 28
Bleaching retention towers 28
Bleached pulp washers 28
What is pulp preparation and papermaking? 29

2.4 Soda mills 30

2.5 Sulfite mills 31

Figure 10. Example Sulfite Pulping System 32

2.6 Semi-chemical mills 33

Figure 11. Example Semi-chemical Pulping System 34

2.7 Mechanical, secondary fiber, and non-wood fiber pulp mills 35
Mechanical pulping 35
Secondary fiber pulping 35
Non-wood fiber pulping 36

2.8 References for Chapter 2 37
IV
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Contents (Continued)
Chapter 3 -
Overview of the
Pulp and Paper
NESHAP
Chapter 4 -
NESHAP
Requirements
for Kraft Mills
Page

3.1 Which mills are subject to the NESHAP? 38

3.2 What processes and equipment systems must be controlled? 39

Figure 12. Equipment Systems Covered by the
Pulping Vent Standards 40

3.3 What are the emission control requirements? 41

Figure 13. Alternative Emission Limits 42

3.4 What control systems will mills typically use to meet the emission
limits? 43

3.5 How do mills demonstrate initial and continuous compliance? 44

Figure 14. What Pollutants or Surrogates Must
Be Measured? 46

3.6 When must mills comply? 47

3.7 What additional requirements apply to new sources? 48

3.8 What is a new source? 49

4.1 Standards for kraft pulping system vents 52
What kraft pulping system vents must be controlled? 52
What are the emission limits for kraft pulping system vents? 53
What does the NESHAP require for enclosures and closed-vent
systems? 54
When must mills comply with the kraft pulping vent standards? . . 55
How does a mill demonstrate initial compliance with the kraft
pulping system vent standards? 56

Figure 15. How Does a Mill Demonstrate Initial
Compliance with the Kraft Pulping
System Vent Emission Limits? 56

How does a mill demonstrate continuous compliance with the
kraft pulping system vent standards? 57
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Contents (Continued)

Page
Figure 16. How Does a Mill Demonstrate Initial and
Continuous Compliance with the
Closed-Vent Systems Standard? 57

Figure 17. How Does a Mill Demonstrate Continuous
Compliance with the Kraft Pulping
System Vent Emission Limits? 58

Must a mill comply at all times? 59

4.2 Standards for kraft pulping process condensates 60
What is a condensate and why control it? 60
What kraft pulping condensates must be controlled? 60
Does the mill have to collect all those streams? 61
What are the control requirements? 61
What does the NESHAP require for condensate closed
collection systems? 62
When must a mill be in compliance? 63
How does a mill demonstrate initial compliance for kraft pulping
process condensate standards? 64

Figure 18. How Does a Mill Demonstrate Initial
Compliance with Kraft Pulping Condensate
Emission Limits? 65

How does a mill demonstrate continuous compliance with
pulping process condensate standards? 65

Figure 19. How Does a Mill Demonstrate Continuous
Compliance with Kraft Pulping Process
Condensate Emission Limits? 66

Must a mill comply at all times? 67

4.3 Standards for the kraft bleaching system vents 68
What bleaching emission points must be controlled? 68
Are there any exemptions to the bleaching requirements? 68
What are the control requirements for chlorinated HAPs? 69
What are the control requirements for chloroform? 69
When must bleaching systems comply? 70
How does a mill demonstrate initial compliance with the
bleaching standards? 71
VI
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Contents (Continued)
Chapter 5 -
NESHAP
Requirements
for Semi-
Chemical and
Soda Mills
Page
How does a kraft mill demonstrate continuous compliance with
the bleaching standards? 72

Figure 20. How Does a Kraft Mill Demonstrate
Continuous Compliance with Emission
Limits for Chlorinated HAPs? 73

4.4 Clean condensate alternative for HVLC vents 75
Which equipment systems can be used to generate the emission
reductions? 76
What emission reductions are creditable? 76
Can a mill use the CCA for only part of the emission reduction
requirement for the HVLC system? 76
How does a mill use the CCA? 77
How does a mill demonstrate initial compliance? 78
How does a mill demonstrate continuous compliance? 78
What approvals are required to use the CCA? 78

4.5 How do the requirements for the NSPS and the NESHAP compare? 79

Figure 21. Comparison of NESHAP and NSPS Alternative
Emission Limit(s) Requirements 80

5.1 Standards for semi-chemical and soda pulping system vent standards .... 82
What pulping system vents must be controlled? 82
What are the emission limits for semi-chemical and soda pulping
system vents? 83
What does the NESHAP require for enclosures and
closed-vent systems at semi-chemical and soda mills? 84
When must mills comply with the semi-chemical and soda
pulping process standards? 85
How does a mill demonstrate initial and continuous compliance
with the pulping system vent standards? 85
Must a mill comply at all times? 85

5.2 Standards for bleaching system vents at semi-chemical and soda mills ... 86
Semi-chemical mills 86
Soda mills 86
vn
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Contents (Continued)
Page
Chapter 6 -
NESHAP ^ Standards for sulfite pulping system vents 88
Reauirements What sulfite PuJPm§ system vents must be controlled? 88
«~, o..u:*« kn-ii What are the emission limits for sulfite pulping system vents? .... 89
for Sulfite Mills „„ . . , xTcc-tAr. . ,- , , , ,
What does the NESHAP require for enclosures and closed-vent
systems? 90
When must mills comply with the sulfite pulping process
requirements? 91
How does a mill demonstrate initial compliance with the sulfite
pulping system vent standards? 91
How does a mill demonstrate continuous compliance with the
sulfite pulping system vent standards? 92

Figure 23. How Does a Mill Demonstrate Initial and
Continuous Compliance with
the Closed-Vent Systems Standard? 92

Figure 24. How Does a Mill Demonstrate Continuous
Compliance with the Sulfite Pulping System
Vent Standards? 93

6.2 Standards for sulfite bleaching system vents 94
When must sulfite bleaching systems comply? 94

Chapter 7 -
NESHAP ^'* Standards for bleaching system vents 95
Reauirements What mechanical, secondary fiber, and non-wood fiber
for Mechanical bleaching system emission points must be controlled? 95
Secondary ' ^e t^iere an^ exemPti°ns to me bleaching requirements? 96
Fiber and Non- What are the control requirements for chlorinated HAPs? 96
wood' Fiber Puln When must mechanical, secondary fiber, and non-wood
fiber bleaching systems comply? 96
How does a mill demonstrate initial compliance with the
bleaching standards? 97
How does a mill demonstrate continuous compliance with the
bleaching standards? 98

Figure 25. How Does a Kraft Mill Demonstrate
Continuous Compliance with Emission
Limits for Chlorinated HAPs? 99
Vlll
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Contents (Continued)
Chapter 8 -
Other Federal
Regulations
Affecting Pulp
and Paper Mills
Appendices
Page

8.1 What other Federal air regulations affect the pulp and paper industry? .. 101

8.2 What other Federal water regulations affect the pulp and paper industry? 103

Figure 26. A Guide to the Acronyms for
Technology-Based Water Standards 105

Figure 27. Applicability of Technology-Based
Standards 106

8.3 What Federal hazardous wastes regulations affect the pulp and paper
industry? 107

8.4 What upcoming regulations will affect pulp and paper mills? 109
A:

I:
List of U.S. Pulp and Paper Mills

NESHAP for Source Category: Pulp and Paper Production

Flowchart Summary of the NESHAP

List of EPA Region Office Contacts

Equipment Diagrams for Pulp and Paper Mills

List of Equipment Affected by the NESHAP

Pulp and Paper NESHAP Control Requirements

Compliance Milestones Timeline for Existing Sources

Summary of Effluent Limitations Guidelines for Bleached Papergrade
Kraft Mills
IX
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Chapter 1 - Introduction
This document does
NOT replace the
NESHAP for purposes
of making legal
interpretations.'
The U.S. Environmental Protection Agency (EPA) published the National
Emission Standards for Hazardous Air Pollutants (NESHAP) for the Pulp
and Paper Industry (40 CFR 63, Subpart S) on April 15, 1998 as part of the
Pulp and Paper Cluster Rules. The NESHAP affects existing and new
major sources that chemically and nonchemically pulp wood and non-wood
fibers for pulp and paper production. The NESHAP requires these sources
to control hazardous air pollutant (HAP) emissions using the maximum
achievable control technology (MACT). The Cluster Rules also revised the
effluent limitations guidelines and standards under the Clean Water Act for
pulp mills that make bleached papergrade products.

1.1 What does this document do?

This document focuses on the NESHAP and describes:

• the pulping and bleaching processes

• the requirements of the NESHAP

• the scope of effluent limitations guidelines and standards
revisions

• additional references and sources of information about pulp
and paper mills
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1.2 Why do I need this document?

You need this document because it will help you understand the NESHAP.
Implementation of the pulp and paper NESHAP is complex for both
affected mills and regulators because:

• There is a tremendous amount of variability in the pulp and
paper industry with respect to processes, equipment, and
products. For example, the task of turning wood into pulp is
performed by different processes using different equipment
and different chemicals at kraft mills, sulfite mills, and
mechanical pulping mills. As a result, different emission
points must be controlled at each type of mill.

• The NESHAP allows for a significant amount of flexibility
in the control strategies used to reach compliance.

• The timelines for compliance vary for different parts of the
mill.

• More stringent control requirements apply to some new
sources.

• Technical requirements for some of the available control
strategies will be specified on a mill-by-mill basis by the
implementing agency.
Chapter 1 - Introductn
-------
1.3 How should I use this document?
If you are familiar with the pulping and bleaching processes, there is no
need to read Chapter 2. You should skip ahead to Chapter 3. Everyone
should read Chapter 3 as it provides the overview of the NESHAP. After
reading Chapter 3, you should decide what other sections of the document
you need.
If You Need the Following Information-
Then Read.
A description of the Cluster Rules
A description of pulping and bleaching processes
An overview of the NESHAP
A description of how new source requirements
apply
NESHAP requirements for kraft mills
NESHAP requirements for soda and semi-chemical
mills
NESHAP requirements for sulfite mills
NESHAP requirements for mechanical, secondary
fiber, and non-wood fiber pulp mills
A description of other existing and upcoming
Federal regulations affecting pulp and paper mills
A list of pulp and paper mills
A copy of the NESHAP
Flowchart summary of the NESHAP
A list of EPA Regional Office contacts
Equipment diagrams
A list of equipment affected by the NESHAP
A summary of the NESHAP control requirements
A timeline of compliance milestones
Summary of effluent limitations guidelines and
standards for bleached papergrade kraft mills
Chapter 1
Chapter 2
Chapter 3
Chapter 3

Chapter 4
Chapter 5

Chapter 6
Chapter 7

Chapter 8

Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Chapter 1 - Introduce
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Stay informed about
new or revised
requirements by
visiting "What's New'
pages of the OECA
and Unified Air
Toxics Websites:

http://es. epa.gov/
oecaJwn2.html
and
http://www.epa.gov/
ttn/uatw/
uatwnew.html
1.4 What are the Pulp and Paper "Cluster Rules"?

The Cluster Rules are a simultaneous publication of Federal air and water
pollution control regulations. They are an example of the EPA's efforts to
simplify compliance by coordinating the regulation of multimedia industrial
pollution and will reduce both air and water pollutant discharges. You can
get an electronic copy of the Cluster Rules from the Federal Register
website at http://www.access.gpo.gov/su_docs/aces/acesl40.html or the
EPA Unified Air Toxics website at http://www.epa.gov/ttn/uatw on the
Rules and Implementation Page.

The goals of this coordinated regulatory approach are to:

• provide greater protection of human health and the
environment

• reduce the overall cost of complying with wastewater
regulations and air emissions controls

• promote and facilitate coordinated compliance planning by
the industry

• promote and facilitate pollution prevention

• emphasize the multimedia nature of pollution control

Figure 1 identifies the mill types covered under the Cluster Rules.
Appendix A lists the mills potentially affected by the Cluster Rules by
facility name and location.

Figure 1.
Types of Mills Covered Under the Cluster Rules
Then it is Subject to These Parts of the Cluster Rules™
If the Mill is this Type...
Kraft
Soda
Sulftte
Semi-Chemical
Mechanical
Non-Wood Fiber
Secondary Fiber
NESHAP
X
X
X
X
X
X
X
Revised Effluent Limitations
Guidelines and Standards
Bleached Papergrade only
Bleached Papergrade only
Papergrade only

Chapter 1 • Introducth
-------
The features of the
NESHAP are:
•Alternative emission
limits
• Varying compliance
periods (3-8 years)
• New and existing
source controls
• Flexibility for
evolving
technologies
• Compliance dates
coordinated with
effluent limitations
guidelines and
standards
The Cluster Rules consist of the following two components:

(1) National Emission Standards for Hazardous Air Pollutants
(NESHAP) from the Pulp and Paper Industry
(40 CFR 63, Subpart S). The pulp and paper NESHAP specifies
emission standards for pulping and bleaching systems at all chemical
pulping mills and bleaching systems at mechanical pulping, non-
wood fiber, and secondary fiber mills.

The air emissions control standards require mills to reduce
hazardous air pollutant emissions through the use of thermal
oxidizers, boilers, lime kilns, recovery furnaces, caustic scrubbers,
or other control devices, or process modifications. In general, the
NESHAP requires mills to:

• collect and incinerate pulping process vent emissions

• collect and control bleaching process vent emissions
with a caustic scrubber

• eliminate the use of certain bleaching chemicals

• collect and treat process condensate streams to
remove HAPs through biological treatment or
stripping (kraft mills only)

The NESHAP is written to encourage pollution prevention
techniques. See Appendix B for a copy of the NESHAP and
Appendix C for a flowchart summary of the NESHAP.

This NESHAP does NOT address emissions from chemical recovery
process combustion sources. Emissions from these sources will be
covered by another NESHAP (Subpart MM) proposed on
April 15, 1998 (63 FR 18754).
Chapter 1 - Introductk
-------
Stay informed
about new or
revised
requirements by
visiting the EPA
Office of Water's
Pulp and Paper
Website:
http://www.epa.
gov/ost/pulppaper/
(2) Effluent Limitations Guidelines and Standards, Pretreatment
Standards, and New Source Performance Standards for the Pulp,
Paper, and Paperboard Category (40 CFR 430, Subparts A-L).
These regulations control discharge of pollutants in wastewaters
generated at pulp and paper mills. The pretreatment standards apply
to mills that discharge wastewater to a municipal wastewater
treatment facility (i.e., Publicly Owned Treatment Works or POTW).
The effluent limitations guidelines and standards are applied to the
mills that directly discharge into receiving water via the National
Pollution Discharge Elimination System (NPDES) permit program.
In addition, the effluent limitations guidelines and standards portion
of the Cluster Rules:

• Includes best management practices (BMP)
regulations for a portion of the pulp, paper, and
paperboard industry. The BMP rules are designed to
prevent or contain leaks and spills of pulping liquor,
soap, and turpentine, and to control any intentional
diversions of these substances.

• Specifies new analytical methods for twelve
chlorinated phenolic pollutants and for adsorbable
organic halides (AOX).

• Revises the subcategorization scheme for existing
effluent limitations guidelines and standards for the
pulp and paper industry (shown in Figure 2) and
revises the effluent limitations guidelines and
standards for Bleached Papergrade Kraft and Soda
subcategory (Subpart B) and the Papergrade Sulfite
subcategory (Subpart E). The EPA revised the
subcategorization scheme to better define the
processes typically found in U.S. mills.

• Includes the Voluntary Advanced Technology
Incentives Program which is designed to encourage
direct discharging bleached papergrade kraft mills to
install more pollution prevention technology than
required by the regulations.
Chapter 1 • tntroductic
-------
Figure 2.

Comparison of the Revised Final
Subcategories with Previous Subcategories
Final Final
Codified Subcategorization
Subpart Scheme
A Dissolving Kraft
Ba Bleached Papergrade Kraft and Soda
C Unbleached Kraft
D Dissolving Sulfite
E Papergrade Sulfue
F Semi-Chemical
G Mechanical Pulp
H Non-Wood Chemical Pulp
I Secondary Fiber Deink
J Secondary Fiber Non-Deink
K Fine and Lightweight Papers from Purchased Pulp
L Tissue, Filter. Non-Woven, and Paperboard from
Purchased Pulp
Previous Subcategorization
Scheme with Previous
40 CFR 430 Subparts Noted in Parentheses
Dissolving Kraft (F)
Market Bleached Kraft (G)
BCT Bleached Kraft (H)
Fine Bleached Kraft (I)
Soda (P)
Unbleached Kraft (A)
Linerboard
Bag and Other Products
Unbleached Kraft and Semi -Chemical (D, V)
Dissolving Sulfite (K)
Nitration
Viscose
Cellophane
Acetate
Papergrade Sulfite (J.U)
Blow Pit Wash
Drum Wash
Semi-Chemical (B)
Ammonia
Sodium
GW-Thermo-Mechamcal (M)
GW-Coarse, Molded, News (N)
GW-Fme Papers (O)
GW-Chemical-Mechanical (L)
Miscellaneous mills not covered by a specific subpart
Demk Secondary Fiber (Q)
Fine Papers
Tissue Papers
Newsprint
Tissue from Wastepaper (T)
Paperboard from Wastepaper (E)
Corrugating Medium
Non-Corrugating Medium
Wastepaper-Molded Products (W)
Builders' Paper and Roofing Felt
(40 CFR Pan 431 Subpart A)
Non-Integrated Fine Papers (R)
Wood Fiber Furnish
Cotton Fiber Furnish
Lightweight Papers (X)
Lightweight Papers
Lightweight Electrical Papers
Non-Integrated
Tissue Paper (S)
Filter and Non- Woven (Y)
Paperboard (Z)
Revised under the Cluster Rules.
Chapter 1 - Introduct
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A major source is a
stationary source that
has the potential to
emit 10 tons per year
of any one HAP or
25 tons per year of
total HAPs.
1.5 What is the purpose of the Pulp and Paper
NESHAP?

The purpose of this NESHAP is to reduce HAP emissions from the pulp and
paper industry, thus reducing public health hazards. The EPA regulated this
industry because pulp and paper mills are major sources of HAP emissions
listed in Section 112 of the Clean Air Act (CAA). Section 112(d) of the
CAA directs EPA to set maximum achievable control technology (MACT)
standards for major stationary sources. MACT standards are technology-
based emission limitations that require the maximum degree of emission
limitations that is achievable considering cost, human health,
environmental, and energy impacts.

Pulp and paper mills emit 240,000 tons of HAPs annually that impact both
air quality and public health. The pulp and paper NESHAP will reduce
1996 emissions of HAPs from pulp and paper facilities by 153,000 tons per
year (a 64 percent reduction). Figure 3 lists the HAPs emitted in the largest
quantities from pulp and paper mills.

Figure 3.

Highest Emitted Hazardous Air Pollutants
from Pulp and Paper Mills
Hazardous Air Pollutants
Acrolein

Acetaldehyde

o-Cresol

Carbon tetrachloride

Chloroform

Cumene

Formaldehyde
Methanol

Methylene chloride

Methyl ethyl ketone

Phenol

Propionaldehyde

1,2,4-Trichlorobenzene

o-Xylene
Chapter 1 - Introduce
-------
The control techniques used to reduce HAP emissions will also reduce
emissions of other pollutants. For example, the NESHAP will reduce
volatile organic compound (VOC) emissions by 450,000 tons per year.
Volatile organic compounds cause a variety of adverse health effects and are
precursors to the formation of tropospheric (ground level) ozone.

Emissions of total reduced sulfur (TRS) compounds cause the odors
commonly associated with pulp and paper production. Exposure to TRS
emissions has been linked to symptoms including headaches, watery eyes,
nasal problems, and breathing difficulties. Total reduced sulfur emissions
are regulated by new source performance standards (NSPS) under
Section 111 of the CAA. Although not specifically regulated by the
NESHAP, the NESHAP will result in a reduction of TRS emissions by
87,000 tons per year.
Chapter 1 - Introducti
-------
The list of mills in
Appendix A is
provided for
information onl\.
The list is not
necessarily
complete, nor does
it represent an EPA
determination that
any specific mill is
subject to the rules.
1.6 How many sources does the NESHAP affect?

Figure 4 shows the location of the pulp and paper facilities in the United
States that are potentially affected by the pulp and paper NESHAP.
Appendix A lists the pulp and paper mills (including facility name, and
location by city and state) that were identified as potentially affected sources
at the time the NESHAP was published.

Figure 4.
Location of Pulp and Paper Mills
Source: Lockwood-Post Directory, 1996.
State
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Iowa
Idaho
Illinois
Indiana

Mills
19
8
2
34
1
10
0
11
24
T
1
10
12

State
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Maine
Michigan
Minnesota
Missouri
Mississippi
Montana
North Carolina
New
Hampshire
New Jersey

Mills
2
5
13
38
3
18
33
9
3
10
1
17
12
14

State
New Mexico
New York
Ohio
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Vermont
Washington
Wisconsin
West Virginia
Total
Mills
1
49
30
6
12
31
9
13
11
12
6
22
46
2
564
Chapter 1 - Introdut,.,
10
-------
Identify your State
and local contacts
using the Membership
Directory at the
STAPPA/ALAPCO
website at
http://www.4cleanair.
org
STAPPA/ALAPCO =
State and Territorial
Air Pollution
Program
Administrators/
Association of Local
Air Pollution Control
Officials
Copies are
available free of
charge from the
EPA library.
1.7 What if I have questions?

If you are the owner or operator of a pulp and paper mill, you can get
additional information from:

• your State or local air pollution control agency

• trade associations, such as Technical Association of the Pulp
& Paper Industry (TAPPI) at http://www.tappi.org or
American Forest and Paper Association (AF&PA) at
http://www.afandpa.org

If you work for a State or local regulatory agency and have questions
regarding the implementation of this NESHAP, you should contact your
EPA Regional Office. A list of EPA Regional Office contacts is included in
Appendix D.

1.8 How do I get additional copies of this document?

You can get copies of this document from:

• EPA's Technology Transfer Network (TTN) on the world
wide web at
http://www.epa.gov/ttn/uatw/pulp/pulppg.html

• Library Services Office (MD-35)
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Telephone: (919)541-2777

• National Technical Information Services (NTIS)
Technology Administrations
5285 Port Royal Road
Springfield, Virginia 22161
Telephone: (703) 605-6000
Fax: (703)321-8547

Note: NTIS will charge a fee for each document
requested.
Chapter 1 - Introduci
11
-------
An overview of this
NESHAP is
available on a
40 minute video
tape. You can view
this tape at your
State or local air
pollution control
office.
Check the UATW
for correction
notices and
amendments.
1.9 Where can I find additional information about this
NESHAP?

You can find information about the basis and purpose of this NESHAP in
the Federal Register notices and background information documents. The
background information documents are:

• Pulp, Paper, Paperboard Industry - Background Information
for Proposed Air Emissions Standards for Manufacturing
Processes at Kraft, Sulfite, Soda, and Semi-chemical Mills.
Publication No. EPA-453/R-93-050a. October 1993

• Pulp, Paper, Paperboard Industry - Background Information
for Promulgated Air Emissions Standards for Manufacturing
Processes at Kraft, Sulfite, Soda, and Semi-Chemical,
Mechanical, and Secondary and Non-wood Fiber Mills.
Publication No. EPA-453/R-93-050b. October 1997

Federal Register notices pertaining to the NESHAP are:

Proposed NESHAP: published December 17, 1993
(58 FR 66078)

• Correction notice to the proposed NESHAP: published
March 17, 1994 (59 FR 12567)

• Notice of Data Availability (NODA): published
February 22, 1995 (60 FR 9813)

• Supplemental Notice: published March 8, 1996
(61 FR 9383)

Promulgated NESHAP: published April 15, 1998
(63 FR 18504)

• Correction of minor errors on the April 15, 1998 Notice:
published August 7, 1998 (63 FR 42238)
Chapter 1 - lntrodu<.
12
-------
• Interpretation and Technical Amendment regarding
applicability to excess emission allowance for condensate
treatment systems: published September 16, 1998
(63 FR 49455)

You can get these documents and other relevant documents from:

EPA's Unified Air Toxics website (UATW) at
http://www.epa.gov/ttn/uatw or
http://www.epa.gov/ttn/uatw/pulp/pulppg.html. These
sites contain background documents, preambles, regulations,
guidance documents, and policy memos

"What's New" page of the UATW at
http://www.epa.gov/ttn/uatw/uatwnew for the most current
information

• The Air Dockets (A-92-40 and A-95-31) which are available
for public inspection between 8 a.m. and 4 p.m., Monday
through Friday, except for Federal holidays, at:

Air and Radiation Docket and Information Center
(MD-6102)
U.S. Environmental Protection Agency
401 M Street SW
Room M-1500
Waterside Mall
Washington, DC 20460
Telephone: (202) 260-7548
Chapter 1 - Introducti*
13
-------
The Kraft Pulp Mill
Compliance
Assessment Guide
covers the Cluster
Rules as well as
NSPS and other
rules affecting kraft
mills.
1.10 Where can I find additional information on the
pulp and paper industry?

You can get additional information from:

• Biermann, C.J. 1993. Essentials of Pulping and
Papermaking. San Diego, CA: Academic Press, Inc.

• Burgess,!. 1995. The Basics of Foul Condensate Stripping.
1995 Kraft Recovery Short Course. Atlanta, GA:
TAPPI PRESS.

EPA. 1998. Permit Guidance Document for Pulp, Paper and
Paperboard Manufacturing Point Source Category, 40 CFR
Part 430. draft. Office of Water, Washington, DC.

EPA. 1995. Office of Compliance Sector Notebook Project:
Profile of the Pulp and Paper Industry.
Publication No. EPA/310-R-95-015.
http://es.epa.gov/oeca/sector/index.htmlttpulp Office of
Enforcement and Compliance Assurance, Washington, DC.

EPA. 1999. Kraft Pulp Mill Compliance Assessment Guide.
Publication No. EPA/310-B-99-001. Office of Enforcement
and Compliance Assurance, Washington, DC.

• How Paper is Made: An Overview of Pulping and
Papermaking from Woodyard to Finished Product. 1997.
Available on CD-ROM, Atlanta. GA: TAPPI PRESS.

Kocurek. M.J. and Stevens, C.F.B., eds. 1983. Pulp and
Paper Manufacture. Third Edition. Joint Textbook
Committee of the Paper Industry.

• Mimms, A., Kocurek, M., Pyatte, J. and Wright, E. eds.
1993. Kraft Pulping. Atlanta, GA: TAPPI PRESS.

Smook, G.A. 1992. Handbook for Pulp and Paper
Technologists. Second Edition. Bellingham, WA: Angus
Wilde Publications.
Chapter 1 • Introduce
14
-------
If you are already
familiar with
pulping and
bleaching
processes, you can
move ahead to
Chapter 3.
The types of pulp
mills are:
• kraft
• soda
• sulfite
• semi-chemical
• mechanical
• secondary fiber
• non-wood fibers
Chapter 2 - Description of the Pulping and
Bleaching Processes
Three major types of fibers are used to make pulp and paper products:
wood; secondary fibers (recycled fibers); and non-wood fibers (e.g., cotton,
flax, hemp). However, the majority of pulp and paper products are made
from wood, and most wood mills use the kraft pulping process.

Because kraft mills represent the majority of the industry, this chapter
describes the processes at kraft mills using wood. A general process
overview for each of the other types of mills is also provided. This chapter
does not explain each individual process, but rather focuses on the main
activities affected by the NESHAP. For further information about the pulp
and paper industry and process operations, please refer to the list of
materials provided in Chapter 1.

2.1 What distinguishes the types of mills that
manufacture pulp and paper?

Kraft, soda, and sulfite mills all use chemicals in their pulping processes.
These processes differ primarily in the chemicals used for digesting wood
chips. Mechanical pulping involves shredding or grinding wood chips
without the use of chemicals and semi-chemical pulping combines chemical
and mechanical methods. Secondary fiber mills mechanically separate pulp
from waste paper products. Non-wood fiber mills can use mechanical and
chemical pulping processes. Figure 5 summarizes the characteristics of the
different types of chemical pulping processes.
15
-------
Figure 5.

Chemical Pulping Process Differences
Pulping
Process Type
Kraft
Soda
Sulfite
Semi-chemical
Typical Typical
Pulp Chemicals Pulp Yield Type of Wood
Produced Used Percent Used
Kraft NaOH, Na2S 40-50 Softwood and
hardwood
Soda NaOH 45-55 Hardwood
Acid sulfite H:SO,, 45-55 Softwood and
M(HSO,) hardwood
(M=Ca. Mg,
Na, NHJ
Neutral Na:SO, 65-80 Hardwood
Sulfite Semi- Na:CO,
chemical
Typical Pulp
Uses
Writing paper;
paper bags;
cardboard;
specialty
products such
as rayon,
acetate, and
cellophane
Writing paper;
specialty
products such
as rayon,
acetate, and
cellophane
Writing paper;
specialty
products such
as rayon,
acetate, and
cellophane
Corrugated
containers
Source: Smook, 1992.
16
Chapter 2 - Pulping a
Bleaching Process
-------
The NESHAP has
the same emission
limits for
papergrade and
dissolving grade
pulp production.
2.2 What is the kraft pulping process?

The pulping process converts raw materials into a fibrous mass that can be
formed into paper or cardboard. Wood contains both cellulose fibers and
lignin; the objective of the kraft pulping process is to dissolve the lignin and
leave most of the cellulose fibers intact.

The main operations performed in the kraft pulping process are:

• digestion of wood to form pulp

• pulp processing to recover spent cooking chemicals and to
remove impurities and uncooked wood chips (deknotting,
pulp washing, pulp screening)

• concentration of used pulping liquor for chemical recovery

Figure 6 depicts a typical overview of a kraft pulp and paper mill. More
detailed diagrams for each equipment system in the pulping process are
provided in Appendix E.

Kraft digesting process

Kraft pulping entails cooking, or digesting, wood chips at elevated
temperature and pressure in an alkaline pulping liquor that contains sodium
sulfide (Na2S) and sodium hydroxide (NaOH). Cooking may be performed
in either batch digester or continuous digester systems. For mills that use
softwood feedstock (e.g., pine), the digester system generally will include a
turpentine recovery system. The turpentine is recovered from digester relief
vent gases.
The pulping liquor and elevated temperature and pressure promote
breakdown of the bonds in the lignin compounds. Depending on pulping
conditions, as much as 90-95 percent of the lignin can be removed from
wood in kraft pulping.

Two types of pulp are produced:

• papergrade (for making paper, paperboard, tissue)

• dissolving grade (for making rayon, cellophane, acetate, food
additives)
Chapter 2 - Pulping a
Bleaching Process
17
-------
Chemical Recovery System
Wood Chips 1 1

oo
X / ' ' I—1—!
_JL_/ F ,
s"^ ^-v Evaporator
Diyeslei System bystem |(l
1

Turpentine
: Recovery
Sytf^tn
Screening
System
C i >
I ' *•
1
c j ^
V ^" Oxygen

\ / I A ^ Svjtpm
YFulp Washing System Y
Knotter System f ^^ ^ f ^ J

^ ^ /^ ~\ System , .,
=; ^ . ' R
._» -i "*- T S

Weak Black 1
Stornyo Tn
Refiners/Cleaners
P^pprrn^kinp System

C|UO»
nk
Bleaching System
^ ______ 7 — __^^^^^

1-Cooklng liquor added to wood chips to dissolve llgniri.
2-Removal of uncooked chips and knots
3-Weak black liquor washed from pulp.
4-Fiber bundles and contaminants screened from pulp
5-Pulp thickened for oxygen delignilication
B-dxyyen Deligtiificalion System for further dclignificalion
7-Pulp bleached to increase whiteness.
8-Pulp is cleaned and prepared for papermaking.
9—Paper sheet formed through dewatering
10-F.vaoorator System removes excess water from the
weak black liquor.
1 1-CheiiiKal recovery system converts the concentrated liquor
iiilo cooking liquor for use in the digester system
Figure 6.
Example Overview of a Kraft Puling Mill with a Papermaking System
-------
Weak black liquor
consists of
dissolved wood
compounds and
spent cooking
chemicals.
Kraft pulp processing steps

Kraft mills remove impurities from the raw pulp prior to bleaching or
papermaking. The primary pulp cleaning operations include deknotting (in
the knotter), brown stock washing (in the pulp washing system), and pulp
screening (in the screening system).
Pulp
from
Digester
Deknotting removes
knots and other
portions of uncooked
wood from the pulp
slurry. Kraft mills
burn the knots and
uncooked wood for
energy recovery,
dispose of them as
waste, or recycle them
for repulping. The diagram to the right shows a typical knotter.

Brown stock washing recovers spent cooking liquor (weak black liquor) for
reuse in the pulping process. Efficient washing is critical to maximize the
return of cooking liquor to chemical recovery and to minimize carryover of
cooking liquor (known as brown stock washing loss) into the bleach plant.
A variety of brown stock washing technologies are used; the most common
technology is a series of two to four rotary vacuum washers. In each
washer, wash water is applied to displace cooking liquor in the pulp;
countercurrent washing is generally used to reduce fresh water
requirements. Other common washer types are diffusion washers, rotary
pressure washers, horizontal belt filters, wash presses, and
dilution/extraction washers. Figure 7 shows a typical rotary vacuum washer
system.
Chapter 2 • Pulping,
Bleaching Proces
19
-------
Hood vent gases
Water
Pulp from
Knotter
System
N)
O
Pulp to
Screen and Decker
Systems
Spent liquor
to Weak Black
Liquor
Storage Tank
Figure 7.
Brown Stock Washing System (Rotary Vacuum)
-------
A screen system
removes oversized
particles from the
pulp slurry prior to
the bleaching or
papermaking
system.

A decker is used to
thicken the pulp for
storage after
screening or
subsequent
delignification
steps.
Pulp screening removes the remaining oversized particles (fiber bundles
and contaminants) from washed pulp. The pulp is diluted to low percent
solids, then passed through a perforated screen, and rejects are continuously
removed from the screen. Methods for removing rejects are shaking and
vibration, hydraulic sweeping action, back-flushing, or pulsing the flow
through the openings with various moving foils, paddles, and bumps. Mills
may operate open, partially closed, or closed screen rooms. In open screen
rooms, wastewater from the screening process is discharged to wastewater
treatment. In closed screen rooms, wastewater is reused in brown stock
washing or other pulping operations and ultimately enters the chemical
recovery system.

A decker system is all of the equipment used to thicken the pulp slurry after
the pulp washing system. It includes decker vents, filtrate tanks, and
vacuum pumps.

Evaporator system

Weak black liquor collected from the pulp washers goes into a weak black
liquor storage tank. The weak black liquor is sent to the multiple effect
evaporator (MEE) to evaporate water and concentrate the weak black liquor
in order to increase solids content. Typically, weak black liquor recovered
from the brown stock washers contains between 13 and 17 percent solids.
The weak black liquor is then concentrated to 60-80 percent solids, which is
required for efficient combustion in the recovery boiler. An MEE will
include four to seven effects, or bodies, arranged in series. At pulp mills
using soft wood, a tall oil recovery system is generally incorporated into the
evaporator system to recover tall oil from the black liquor. Tall oil is sold
for use in manufacturing cosmetics.

Oxygen delignification system

Some mills that produce bleached pulp may also have an oxygen
delignification stage either in the pulping area or as a prebleaching stage.
The oxygen delignification process reduces the lignin content without
reducing pulp strength or yield. High efficiency oxygen delignification
minimizes the amount of bleaching chemicals needed to achieve adequate
pulp brightness.
Chapter 2 • Pulping,
Bleaching Proces
21
-------
There are currently two types of oxygen delignification systems available:
high consistency and medium consistency. Medium consistency systems
are more popular due to safer operation and lower capital costs. Design and
placement of these systems vary from mill to mill. Oxygen delignification
systems of the two-stage design are most often employed in the U.S. for
new installations. Figure 8 shows a typical oxygen delignification system.

Gas collection systems

Gas collection systems, or noncondensible gas (NCG) systems, are used to
collect gases from the various pulping processes and transport them to an
appropriate air pollution control device. There are two basic categories of
NCGs: low volume, high concentration (LVHC); and high volume, low
concentration (HVLC).

Low volume, high concentration (LVHC) systems typically collect gases
from the following systems:

• digester system

• turpentine recovery system

• evaporator system

• steam stripper system

• any other system serving one of these functions

High volume, low concentration (HVLC) systems typically collect gases
from the following systems:

• knotter system

• pulp washing system

• screen system

• oxygen delignification system

• weak liquor storage tanks

• any other equipment serving one of these functions
Chapter 2 • Pulping i
Bleaching Proce&
22
-------
Pulpfran
Screen and
Decker System
Oxygen
To\\er
Washer

filtrate
tank
Hood vent gases
PUlp to
Bleaching System
Wsak Black
Liquor
Figure 8.
Typical Oxygen Delignification System (Medium Consistency)
-------
Historically, most
LVHC gases have
been controlled,
while a smaller
portion of the
HVLC gases have
been controlled.

Steam stripper
systems were
historically
installed to control
TRS odor.
A number of mills use a dedicated incinerator to control NCG emissions,
but most mills use process combustion sources such as the lime kiln, power
boilers, or a recovery boiler.

Condensate stripping

The pulping process equipment may include a steam stripper system to
remove organics and total reduced sulfur (TRS) compounds from various
liquid process condensate streams. Steam stripping is a multistage
distillation separation process that uses direct steam as the heat source. The
pulping process condensate streams most often stripped are the turpentine
decanter underflow, blow steam condensates, and certain evaporator
condensates. The stripped condensates may then be used as hot process
water.

Kraft pulping process condensates originate from the following systems:

• digester system

• turpentine recovery system

• evaporator system
Chapter 2 - Pulping a
Bleaching Process
24
-------
Each bleaching
stage performs
three functions:
• mixing of pulp
and bleaching
chemicals
• reaction of
bleaching
chemicals with
the pulp
• washing the
chemicals out of
the pulp
2.3 What is bleaching?

Bleaching brightens the pulp in a series of chemical operations that are
together called a bleaching line. A bleaching line typically consists of a
sequence of three to six bleaching stages. The number of stages varies
depending on the brightness requirements of the pulp and the specific
design of the mill. Typically, the stages are sequenced as an alternating
series of bleaching and extraction stages. In a bleaching stage, the pulp is
treated with chemical bleaching agents. In an extraction stage, chemicals
(usually sodium hydroxide) are added to neutralize the chemical reactions
and the acidity of the pulp prior to the next bleaching stage. An extraction
stage is not required in all cases.

Each bleaching stage consists of three steps: mixing of pulp and bleaching
chemical (and in some cases steam); reaction of the chemical with the pulp
in a retention tower; and washing the chemical out of the pulp. Thus, the
equipment considered part of a stage includes chemical and steam mixers,
retention (bleaching or extraction) towers, and the washers and their
associated seal (filtrate) tanks and/or vacuum pumps.

Figure 9 depicts the major equipment found in a typical three-stage
bleaching plant. The function of these equipment systems and a brief
description follow.
Chapter 2 - Pulping t
Bleaching Procesi
25
-------
c
(D
(O
*!
£ I s
3 2
•a n
a
i
in
£. 03
91
If
Bleaching
Tower
Extraction
Tower
Bleaching
Tower
g
I
» a
f " "
J
2 -•
-------
Bleaching stage
means all process
equipment
associated with a
discrete step of a
chemical
application and
removal in the
bleaching process.

Bleaching line
means a group of
bleaching stages
arranged in series
such that bleaching
oj the pulp
progresses as the
pulp moves from
one stage to the
next.
Bleaching chemicals

Almost any oxidant could be used as a bleaching agent. However, for
bleaching pulp, the chemical must be both powerful and inexpensive to
produce or purchase. There are a variety of chemicals that meet these
criteria. Both chlorinated and non-chlorinated chemicals are used for
bleaching. The chemicals and their common bleaching stage abbreviations
are shown below. These bleaching chemicals are grouped into two
categories: chlorinated and non-chlorinated.
Chemicals Abbreviation
Chlorinated Bleach Chemicals
Elemental chlorine
Hypochlorite
Chlorine dioxide
Chlorine with chlorine dioxide
substitution
C
H
D
(CD), (C+D)

Non-chlorinated Bleach Chemicals
Oxygen
Peroxide
Ozone
O
P
z
Chlorinated bleaching chemicals. There are three chlorinated chemicals
commonly used for bleaching pulp: elemental chlorine (C), chlorine
dioxide (D), and hypochlorite (H). Since elemental chlorine is a good
delignifying agent, it performs best when used in the first bleaching stage.

Non-chlorinated bleach chemicals. Common examples of non-chlorinated
bleaching chemicals include: oxygen (O); peroxide (P); and ozone (Z).
Bleach stages that use various combinations of alkali, oxygen, and peroxide
are common in many bleach plants.
Chapter 2 - Pulping a
Bleaching Process
27
-------
The NESHAP
requires collection
and control of HAP
emissions from the
chlorinated
bleaching stages
only!
Bleaching mixers

Bleaching chemicals must be thoroughly mixed with the pulp to ensure pulp
quality, to minimize chemical waste, and to minimize the generation of
bleaching contaminants such as chlorinated dioxins and furans. Enclosed
rotary high-shear mixers or static in-the-pipe mixers are used to mix the
pulp and bleaching chemicals.

Bleaching retention towers

Retention towers are used to maintain bleaching conditions for the pulp as it
passes through each bleaching stage. For complete bleaching chemical
reaction, it is necessary to maintain a certain temperature, time, consistency,
pressure, and pH for each bleach stage. Conditions vary with the bleaching
chemical used (e.g.. chlorine, chlorine dioxide, hydrogen peroxide). In
many bleaching systems, the retention towers are named by the bleach
chemical used or the function of that particular bleaching stage
(e.g.. chlorination tower).

There are two primary types of retention towers: the upflow tower; and the
downflow tower. The choice of tower design depends on the particular
conditions desired for the bleach stage. As a general rule, chlorinated
bleaching stages use an upflow tower design or a similar design. See
diagram number 29 in Appendix E.

Bleached pulp washers

To minimize chemical usage and equipment corrosion, it is important to
remove as much bleaching chemical as possible from the pulp before it
enters the next bleaching stage. Bleached pulp washing is performed in the
same type of equipment that washes the brown stock. See discussion on
brown stock washers on page 19.

More detailed diagrams on the air and water discharges of each system are
provided in Appendix E.
Chapter 2 - Pulping a
Bleaching Process
28
-------
What is pulp preparation and papermaking?

The final stages at a pulp and paper mill include the preparation of pulp for
papermaking and the actual papermaking process. In the pulp preparation
area, the pulp fibers are cleaned to remove unwanted particles (such as dirt
and sand) from the pulp stock. The cleaned fibers will then undergo some
level of refining. In the refining process, the pulp fibers are subjected to
mechanical action to develop their optimal papermaking properties with
respect to the product being made.

In the papermaking process, the pulp stock is converted into paper. This
process begins when the pulp stock is distributed across the forming table.
On the forming table, the paper sheet formation starts as the excess water
contained in the pulp stock drains from the pulp fibers. The newly formed
paper sheet is removed from the forming table and is conveyed through a
series of presses to remove additional water and to continue the sheet
forming process. The remaining water contained in the paper sheet is
removed as the sheet travels around a series of steam-heated cylinders.
After the paper sheet leaves the dryers, it may undergo several other
processes, depending on the final paper product. These additional processes
include; calendering (where the sheet is pressed to reduce thickness and
smooth the surface), winding (where the sheet is wound onto a reel), and
coating (where various chemical or dyes are applied to the paper sheet).
Chapter 2 - Pulping t
Bleaching Proce&
29
-------
The soda pulping
process was the first
chemical pulping
method and was the
precursor to the kraft
pulping process.
2.4 Soda mills

The soda pulping process utilizes an alkaline liquor with sodium hydroxide
as the only active chemical. Except for the difference in chemicals used,
this process is the same as that described for the kraft mill.
Chapter 2 - Pulping a
Bleaching Process
30
-------
The sulfite pulping
process uses acid
solutions of sulfurous
acid (H2SO<) and
bisulfite ions (HSO,').
2.5 Sulfite mills

The sulfite pulping process uses an acid solution of sulfurous acid (H2SO3)
and bisulfite ion (HSO-,") to break the lignin bonds between wood fibers,
while kraft mills use an alkaline solution. Because the sulfite cooking
process is an oxidizing reaction, sulfur dioxide is generated instead of the
reduced sulfur compounds generated by the kraft process (a reducing
reaction). Thus, the chemical recovery processes at sulfite mills are
different than at kraft mills. Otherwise, the process is similar to the kraft
process.

SuJfite pulp has less color than kraft pulp and can be more easily bleached,
although the sulfite pulp is not as strong as kraft pulp. Figure 10 depicts an
overview of a typical sulfite pulping system.
Chapter 2 - Pulping
Bleaching Proces
31
-------
Chemical
Recovery
System
Acid
Making
System
Strong Liquor
Storage Tank*
Acid Condensate
Storage Tank*
Evaporator System
Weak Liquor
Storage Tank"
pulp flow

liquid streams

>• gas streams

high volume,
low concentration
low volume,
high concentration
*AFfected \ource only at ne
I
Digester System
Knotter
System
Pulp Washing System
Screen System
and Decker System
Pulp to Bleaching Systems, Pulp
Dryers, or Papermaking System
Figure 10.

Example Sulfite Pulping System
32
-------
Semi-chemical pulp is
generally not
bleached.
2.6 Semi-chemical mills

Semi-chemical pulping involves partial digestion of wood chips in a weak
chemical solution such as sodium sulfite (Na2SO3) and sodium carbonate
(Na2CO3) followed by mechanical refining for fiber separation. Semi-
chemical pulp is very stiff, making this process common in corrugated
container manufacture. Figure 11 shows an overview of a typical semi-
chemical pulping system.
Chapter 2 - Pulping a,
Bleaching Process
33
-------
—^ > liquid streams

HVLC- high volume,
low concentration

LVHC • low volume
high concentration
Digester System
Refiners
Pulp Washing System*

Collection System
• HVIC
Refiners
Pulp to Pulp Dryers
or Papermaklng System.
'Aflecud source only at new solaces
Figure 11.

Example Semi-chemical Pulping System
34
-------
Bleaching systems
that use chlorine or
chlorine dioxide are
the only emission
sources at
mechanical,
secondary fiber, and
non-wood fiber mills
affected by the pulp
and paper NESHAP.
Secondary fiber
mills make pulp
from recycled
paper and other
products.
2.7 Mechanical, secondary fiber, and non-wood fiber
pulp mills

Mechanical pulping

Mechanical pulping uses physical pressure instead of chemicals to separate
wood fibers. Mechanical pulping processes have the advantage of
converting up to 95 percent of the dry weight of the fiber source into pulp,
but require an enormous amount of energy relative to chemical pulping.
Mechanically produced pulp is of lower strength than chemically produced
pulp and is used principally for newsprint and other non-permanent paper
goods.

Mechanical pulps are brightened with hydrogen peroxide (H2O2) and/or
sodium sulfite (Na2SO-,). The brightening chemicals are applied during the
pulp processing stage (e.g., in-line brightening), or in chemical application
towers. These chemicals only brighten the pulp and do not permanently
bleach the pulp. Typically, bleaching of mechanical pulps using chlorine or
chlorine dioxide is not practiced because of the high cost of bleaching
chemicals and negative impact on pulp yield.

Secondary fiber pulping

Secondary fibers include any fibrous material that has undergone a
manufacturing process and is being recycled as the raw material for another
manufactured product. Secondary fibers have less strength and bonding
potential than virgin fibers. The fibrous material is dropped into a large
tank, or pulper, and mixed by a rotor. The pulper may contain either hot
water or pulping chemicals to promote dissolution of the paper matrix.
Debris and impurities are removed by "raggers"(\vires that are circulated in
the secondary fiber slurry so that debris accumulates on the wire) and
"junkers" (bucket elevators that collect heavy debris pulled to the side of the
pulper by centrifugal force).
Chapter 2 - Pulping a
Bleaching Procest
35
-------
The NESHAP does
not apply to mills
that rewater
purchased pulp
(e.g., dried bales or
sheets of pulp being
made into a slurry).
Non-wood fiber pulping

Non-wood pulping is the production of pulp from fiber sources other than
trees. Non-wood fibers used for papermaking include straws and grasses
(e.g., flax, rice), bagasse (sugar cane), hemp, linen, ramie, kenaf, cotton, and
leaf fibers. Pulping of these fibers may be performed by mechanical means
at high temperatures or using a modified kraft or soda process. Non-wood
fiber pulp production is not common in the U.S.
Chapter 2 - Pulping nr
Bleaching Process*
36
-------
2.8 References for Chapter 2

Biermann, C.J. 1993. Essentials of Pulping and Papermaking. San Diego,
CA: Academic Press, Inc.

Burgess,!. 1995. The Basics of Foul Condensate Stripping. 1995 Kraft
Recovery Short Course. Atlanta, GA: TAPPI PRESS.

EPA. 1995. Office of Compliance Sector Notebook Project: Profile of the
Pulp and Paper Industry. EPA/310-R-95-015. Office of Enforcement and
Compliance Assurance, Washington, DC.

EPA. 1993. Pulp, Paper, Paperboard Industry - Background Information
for Proposed Air Emissions Standards for Manufacturing Processes at Kraft,
Sulfite, Soda, and Semi-chemical Mills. EPA-453/R-93-050a. Office of
Air Quality Planning and Standards, Research Triangle Park, NC.

Mimms. A., Kocurek. M.. Pyatte, J.. and Wright, E., eds. 1993. Kraft
Pulping. Atlanta, GA: TAPPI PRESS.

Smook, G.A. 1992. Handbook for Pulp and Paper Technologists. Second
Edition. Bellingham. WA: Angus Wilde Publications.
Chapter 2 - Pulping at
Bleaching Process
37
-------
A copy of the
April 15, 1998
NESHAP is in
Appendix B. Refer
to the UATWfor
correction notices
and amendments.

The NESHAP does
NOT apply to
paper mills unless
they also produce
pulp.

Find a list of HAP s
at http://www.epa.
gov/ttn/uahv/
pollsour.html
Chapter 3 - Overview of the Pulp and Paper
NESHAP
3.1 Which mills are subject to the NESHAP?

The pulp and paper NESHAP applies to existing and new major sources that
produce pulp, paper, or paperboard, and use any of these pulping processes:

• kraft using wood

• soda using wood

• sulfite using wood

• semi-chemical using wood

• mechanical using wood

• processes using secondary fibers or non-wood fibers

A major source is any mill that emits or has the potential to emit
(considering Federally enforceable controls) 10 tons per year (tpy) or more
of any HAP or 25 tpy or more of any combination of HAPs.
38
-------
General Requirements
of the NESHAP:
• vent control on
pulping systems
• treatment of
condensa tes from
kraft pulping
systems only
• vent control on
bleaching systems
• elimination of
certain bleaching
chemicals
• no control of
papermaking
systems
3.2 What processes and equipment systems must be
controlled?

The NESHAP has separate emission limits for pulping system vents,
pulping process condensate streams, and bleaching systems. The
applicability of these standards varies depending on the type of mill.
If the Mill is
This Type...
Kraft
Sulfite
Semi-chemical
Soda
Mechanical
Secondary Fiber
Non-Wood Fiber
Then the NESHAP Covers
Pulping Pulping
System Vents Condensates
X X
X
X
X

These Processes...
Bleaching Systems
That Use the
Following
Compounds
Chlorine or any
chlorinated compound
Chlorine or any
chlorinated compound
Chlorine or any
chlorinated compound
Chlorine or any
chlorinated compound
Chlorine or chlorine
dioxide
Chlorine or chlorine
dioxide
Chlorine or chlorine
dioxide
Chapter 3 - Overview
NESHj
39
-------
For purposes of
this NESHAP,
LVHC systems are:
• digester
system
• turpentine
recovery system
• evaporator
system
• steam stripper
system
• any other
system serving
one of these
functions

Systems that are
not regulated:
• wood yards
• pulping systems
at mechanical,
non-wood, and
secondary fiber
pulp mills
• tall oil recovery
systems
• causticizing
systems
• papermaking
systems
In addition, the specific pulping process vents covered by the standards vary
depending on the type of mill and the classification of the pulping system as
a new or existing source. See Figure 12. The applicability and control
requirements of each type of mill are explained in detail in Chapters 4
through 7.
Figure 12.
Equipment Systems Covered by the
Pulping Vent Standards
If the
Mill is
This
Type-
Kraft
Soda
Sulfite
Semi-
chemical
£
Then These Equipment Systems are
Covered at Existing Sources...
• LVHC systems
• Pulp washing system
• Oxygen delignification system
• Decker systems that use any process water
other than fresh water or paper machine
white water or any process water with
total HAPs concentration > 400 ppmw
• Knotter systems with HAP emissions
greater than 0.05 kg/Mg oven-dried pulp
• Screen systems with HAP emissions
greater than 0. 1 kg/Mg oven-dried pulp
• Combined knotter and screen systems with
HAP emissions greater than 0.15 kg/Mg
oven-dried pulp
LVHC systems
• Digester system
• Evaporator system
• Pulp washing systems
LVHC systems
And These Equipment
Systems are Covered at
New Sources .~
Same as existing sources
plus all...
• Decker systems
• Screen systems
• Knotter systems
• Weak liquor storage
tanks
Same as existing sources
plus all...
Pulp washing systems
Same as existing sources
plus all...
• Weak liquor storage
tanks
• Strong liquor storage
tanks
• Acid condensate storage
tanks
Same as existing sources
plus all...
Pulp washing systems
b See Appendix F for a list of specific equipment within each system.
See page 49 for the definition of a new source.
Chapter 3 - Overview
NESH,
40
-------
The NESHAP has
one alternative
emission limit for
pulping system
vents, pulping
condensates, and
bleaching systems
that does not
require testing and
monitoring.
3.3 What are the emission control requirements?

The NESHAP provides several alternative emission limits for the pulping
vent standard, pulping condensates standard, and bleaching system standard.
For each regulated emission point, a mill can choose the emission limit with
which to comply and can use any emission control technology to achieve
compliance.

The format (e.g., percent reduction or outlet concentration) of the alternative
emission limits varies depending on the type of mill (Figure 13). For ease
of explanation, Figure 13 provides only the formats of the alternative limits,
since the actual emission limits vary depending on the type of mill. The
emission limits for each type of mill are presented in Chapters 4 through 7
and are summarized in Appendix G.

Where two or more pulping processes share a piece of equipment, that piece
of equipment is considered a part of the pulping process type with the more
stringent NESHAP requirements for that piece of equipment.
Chapter 3 - Overview
NESM
41
-------
Figure 13.
Alternative Emission Limits
For the Following
Standards...
The Regulated
Pollutant is...
And a Mill Can Choose One of the
" * &
Following Emission Limits ...
Pulping system vents

•Kraft
• Soda
• Semi-chemical
Total HAPs
Percent reduction
Outlet concentration (parts per
million by volume) for thermal
oxidizer
Design specification for thermal
oxidizer
Duct vents to a boiler, recovery
furnace, or lime kiln
Pulping system vents
• Sulfite
Total HAPs
Percent reduction
Mass emission limit (Ib/ton oven-
dried pulp)
Pulping system condensates
•Kraft
Total HAPs
Recycling to equipment subject to
pulping standards
Biological treatment
Percent reduction (HAP mass in
the condensates)
Mass removal (Ib/ton oven-dried
pulp)
Outlet concentration (parts per
million by weight)
Bleaching system
• Kraft
• Soda
• Sulfite
Chlorinated HAPs
(other than
chloroform)
• Percent reduction
• Outlet concentration (ppmv) from
the treatment device
• Mass emission limit (Ib/ton oven-
c
dried pulp)
• Eliminate use of chlorinated
compounds
Chloroform
• Eliminate use of hypochlorite and
chlorine
• Effluent (water) limitations
Emission limits vary for different types of pulping systems and control devices. A mill will likely use several
closed-vent systems and each one can comply with any of these alternative emission limits.
Percent reduction and mass emission limits apply to sulflte pulping system vents, and any emissions from vents,
wastewater, and condensate streams from the control device.
Mass emission limit applies to total emission from all regulated bleaching stages in the bleaching system.
Chapter 3 • Overview
NESH,
42
-------
3.4 What control systems will mills typically use to
meet the emission limits?

The control systems that most mills are likely to use to meet the emission
limits shown in Figure 13 are listed below:

• Pulping system vents

thermal oxidizers
power boilers, lime kilns, recovery furnaces

• Pulping process condensates

steam strippers
biological treatment
recycling to pulping equipment that is controlled by
the NESHAP

• Bleaching system vents

caustic scrubbers (for chlorinated HAPs, other than
chloroform)
process modifications to eliminate the use of chlorine
and hypochlorite
Chapter 3 - Overview
NESh
43
-------
Figure 14 explains
in general how
mills must
demonstrate
compliance with
the NESHAP.
Administrator
means an
authorized
representative of
the EPA (e.g., a
State that has been
delegated the
authority to
implement and
enforce this
NESHAP).
3.5 How do mills demonstrate initial and continuous
compliance?

In general, mills must conduct an initial performance test and then
continuously monitor a set of control device or process operating
parameters. Exceeding a monitoring parameter will constitute a violation of
the standard.

Initial performance test. A performance test is required for most sources
regulated by this NESHAP. The performance test serves two purposes:

(1) To demonstrate that the control device complies with the
emission limit (Figure 14 explains the pollutants that must be
measured and the allowable surrogates that a mill may
choose to measure as an alternative)

(2) To establish the process operating parameter values (e.g., fire
box temperature for thermal oxidizers) that must be
monitored to demonstrate continuous compliance with the
standard

The NESHAP specifies the required monitoring parameters for most control
devices. If a mill uses a control device for which the monitoring parameters
are not specified, then the mill must propose and demonstrate, to the
satisfaction of the Administrator, a set of monitoring parameters that can
prove continuous compliance with the NESHAP. During the performance
test, mills must test simultaneously for emissions and monitor the
appropriate operating parameters to establish the parameter values (e.g., the
specific fire box temperature) that constitute continuous compliance.
Chapter 3 - Overview
NESH
44
-------
The NESHAP
generally requires
continuous
monitoring of
operating
parameters (not
emissions) to
demonstrate
compliance.
Continuous monitoring. Continuous monitoring is used to demonstrate
that a mill is in compliance with the NESHAP at all times. Mills must
continuously monitor operating parameters and report all instances where
the values deviate from the maximum or minimum values established
during the initial performance test. As an alternative, mills may install a
continuous emissions monitor.

Recordkeeping and reporting requirements. Mills must comply with the
recordkeeping and reporting requirements of the NESHAP General
Provisions (40 CFR 63) and those of the pulp and paper NESHAP. These
requirements include initial notifications, retaining records of performance
tests and monitoring data, and periodic reporting of periods of excess
emissions. Table 1 of Appendix B identifies which sections of the General
Provision requirements apply and which are overridden by this NESHAP.

In addition, the pulp and paper NESHAP requires some mills to submit a
control strategy report. The control strategy report must be submitted with
the initial notification (by April 15, 1999) and updated every 2 years until
compliance is achieved. The report must include the following:

• description of emission controls or process modifications
selected for compliance

• compliance schedule

• a report on the progress of installing the emission controls or
process modifications during the past 2-year period.

The control strategy report is required only if a mill uses one of the
following strategies that provide either additional compliance time or
compliance flexibility:

• Bleaching systems that comply with the Voluntary
Technology Advanced Incentives Program (see page 70)

• HVLC system vents that comply after April 16, 2001

• HVLC system vents that comply with the Clean Condensate
Alternative (see page 75)
Chapter 3 - Overview
NESHj
45
-------
Figure 14.
What Pollutants or Surrogates Must Be Measured?
If These Systems are
Covered by the
NESHAP-.
Pulping
Bleaching
Condensates
Biological
treatment
Steam stripping
Then the
Regulated
Pollutant is...
Total HAPs
Chlorinated
HAPs (excluding
chloroform)
Chloroform
Total HAPs
(in condensates)
Total HAPs
(in condensates)
And a
Performance
Test is Required
at this
Frequency ...
Initially
Initially
None
Quarterly
Initially
And a Mill Ma?
Choose to Test
for this
Surrogate
Pollutant...
Methanol
Chlorine
~
Methanol
Methanol
And These
Parameters
Must be
Continuously
Monitored
Operating
parameters or
methanol outlet
concentration
Operating
parameters or
chlorine outlet
concentration
None
Operating
parameters
(daily)
Operating
parameters or
methanol outlet
concentration
The U.S. EPA or the delegated authority may require an owner or operator to conduct performance tests at the
affected facility at any other time when the action is authorized under Section 114 of the CAA (40 CFR subsection
63.7(a)(3)).
Compliance tests are conducted using the following methods:
Compound(s)
Total HAPs; methanol
Chlorinated HAPs
Chlorine
Total HAPs; methanol in
condensates
Methanol in condensates
Test method
M308
Any method approved by the Administrator
M26A

M305
NCASI GC/FTD
Q
A mill can comply by eliminating the use of chlorine and hypochlorite or by complying with the numerical limits
of the effluent limitations guidelines and standards for water in 40 CFR 430.
The initial performance test and 1st quarter percent reduction tests must be performed for total HAPs. However,
if a relationship between total HAPs and methanol destruction is established in the 1st quarter percent reduction
tests, methanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and 4th quarter tests.
e The National Council of the Paper Industry for Air and Stream Improvement (NCASI) direct injection gas
chromatography/flame ionization (GC/FTD) method may be used as an alternative to EPA Method 305.
Chapter 3 - Overview
NESH.
46
-------
For purposes of
this NESHAP,
HVLC systems are:
• knotter system
•pulp washing
system
• screen system
• oxygen
delignification
system
• weak liquor
storage tanks
3.6 When must mills comply?

The major compliance milestones for affected sources are shown below.
This information presents only a portion of the requirements faced by
owners and operators of pulp and paper mills. Appendix H provides the
detailed milestone compliance timeline for existing sources.
Affected Sources Must Comply by April 16, 2001...
Except for the Following...
New sources
»i
HVLC system vents at kraft mills
Dissolving grade bleaching systems
at kraft or sulfite pulping mills
Bleaching system at any mill
choosing to implement the
Voluntary Advanced Technology
Incentives Program for effluent
limitations guidelines and
standards
Which Must Comply...
At startup or by June 15, 1998,
whichever is later
Within 8 years (April 17, 2006)
Within 3 years of publication of the
revised effluent limitations
guidelines and standards
Within 6 years (April 15, 2004)
LVHC systems must still meet the April 16, 2001 compliance date (see page 55).
Dissolving grade bleaching systems are similar to bleaching systems at bleached kraft
or sulfite mills, but usually contain six to eight bleach stages for maximum delignification
and pulp cleanliness. The April 15, 1998 Cluster Rules did not publish effluent
limitations guidelines and standards for these subcategories. Development of these
revised rules is underway.
Refer to page 70.
Also, by April 15, 1999, the following is due:

• Initial notification

• Initial control strategy report
Chapter 3 - Overview
NESH
47
-------
For new sources,
the emission limits
are the same as
existing sources.
See page 49 for the
definition of a new
source.
3.7 What additional requirements apply to new
sources?

New sources at pulp and paper mills have more stringent compliance
requirements than existing sources. These include:

• More emission points must be controlled. For pulping
systems, the emission limits (see Figure 12) for new and
existing processes are the same, but more emission points
must be controlled at new sources. For bleaching systems
and pulping condensates, the emission limits and emission
points that must be controlled for new and existing sources
are identical.

• Earlier compliance dates. New sources must comply at the
date of startup or on June 15, 1998, whichever is later.

• Preconstruction approval. The owner or operator of mills
subject to the pulp and paper NESHAP must submit an
application to EPA for approval to construct any new source
that is subject to this rule. The preconstruction approval
process applies only if two conditions are met:

if the construction or reconstruction involves pulping
and/or bleaching system equipment as defined in
Section 3.8

the new or reconstructed source in and of itself is a
major source

Construction must not commence until the EPA Administrator
approves the application. The EPA Administrator will approve the
application after determining that the source, if properly constructed,
will not cause a violation of the NESHAP. The requirements for the
submission and approval of construction applications are contained
in 40 CFR 63.5 (e) and (f).
Chapter 3 - Overvie\
NESI
48
-------
The definition of a
new source is
different under the
Clean Water Act.
See 40 CFR 122.2
and
40 CFR 430.01 (j)
for the definition of
a new source for
effluent limitations
guidelines and
standards, and
pretreatment
standards.
Upon
reconstruction, an
existing source
immediately
becomes subject to
the new source
requirements!
3.8 What is a new source?

What constitutes a new or reconstructed source for each mill type that is
subject to this NESHAP is defined below.
A New
Source at a ...
Kraft mill,
Soda mill,
Semi-
cherrucal mill,
or
Sulfite mill.
Mechanical
pulping mill
Other mills
Using...
Wood
Wood
Secondary
or non-
wood fibers
Is the Construction of Any
One of the Following...
• A new mill
• New pulping system
• New bleaching system
• Additional pulping line
• Additional bleaching line
• Bleaching system
• Bleaching line
• Bleaching system
• Bleaching line
Or the
Reconstruction* of
Any One of the
Following—
• Pulping system
• Bleaching system
Bleaching system
Bleaching system
That
Commences
After...
12/17/93
03/08/96
03/08/96
Reconstruction means replacement of components to the extent that the fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost that would be required to construct a
comparable new source. (40 CFR 63.2 Suhpart A).
What is an "Additional Line?" An additional line means a line that adds
capacity to an existing pulping or bleaching system. For example, consider a
mill with two existing pulping lines. The construction of a third line would
constitute an additional line and would be subject to new source controls. On
the other hand, a like-kind replacement of one of the lines would not be
considered an additional line. However, the replacement of one of the lines
with a new line that increases the capacity of the pulping system would be
considered an additional line that is subject to the new source requirements.

What Does "Reconstruction" Mean? Reconstruction means the replacement
of components to the extent that the fixed capital cost of the new components
exceeds 50 percent of the fixed capital cost that would be required to construct
a comparable new source. If this condition is met, upon construction, an
existing source immediately becomes subject to the MACT standards for new
sources irrespective of any change in emissions of HAPs. See 40 CFR 63.2
and 63.5.
Chapter 3 - Overview
NESM
49
-------
The pulp and paper NESHAP defines either the entire pulping system or
bleaching system as the equipment to which the 50 percent criterion is applied.
For example, consider a mill that is refurbishing one of its two pulping lines by
replacing worn out equipment or components. To determine if reconstruction
occurs, the replacement costs would be compared to the construction costs for
replacing the entire pulping system (e.g., both lines). If the replacement cost is
less than 50 percent, the line is treated as an existing source. However, if the
cost exceeds 50 percent, then the replacement/construction project would be
deemed as a reconstruction of the pulping system, and both lines would
become subject to the new source provisions, even if emissions after the
reconstruction are the same or decrease.
Chapter 3 - Overvfa
NESl
50
-------
Systems that are
not regulated:
• wood yards
• tall oil recovery
systems
• causticizing
systems
•papermaking
systems
The CCA focuses
on reducing HAP
emissions
throughout the mill
by reducing the
HAP mass in
process water
streams that are
recycled to various
process areas in
the mill.
Chapter 4 - NESHAP Requirements
for Kraft Mills
For kraft mills, the NESHAP contains emission standards for pulping
system vents, pulping process condensates, and bleaching system vents.

There are several alternative emission limits for each process covered.
Compliance times will vary based on the process and emission limit
selected, even within the same mill. This designed flexibility promotes and
encourages new technologies, particularly joint air/water controls and
pollution prevention technologies.

The NESHAP also includes an option called the Clean Condensate
Alternative (CCA). The CCA applies only to kraft pulping system vent
standards for the HVLC system and features both pollution prevention and
emission averaging. The CCA is described on page 75.
If You Need the Following Information...
Then Read..
Standards for kraft pulping system vents

Standards for kraft pulping process
condensates

Standards for kraft bleaching system vents

Description of the clean condensate alternative

Comparison of requirements for the NESHAP
and the NSPS
Section 4.1

Section 4.2

Section 4.3

Section 4.4

Section 4.5
51
-------
For purposes of this
NESHAP, the LVHC
system includes all
vents from:
• digester system
• turpentine recovery
system
• evaporator system
• steam stripper
system

and

The HVLC system
includes all vents
from:
• pulp washing
system
• knotter system
• screen system
• decker system
• oxygen
delignification
system
• weak liquor storage
tanks

The combined
knotter and screen
system limit applies
if the mill is unable
to differentiate
emissions between
the two systems.
4.1 Standards for kraft pulping system vents

The NESHAP requires the pulping system emission points to be enclosed,
collected in a closed-vent system, and then vented to a control device. This
section describes the emission points that must be controlled, the four
alternative emission limits, and the compliance requirements.

What kraft pulping system vents must be controlled?

The NESHAP specifies that vents from the mill systems must be controlled.
All the vents from the LVHC system must be controlled. The HVLC vents
requiring control vary based on the quantity of emissions and whether the
source is new or existing.
The Following Pulping Systems Must be Controlled ...
Existing Sources
LVHC system
• Pulp washing system
• Oxygen delignification system
• Decker systems that use any process water other than fresh water or paper
machine white water, or process water with a concentration of HAPs greater
than 400 parts per million by weight (ppmw)
• Knotter systems with HAP emissions equal to or greater than 0.1 pounds per
ton oven-dried pulp
• Screen systems with HAP emissions equal to or greater than 0.2 pounds per ton
oven-dried pulp
• Combined knotter and screen systems with HAP emissions equal to or greater
than 0.3 pounds per ton oven-dried pulp
New Sources
• Same as existing sources plus...
• All decker systems
• All screen systems
• All knotter systems
• All weak liquor storage tank vents
Each equipment system has multiple emission points. For example, the evaporator system
comprises pre-evaporators, multi-effect evaporators, concentrators, vacuum systems,
associated condensers, hot wells, and condensate streams. A complete list of the emission
points in each equipment system is provided in Appendix F.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
52
-------
These emission
limits apply to each
control device.
A fifth alternative is
available for krafi
HVLC system vents
only. See
Section 4.4 for an
explanation of the
Clean Condensate
Alternative.
What are the emission limits for kraft pulping system vents?

The emissions from kraft pulping system vents must meet one of four
alternative emission limits, as shown below. These emission limits apply to
each control device used to control HAP emissions. A mill will likely use
several closed-vent systems and control devices (including both add-on
control devices and existing combustion devices) and each can comply with
any of these four alternative emission limits. These emission limits apply to
both new and existing sources.
Pulping System Vent Gases Must be Collected in a Closed-vent
System and Routed to One of These Four Control Devices...
3.
4.
A boiler, lime kiln, or recovery furnace in which the HAP gas
stream is introduced with the primary fuel or into the flame zone

A thermal oxidizer operated at a minimum temperature of 1,600°F
and a minimum residence time of 0.75 seconds

A thermal oxidizer that reduces the total HAP concentration at the
outlet to < 20 ppmv corrected to 10% O2 on a dry basis, measured
as total HAPs or methane!
Any control device that reduces total HAP emissions by >98% by
weight, measured as total HAPs or methanol
Chapter 4 - NESHAP Requirement*
Kraft Milk
Pulping System Ventt
53
-------
A closed-vent
system means a
system that is not
open to the
atmosphere and
comprises piping,
ductwork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems?

All regulated equipment system vents must be enclosed and routed through
a closed-vent system to the control device that is selected for compliance.
The requirements for enclosures and closed-vent systems are presented
below. The requirements are intended to prevent leaks and ensure that
process openings (e.g., sampling ports on a brown stock washer enclosure)
are closed while the mill is in operation.
This Equipment...
Must Meet These
Requirements....
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance,
or repairs
Components operated at positive
pressure
Operate with no detectable leaks
(500 parts per million by volume
[ppmv] VOC above background)
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so that
the valve or closure mechanism
cannot be opened without breaking
the seal
or
If computer controlled, monitor for
presence of gas stream flow at least
once every 15 minutes
Chapter 4 • NESHAP Requirement
Kraft Mills
Pulping System Vents
54
-------
Compliance Dates:

LVHC system:
April 16, 2001

HVLC system:
April']7, 2006
HVLC systems that
comply before
April 16, 2001 are
not required to
submit a
compliance
strategy report.
When must mills comply with the kraft pulping vent standards?

The LVHC system sources at kraft mills must comply with the NESHAP by
April 16, 2001, while the HVLC system sources must comply by
April 17,2006.

For HVLC system vents complying after April 16, 2001, a non-binding
compliance strategy report must be submitted initially and updated every
2 years until compliance is achieved. The compliance strategy report must
contain, among other information, a description of the emission controls or
process modifications selected for compliance and a compliance schedule
indicating when each step toward compliance will be reached.

For safety purposes, kraft mills typically separate pulping vent streams into
two groups: low volume, high concentration (LVHC) vent streams and high
volume, low concentration (HVLC) vent streams. The NESHAP does not
specify which vents must be routed to the LVHC and HVLC collection
systems. Each mill makes this decision. However, compliance dates are
based on EPA's definition of LVHC and HVLC system equipment, and
these compliance dates do not change based on how a mill chooses to
collect their system vents. For example, a mill could control an evaporator
vent (LVHC source) along with a group of HVLC vents. In such cases, the
emissions from this closed-vent system would have to comply by
April 2001. because 2001 is the compliance date specified for the LVHC
system source.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
55
-------
The test method
specified is used to
determine pollutant
concentration.
Additional
calculations or
formulas are
specified in the
NESHAP to
convert the
concentration
values into the
appropriate format
to demonstrate
compliance with a
particular emission
limit.
How does a mill demonstrate initial compliance with the kraft
pulping system vent standards?

A mill must demonstrate compliance through an initial performance test for
each closed-vent system and control device. However, the rule contains two
alternative emissions limits for which an initial performance test of the control
device is not required. If a mill complies with the pulping system vents
standards by venting the gases to a boiler, lime kiln, or recovery furnace, the
mill must demonstrate only that the gases are being introduced with the
primary fuel or into the flame zone. Also, if a mil! complies with the pulping
system vents standards by venting the gases to a thermal oxidizer operating at
the minimum design specifications, the mill must demonstrate only that the
gases are being properly introduced into the thermal oxidizer.

The initial performance test has three objectives:

(1) To demonstrate that each control device complies with the emission
limit. Refer to Figure 15.

(2) To demonstrate that the closed-vent system captures and contains
all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that must be
monitored to demonstrate continuous compliance. For example, the
test would establish the minimum fire box temperature of the thermal
oxidizer that indicates 98 percent by weight reduction of total HAPs.

Figure 15.
How Does a Mill Demonstrate Initial Compliance with
the Kraft Pulping System Vent Emission Limits?
To Demonstrate Initial
Compliance With This
Emission Limit...
Introduce HAP emission
stream with the primary
fuel or into the flame zone
Operate at a minimum
temperature of l,600°F
and a minimum residence
time of 0.75 seconds
Reduce the total HAP
concentration at the outlet
to $ 20 ppmv corrected to
10% O, on a dry basis
Reduce total HAP
emissions by >9H9< by
weieht
Conduct an Initial
Performance Test
Following This Method...
None required
Demonstrate that gases are
properly introduced.
None required
Method 308
Method 308
To Measure These
Parameters...
None required
None required
Total HAP or methanol
concentration at the outlet
of the thermal oxidizer
Total HAP or methanol
mass at the control device
inlet and outlet
Chapter 4 - NESHAP Requirement
Kraft Mills
Pulping System Vents
56
-------
Continuous
monitors are
required except for
vent streams that
are combusted in a
lime kiln, recovery
furnace, or boiler.
These same tests
are required as
part of the initial
performance test.
How does a mill demonstrate continuous compliance with the
kraft pulping system vent standards?

Mills must install a continuous monitoring system to measure either HAP
concentration or control device operating parameters. Figure 17 presents
the monitoring, reporting, and recordkeeping requirements for each
alternative emission limit.

In addition, a mill must periodically inspect and maintain all enclosures and
closed-vent systems. These requirements are explained in Figure 16. The
mill must maintain a site-specific inspection plan for the enclosures and
closed-vent system. Records of all inspection results and repairs must also
be kept according to the specifications of 40 CFR 63.454.

Figure 16.

How Does a Mill Demonstrate initial and Continuous Compliance with
the Closed-Vent Systems Standard?
If the System has...
Enclosure opening
Closed-vent system
Positive pressure
closed-vent system
Bypass line valve
Then Inspect-
Visually inspect e\ery 30
days to ensure closed and
sealed
Annually demonstrate
negative pressure
Visually inspect every 30
days for visible detects
Annually demonstrate no
detectable leaks (less than
500 ppmv)
Inspect every 30 da\s to
ensure valve is in a closed
position and vent stream is
not diverted through
bypass line
And Report...
Any exceedences of the
closed-vent standard in
quarterly reports. If no
exceedences occur, submit
semi-annual reports.
Same as above
Same as above
Same as above
Same as above
And Keep
Records of...
All visual checks and
any repairs
All pressure tests
All visual checks and
repairs
All leak tests
All visual checks and
repairs
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
57
-------
(J\
00
Figure 17.
How Does a Mill Demonstrate Continuous Compliance with the Kraft Pulping
System Vent Emission Limits?
If a Mill Chooses This
Alternative Emission
Limit...
Introduce HAP emission
stream with the primary
fuel or into the flame
zone
Operate at a minimum
temperature of 1 ,600°F
and a minimum
residence time of 0.75
seconds
Reduce the total HAP3
concentration at the
outlet to $ 20 ppmv
corrected to 1 0% O2 on a
dry basis
Reduce total HAP3
emissions by ^98% by
weight
Then Continuously Monitor These
Parameters...
None required
Fire box temperature
Fire box temperature
or
Total HAP concentration
When using a thermal oxidizer, monitor
fire box temperature
When using a control device other than
a thermal oxidizer or incineration,
operating parameters must be
established during the initial
performance test and approved by the
Administrator
And Report This Information... And Keep These Records for 5 Years...
None required None required
• Certify in the performance test report that Fire box temperature
the minimum residence time is achieved
• Semi-annual emissions and continuous
monitoring performance report
• If exceedences occur, then quarterly
reports are required (40 CFR 63.10(e))
• Semi-annual emissions and continuous Fire box temperature
monitoring performance report
• If exceedences occur, then quarterly
reports are required (40 CFR 63.10(e))
3
Same as above Total HAP concentration
Same as above Fire box temperature
Same as above Parameters approved by the Administrator
Methanol may be used as a surrogate for total HAPs.
Administrator means an authorized representative of the EPA (e.g., a State that has been delegated the authority to implement and enforce this
NESHAP).
-------
Must a mill comply at all times?
The NESHAP does
not specify rigid
averaging times,
but rather allows
State permitting
authorities
flexibility in
establishing mill-
specific times.
Check the UATW
periodically for
additional
information
concerning
averaging times.
For pulping system vents, the NESHAP establishes an allowable percent of
operating time during which HAP emission levels in excess of the
established limit shall not be considered to be a violation of the standard.
Periods of excess emissions include when the control device is inoperable
and when the operating parameter values established during the initial
performance test cannot be maintained at the appropriate level. The
allowance is in addition to excused periods under the startup, shutdown or
malfunction provisions, and is calculated by dividing the time of excess
emissions by the total process operating time in a semi-annual reporting
period.

The excess emissions allowances are:

• 1 percent of operating time for control devices used for
LVHC system vents

• 4 percent of operating time for control devices used for
HVLC system vents

• 4 percent of operating time for control devices used for
combined LVHC and HVLC system vents (i.e., controlled by
the same device)

Even though periods of excess HAP emissions may be exempt under the
MACT requirements, these periods of excess emissions must still comply
with NSPS total reduced sulfur (TRS) requirements, and any applicable
State requirements.

To calculate the percent of periods of excess emissions in a semi-annual
period, divide the number of hours in the reporting period during which the
control device was not operating or parameter deviations occurred by the
total number of process operating hours and multiply by 100 percent. For
example, to calculate the semi-annual excess emissions for an LVHC
system control device where the device down time was 25 hours and the
total process operating time was 4,250 hours:
Control device down time
Total process operating time
x 100%
25 hours
4,250 hours
x 100% = 0.59%
Chapter 4 - NESHAP Requiremem
Kraft MIL
Pulping System Ven\
59
-------
The condensate
streams subject to
control and the
alternative emission
limits are the same for
new and existing
sources.
Liquid streams
intended for
byproduct recovery,
such as the combined
turpentine/water
streams prior to the
turpentine decanter or
concentrated black
liquor, are not
considered process
condensate streams
subject to the control
requirements of this
regulation.
4.2 Standards for kraft pulping process condensates

The NESHAP requires condensate streams from the pulping system to be
collected in a closed collection system and treated. The NESHAP provides
five alternative emission limits (shown on page 61). This section describes
the condensates that must be controlled and the alternative emission limits.

What is a condensate and why control it?

Kraft pulping condensates are HAP-containing liquids that are condensed
from pulping system vent streams. These HAP-containing liquids result
from the contact of water with organic compounds in the pulping process.
In absence of these Cluster Rules, most condensates would be discharged
into open collection systems and transported to either the wastewater
treatment plant or a publicly owned wastewater treatment plant. The
emissions of concern are the HAPs that volatilize as the condensates travel
through these open systems.

What kraft pulping condensates must be controlled?

The NESHAP requires control of condensates from all of the equipment in
the following systems:

• digester system

• turpentine recovery system

• evaporator system (condensates from weak liquor feed stage
vapors and vacuum systems only).

• LVHC collection system

• HVLC collection system

The LVHC and HVLC collection system condensates means those
condensates generated by the condensation of moisture in the closed-vent
collection systems that convey the LVHC and HVLC system vent gases to a
control device.
Chapter 4 - NESHAP Requiremei.
Kraft Mills
Pulping Process Condensates
60
-------
Does the mill have to collect all those streams?
By segregating
condensate streams
containing the
greatest amount of
HAP and treating
only these streams, an
equivalent emission
reduction can be
achieved at a lower
cost.
Most mills are
expected to use
steam stripping for
alternative
emission limits 4
and 5.
No. A mill may choose to collect and control all the condensate streams
from the equipment systems listed on page 60. Alternatively, the NESHAP
contains two options for minimizing the volume of condensate that must be
treated (referred to as volume reduction options). These options are
summarized below.
A Mill Must Collect and Control One of the Following
Combinations of Streams...
All condensate streams
Volume reduction option 1: Treat all LVHC and HVLC collection system
streams plus streams that contain 65% of the total HAP mass from the digester
system, turpentine recovery system, and evaporator system (only condensates
from weak liquor feed stage vapors and vacuum systems)
Volume reduction option 2: Treat any subset of the regulated streams that
contain m total 7 2 Ibs HAP per ton of oven-dried pulp at mills that do not
perform bleaching or 11 1 Ibs HAP per ton of oven-dried pulp at mills that
perform bleaching ^
What are the control requirements?

The NESHAP provides five alternative emission limits for condensate
streams as shown below. The three strategies expected to be used by most
mills are: recycling, biological treatment, and steam stripping.
Kraft Pulping Process Condensates Must be Collected in a Closed-collection
System and Treated to Meet One of These Five Alternative Emission Limits...
1. Recycle the condensate to a piece of equipment that meets the control standards
lor pulping system vents (see page 53)

2. Use a biological treatment system to reduce or destroy the total HAPs by
>92% by weight

3. Treat the condensates to reduce or destroy the total HAPs by s92% by weight

4 Treat the condensates to remove 10.2 pounds HAPs per ton of oven-dried pulp
at mills performing bleaching or 3.3 pounds HAPs per ton of oven-dried pulp
at mills that do not perform bleaching

5. Treat the condensates to achieve a total HAP concentration of £330 ppmw at
the outlet of the control device at mills that perform bleaching or s210 ppmw at
the outlet of the control device at mills that do not perform bleaching
Measured as total HAPs only.
Measured as total HAPs or methanol.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
61
-------
The condensate
tank requirement
applies only to
tanks used to store
or handle the
regulated
condensates, not
tanks used to store
weak liquor.
What does the NESHAP require for condensate closed
collection systems?

Regardless of the emission limit selected, the condensates subject to control
must be transported in a closed collection system such that no emissions
occur. The NESHAP requirements for closed collection systems are
presented below.
This Equipment....
Must Meet ALL of These
Requirements....
Closed collection systems used to
transport pulping process condensates
containing HAPs
All of the individual drain system
requirements specified in §63.960,
63.961, and 63.962 of Subpart RRa
except that any air vents in the
collection system must meet standards
of §63.443 (c) and (d) for the closed-
vent systems and HAP reductions for
kraft pulping system vent emissions
Condensate tanks used in the closed
collection system
Operate with no detectable leaks
(500 ppmv VOC above background)
and
Vent emissions to a closed-vent system
(see page 54) and route to a control
device (see page 53)
and
When the tank contains pulping
process condensates or any HAP
removed from the pulping condensate
stream, all openings must be kept in a
closed, sealed position - except during
sampling, inspection, maintenance, or
repair operations
Subpart RR of 40 CFR 63 (National Emission Standards for Individual Dram Systemsj
establishes design, operating, inspection, and monitoring requirement standards for
controlling air emissions from individual drain systems. The standards control
emissions from individual drain systems using covers or seals, or hard-piping.
Subpart RR also requires inspections of water seals and closure devices for defects or
damage initially and establishes repair requirements for individual drain systems. The
NESHAP requires inspection every 30 days.
Chapter 4 - NESHAP Requiremenl
Kraft Mills
Pulping Process Condensates
62
-------
The mill can meet the closed collection system requirements in two ways:

• Hardpiping

• Use existing drains, but cover all openings and route all open
vents through a closed-vent collection system to a control
device meeting the NESHAP requirements for pulping
system vents.

If there are air vents off the closed collection system, these vents must be
routed to a closed-vent system. These air vents must comply with the kraft
pulping system standards for closed-vent systems and HAP emissions (see
pages 53 and 54).

When must a mill be in compliance?

Mills must achieve compliance with the pulping process condensate
requirements by April 16. 2001.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Compensates
63
-------
How does a mill demonstrate initial compliance for kraft pulping
process condensate standards?

Mills must conduct a performance test to demonstrate initial compliance. A
performance test is required for each closed collection system and treatment
option.

With respect to pulping condensates, the performance test serves four
purposes:

(1) To demonstrate that the appropriate condensate streams are
being collected and treated. The options for determining the
streams to be collected and controlled are presented on page 61. If a
mill uses one of the volume reduction options, the NESHAP
requires documentation to support the choice. For example, if a mill
opts to control condensate streams based on mass of total HAPs. the
mill must present test results to support that a complying mass of the
total HAPs is collected. Even in the case where a mill chooses to
collect and treat all pulping condensate streams, the mill must
demonstrate that all of the condensate streams have been identified
and collected.

(2) To demonstrate that the closed collection system does not allow
any emissions to occur. Refer to page 62.

(3) To demonstrate that the control device complies with the
emission limit. For all alternative emission limits except biological
treatment, the mill can measure either total HAPs or methanol
concentration to document compliance with the emission limits. For
biological treatment, total HAPs concentration must be measured.
See Figure 18.

(4) To establish the process operating parameter values that must
be continuously monitored. During the performance test, the mill
must measure the parameter values that the mill will monitor to
indicate continuous compliance. For example, the values of steam
feed rate, condensate feed rate, and temperature are specified as the
monitoring parameters for steam strippers.
Chapter 4 - NESHAP Requiremei.
Kraft Mills
Pulping Process Condensates
64
-------
For the recycle
treatment option,
the performance
test would consist
only of verifying
that no leaks were
present in the
closed collection
system and
confirming closed-
vent system and
control device
requirements.

The test method
specified is used to
determine liquid
stream pollutant
concentration.
Additional
calculations or
formulas are
specified in the
NESHAP to
convert the
concentration
values into the
format appropriate
to demonstrate
compliance with a
particular emission
limit.
Figure 18.
How Does a Mill Demonstrate Initial
Compliance with Kraft Pulping Condensate Emission Limits?
To Demonstrate Initial
Compliance With This
Emission Limit...
Recycle the condensate to
controlled equipment
Use a biological treatment
system to meet ^929r
reduction
Treat condensates to meet
>927c reduction
Treat the condensates to
meet mass limits
Treat the condensates to
meet concentration limits
Conduct an Initial
Performance Test
Following This Method...
None required
Method 305
and
Part 63. Appendix C
(e.g.. WATERS)
Method 305
Method 305
Method 305
To Measure These
Parameters...
None required
Total HAP concentration
and
Fraction of total HAPs
removed (fhlll)
Total HAP or methano!
mass at the control device
inlet and outlet
Total HAP or methanol
mass at the control device
inlet and outlet
Total HAP or methanol
concentration at the control
device outlet
How does a mill demonstrate continuous compliance with
pulping process condensate standards?

Mills must install continuous monitors to measure control device operating
parameters, except when recycling condensates to controlled process
equipment. In addition, quarterly percent reduction testing is required if a
mill chooses to comply using biological treatment. The monitoring
requirements depend on the alternative emission limit selected. Figure 19
summarizes the monitoring, reporting, and recordkeeping requirements for
each alternative emission limit.

The closed collection system must be visually inspected every 30 days
according to the following requirements:

• National Emission Standards for Individual Drain Systems
(63.964 subpart RR) requires inspection and monitoring

• Subpart S requires reporting and recordkeeping of all visual
inspection results. Semi-annual reports must be submitted.
If exceedences occur, then quarterly reports are required.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
65
-------
Figure 19.
How Does a Mill Demonstrate Continuous Compliance with Kraft Pulping Process Condensate Emission Limits?
If a Mill Chooses to
Comply With
Alternative Emission
Limits Using This
Technique...
Recycle the condensale
to controlled
equipment
Steam stripper (percent
reduction,
concentration, or mass
limits)
Steam stripper
(concentration)
Use a biological
treatment system
Other device
Volume reduction
options
Then Continuously Monitor All of
These Parameters...
None requiied
Process wastewater feed rale
Steam feed rate
Process wastcwalei column feed
temperature
Steam stripper outlet concentration
Quarterly test of percent HAP
reduction'
Outlet soluble BOD,;
Mixed liquor volatile suspended solids
Horsepower of aerator units
Inlet liquid flow
Liquid temperature
Operating parameters demonstrated to
the Administrator's satisfaction
Same as above
And Report This Information...
None icqwieJ
• Semi-annual emissions and continuous
monitoring performance report
« If cxcecdences occur, then quarterly
reports are required
(4()CFRfi3.K)(c))
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
And Keep These Records for 5 Years...
None required
Process wastewater feed rate
Steam feed rate
Process wastcwalei column feed
temperature
Steam stripper outlet concentration
Percent HAP reduction
Outlet soluble BOD,
Mixed liquor volatile suspended solids
Horsepower of aerator units
Inlet liquid flow
Liquid temperature
Parameters approved by the Administrator
Same as above
The initial performance test and 1st quarter percent reduction tests must be performed for total HAPs. However, if a relationship between total HAPs and
methanol destruction is established in the 1st quarter percent reduction tests, mcthanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and
quarter tests.
-------
Although there are
no explicit back-up
control
requirements as
part of the
NESHAP, back-up
controls may be
necessary for mills
that are concerned
that the excess
emission allowance
is inconsistent with
expected control
device operating
experience.
Must a mill comply at all times?

The NESHAP provides a 10 percent excess emissions allowance for all
control devices other than biological treatment systems (63 FR 49455). For
example, the allowance accounts for steam stripper tray damage or
plugging, efficiency losses in the stripper due to contamination of
condensate with fiber or black liquor, steam supply downtime, and
combustion control device downtime.

Unlike the pulping standard, the 10 percent allowance for condensates
includes excused periods of excess emissions associated with the startup,
shutdown, and malfunction.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
67
-------
Bleaching is the
brightening of pulp by
the addition of
oxidizing or reducing
chemicals.
A bleaching line is
a group of
bleaching stages
arranged in a
series such that
bleaching of the
pulp progresses as
the pulp moves
from one stage to
the next. Typically
a bleaching line
contains 3-5 stages.
4.3 Standards for the kraft bleaching system vents

At kraft mills, the emission limits apply to bleaching systems that use
chlorine or chlorinated compounds. The rules have emission limits for both
chloroform and chlorinated HAP. Kraft mills must comply with both of
these requirements. This section describes the emission points that must be
controlled, the alternative emission limits, and compliance requirements.

What bleaching emission points must be controlled?

The NESHAP applies only to bleaching lines that use chlorinated
compounds and only to the bleaching stages where chlorine or chlorinated
compounds are introduced. Extraction stages are not covered. All vents in
a regulated stage must be controlled. A stage consists of the following
equipment:

• retention towers

• washers

• seal tanks

• chemical and steam mixers (if vented to the atmosphere)

• vacuum pumps (if present)

Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or any chlorinated
HAP is exempt from all NESHAP requirements for bleaching.
Chapter 4 - NESHAP Requiremer.
Kraft Mills
Bleaching Systems
68
-------
The requirements for
enclosures and
closed-vent systems
are the same as for
the pulping system
vent standards
(page 54).
What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are
introduced must be enclosed and routed via a closed-vent collection system
to a control device. The rules provide three alternative emission limits for
demonstrating compliance, as shown below. Most mills are expected to use
caustic scrubbers to comply.
Bleaching System Gases Must be Collected in a Closed-vent System and Meet One
of These Three Alternative Emission Limits ...
3.
Reduce chlorinated HAP emissions by 99<7r by weight
Achieve a total outlet mass emission rate < 0.002 pounds chlorinated HAPs
per ton oven-dried pulp for all subject stages
Achieve an outlet concentration of chlorinated HAPs < 10 ppmv
Some mills may be able to meet the outlet concentration or mass limits through use of
process modifications (i.e.. 100 percent chlorine dioxide substitution). In these cases.
enclosures and closed-vent systems are not required.
Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or
as chlorine.

What are the control requirements for chloroform ?

The rules provide two alternative emission limits for chloroform control.
Both of these options (shown below) require process modifications. A mill
can comply by eliminating the use of chlorine and hypochlorite or by
complying with the numerical limits of the effluent limitations guidelines
and standards for water. If the compliance date for the effluent limitations
guidelines and standards is different than for the NESHAP, the NESHAP
compliance dates must be met.
To Reduce Chloroform Emissions From the Bleaching Process,
Use One of These Two Options...
1. Eliminate the use of chlorine and hypochlorite
2. Comply with applicable Effluent Limitations Guidelines and Standards
(40 CFR 430)a
Refer to Appendix I for a summary of the wastewater regulations for bleached papergrade
kraft mills.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
69
-------
Bleaching Systems
Compliance Dales:

Most mills:
April 16, 2001

Mills enrolled in
VATIP: April 15,
2004
VATIP is available
only to papergrade
kraft and
papergrade soda
mills that discharge
directly to
receiving waters.
When must bleaching systems comply?

Bleaching systems must comply by April 16. 2001 with two exceptions.

• Mills enrolled in the Voluntary Advanced Technology
Incentives Program (VATIP)

• Dissolving grade kraft mills

Voluntary Advanced Technology Incentives Program (VATIP). Under the
Effluent Limitations Guidelines and Standards (40 CFR Part 430.24), a mill
may choose to enroll one or more of its bleach lines in the Voluntary
Advanced Technology Incentives Program. The program provides extended
compliance with the water pollution control requirements for bleached
papergrade kraft and soda mills in exchange for achieving greater water
pollutant reductions than the regulatory baseline. Mills electing this
program receive a 3-year extension for complying with the NESHAP
bleaching standards (i.e.. must comply by April 15, 2004). Three conditions
must be met to qualify for the extension.

• No increase in the application rates of either chlorine or
hypochlorite (in kg per Mg oven-dried pulp) in the bleaching
system beyond current levels. The current application rate is
defined as the average daily rates used over the three months
prior to June 15. 1998. The application rate limitation is
provided to prevent a bleaching system from "backsliding"
(i.e.. increasing chlorinated bleaching chemical use during
the extended compliance period). EPA is considering
guidance and rule changes pertaining to "backsliding."
Check the TTN at www.epa.gov/ttn/uatw/uatwnew.html
for updates.

• Submit a control strategy report by April 1999.

• Submit an updated control strategy report every two years
under 63.455(b) until compliance is achieved. The report
must contain milestones and status reports for achieving
compliance.
Chapter 4 - NESHAP Requirement
Kraft Mills
Bleaching Systems
70
-------
The compliance
date for dissolving
grade krqft mills is
not specified in the
NESHAP, but is
anticipated
between
2003-2005.
Dissolving grade kraft mills must comply within 3 years after publication
of revised effluent limitations guidelines and standards under 40 CFR
430.14 through 430.17 and 40 CFR 430.44 through 430.47. These rules are
scheduled to be revised sometime between 2000 and 2002.

How does a mill demonstrate initial compliance with the
bleaching standards?

Chlorinated HAPs. Mills must demonstrate initial compliance with
chlorinated HAP standards by conducting an initial performance test for
each bleaching stage where chlorine or chlorinated compounds are
introduced.

The initial performance test has two objectives:

(1) To demonstrate that the control device complies with the
emission limit.

(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that
must be monitored to demonstrate continuous
compliance.

At the option of the mill, compliance may be demonstrated by measuring
either total chlorinated HAPs (including chloroform) or chlorine
concentration. The following methods must be used:
Chlorinated HAPs
Chlorine
Any method that has been
demonstrated to the Administrator's
satisfaction.

Method 26A, as modified by
63.457(b)(5) of the rules.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
71
-------
Continuous
monitoring is
required unless a
mill complies by
eliminating all use
of chlorine or
chlorinated
compounds as
bleaching agents.
These same tests
are required as
part of the initial
performance test.
Chloroform. No initial performance test is required if the mill chooses to
eliminate use of chlorine and chlorinated HAPs. The mill must demonstrate
in the initial notification that is not using these chemicals. Alternatively, if a
mill chooses to comply with the Effluent Limitations Guidelines and
Standards, then all compliance demonstration requirements of 40 CFR 430
apply.

How does a kraft mill demonstrate continuous compliance with
the bleaching standards?

For chlorinated HAPs, a continuous monitoring system must measure
either emissions, or control device or process operating parameters. The
monitoring, reporting, and recordkeeping requirements are summarized in
Figure 20.

For chloroform, if the mill chooses to eliminate the use of hypochlorite and
chlorine, then no parametric monitoring is required to show continuous
compliance. If the mill chooses not to eliminate the use of hypochlorite and
chlorine, then the mill must comply with the effluent limitations guidelines
and standards.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
12
-------
Figure 20.
How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlorinated HAPs?
If a Mill Chooses This
Technique to Comply
With This Alternative
Emission Limit-
Gas scrubber to reduce
chlorinated HAP
emissions by 999r by
weight or to achieve an
outlet mass emission
rate < 0.002 pounds
chlorinated HAPs per
ton oven-dried pulp
Gas scrubber to achieve
an outlet concentration
of chlorinated HAPs
< 10 ppmv
Any control device
other than a gas
scrubber or process
modifications
Continuously Monitor These
Parameters...
pH or oxidation/reduction potential ol
effluent
Vent gas inlet flow rate
Scrubber liquid influent flow rate
Chlorine concentration at the outlet or
measure all three of the following
parameters
pH or oxidation/reduction potential of
effluent
Vent gas inlet flow rate
Scrubber liquid influent (low rate
Determine appropriate monitoring
parameter values during the initial
performance test
Report This Information...
• Semi-annual emissions and continuous
monitoring perlormance report
• If exceedences occur, then quaiteily
reports are required
(40CFR63.10(e))
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
And Keep These Records for 5 Years...
pH or oxidation/reduction potential ot
effluent
Vent gas inlet flow rate
Scrubber liquid influent flow rate
Chlorine concentration or all of the
following
pH or oxidation/reduction potential of
effluent
Vent gas inlet flow
Scrubber liquid influent flow rate
Parameters approved by the Administrator
As specified in 40 CFR Part 63.453(n)
-------
Check the UATWat
www. epa. gov/ttn/
uatw/uatwnew.html
for updates.
Mills in the voluntary advanced technology incentives program must
monitor compliance in the interim!

The figure below summarizes the monitoring, reporting, and recordkeeping
requirements for mills enrolled in the VATIP that receive the 3-year
compliance date extension. These requirements apply from June 1998 up to
the time that the mill demonstrates compliance with all the applicable
bleaching system emission limits.
If a Mill
Chooses This
Alternative
Emission
Limit..
No increase in
the use of
hypochlorite
and chlorine

Then Continuously
Monitor These
Parameters...
Chlorine and
hypochlorite
application rates in
Ib/ton oven-dried
pulp (daily average)

And Report This
Information...
An initial control
strategy report by
April 1999 meets
the requirements of
63.455. Updated
control strategy
report every 2 years,
and
Daily application
rates of chlorine and
hypochlorite must
be reported every
six months

And Keep These
Records for
5 Years...
Daily application
rates

EPA is considering guidance and rule changes pertaining to
"backsliding" from existing controls during the initial period when a
mill is working toward meeting its voluntary advanced technology best
available technology (BAT). The change would make the restriction on
the daily application rates apply from April 2001 up to the time that the
mill demonstrates compliance with all the applicable bleaching system
emission limits.
Chapter 4 • NESHAP Requirements,
Kraft Mills
Bleaching Systems
74
-------
The CCA applies
only to the kraft
HVLC system:
• washers
• knotters and
screens
• deckers
• oxygen
delignification
4.4 Clean condensate alternative for HVLC vents

The clean condensate alternative (CCA) is a pollution prevention alternative
emission limit for pulping vents that is available only to kraft HVLC
systems. The CCA allows mills to meet the HVLC emission limits by
reducing the HAP concentration in the process waters that are recycled to
other pieces of process equipment. This approach allows mills to control
HAP emissions by reducing the amount of HAPs that are volatilized from
selected process equipment instead of using combustion devices to control
HVLC system vent streams. By reducing the HAP concentration in process
water, the amounts of volatilized HAPs are also reduced.

To achieve compliance, the facility must demonstrate that the HAP
emission reductions using the CCA technology are equal to or greater than
those emission reductions that would have been achieved through
compliance with the HVLC system requirements.

For example, a mill could use a stand-alone biological treatment device to
reduce the total HAP concentration in pulping process condensates. The
effluent from the stand-alone biological treatment device could be used as
process water in the pulping washing system and causticizing system. In
this scenario, initial compliance using the CCA would be demonstrated by
showing that the reduction of emissions from both the pulping washing
system and causticizing system is equal to or greater than the reductions that
would have been achieved by applying the pulping vent standards to the
pulp washing system vent emissions.
Chapter 4 - NESHAP Requirements -
Kraft Mills
Clean Condensate Alternative
75
-------
The CCA is similar
to emission
averaging.
The concept of the
CCA is the reduction
of HAP emissions
through reduction of
HAP concentration in
process water.
The CCA can be
used by both new
and existing
sources.
Which equipment systems can be used to generate the
emission reductions?

Process condensates are recycled throughout the mill. The CCA allows
mills to take credit for emission reductions achieved in several systems
through the use of CCA technologies.
Sources From Which Emission Reductions Can be Credited...
Pulping systems (HVLC)
Bleaching systems
Causticizing systems
Papermaking systems
What emission reductions are creditable?

A CCA technology must achieve the emission reductions by removing
HAPs from condensate streams. The CCA emission reductions are
generated by:

• control of condensates that are not regulated under the kraft
pulping condensate standard

• control beyond the levels required by the condensate
standard

Emission reductions from add-on controls on vent streams do not count.

Can a mill use the CCA for only part of the emission reduction
requirement for the HVLC system?

Yes. The HAP emission reductions resulting from the CCA can be used as
partial or complete fulfilment of the emission reductions required for the
HVLC pulping standard. For example, a mill may elect to use the CCA in
lieu of vent controls for the washer system, but comply by using vent
controls for the rest of the HVLC system.
Chapter 4 - NESHAP Requirements.
Kraft Mills
Clean Condensate Alternative
76
-------
All CCA emission
reductions must be
based on actual test
data.
How does a mill use the CCA?

A mill must follow these steps to implement the CCA:

(1) Determine baseline emissions. Baseline emissions are to be
measured after compliance has been achieved with all of the
following:

• Kraft pulping process condensate standards

• All effluent limitations guidelines and standards in
40 CFR subpart B

• Emission reductions attributable to control
technology required by local, State, or Federal
agencies

Furthermore, baseline emissions must include any control
equipment installed and operated before December 17, 1993.

(2) Calculate emission reductions that would have been achieved
through compliance with the kraft pulping HVLC system
standards.

(3) Measure emissions reductions achieved by the CCA.
(4)
Emission reductions _ Baseline
achieved bv the CCA emissions
Emission levels after
the CCA has been
implemented
Demonstrate compliance through the CCA by documenting
that emission reductions achieved through the CCA are
greater than or equal to emission reductions that would have
been achieved through compliance with the kraft pulping
HVLC system standards.
Chapter 4 - NESHAP Requirements -
Kraft Mills
Clean Condensate Alternative
-------
The compliance
date for existing
CCA sources is
April 17, 2006.
How does a mill demonstrate initial compliance?

A mill must conduct a performance test before and after CCA
implementation. Baseline emission levels and all CCA emission reductions
must be based on actual test data.

How does a mill demonstrate continuous compliance?

The control strategy using the CCA will vary between mills, depending on
mill configuration and emission points selected. Thus, the monitoring and
reporting requirements for the CCA are not specified in the rules. Each mill
must propose monitoring, reporting, and recordkeeping requirements for the
Administrator's approval.

What approvals are required to use the CCA ?

Mills that opt to use the CCA must submit a CCA control strategy report
along with the initial notification. Updates are required every 2 years. The
requirements of the control strategy report are specified at
40 CFR 63.455(b) and 40 CFR 63.447(g).

The mill must report to the Administrator by the final compliance date the
rationale, calculations, test procedures, and data used to demonstrate
compliance. The Administrator will make the final compliance
determination.
Chapter 4 • NESHAP Requirement.
Kraft Mills
Clean Condensate Alternative
78
-------
4.5 How do the requirements for the NSPS and the
NESHAP compare?

Figure 21 compares NSPS and NESHAP for kraft pulping emission sources.
Note that demonstrating compliance with a NESHAP alternative emission
limit(s) does not necessarily mean that NSPS requirements are automatically
met. In fact, the only alternative emission limit(s) of the NESHAP that also
satisfies the NSPS requirement is the thermal oxidizer design requirement
(1600 °F for 0.75 seconds).
Chapter 4 - NESHAP Requirements -
Kraft Mills - NSPS vs. NESHAP
79
-------
The MACT control
technologies can be
used to comply with
the NSPS, but mills
still must
demonstrate that
the NSPS emission
limits for TRS are
being met.
A thermal oxidizer
is the only option
where meeting the
NESHAP
automatically
meets the NSPS.
Figure 21.
Comparison of NESHAP and NSPS Alternative Emission
Limit(s) Requirements
If a Mill
Uses This
Control
Option...
Lime Kiln
Recovery
Furnace
Power
Boiler
Thermal
Oxidizer
Other means
Uncontrolled
digester
system
The NSPS
Requires...
less than 8 ppmv
TRS at 1 0%
oxygen
Straight recovery:
5 ppmv TRS at
8% oxygen
Cross recovery
25 ppmv TRS at
8% oxygen
1200°Ftbr
0.5 second
l200cFror
0.5 second

5 ppmv TRS at
actual oxygen
content ot
untreated stream
0.005 g TRS/kg
air-dried pulp
(ADP)
Does NESHAP
And the NESHAP Compliance Ensure
Requires... NSPS Compliance?
Introduce vent stream
with primary fuel into
flame zone.
Introduce vent stream
with primary fuel into
flame zone.
Same as above
Introduce vent stream
with primary fuel into
flame zone.
!600°Ffor075
second
or
20 ppmv total HAPs
or methanol at 10%
oxygen
or
98% reduction by
weight of total HAPs
or methanol
98% reduction by
weight of total HAPs
or methanol
Vent gases must be
routed to a closed-
vent collection
svstem.
No
No
No
No
Yes
No
No
No
No
Chapter 4 - NESHAP Requirements -
Kraft Mills - NSPS vs. NESHAP
80
-------
The NESHAP
requirements for semi-
chemical and soda
mills are similar to the
requirements for kraft
mills except that
pulping process
condensates are not
regulated at semi-
chemical and soda
mills.
Chapter 5 - NESHAP Requirements for
Semi-Chemical and Soda Mills
For semi-chemical and soda mills, the NESHAP contains emission
standards for pulping system vents and bleaching system vents. There are
several alternative emission limits for both processes, and mills can choose
the emission limits with which to comply.

The requirements in the NESHAP for semi-chemical and soda mills are
described in this chapter.
If You Need the Following Information...
Then Read..
Standards for semi-chemical and soda pulping
system vents

Standards for semi-chemical and soda
bleaching system vents
Section 5.1

Section 5.2
81
-------
For purposes of
this NESHAP, the
LVHC system
includes all vents
from:
• digester system
• turpentine
recovery
system
• evaporator system

For semi-chemical
and soda mills, the
NESHAP does not
apply to existing
HVLC systems.
5.1 Standards for semi-chemical and soda pulping
system vent standards

What pulping system vents must be controlled?

The NESHAP requires certain equipment in the pulping systems at semi-
chemical and soda mills to be enclosed, collected in a closed-vent system,
and then vented to a control device.
The Following Pulping System Vents Must be Controlled.
Existing Sources
LVHC system
New Sources
LVHC system
• Pulp washing system
Each equipment system has multiple emission points. For example, the
pulp washing system can include vacuum drum washers, diffusion washers,
rotary pressure washers, horizontal belt filters, intermediate stock chests,
associated vacuum pumps, filtrate tanks, and foam breakers. A complete
list of the emission points in each equipment system is provided in
Appendix F.
Chapter 5 - NESHAP Requirement
Semi-Chemical and Soda Mills
Pulping System Vents
82
-------
The NESHAP does
not provide the
Clean Condensate
Alternative to semi-
chemical and soda
pulping systems
because the Clean
Condensate
Alternative was
provided to kraft
mills as an option
for meeting the
HVLC system
emission limits.

HVLC systems at
existing semi-
chemical and soda
mills are not
regulated by the
NESHAP.
What are the emission limits for semi-chemical and soda
pulping system vents?

The emissions from semi-chemical and soda pulping system vents must
meet one of four alternative emission limits, as shown below. These
emission limits apply to each control device used to control HAP emissions.
A mill will likely use several closed-vent systems and control devices
(including both add-on control devices and existing combustion devices)
and each can comply with any of these four alternative emission limits.
These emission limits apply to both new and existing sources.
Pulping System Vent Gases Must be Collected in a Closed-vent
System and Routed to One of These Four Control Devices...
3.
4.
Any control device that reduces total HAP emissions by >98% by
weight, measured as total HAPs or methanol

A boiler, lime kiln, or recovery furnace in which the HAP gas
stream is introduced with the primary fuel or into the flame zone

A thermal oxidizer operated at a minimum temperature of 1,600°F
and a minimum residence time of 0.75 seconds

A thermal oxidizer that reduces the total HAP concentration at the
outlet to < 20 ppmv corrected to 10% O2 on a dry basis, measured
as total HAPs or methanol
Note: These emission limits are the same as for kraft mills (presented on
page 53).
Chapter 5 • NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
83
-------
A closed-vent
system means a
system that is not
open to the
atmosphere and
comprises piping,
ductwork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems at semi-chemical and soda mills?

All regulated equipment system vents must be enclosed and routed through
a closed-vent system to the control device that is selected for compliance.
The requirements for enclosures and closed-vent systems are presented
below. The requirements are intended to prevent leaks and ensure that
process openings (e.g., sampling ports on a brown stock washer enclosure)
are closed while the mill is in operation.
This Equipment...
Must Meet These
Requirements....
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance,
or repairs
Components operated at positive
pressure
Operate with no detectable leaks
(500 pprnv VOC above
background)
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so that
the valve or closure mechanism
cannot be opened without breaking
the seal
or
If computer controlled, monitor for
presence of gas stream flow at least
once every 15 minutes
Note: These requirements are the same as for kraft mills (presented on
page 54).
Chapter 5 - NESHAP Requirement
Semi-Chemical and Soda Mills
Pulping System Vents
84
-------
Because semi-
chemical and soda
mills are not
affected by the
Effluent Limitations
Guidelines and
Standards, the
NESHAP does not
allow these mills
any extended
compliance times.
When must mills comply with the semi-chemical and soda
pulping process standards?

Pulping systems at semi-chemical and soda mills must comply with the
MACT standards by April 16, 2001.

How does a mill demonstrate initial and continuous compliance
with the pulping system vent standards?

A mill must demonstrate compliance through an initial performance test and
then continuously monitor a set of control device operating parameters for
each closed-vent system and control device. When complying by venting
gases to a boiler, lime kiln, or recovery furnace, the initial performance test
must demonstrate that the gases are being introduced with the primary fuel
or into the flame zone.

The initial and continuous compliance requirements for semi-chemical and
soda mills are identical to those for kraft mills. Please read pages 56
through 59 of this document.

Must a mill comply at all times?

For pulping system vents, the NESHAP establishes an allowable percent of
operating time during which HAP emission levels in excess of the
established limit shall not be considered to be a violation of the standard.

For soda and semi-chemical mills, the excess emission allowances are:

1 percent of operating time for control devices used for
LVHC system vents

4 percent of operating time for control devices used for pulp
washing systems (HVLC)

• 4 percent of operating time for control devices used for
combined LVHC and pulp washing system vents
(i.e., controlled by the same device)

The excess emission allowances are the same for kraft, semi-chemical, and
soda mills. Refer to page 59 for additional details.
Chapter 5 - NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
85
-------
Currently, there is
only one soda mill
operating in the
U.S.
5.2 Standards for bleaching system vents at
semi-chemical and soda mills

Semi-chemical mills

Generally, semi-chemical mills in the United States do not have bleaching
systems and therefore are not subject to bleaching standards. Technically,
the rule would apply if a semi-chemical mill installed a bleaching system
using chlorine. While this is not expected to occur, such a mill would have
to comply with the emission standards for chlorinated HAPs (excluding
chloroform) from bleaching vents. The rule would not apply to bleaching
systems using chlorinated compounds other than chlorine. Refer to
Section 4.3 for information about bleaching standards, excluding the
chloroform standard.

Soda mills

At soda mills, emission limits apply to bleaching systems that use chlorine
or chlorinated compounds. The emission standards and compliance
demonstration requirements for soda mills are the same as for kraft mills
(presented in Section 4.3) and are not repeated in this chapter. Refer to the
following pages for specific information.

• Emission points to be controlled—page 68

• Control requirements for chlorinated HAPs and
chloroform—page 69

• How to demonstrate initial compliance—page 71

• How to demonstrate continuous compliance—page 72.
Chapter 5 - NESHAP Requiremen
Semi-Chemical and Soda Mills
Bleaching System Vents
86
-------
Chapter 6 - NESHAP Requirements for
Sulfite Mills
For sulfite mills, the NESHAP contains emission standards for pulping
system vents and bleaching system vents.

The NESHAP contains two alternative emission limits for pulping system
vents. Each mill can choose to comply with either limit. Different
numerical emission limits are specified for calcium- and sodium-based
pulping systems than for magnesium- and ammonium-based pulping
systems.

The NESHAP also contains several alternative emission limits for bleaching
process system vents. The NESHAP does not regulate pulping process
condensates at sulfite mills.
If You Need the Following Information...
Then Read-
Standards for sulfite pulping system vents

Standards for sulfite bleaching system vents
Section 6.1

Section 6.2
87
-------
The emission limits
are the same for
existing and new
sources.
Appendix C
contains a
flowchart summary
of the NESHAP.
6.1 Standards for sulfite pulping system vents

The NESHAP requires the pulping systems to be enclosed, collected in a
closed-vent system, and then vented to a control device. This section
describes the emission points that must be controlled, the two alternative
emission limits, and the compliance requirements.

What sulfite pulping system vents must be controlled?

The NESHAP specifies that all the vents from the digester system,
evaporator system, and pulp washing systems must be controlled.
Additional equipment must be controlled at new sources. These pulping
svstem vents are identified below.
The Following Pulping System Vents Must be Controlled.
Existing Sources

• Digester system

• Evaporator system

• Pulp washing system
New Sources

• Same as existing sources plus...

• All weak liquor storage tanks

• All strong liquor storage tanks

• All acid condensate storage tanks
Each equipment system has multiple emission points. For example, the
evaporator system comprises pre-evaporators, multi-effect evaporators,
concentrators, vacuum systems, associated condensers, hot wells, and
condensate streams. A complete list of the emission points in each
equipment system is provided in Appendix F.
Chapter 6 - NESHAP Requiremei
Sulfite Mills
Pulping System Vents
88
-------
These emission
limits apply to the
entire source, not
to individual pieces
of equipment as do
the emission limits
for pulping system
vents at other mills.
Outlet emission
level and percent
reduction
requirements must
account for HAP
releases from vents,
condensates, and
wastewater from
control devices
used to reduce
HAP emissions.
What are the emission limits for sulfite pulping system vents?

The sulfite pulping system vents must meet either a percent reduction or
mass emission limit identified for the specific type of sulfite pulping process
(i.e., calcium- and sodium-based or magnesium- and ammonium-based
pulping processes). The emission limits apply to the combined emissions
from both the regulated equipment and any vents, wastewater, and
condensate streams generated from any control device used to reduce the
HAP emissions. Therefore, a mill must choose either the percent reduction
or the mass emission format and demonstrate compliance with the emission
limit using the combined emissions from the entire pool of regulated
equipment. Compliance may not be demonstrated at individual pieces of
equipment or individual closed-vent systems.
If the Sulfite Pulping System
is This Type...
Then Choose One of the
Following Emission Limits...
Calcium-based and
Sodium-based
Reduce total HAP concentration to
<0.89 Ib/ton oven-dried pulp,
measured as total HAPs or
methanol
or
Reduce total HAP emissions by
>92% by weight, measured as total
HAPs or methanol
Ammonium-based and
Masnesium-based
Reduce total HAP concentration to
<2.2 Ib/ton oven-dried pulp,
measured as total HAPs or
methanol
or
Reduce total HAP emissions by
>87% by weight, measured as total
HAPs or methanol
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
89
-------
A closed-vent
system means a
system that is not
open to the
atmosphere and
comprises piping,
ductwork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems?

All regulated equipment systems must be enclosed and routed through a
closed-vent system to the control device that is selected for compliance.
The requirements for enclosures and closed-vent systems are presented
below. The requirements are intended to prevent leaks and ensure that
process openings (e.g.. sampling ports on a brown stock washer enclosure)
are closed while the mill is in operation.
This Equipment....
Must Meet These
Requirements....
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance,
or repairs
Components operated at positive
pressure
Operate with no detectable leaks
(500 ppmv VOC above
backeround)
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so that
the valve or closure mechanism
cannot be opened without breaking
the seal
or
If computer controlled, monitor for
presence of gas stream flow at least
once every 15 minutes
Note: These requirements are the same as for kraft mills (presented on
page 54).
Chapter 6 • NESHAP Requiremet.
Sulfite Mills
Pulping System Vents
90
-------
When must mills comply with the sulfite pulping process
requirements?

Affected sources at sulfite mills must comply with the NESHAP by
April 16,2001.

How does a mill demonstrate initial compliance with the sulfite
pulping system vent standards?

A mill must demonstrate compliance through an initial performance test.
Total HAP may be measured as methanol using Method 308.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the
emission limit.

(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 23.

(3) To establish the process operating parameter values that must
be monitored to demonstrate continuous compliance. For
example, at a calcium-based and sodium-based sulfite mill, the vent
gas flow rate, scrubbing media flow rate, and pH of the scrubber
effluent that indicate 92 percent reduction by weight of total HAPs
or methanol usins Method 308.
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
91
-------
The excess
emissions
allowance (for
kraft, semi-
chemical, and soda
mills) does NOT
apply to sulfite
mills.
These same tests
are required as
part of the initial
performance test.
How does a mill demonstrate continuous compliance with the
sulfite pulping system vent standards?

Mills must install a continuous monitoring system to measure either control
device or process operating parameters. Control device (other than gas
scrubbers) or process parameters to be monitored are determined by the
facility (i.e., site-specific). Continuous monitors for the selected parameters
are required to demonstrate continuous compliance. Figure 24 presents the
continuous compliance monitoring requirements.

In addition, the mill must comply with the requirements for periodic
inspection and maintenance of all enclosures and closed-vent systems.
These requirements are explained in Figure 23. The mill must maintain a
site-specific inspection plan for the enclosures and closed-vent system.
Records of repairs based on the inspections must also be kept.

Figure 23.
How Does a Mill Demonstrate initial and Continuous Compliance with
the Closed-Vent Systems Standard?
If the System has...
Enclosure opening
Closed-\em s>slem
Positive pressure
closed- vent system
Bypass line valve
Then Inspect...
Visually inspect e\ery 30
days 10 ensure closed and
sealed
Annually demonstrate
negat:\ e pressure
VisualK inspect every 30
daw tor visible detects
Annually demonstrate no
detectable leaks (less than
500 ppmv)
Inspect every 30 days to
ensuie val\e is in a closed
position and \ent stream is
not diverted through
bypass line
And Report-
Any exceedences of the
closed-vent standard in
quarterly reports If no
exceedences occur, submit
semi-annual reports.
Same as above
Same as above
Same as above
Same as above
And Keep
Records of...
All visual checks
any repairs
All pressure tests
All visual checks
repairs
AH leak tests
All visual checks
repairs

and

and
Note: These are the same requirements as for kraft mills (presented on
page 57).
Chapter 6 - NESHAP Requiremen
Sulfite Mills
Pulping System Vents
-------
Figure 24.

How Does a Mill Demonstrate Continuous Compliance with the
Sulfite Pulping System Vent Standards?
And the Mill Chooses
If the Sulfite Pulping This Alternative And the Mill Chooses
System is This Type... Emission Limit... This Technique...
Calcium-based and Reduce lolal HAP' Gas scrubber
Sodium-based conccnlralion at the outlet
to <0.89 Ih/lon or reduce
lolal HAP' emissions by
>92'/f by weight

Silc-specific paiameters

Ammonium-based and Reduce total HAP' Same as above
Magnesium-based concentration al the outlet
to <2.2 Ih/lon or reduce
lolal HAP' emissions by
>87% by weight

Continuously Monitor
These Parameters...
pH or oxidation/reduction
potential of effluent

Vent gas inlet How rale

Scrubber liquid influent
How rate

Determine appropriate
monitoring paiameter
values during the, initial
performance test
Same as above

And Report This
Information...
• Semi-annual
emissions and
continuous
monitoring
performance
report
• If exceedences
occur, then
quarterly reports
are required
(40 CTR
63.IO(e))
Same as above

Same as above

And Keep These
Records for
5 Years...
pH or oxidation/
reduction potential of
effluent

Venl gas inlet How
rate

Scrubber liquid
influent flow rate

Parameters approved
by the Administrator

Same as above

. Methanol may be used as a surrogate for total HAPs.
As specified in 40 CFR Part 63.453(a).
-------
The compliance
date for dissolving
grade sulfite mills
is not specified in
the NESHAP, but is
anticipated
between
2003-2005.
6.2 Standards for sulfite bleaching system vents

At sulfite mills the emission limits apply to bleaching systems that use
chlorine or chlorinated compounds. The NESHAP has emission limits for
both chloroform and chlorinated HAP. Sulfite mills must comply with both
of these requirements. The emission standards and compliance
demonstration requirements for sulfite mills are the same as for kraft mills
(presented in Section 4.3) and are not repeated in this chapter. Refer to the
following pages for specific information.

• Emission points to be controlled—page 68

• Control requirements for chlorinated HAPs and
chloroform—page 69

• How to demonstrate initial compliance—page 71

• How to demonstrate continuous compliance—page 72.

When must sulfite bleaching systems comply?

Bleaching systems must comply b\ April 16, 2001 with one exception.

• Dissolving grade sulfite mills must comply within 3 years after
publication of revised effluent limitations guidelines and standards
under 40 CFR 430.14 through 430.17 and 40 CFR 430.44 through
430.47. These rules are scheduled to be revised sometime between
2000 and 2002.
Chapter 6 - NESHAP Requiremei
Sulfite Mills
Bleaching System Vents
94
-------
Secondary fiber
means recycled fiber.
The chloroform
control requirements
of the NESHAP do not
apply to bleaching
systems at these types
of mills.
Typically, a bleaching
line contains
3-5 stages.
Chapter 7 - NESHAP Requirements for
Mechanical, Secondary Fiber,
and Non-wood Fiber Pulp Mills
The NESHAP regulates bleaching system vents for mechanical pulping,
secondary fiber, and non-wood fiber pulp mills. The NESHAP applies to
bleaching systems that use chlorine or chlorine dioxide, and has identical
requirements for mechanical, secondary fiber, and non-wood fiber
processes.

The pulping process system vents and condensates are not regulated at these
mills.

7.1 Standards for bleaching system vents

At mechanical, secondary fiber, and non-wood fiber pulp mills the
NESHAP regulates chlorinated HAPs (excluding chloroform). The
emission limits apply to bleaching systems that use chlorine or chlorine
dioxide. However, if a bleaching system for one of these processes also
accepts pulp from processes at a kraft. semi-chemical, soda, or sulfite mill,
then the more stringent bleaching system requirements will apply (i.e., the
bleaching system also must meet the chloroform control requirements).

What mechanical, secondary fiber, and non-wood fiber
bleaching system emission points must be controlled?

The NESHAP applies only to bleaching stages that use chlorine or chlorine
dioxide. Extraction stages are not covered. All vents in a regulated stage
must be controlled. A stage consists of the following equipment:

• retention towers

• washers

• seal tanks

• chemical and steam mixers (if vented to the atmosphere)

• vacuum pumps (if present)
95
-------
There are no control
requirements for
chloroform at these
other types of mills.
The requirements for
enclosures and
closed-vent systems
are the same as for
the pulping system
vent standards
(page 54).
Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or chlorine dioxide is
exempt from all NESHAP requirements for bleaching.

What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are
introduced must be enclosed and routed via a closed-vent collection system
to a control device. The rule provides three alternative emission limits for
demonstrating compliance, as shown below. Most mills are expected to use
caustic scrubbers to comply.
Bleaching System Gases Must be Collected in a Closed-vent System
__ Ta
and Meet One of These Three Alternative Emission Limits ...
1. Reduce chlorinated HAP emissions by 99% by weight

2. Achieve a total outlet mass emission rate < 0.002 pounds
chlorinated HAPs per ton oven-dried pulp for all subject stages

3. Achieve an outlet concentration of chlorinated HAPs < 10 ppmv
Some mills may be able to meet the outlet concentration or mass limits through use ot
process modifications (i.e.. 100 percent chlorine dioxide substitution). In these cases.
enclosures and closed-vent systems are not required.
Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or
as chlorine.
Note: These emission limits are the same for kraft mills (presented on
page 69).

When must mechanical, secondary fiber, and non-wood fiber
bleaching systems comply?

All mechanical, secondary fiber, and non-wood fiber processes must comply
with the chlorinated HAP control requirements by April 16, 2001.
Chapter 7 - NESHAP Requiremen
Mechanical Pulping, Secondai,
Fiber, and Non-wood Fiber Mills
Pulping System Vents
96
-------
How does a mill demonstrate initial compliance with the
bleaching standards?

Chlorinated HAPs. The mill must demonstrate initial compliance with
chlorinated HAP standards by conducting an initial performance test for
each bleaching stage where chlorine or chlorinated compounds are
introduced.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the
emission limit.

(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameters that must
be monitored to demonstrate continuous compliance.

At the option of the mill, compliance may be demonstrated by measuring
either total chlorinated HAPs or chlorine concentration. The following
methods must be used:
Chlorinated HAPs
Any method that has been
demonstrated to the Administrator's
satisfaction.
Chlorine
Method 26A, as modified by
63.457(b)(5) of the rule.
Chapter 7 - NESHAP Requirements
Mechanical Pulping, Secondary
Fiber, and Non-wood Fiber Mills
Pulping System Vents
97
-------
Continuous
monitoring is
required unless a
mill complies by
eliminating all use
of chlorine or
chlorinated
compounds as
bleaching agents.
These same tests
are required as
part of the initial
performance test.
How does a mill demonstrate continuous compliance with the
bleaching standards?

In addition, the mill must conduct periodic inspection and maintenance of
all enclosures and closed-vent systems. These requirements are explained
below. The mill must maintain a site-specific inspection plan for the
enclosures and closed-vent system. Records of repairs based on the
inspections must also be kept.
If the System has...
Enclosure opening
Closed- vent system
Positive pressure
closed-vein system
Bypass line valve
Then Inspect-
Visually inspect every 30
days to ensure closed and
sealed
Annually demonstrate
negative pressure
Visually inspect every 30
days tor visible delects
Annually demonstrate no
detectable leaks (less than
500 ppm\ )
Inspect every 30 days to
ensure \alve is in a closed
position and vent stream is
not diverted through
hvpass line
And Report...
Any exceedences of the
closed-vent standard in
quarterly reports. If no
exceedences occur, submit
semi-annual reports.
Same as above
Same as above
Same as above
Same as above
And Keep
Records of...
All visual checks and
any repairs
All pressure tests
All visual checks aru.
repairs
All leak tests
All visual checks and
repairs
Note: These are the same requirements as for kraft mills (presented on
page 57).
Chapter 7 - NESHAP Requirement
Mechanical Pulping, Seconda*
Fiber, and Non-wood Fiber Miffs
Pulping System Vents
98
-------
Figure 25.
How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlorinated HAPs?
If a Mill Chooses This
Technique to Comply
With This Alternative
Emission Limit...
(las scrubber lo reduce
dilonnaled HAP
emissions hy 99'/r by
weight or to achieve an
outlet mass emission
rate < 0.002 pounds
chlorinated HAPs per
ton oven-dried pulp
Gas scrubber to achieve
an outlet concentration
of chlorinated HAPs
< 10 ppmv
Any control device
other than a gas
scrubber or process
modifications
Continuously Monitor These
Parameters...
pH or oxidation/reduction potenli.il ol
cl'llncnl
Venl gas inlet How rale
Scrubber liquid influent flow rate
Chlorine concentration at the outlet or
measure all three of the following
parameters
pH or oxidation/reduction potential of
effluent
Vent gas inlet How rate
Scrubber liquid influent flow rate
Determine appropriate monitoring
parameter values during the initial
performance test
Report This Information...
• Semi-annual emissions and continuous
monitoring peiloimance repoit
• II exceedences occiu, then i|iiai Icily
reports arc required
(40CFR63.10(e))
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
Same as above
And Keep These Records for 5 Years...
pH or oxidation/reduction potential of
elfluenl
Venl gas inlet How rate
Scrubber liquid influent flow rate
Chlorine concentration or all of the
following
pH or oxidation/reduction potential of
effluent
Vent gas inlet flow
Scrubber liquid influent flow rate
Parameters approved by the Administrator
As specified in 40 CFR Part 63.453(n)
Note: This is the same figure as the one presented on page 73.
-------
-------
The Cluster Rules do
NOT represent all of
the air and water
pollution regulation of
the pulp and paper
industry.
Chapter 8 • Other Federal Regulations Affecting
Pulp and Paper Mills
The Cluster Rules do not represent all of the air and water pollution
regulation of the pulp and paper industry. Pulp and paper mills are subject
to additional air requirements under the CAA; additional water requirements
under the Clean Water Act; and other Federal, State and local laws not
associated in any way with the Cluster Rules.

Federal regulations affecting the pulp and paper industry include:

National Ambient Air Quality Standards (NAAQS)

• Kraft Mill New Source Performance Standards (NSPS)
(40 CFR 60, Subparts B and BB)

Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and
DC)

Gas-Fired Turbines NSPS (40 CFR 60, Subpart GG)

Prevention of Significant Deterioration (PSD)/New Source
Review (NSR)

• National Pollutant Discharge Elimination System (NPDES)
Related Statutes and Regulations

• Spill Prevention Control and Countermeasure (SPCC) Plans
(40 CFR 112)

• Notice of Discharge of Reportable Quantities of Hazardous
Substances (40 CFR 116 and 117)

• Resource Conservation and Recovery Act (RCRA)

• Emergency Planning and Community Right-to-Know Act
(EPCRAVComprehensive Environmental Response,
Compensation and Liability Act (CERCLA)
100
-------
B ACT = best
available control
technology

LAER = lowest
achievable emissions
rate
8.1 What other Federal air regulations affect the pulp
and paper industry?

Federal air regulations affecting the pulp and paper industry are shown
below.
The Following Air
Regulation...
Affects...
By...
NAAQS
Energy generation
at pulp and paper
mills
Controlling NOX, PM,
VOC,a and SO2 as part
of the state
implementation plans
NSPS
40 CFR 60. Subpart B Kraft pulp mills
40 CFR 60,
Subpart BB
Kraft pulp mills
40 CFR 60, Subpart D, Industrial boilers
Db. and DC
40 CFR 60,
Subpart GG
Gas-fired turbines
Controlling PM and
TRS at existing
sources under state
regulations. State
regulations are based
on EPA guidelines.

Controlling PM and
TRS

Controlling PM, NOX,
SO,

Controlling PM, SO2,
NO.
PSD/NSR
Pulp and paper
mills installing new
or modified
equipment
Requiring a
pre-construction
permit that imposes
emission limitations
based on BACT or
LAER for criteria
pollutants for which
there is a significant
increase
Chapter 8 - Other
Regulations
101
-------
National Ambient Air Quality Standards (NAAQS) have been established
for six criteria pollutants. Pulp and paper mills are potential sources of
paniculate matter (PM), ozone precursors (volatile organic compounds
[VOCs] and nitrogen oxides [NOJ), and sulfur dioxide (SO2). Each State
must develop a State Implementation Plan (SIP) to identify sources of air
pollution and to determine what actions are necessary to achieve attainment
with the NAAQS for all criteria pollutants. The SIP contains emission
regulations that may affect the pulp and paper industry, including emission
limitations and standards and pre-construction permitting requirements
(e.g.. New Source Review [NSR], Prevention of Significant Deterioration
[PSD]).

Kraft Mill New Source Performance Standards (NSPS) (40 CFR 60,
Subpart BB). The majority of kraft mills in operation are currently
regulated under the kraft mill NSPS (40 CFR Subpart BB) or State
regulations for existing sources promulgated under Section 11 l(d) of the
Act (40 CFR 60, Subpart B). The kraft mill NSPS sets emission limits for
particuiate matter and TRS for recovery furnaces, smelt dissolving tanks,
lime kilns, digester systems, brown stock washer systems, multiple effect
evaporators, black liquor oxidation systems, and condensate stripper
systems. See page 79 for a more detailed discussion of the kraft mill NSPS,
as this regulation applies to kraft mills only.

Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and DC) and Gas-
Fired Turbines NSPS (40 CFR 60, Subpart GG). Almost all pulp and
paper facilities have boilers and turbines for generating electricity and
steam. Newer combustion units may be subject to regulation under one of
these rules which set emissions limits for particuiate matter, nitrogen
oxides, and sulfur dioxide.
Chapter 8 - Otht.
Regulation
102
-------
NPDES = National
Pollutant Discharge
Elimination System
8.2 What other Federal water regulations affect the
pulp and paper industry?

Federal water regulations affecting the pulp and paper industry are shown
below:
The Following Water
Regulation...
NPDES: Technology and
water quality-based
limitations

Pretreatment program

Storm water permit
application

Section HOofCWA
(40CFR 110)
Spill Prevention Control and
Countermeasure (SPCC)
(40CFR 112)

Notice of Discharge of
Reportable Quantities of
Hazardous Substances
(40CFR 116 and 117)

Affects...
Direct-discharging of
pollutants into
navigable waters

Indirect-discharging
of pollutants to
publicly-owned
treatment works
(POTWs)
Any facility

Any facility

Oil storing/
consuming facilities

Any facility

By...
Setting effluent
limitations on pollutants
based on available
technology and intended
use of receiving
waterbody; also sets
monitoring and reporting
requirements
Setting pollutant
discharge limits to
POTWs

Establishing pollution
prevention plans and
best management
practices (BMP)
Prohibiting oil
discharges
Requiring a spill
prevention and control
plan, reporting, plan
updates, and training
obligations
Requiring reporting of
designated hazardous
substance discharges to
U.S. government
following the
Department of
Transportation
regulations
Chapter 8 - Otht
Regulation
103
-------
The acronyms are
defined on the next
page in Figure 26.
The applicability of
these standards is
explained on
page 106 in
Figure 27.
National Pollutant Discharge Elimination System (NPDES) Program
(Clean Water Act, Section 402). The NPDES program controls direct
discharges into navigable waters. The scope of this program is quite broad,
and most point source discharges associated with a pulp and paper mill will
be subject to NPDES permitting requirements. The effluent limitations
guidelines and standards and requirements for direct discharging mills are
presented in the table below. The applicability of these standards is more
fully explained in Figure 27.
For These Mill Types or
Production Operations...
Disseising Kraft
Bleached Papergrade Kraft
and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-chemical
Mechanical
Non-wood Chemical
Secondary Fiber Deink
Fine and Lightweight Papers
from Purchased Pulp
Tissue. Filter, Non-Woven.
and Paperboard from
Purchased Pulp
These Clean
BAT,
PSES, and
PSNS
X
X
X
X
X
X

Water Act
Apply...
BPT,
BCT,
NSPS
X
X
X
X
X
X
X
X
X
X
X
Standards
BMP
X
X
X
X
X
X

' The effluent limitations guidelines and standards for these subcategories were revised in
the Cluster Rules
Chapter 8 - Other
Regulations
104
-------
Figure 26.

A Guide to the Acronyms for Technology-Based Water Standards
Acronym
PSESa
PSNSa
BPT
BCT
BAT
BMP
NSPS
Definition
Pretreatment Standards for Existing
Sources
Pretreatment Standards for New
Sources
Best Practical Control Technology
Currently Available
Best Conventional Pollutant Control
Technology
Best Available Technology
Economically Achievable
Best Management Practices
New Source Performance Standards
Description of Standard
Industry-by-industry pretreatment
standards for existing sources that
discharge their wastewater indirectly
(i.e., to a POTW).
Industry-by-industry pretreatment
standards for new sources that
discharge their wastewater indirectly
(i.e., to a POTW).
A baseline standard, applicable in all
circumstances
More stringent than BPT. Only
applies if certain cost tests are met.
Must be "cost-reasonable." See
51 FR 24,974-24,976 (July 9, 1986),
for EPA's BCT methodology.
A standard similar to BPT/BCT, but
with cost concerns playing a lesser
role. A "best of the best" standard.
Designed to prevent or contain leaks
and spills of pulping liquor, soap.
and turpentine, and to control any
intentional diversions of these
substances.
Applicable to new direct discharge
sources, as defined in 40 CFR 122.2.
Although the categorical standards in 40 CFR Part 430 cover kraft pulp mills, most kraft pulp mills are direct
dischargers subject to NPDES permit requirements and not the pretreatment standards.
Chapter 8 - Othe
Regulation*
105
-------
Figure 27.
Applicability of Technology-Based Standards

If a Mill
Discharges These
Pollutants...
Conventional
pollutants
Toxic and
conventional
pollutants
Any pollutants
An\ pollutants
Any pollutants

To These Direct
Receivers
Surface waters
Surface waters

Surface waters
POTWs
POTWs

And the Mill is
Classified as an...
Existing source
Existing source

New source
Existing source
New Source
Then the
Required
Standards
That
Apply
are...
BPTor
BCT
BAT

NSPS
PSES
PSNS
Source: 40 CFR 125.3
Spill Prevention Control and Countermeasure (SPCC) Plans
(40 CFR 112). This regulation applies to all facilities that store or use oil or
oil products, and which because of their location, could reasonably be
expected to discharge oil into navigable waters of the United States. Such
facilities are required to prepare a SPCC plan.

Notice of Discharge of Reportable Quantities of Hazardous Substances
(40 CFR 116 and 117). This regulation defines the discharges into
navigable waters of the United States that must be reported to appropriate
agencies of the U.S. Government. This requirement does NOT apply to
discharges covered by a facility's NPDES permit.
Chapter 8 - Other
Regulations
106
-------
TRI = Toxic
Release lnvenlor\
8.3 What Federal hazardous wastes regulations
affect the pulp and paper industry?

Federal hazardous wastes and emergency planning regulations affecting the
pulp and paper industry are shown below:
The Following
Hazardous Waste
Regulation-
Affects.
By,
RCRA
Black liquor at pulp
mills
Requiring reclamation and
reuse of black liquor
EPCRA/CERCLA Pulp mills
Requiring that air and
water discharges from the
mill be accounted for by
filing TRI Form R reports
for certain pollutants
Requiring mills to provide
information on chemicals
used in the bleach plant
Requiring mills to report
emergency spills or off-
site releases (air, water, or
solid wastes)
Resource Conservation and Recovery Act (RCRA). Most RCRA
requirements are not industry specific but apply to any company that
transports, treats, stores, or disposes of hazardous wastes. The pulping
process generally does not generate significant RCRA-related hazardous
waste streams. However, handling of black liquor can create RCRA-related
concerns. Black liquor is exempt from regulation as a solid waste under
40 CFR 261.2(e) and Table 1, 261.4(a)(6), but only if the black liquor is
reclaimed in a recovery furnace and reused in the pulping process.
Therefore, potential liquor spills that are not reused in the process, such as
leaks from surface impoundments used to store black liquor prior to
recovery will be an issue for RCRA compliance assessment.
Chapter 8 - Other
Regulations
107
-------
Emergency Planning and Community Right-to-Know Act (EPCRA)/
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA). EPCRA section 313 requires manufacturing facilities to
submit an annual toxic chemical release report. This requirement applies to
facilities in SIC codes 20 through 39, that have ten or more employees, and
that manufacture, process, or use specified chemicals in amounts greater
than threshold quantities. This report, referred to as the Form R, covers
releases and transfer of toxic chemicals to various facilities and
environmental media, and allows EPA to compile the national Toxic
Release Inventory (TRI) database.

Air emissions and water effluents of certain pollutants from pulping
processes must be accounted for in the annual TRI Form R report. Solid
waste discharges from the pulping area are not generally a significant issue
for Form R reporting purposes because these releases generally remain on-
site. Pulp and paper mills must also report emergency "spills" or certain
off-site releases that might occur as the result of process upsets or other
malfunctions. These releases could include abnormal air emissions, and in
some situations, water or solid waste discharges directly from the pulping
area.
Chapter 8 - Other
Regulations
108
-------
More regulations
are coming!

Upcoming pulp
mill combustion
sources NESHAP
scheduled for 1999.
Five NESHAP for
combustion sources
are scheduled for
2000.

Effluent limitations
guidelines and
standards
scheduled for
2000-2002.
8.4
What upcoming regulations will affect pulp
paper mills?
and
Pending regulations that will affect the pulp and paper industry include:

• Chemical Recovery Combustion Sources and Kraft, Soda,
Sulfite, and Stand-Alone Semi-chemical Pulp Mills
NESHAP (63 FR 18754, proposed standards, April 15,
1998). EPA plans to finalize and publish emission standards
that will affect recovery furnaces, lime kilns, and smelt
dissolving tanks.

• NESHAP for Combustion Sources. EPA plans to publish
five NESHAP that will affect power boilers, process heaters,
gas turbines, reciprocating internal combustion engines, and
incinerators.

• Effluent Limitations Guidelines and Standards. EPA plans
to publish revised effluent limitations guidelines and
standards for additional subcategories in the near future.
These include: dissolving kraft; dissolving sulfite;
unbleached kraft; semi-chemical; mechanical pulp; non-
wood chemical pulp; secondary fiber deink: secondary fiber
non-deink; fine and lightweight fibers from purchased pulp;
and tissue, filter, non-woven, and paperboard from purchased
pulp.

Pending water regulations consist of EPA proposing effluent limitations
guidelines and standards for the pulp and paper industry subparts that were
not included in the Cluster Rules. And finally, EPA is considering whether
pulp mill wastewater treatment system sludges are to be considered a
hazardous waste and subject to RCRA Subtitle C. Since the effluent
guidelines address concerns about chlorine containing compounds, it is
expected that there will be no change in the exemption of pulp mill sludges
from being classified as a hazardous waste.
Chapter 8 - Other
Regulations
109
-------
Appendix A

List of U.S. Pulp and Paper Mills

Source: Lockwood-Post Directory, 1996
-------
Name
KETCHIKAN PULP CO.
ALASKA PULP CORP.
MACMILLAN BLOEDEL CORP.
KIMBERLY-CLARK CORP.
BOISE CASCADE CORP.
HAMMERMILL PAPERS GROUP
SCOTT PAPER CO.
ALABAMA PINE RIVER
INTERNATIONAL PAPER CO.
JAMES RIVER CORP.
ALABAMA RIVER PULP CO.
CHAMPION INTERNATIONAL
CONTAINER CORP. OF AMERICA
GULF STATES PAPER CORP
MEAD COATED BOARD INC
UNION CAMP CORP.
MEAD CORP.
NATIONAL GYPSUM CO.
GAF BUILDING MATERIALS CORP.
MOBILE PAPERBOARD CORP.
KEYES FIBER CO.
POTLATCH CORP.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP.
GREEN BAY PACKAGING INC.
INTERNATIONAL PAPER CO
GAYLORD CONTAINER CORP.
CELOTEX CORP.
STONE CONTAINER CORP.
PONDEROSA PAPER PRODUCTS INC.
LOUISIANA-PACIFIC CORP.
SIMPSON PAPER CO.
B.J. FIBRES
CONTAINER CORP. OF AMERICA
City
KETCHIKAN
SITKA
PINE HILL
COOSA PINES
JACKSON
SELMA
MOBILE
CLAIBORNE
MOBILE
PENNINGTON
PERDUE HILL
COURTLAND
BREWTON
DEMOPOLIS
MAHRT
PRATTVILLE
STEVENSON
ANNISTON
MOBILE
MOBILE
ALBERTVILLE
MCGEHEE
PINE BLUFF
ASHDOWN
CROSSETT
MORRILTON
CAMDEN
PINE BLUFF
CAMDEN
SNOWFLAKE
FLAGSTAFF
SAMOA
ANDERSON
SANTA ANA
SANTA CLARA
State
AK
AK
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
AR
AR
AR
AZ
AZ
CA
CA
CA
CA
Mill Type
sulfite

co-semi
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
semichem

kraft
kraft
kraft
kraft
kraft
kraft
kraft

kraft

kraft
kraft

Bleached?
bleached

unbleached
bleached
bleached
bleached
bleached
bleached
bleached
bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached

bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached

bleached

bleached
bleached

A-l
-------
Name
CELLULO CO. INC.
LOS ANGELES PAPER BOX & BOARD
LUNDAY-THAGARD ROOFING CO.
USG INDUSTRIES PAPERBOARD CO.
INLAND CONTAINER CORP.
LEATHERBACK INDUSTRIES
P & G PAPER PRODUCTS CO.
NEWARK PACIFIC PAPERBOARD
CORP.
NATIONAL GYPSUM CO.
SPECIALTY PAPER MILLS INC.
PABCO PAPER
SIMPSON PAPER CO.
SIMPSON PAPER CO.
KIMBERLY-CLARK
KEYES FIBRE CO.
WILLAMETTE INDUSTRIES INC.
DOMTAR GYPSUM
SIERRA TISSUE INC.
FONTANA PAPER MILLS INC.
SIMPSON PAPER CO
DOMTAR GYPSUM
CONTAINER CORP. OF AMERICA
GOLDEN STATE NEWSPRINT CO. INC
CALIFORNIA PAPERBOARD CORP.
INLAND CONTAINER CORP.
SONOCO PRODUCTS CO.
PACKAGING CO. OF CALIFORNIA
REPROCELL
PACKAGING CO. OF CALIFORNIA
PAPER-PAK PRODUCTS INC.
REPUBLIC PAPERBOARD CO.
KIMBERLY-CLARK CORP.
STONE CONTAINER CORP.
THE DEXTER CORP.
CELLU TISUE CORP.
City
FRESNO
LOS ANGELES
SOUTH GATE
SOUTH GATE
NEWARK
HOLLISTER
OXNARD
LOS ANGELES

STOCKTON
SANTA FE SPRINGS
VERNON
POMONA
FAIRHAVEN
FULLERTON
SACRAMENTO
OXNARD
VERNON
PONOMA
FONTANA
RIPON
SAN LEANDRO
VERNON
POMONA
SANTA CLARA
ONTARIO
CITY OF INDUSTRY
CITY OF INDUSTRY
SUN VALLEY
RED BLUFF
LA VERNE
DENVER
NEW MILFORD
UNCASVILLE
WINDSOR LOCKS
EAST HARTFORD
State Mill Type Bleached?
CA
CA
CA
CA
CA
CA
CA
CA

CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CO
CT
CT
CT
CT
A-2
-------
Name
WINDSOR-STEVENS INC.
RAND WHITNEY PAPERBOARD CORP.
FEDERAL PAPER BOARD CO.
ROGERS CORP.
SIMKINS INDUSTRIES INC.
LYDALL INC.
JAMES RIVER CORP.
NVF CORP.
CHAMPION INTERNATIONAL
STONE CONTAINER CORP.
ST. JOE FOREST PRODUCTS CO.
GEORGIA-PACIFIC CORP.
BUCKEYE FL LIMITED PARTNERSHIP
CONTAINER CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
ITT RAYONIER INC.
ATLAS TISSUE MILLS
STONE CONTAINER CORP
U.S. GYPSUM CORP
FEDERAL PAPER BOARD CO.
GEORGIA-PACIFIC CORP.
WEYERHAUSER PAPER CO.
GEORGIA-PACIFIC CORP
OILMAN PAPER
STONE CONTAINER CORP
INTERSTATE PAPER CORP.
PACKAGING CORP. OF AMERICA
RIVERWOOD INTERNATIONAL GA
INC.
UNION CAMP CORP.
INLAND ROME INC.
ITT RAYONIER INC.
AUSTELL BOX BOARD CORP.
P & G PAPER PRODUCTS CO.
HOLLINGSWORTH & VOSE CO.
SONOCO PRODUCTS CO.
City
WINDSOR
MONTVILLE
VERSAILLES
MANCHESTER
NEW HAVEN
MANCHESTER
NEWARK
YORKLYN
CANTONMENT
PANAMA CITY
PORT ST. JOE
PALATKA
PERRY
FERNANDINA BEACH
JACKSONVILLE
FERNANDINA BEACH
HIALEAH
JACKSONVILLE
JACKSONVILLE
AUGUSTA
CEDAR SPRINGS
OGLETHORPE
BRUNSWICK
ST. MARY'S
PORT WENTWORTH
RICEBORO
CLYATTSVILLE
MACON

SAVANNAH
ROME
JESUP
AUSTELL
ALBANY
HAW KINS VILLE
ATLANTA
State
CT
CT
CT
CT
CT
CT
DE
DE
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
GA
GA
GA
GA
GA
GA
GA
GA
GA

GA
GA
GA
GA
GA
GA
GA
Mill Type

kraft
kraft
kraft
kraft
kraft
kraft
kraft
sulfite

co-semi
co-semi
kraft
kraft
kraft
kraft
kraft
kraft
kraft

kraft
kraft
kraft

Bleached?

bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
bleached

bleached
unbleached
bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached

unbleached
unbleached
bleached

A-3
-------
Name
JEFFERSON SMURHT CORP.
FORT HOWARD CORP.
PACKAGING CORP. OF AMERICA
AUGUSTA NEWSPRINT CO.
DEERFIELD SPECIALTY PAPERS INC.
SOUTHEAST PAPER MFG. CO
PONDEROSA GEORGIA
SWEETWATER PAPER BOARD CO.
CONSOLIDATED PACKAGING CORP.
PACKAGING CORP. OF AMERICA
POTLATCH CORP.
JEFFERSON SMURHT CORP.
IVEX CORP.
CHICAGO PAPERBOARD CORP
QUAKER OATS CO.
SONOCO PRODUCTS CO.
IVEX CORP.
CELOTEX CORP.
DAVEY CO.
FSC PAPER CO.
GEORGIA-PACIFIC CORP.
WESTON PAPER AND MFG. CO
KEYES FIBRE CO.
PACKAGING CORP. OF AMERICA
INLAND CONTAINER CORP.
KIEFFER PAPER MILLS INC.
FIBRE FORM CORP.
JEFFERSON SMURFIT CORP.
ROCK-TENN CO.
BRIDGEWATER PAPER CO. INC.
GEORGIA-PACIFIC CORP.
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
TAMKO ASPHAULT PRODUCTS
REPUBLIC PAPERBOARD CO.
City
CEDARTOWN
RINCON
MACON
AUGUSTA
NIXON
DUBLIN
AUGUSTA
AUSTELL
FORT MADISON
TAMA
LEWISTON
ALTON
JOLIET
CHICAGO
PEKIN
ROCKTON
PEORIA
QUINCY
AURORA
ALDIP
TAYLORVILLE
TERRE HAUTE
HAMMOND
GRIFFITH
NEWPORT
BROWNSTOWN
COLUMBIA CITY
LAFAYETTE
EATON
INDIANAPOLIS
GARY
CARTHAGE
W ABASH
PHILLIPSBURG
HUTCHINSON
State Mill Type Bleached?
GA
GA
GA
GA
GA
GA
GA
GA
IA semichem unbleached
IA
ID kraft bleached
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IN semichem unbleached
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
A-4
-------
Name
WESTVACO CORP.
WILLAMETTE INDUSTRIES INC. (25A)
WILLAMETTE INDUSTRIES (25B)
AHLSTROM FILTRATION INC.
W.R. GRACE & CO.
STONE CONTAINER CORP.
RIVERWOOD INTERNATIONAL CORP.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
INTERNATIONAL PAPER CO.
JAMES RIVER CORP.
BOISE CASCADE CORP.
WILLAMETTE INDUSTRIES INC.
GAYLORD CONTAINER CORP.
INTERNATIONAL PAPER CO.
M.D. VALENTINE PAPER CO INC.
CELOTEX CORP.
G. S. ROOFING PRODUCTS
WESTFIELD RIVER PAPER CO. INC.
STRATHMORE PAPER CO.
ESLEECK MANUFACTURING CO. INC.
CROCKER TECHNICAL PAPERS INC.
WESTFIELD RIVER PAPER CO. INC.
MERRIMAC PAPER CO. INC.
ERVING PAPER MILLS
JAMES RIVER CORP.
MEAD CORP.
HOLLINGSWORTH & VOSE CO.

JAMES RIVER CORP.
MEAD CORP.

City
WICKLIFFE
HAWESVILLE
HAWESVILLE
MADISONVILLE
OWENSBORO
HODGE
WEST MONROE
MANSFIELD
PORT HUDSON
BASTROP
ST. FRANCISVILLE
DERIDDER
CAMPTI
BOGALUSA
PINEVILLE
LOCKPORT
MARRERO
SHREVEPORT
RUSSELL
TURNERS FALLS
TURNERS FALLS
FITCHBURG
LEE
LAWRENCE
ERVING
FITCHBURG
SOUTH LEE
EAST WALPOLE
DALTON
WEST SPRINGFIELD
SOUTH LEE
DALTON
State
KY
KY
KY
KY
KY
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
Mill Type Bleached?
kraft bleached
kraft bleached
semichem bleached

co-semi unbleached
co-semi unbleached
co-semi unbleached
kraft bleached
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft unbleached
kraft unbleached

A-5
-------
Name
NEWARK ATLANTIC PAPERBOARD
JAMES RIVER CORP.
BYRON WESTON CO.

STRATMORE PAPER CO.
NVFCO.
TEXTON USA
STRATHMORE PAPER CO.

SEAMAN PAPER CO. OF MASS. INC.
KIMBERLY-CLARK CORP.
NATICK PAPERBOARD CORP
RISING PAPER DIV.
CASCADES DIAMOND INC.
ROLAND-FITCHBURG PAPER INC.
STRATHMORE PAPER CO.
HAVERHILL PAPERBOARD CORP.
PERKIT FOLDING BOX CORP.
JAMES RIVER CORP.
SOUTHWORTH CO.
HOLLINGSWORTH & VOSE CO.
BALDWINVILLE PRODUCTS INC.
NEPONSET RIVER PAPER INC.
SONOCO PRODUCTS CO.
WESTVACO CORP.
SIMKINS INDUSTRIES INC
CHESAPEAKE PAPERBOARD CO.
S D WARREN CO.
S.D. WARREN CO.
GEORGIA-PACIFIC CORP.
BOISE CASCADE CORP.
INTERNATIONAL PAPER CO
C3ty
LAWRENCE
PEPPERELL
DALTON
DALTON
RUSSELL
HOLYOKE
RUSSELL
WESTFIELD
DALTON
OTTER RIVER
LEE
NATICK
HOUSATONIC
THORNDIKE
FITCHBURG
MILLERS FALLS
HAVERHILL
BOSTON
ADAMS
WEST SPRINGFIELD
WEST GROTON
ERVING
HYDE PARK
HOLYOKE
LUKE
CATONSVELLE
BALTIMORE
WESTBROQK.
HLNCKLEY
WOODLAND;
RUMFORD
JAY
State
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MD
MD
MD
ME
ME
ME
ME
ME
Mill Type Bleached?

kraft bleached

kraft bleached
kraft bleached
kraft bleached
kraft bleached
kraft bleached
A-6
-------
Name
LINCOLN PULP & PAPER CO. INC.
JAMES RIVER CORP.
GREAT NORTHERN PAPER INC.
CHAMPION INTERNATIONAL
JAMES RIVER CORP.
EASTERN FINE PAPER INC.
STATLER TISSUE CO.
YORKTOWNE PAPER MILLS CO.
SCOTT PAPER CO.
FRASER PAPER LTD.
KEYES FIBRE CO.
GREAT NORTHERN PAPER CO.
MADISON PAPER INDUSTRIES
MEAD CORP.
CHAMPION INTERNATIONAL
S D WARREN CO.
MENASHA CORP.
PACKAGING CORP. OF AMERICA
STONE CONTAINER CORP.
JEFFERSON SMURFIT CORP.
PLAINWELL PAPER CO. INC.
JAMES RIVER CORP.
MONROE PAPER CO.
JAMES RIVER CORP.
KIMBERLY-CLARK CORP
WHITE PIGEON PAPER CO.
ROCK-TENN CO.
JAMES RIVER CORP.
FLETCHER PAPER CO
SIMPSON PAPER CO
SIMPLEX PRODUCTS GROUP
P & G PAPER PRODUCTS CO.
E. B. EDDY PAPER INC.
BIG M PAPERBOARD
JAMES RIVER CORP.
City
LINCOLN
OLD TOWN
MILLINOCKET
BUCKSPORT
LIVERMORE
BREWER
AUGUSTA
GARDINER
WINSLOW
MADAWASKA
WATERVILLE
EAST MILLINOCKET
MADISON
ESCANABA
QUINNESEC
MUSKEGON
OTSEGO
FILER CITY
ONTONAGON
MONROE
PLAINWELL
PARCHMENT
MONROE
ROCHESTER
MUNISING
WHITE PIGEON
OTSEGO
YPSILANTI
ALPENA
VICKSBURG
CONSTATINE
CHEBOYGAN
PORT HURON
PALMYRA
KALAMAZOO
State
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
Mill Type Bleached?
kraft bleached
kraft bleached
sulfite unbleached

kraft bleached
kraft bleached
kraft bleached
semichem unbleached
semichem unbleached
semichem unbleached

A-7
-------
Name
MANISTIQUE PAPERS INC.
GEORGIA-PACIFIC CORP.
AMERICAN FIBRIT CO.
WALDORF CORP.
DETROIT RIVER PAPER CO.
SIMPLICITY PATTERN CO. INC.
MENOMINEE PAPER CO. INC.
FRENCH PAPER CO
JAMES RIVER CORP.
CONVERTERS PAPERBOARD CO.
MICHIGAN PAPERBOARD
BOISE CASCADE CORP.
POTLATCH CORP.
BLANDIN PAPER CO.
CHAMPION INTERNATIONAL
CERTAINTEED CORP.
POTLATCH CORP.
LAKE SUPERIOR PAPER INDUSTRIES
HENNEPIN PAPER CO.
WALDORF CORP.
TAMKO ASPHAULT PRODUCTS INC.
U.S. GYPSUM CORP.
TALLMAN CONDUIT CO
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
WEYERHAEUSER PAPER CO.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
INTERNATIONAL PAPER CO.
BURROWS PAPER CORP.
JAMES RIVER CORP.
NEWSPRINT SOUTH INC.
ATLAS ROOFING CO.
STONE CONTAINER CORP.
FEDERAL PAPER BOARD CO.
City
MANISTIQUE
KALAMAZOO
BATTLE CREEK
BATTLE CREEK
DETROIT
NILES
MENOMINEE
NILES
PORT HURON
ROCKFORD
BATTLE CREEK
INTERNATIONAL FALLS
CLOQUET
GRAND RAPIDS
SARTELL
SHAKOPEE
BRAINERD
DULUTH
LITTLE FALLS
ST. PAUL
JOPLIN
N. KANSAS CITY
LOUISIANA
MOSS POINT
NEW AUGUSTA
COLUMBUS
NATCHEZ
MONTICELLO
REDWOOD
PICKENS
WIGGINS
GRENADA
MARIDIAN
MISSOULA
RIEGELWOOD
State
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MN
MN
MN
MN
MN
MN
MN
MN
MN
MO
MO
MO
MS
MS
MS
MS
MS
MS
MS
MS
MS
MS
MT
NC
Mill Type Bleached?

kraft bleached
kraft bleached

kraft bleached
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft unbleached

kraft bleached
kraft bleached
A-8
-------
Name
CHAMPION INTERNATIONAL
WEYERHAEUSER PAPER CO.
WEYERHAEUSER PAPER CO.
CHAMPION INTERNATIONAL
U.S. PACKAGING INC.
ALPHA CELLULOSE CORP.
CAROLINA PAPER BOARD CORP.
SEALED AIR
JACKSON PAPER MFG. CO.
CASCADES INDUSTRIES INC.
LAUREL HILL PAPER CO
L YD ALL INC.
CELLU PRODUCTS
CELOTEX CORP.
P. H GLATFELTER CO.
HALIFAX PAPERBOARD CO. INC.
JAMES RIVER CORP.
GROVETON PAPER BOARD INC.
CPM INC
QUIN-T CORP. - NH
LYDALL INC.
PAPER SERVICES LTD
PENACOOK FIBRE CO
PAPERTECH CORP.
ASHUELOT PAPER CO
COY PAPER CO.
MONADNOCK PAPER MILLS INC.
G.E. ROBERTSON & CO.
CAMDEN PAPERBOARD
GEORGIA-PACIFIC CORP.
HOMASOTE CO.
U.S. GYPSUM CORP.
MILLEN INDUSTRIES
KIMBERLY-CLARK CORP.
JAMES RIVER CO.
City
CANTON
NEW BERN
PLYMOUTH
ROANOKE RAPIDS
MAXTON
LUMBERTON
CHARLOTTE
ROCKINGHAM
SYLVA
ROCKINGHAM
CORDOVA
TROY
PATTERSON
GOLDSBORO
PISGAH FOREST
ROANOKE RAPIDS
BERLIN
GROVETON
CLAREMONT
TILTON
ROCHESTER
HIND ALE
PENACOOK
WEST HOPKINTON
HINSDALE
CLAREMONT
BENNINGTON
HINSDALE
CAMDEN
DELAIR
W. TRENTON
CLARK
GARWOOD
SPOTSWOOD
WARREN GLEN
State
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
ND
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NJ
NJ
NJ
NJ
NJ
NJ
NJ
Mill Type Bleached?
kraft bleached
kraft bleached
kraft bleached
kraft unbleached

kraft bleached
semichem unbleached

A-9
-------
Name
JAMES RIVER CO.
DAVEY CO.
JAMES RIVER CORP.
NEWARK BOXBOARD CO.
MARCAL PAPER MILLS INC.
GARDEN STATE PAPER CO.
LOWE PAPER CO.
LEATHERBACK INDUSTRIES
INTERNATIONAL PAPER CO.
FINCH PRUYN & CO. INC.
JAMES RIVER CORP.
U.S. GYPSUM CORP.
MCINTYRE PAPER CO. INC.
EASTMAN KODAK
NORTH END PAPER CO.
HOLLINGSWORTH & VOSE CO.
CLIMAX MFG. CO.
SCHOELLER TECHNICAL PAPERS INC
COLUMBIA CORP.
SPAULDING COMPOSITES CO.
MOHAWK PAPER MILLS INC.
COLUMBIA CORP.
BURROWS PAPER CORP.
TAGSONS PAPERS INC.
FORT ORANGE PAPER CO. INC
RED HOOK PAPER CO.
LEWIS MILL
C & A WALLCOVERINGS INC.
HAMMERMILL PAPERS BUSINESS
City
MILFORD
JERSEY CITY
MILFORD
NEWARK
ELMWOOD PARK
GARFIELD
RIDGEFffiLD
ALBUQERQUE
TICONDEROGA
GLENS FALLS
GOUVERNEUR
OAKFIELD
FAYETTEVILLE
ROCHESTER
FULTON
GREENWICH
CARTHAGE
PULASKI
WALLOOMSAC
TONAWANDA
WATERFORD
CHATHAM
LITTLE FALLS
MECHANICVILLE
CASTLETON-ON-
HUDSON
RED HOOK
BEAVER FALLS
PLATTSBURGH
OSWEGO
State Mill Type Bleached?
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NM
NY kraft bleached
NY sulfite bleached
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
A-10
-------
Name
POTSDAM PAPER MILLS
BURROWS PAPER CORP.
LYDALL INC.
EASTMAN KODAK CO.
INTERNATIONAL PAPER CO.
CORNWALL PAPER MILLS
COTTRELL PAPER CO. INC.
KIMBERLY-CLARK CORP.
HOLLINGSWORTH & VOSE CO
STEVENS & THOMPSON PAPER
CO.INC.
LYONS FALLS PULP & PAPER INC.
CHAMPION INTERNATIONAL
KNOWLTON SPECIALTY PAPERS INC.
JAMES RIVER CORP.
JAMES RIVER CORP
MOHAWK PAPER MILLS INC
PAPYRUS NEWTON FALLS INC.
SPECIALTY PAPER BOARD INC.
JAMES RIVER CORP.
SCOTT PAPER CO.
SONOCO PRODUCTS CO.
FLOWER CITY TISSUE MILLS CO.
NORFOLK PAPER CO.
CASCADES NIAGARA FALLS INC.
PACKAGING CORP. OF AMERICA
DOMTAR GYPSUM
MARTISCO PAPER CO. INC.
LYONS FALLS PULP & PAPER INC.
MEAD PAPER
STONE CONTAINER CORP.
CONTAINER CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
FRANKLIN BOXBOARD CO.
PACKAGING CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
City
POTSDAM
LITTLE FALLS
HOOSICK FALLS
ROCHESTER
CORINTH
CORNWALL
ROCK CITY FALLS
ANCRAM
GREENWICH
MIDDLE FALLS

LYONS FALLS
DEFERIET
WATERTOWN
SOUTH GLENS FALLS
BROWNVILLE
COHOES
NEWTON FALLS
BEAVER FALLS
CARTHAGE
FORT EDWARD
AMSTERDAM
ROCHESTER
NORFOLK
NIAGARA FALLS
PLATTSBURGH
LOCKPORT
MARCELLUS
LYONS FALLS
CHILLICOTHE
COSHOCTON
CIRCLEVILLE
MIDDLETON
FRANKLIN
RITTMAN
LOCKLAND
State Mill Type Bleached?
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY

NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
OH kraft bleached
OH semichem unbleached
OH semichem unbleached
OH
OH
OH
OH
A-ll
-------
Name
CLEANERS HANGER CO.
CHASE PACKAGING CORP.
OHIO PULP MILLS INC.
MIAMI PAPER
U.S. GYPSUM CORP.
SORG PAPER CO.
DUPONT SPECIALTY IMAGING
MEDIA
CRYSTAL TISSUE CO.
SONOCO PRODUCTS CO.
CHENEY PULP & PAPER CO.
BECKETT PAPER CO.
GAYLORD CONTAINER CORP.
GEORGIA-PACIFIC CORP.
CHAMPION INTERNATIONAL
CINCINNATI PAPERBOARD CORP.
ROCK-TENN CO.
GREIF BOARD CORP.
APPLETON PAPERS INC.
SONOCO PRODUCTS CO.
HOWARD PAPER MILLS INC.
CERTAINTEED CORP.
HOWARD PAPER MILLS INC
MIDDLETOWN PAPERBOARD INC.
WEYERHAEUSER PAPER CO.
NATIONAL GYPSUM CO.
PORT HOWARD CORP.
ROBEL TISSUE MILLS INC.
GEORGIA-PACIFIC CORP.
GEORGIA-PACIFIC CORP.
GEORGIA-PACIFIC CORP.
BOISE CASCADE CORP.
POPE & TALBOT INC.
JAMES RIVER CORP.
INTERNATIONAL PAPER CO.
WEYERHAEUSER PAPER CO.
City
MASSILLON
CHAGRIN FALLS
CINCINNATI
WEST CARROLLTON
GYPSUM
MIDDLETON
COLUMBUS

MIDDLETON
MUNROE FALLS
FRANKLIN
HAMILTON
BALTIMORE
FRANKLIN
HAMILTON
CINCINNATI
CINCINNATI
MASSILLON
WEST CARROLLTON
LANCASTER
DAYTON
MILAN
URBAN A
MIDDLETOWN
VALLIANT
PRYOR
MUSKOGEE
PRYOR
PRYOR
ARDMORE
TOLEDO
ST HELENS
HALSEY
CLATSKANIE
GARDINER
SPRINGFIELD
State
OH
OH
OH
OH
OH
OH
OH

OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OK
OK
OK
OK
OR
OR
OR
OR
OR
OR
Mill Type Bleached?

kraft unbleached

co-semi unbleached
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft unbleached
A-12
-------
Name
WILLAMETTE INDUSTRIES INC.
WEYERHAEUSER PAPER CO.
JAMES RIVER CORP.
JAMES RIVER CORP.
SMURFIT NEWSPRINT CORP.
SMURFIT NEWSPRINT CORP.
WILLAMETTER INDUSTRIES INC.
P. H. GLATFELTER CO.
APPLETON PAPERS INC.
INTERNATIONAL PAPER CO.
P & G PAPER PRODUCTS CO.
WESTVACO CORP.
AHLSTROM FILTRATION INC.
BRANDYWINE PAPER CORP.
YORKTOWNE PAPER MILLS INC
NEWMAN AND COMPANY INC
SHRYOCK BROTHERS
INTERSTATE CONTAINER CORP.
HAMMERMILL PAPERS BUSINESS
AMERICAN PAPER PRODUCTS CO.
CONTAINER CORP. OF AMERICA
EXTON PAPER
SCOTT PAPER CO.
NATIONAL GYPSUM CO.
WOODSTREAM CORP
STONE CONTAINER CORP.
ROCK-TENN CO.
READING PAPERS OARD CORP.
SONOCO PRODUCTS CO.
QUIN-T CORP. - PA
HENRY MOLDED PRODUCTS INC.
SEALED AIR
POPE & TALBOT INC.
CORNELLY CONTAINERS
DAVEY CO.
City
ALBANY
NORTH BEND
HALSEY
WEST LINN
OREGON CITY
NEWBURG
JOHNSONBURG
SPRING GROVE
ROARING SPRING
ERIE
MEHOBANY
TYRONE
MT HOLLY SPRINGS
DOWNTNGTOWN
YORK
PHILIDELPHIA
DOWNINGTOWN
READING
LOCK HAVEN
EDEN
PHILADELPHIA
MODENA
CHESTER
MILTON
LITITZ
YORK
DELAWARE WATER GAP
READING
DOWNINGTOWN
ERIE
LEBANON
MODENA
RANSOM
PHILIDELPHIA
DOWNINGTOWN
State
OR
OR
OR
OR
OR
OR
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
Mill Type Bleached?
kraft bleached
semichem unbleached

kraft bleached
kraft bleached
kraft bleached
soda bleached
sulfite bleached

A-13
-------
Name
City
State MiH Type Bleached?
SIMPSON PAPER CO.
M.H. DIELECTRICS INC.
UNION CAMP CORP.
WILAMETTE IND.
BOWATER SOUTHERN PAPER CO.
MIQUON PA
MOUNT HOLLY SPRINGS PA
EASTOVER SC kraft bleached
BENNETTSVILLE SC kraft bleached
CATAWBA SC kraft bleached
INTERNATIONAL PAPER CO.
STONE CONTAINER CORP.
WESTVACO CORP.
SONOCO PRODUCTS CO.
KIMBERLY-CLARK CORP.
GEORGETOWN SC
FLORENCE SC
NORTH CHARLESTON SC
HARTSVILLE SC
BEECH ISLAND SC
kraft bleached
kraft unbleached
kraft unbleached
semichem unbleached
CAROTELL PAPER BOARD CORP.
BOWATER SOUTHERN PAPER CO.
PACKAGING CORP. OF AMERICA
INLAND CONTAINER CORP.
MEAD CORP.
TAYLORS SC
CALHOUN TN
COUNCE TN
NEW JOHNSONVILLE TN
KING SPORT TN
kraft bleached
kraft unbleached
semichem unbleached
soda bleached
TAMKO ASPHAULT PRODUCTS INC.
PONDEROSA OF TENNESSEE
ROCK-TENN CO.
LYDALL INC.
P & G CELLULOSE
KNOXVILLE
MEMPHIS
CHATTANOOGA
COVINGTON
MEMPHIS
TN
TN
TN
TN
TN
KIMBERLY-CLARK CORP. MEMPHIS
SONOCO PRODUCTS CO. NEWPORT
AHLSTROM FILTRATION INC CHATTANOOGA
CHATTANOOGA PAPERBOARD CORP. CHATTANOOGA
TEMPLE-INLAND FOREST PROD. INC SILSBEE
TN
TN
TN
TN
TX
kraft
bleached
SIMPSON PAPER CO.
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
INTERNATIONAL PAPER CO.
INLAND-ORANGE INC.
PASADENA
LUFKIN
HOUSTON
TEXARKANA
ORANGE
TX
TX
TX
TX
TX
kraft
kraft
kraft
kraft
kraft
bleached
bleached
bleached
bleached
unbleached
CELOTEX CORP.
ROCK-TENN CO.
CORRUGATED SERVICES
U.S. GYPSUM CORP.
EQUITABLE BAG CO. INC.
SAN ANTONIO
DALLAS
FORNEY
GALENA PARK
ORANGE
TX
TX
TX
TX
TX
A-14
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Name
WESTVACO CORP.
CHESAPEAKE CORP.
UNION CAMP CORP.
STONE CONTAINER CORP.
GEORGIA-PACIFIC CORP
VIRGINIA FIBRE CORP.
JAMES RIVER CORP.
GEORGIA BONDED FIBERS
BEAR ISLAND PAPER CO.
SONOCO PRODUCTS CO.
ROCK-TENN CO.
MANCHESTER BOARD & PAPER CO.
EHV-WEIDMANN INDUSTRIES INC.
SPECIALTY PAPERBOARD
SIMPSON PAPER CO.
CPM INC.
PUTNEY PAPER CO. INC.
SPECIALTY PAPER BOARD
BOISE CASCADE CORP.
WEYERHAEUSER PAPER CO.
LONGVIEW FIBRE CO.
JAMES RIVER CORP.
SIMPSON TACOMA KRAFT CO.
WEYERHAEUSER PULP MILL
PORT TOWNSEND PAPER CORP.
ITT RAYONIER INC.
GEORGIA-PACIFIC CORP.
SCOTT PAPER CO.
WEYERH.AEUSER PAPER CO.
SONOCO PRODUCTS CO.
PONDERAY NEWSPRINT CO.
CONTAINER CORP. OF AMERICA
BOISE CASCADE CORP.
KEYES FIBRE CO.
NORTH PACIFIC PAPER CO.
City
COVINGTON
WEST POINT
FRANKLIN
HOPEWELL
BIG ISLAND
AMHERST
RICHMOND
BUENA VISTA
ASHLAND
RICHMOND
LYNCHBURG
RICHMOND
ST. JOHNSBURY
SHELDON SPRINGS
GILMAN
E. RYEGATE
PUTNEY
SHELDON SPRINGS
WALLULA
LONGVIEW
LONGVIEW
CAMAS
TACOMA
EVERETT
PORT TOWNSEND
PORT ANGELES
BELLINGHAM
EVERETT
COSMOPOLIS
SUMNER
USK
TACOMA
VANCOUVER
WENATCHEE
LONGVIEW
State
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VT
VT
VT
VT
VT
VT
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
Mill Type
kraft
kraft
kraft
kraft
semichem
semichem

co-semi
co-semi
co-semi
co-sulfite
kraft
kraft
kraft
sulfite
sulfite
sulfite
sulfite

Bleached?
bleached
bleached
bleached
unbleached
unbleached
unbleached

bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
bleached
bleached
bleached
bleached

A-15
-------
Name
BOISE CASCADE CORP.
DAISHOWA AMERICA CO. LTD.
GRAYS HARBOR PAPER CO.
ITT-RAYONIER, INC.
INLAND EMPIRE PAPER CO.
GEORGIA-PACIFIC CORP.
CONSOLIDATED PAPERS INC.
MOSINEE PAPER CO.
THILMANY PULP & PAPER CO.
PACKAGING CORP. OF AMERICA
CROSS POINTE PAPER CORP.
BADGER PAPER MILLS INC.
WEYERHAUSER
WAUSAU PAPER MILLS CO.
GEORGIA-PACIFIC CORP.
NICOLET PAPER CO.
GLOBE BUILDING MATERIALS INC.
BELOIT BOX BOARD CO.
SCOTT PAPER CO.
POPE & TALBOT INC.
WARD PAPER CO. /INTN'L. PAPER
MEAD CORP.
U.S. PAPER MILLS INC.
CONSOLIDATED PAPERS INC.
JAMES RIVER CORP.
SHAWANO PAPER MILS
STEVENS POINT DIV.
FORT HOWARD CORP.
RHINELANDER PAPER CORP. INC.
SCOTT PAPER CO.
NIAGARA OF WISCONSIN PAPER
CORP.
FOX RIVER PAPER CO. INC.
POPE & TALBOT INC.
NEENAH PAPER
KERWIN PAPER CO.
City
STEILACOOM
PORT ANGELES
HOQUIAM
HOQUIAM
MILLWOOD
NEKOOSA
WISCONSIN RAPIDS
MOSINEE
KAUKAUNA
TOMAHAWK
PARK FALLS
PESHITIGO
ROTHSCHILD
BROKAW
PORT EDWARDS
DEPERE
CORNELL
BELOIT
MARINETTE
EAU CLAIRE
MERRILL
MENASHA
DEPERE
WISCONSIN RAPIDS
GREEN BAY
SHAWANO
STEVENS POINT
GREEN BAY
RHINELANDER
OCONTO FALLS
NIAGARA

APPLETON
EAST LADYSMITH
STEVENS POINT
APPLETON
State
WA
WA
WA
WA
WA
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI

WI
WI
WI
WI
Mill Type Bleached?

kraft bleached
kraft bleached
kraft unbleached
kraft unbleached
semichem unbleached
sulfite bleached
sulfite bleached
sulfite bleached
sulfite bleached
sulfite bleached

A-16
-------
Name
GEO A. WHITING PAPER CO.
WISCONSIN TISSUE MILLS INC.
P&G
WISCONSIN PAPERBOARD
JAMES RIVER CORP.
PONDEROSA PULP PRODUCTS
P. H. GLATFELTER CO.
MIDTEC PAPER CORP.
APPLETON PAPERS INC.
CONSOLIDATED PAPERS INC.
U.S. PAPER MILLS CORP.
CONSOLIDATED PAPERS INC.
FILTER MATERIALS INC.
KIMBERLY-CLARK
KIMBERLY-CLARK CORP.
BADGER PAPER MILLS INC.
HALLTOWN PAPERBOARD CO.
BANNER FIBREBOARD CO
City
MENASHA
MENASHA
GREEN BAY
MILWAUKEE
ASHLAND
OSHKOSH
NEEHAH
KIMBERLY
COMBINED LOCKS
STEVENS POINT
MENASHA
WISCONSIN RAPIDS
WAUPACA
NEENAH
NEENAH
NEENAH
HALLTOWN
WELLSBURG
State Mill Type Bleached?
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
wv
wv
A-17
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Appendix B

NESHAP for Source Category: Pulp and Paper Production

(40 CFR 63 Subpart S)
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18616 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
2,3,7,8-TCDF). chloroform, biochemical
oxygen demand (BOD), and total
suspended solids (TSS). Methods for
monitoring these pollutants are
specified in tables at 40 CFR part 136.
When available, mediods published by
voluntary consensus standards bodies
are included in the list of approved
methods in these tables. Specifically,
voluntary consensus standards are
approved for the determination of
chloroform, BOD, and TSS (from the
18th edition of Standard Methods). In
addition, USGS methods are approved
for BOD and TSS.
For TCDD and TCDF, EPA is
specifying the use of EPA Method 1613,
promulgated at 62 FR 48394 (September
15, 1997). This method was developed
to support data gathering for regulation
of pulp and paper industry discharges
and incorporates procedures from EPA,
academia, industry (NCASI and the Dow
Chemical Co.) and a commercial
laboratory. There were no voluntary
consensus standards methods available
for these pollutants by high resolution
gas chromatography (HRGC) coupled
with high resolution mass spectrometry
(HRMS) at the time EPA Method 1613
was developed. Both HRGC and HRMS
are required to separately detect and
measure dioxin and furan isomers at
low concentrations (i.e., low parts per
quadrillion (ppq)). High resolution
techniques are necessary to conduct the
assay in the presence of interfering
analytes. EPA is unaware of the
existence of an HRGC/HRMS method
from a voluntary consensus standards
body for determination of TCDD and
TCDF in the low ppq range in pulp and
paper industry discharges.

XI. Background Documents
The summary of public comments
and agency responses and the
environmental impacts statement for die
NESHAP are contained in the final
Background Information Document
(BID). A paper copy of the final
Background Information Document for
the NESHAP may be obtained from the
U.S. EPA Library (MD-35). Research
Triangle Park, North Carolina 27711,
telephone (919) 541-2777; or from the
National Technical Information
Services, 5285 Port Royal Road,
Springfield, Virginia 22151, telephone
(703) 487-4650. To obtain the final
Background Information Document,
please refer to "Pulp, Paper, and
Paperboard Industry—Background
Information for Promulgated Air
Emission Standards, Manufacturing
Processes at Kraft, Sulfite, Soda, Semi-
Chemical, Mechanical, and Secondary
and Non-wood Fiber Mills, Final EIS"
(EPA-453/R-93-050b). An electronic
copy of the final Background
Information Document is available from
die Technology Transfer Network
described in die SUPPLEMENTARY
INFORMATION section of this document.
Documents supporting the effluent
limitations guidelines and standards
may be obtained by contacting the
National Technical Information
Services, 5285 Port Royal Road,
Springfield, Virginia 22151, telephone
(703) 487-4650.
EPA's technical conclusions
concerning the wastewater regulations
are detailed in die "Supplemental
Technical Development Document for
Effluent Limitations Guidelines and
Standards for the Pulp, Paper, and
Paperboard Point Source Category"
(EPA-821-R-9 7-011, DCN 14487). The
Agency's economic analysis is found in
the "Economic Analysis for the National
Emissions Standards for Hazardous Air
Pollutants for Source Category: Pulp and
Paper Production: Effluent Limitations
Guidelines, Pretreatment Standards, and
New Source Performance Standards for
die Pulp, Paper, and Paperboard
Industry—Phase I," referred to as the
Economic Analysis (EPA-821-R-97-
012, DCN 14649). This document also
includes an analysis of the incremental
costs and pollutant removals for the
effluent regulations. Analytical methods
used in the development of the effluent
guidelines are found in "Analytical
Methods for the Determination of
Pollutants in Pulp and Paper Industry
Wastewater," a compendium of
analytical methods (EPA 821-B-97-00).
The environmental assessment is
presented in the "Water Quality
Assessment of Final Effluent
Limitations Guidelines for the
Papergrade Sulfite and Bleached
Papergrade Kraft and Soda
Subcategories of the Pulp, Paper, and
Paperboard Industry" (EPA-823-R-97-
009, DCN 14650). The statistical
analyses used in this rulemaking are
detailed in the "Statistical Support
Document for the Pulp and Paper
Industry: Subpart B" (DCN 14496). The
best management practices program is
presented in "Technical Support
Document for Best Management
Practices for Spent Pulping Liquor
Management, Spill Prevention, and
Control (DCN 14489), also referred to as
the BMP Technical Support Document.
The Advanced Technology Incentives
Program is presented in the "Technical
Support Document for the Voluntary
Advanced Technology Incentives
Program," (EPA-821-R-97-014, DCN
14488).

List of Subjects

40 CFR Part 63

Environmental protection, Air
pollution control, Hazardous
substances, Reporting and
recordkeeping requirements.

40 CFR Part 261

Hazardous waste, Recycling,
Reporting and recordkeeping
requirements.

40 CFR Part 430

Paper and paper products industry.
Reporting and recordkeeping
requirements, Waste treatment and
disposal, Water pollution control.
Dated: November 14, 1997.
Carol M. Browner,
Administrator.

For the reasons set out in the
preamble, title 40, chapter I of the Code
of Federal Regulations is amended as
follows:

PART 63—NATIONAL EMISSION
STANDARDS FOR HAZARDOUS AIR
POLLUTANTS FOR SOURCE
CATEGORIES

1. The authority citation for part 63
continues to read as follows:
Authority: 42 U.S.C 7401,erseq

2. Part 63 is amended by adding
subpart S to read as follows:

Subpart S—National Emission Standards
for Hazardous Air Pollutants from the Pulp
and Paper Industry
Sec
63.440 Applicability.
63.441 Definitions
63.442 [Reserved]
63.443 Standards for the pulping system at
kraft, soda, and semi-chemical processes.
63.444 Standards for the pulping system at
sulfite processes.
63.445 Standards for the bleaching system.
63.446 Standards for kraft pulping process
condensates.
63.447 Clean condensate alternative.
63.448-63.449 [Reserved]
63.450 Standards for enclosures and closed-
vent systems.
63.451-63452 [Reserved]
63.453 Monitoring requirements
63.454 Recordkeeping requirements.
63.455 Reporting requirements.
63.456 [Reserved]
63 457 Test methods and procedures.
63458 Delegation of authority.
63.459 [Reserved]
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Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998 /Rules and Regulations 18617
Table 1 to Subpart S.—General Provisions
Applicability to Subpart S

Subpart S—National Emission
Standards for Hazardous Air Pollutants
from the Pulp and Paper Industry

§63.440 Applicability.
(a) The provisions of this subpart
apply to the owner or operator of
processes that produce pulp, paper, or
paperboard; that are located at a plant
site that is a major source as defined in
§ 63.2 of subpart A of this part; and tiiat
use the following processes and
materials:
(1) Kraft, soda, sulfite, or semi-
chemical pulping processes using wood;
or
(2) Mechanical pulping processes
using wood; or
(3) Any process using secondary or
non-wood fibers.
(b) The affected source to which the
existing source provisions of this
subpart apply is as follows:
(1) For the processes specified in
paragraph (a)(l) of this section, the
affected source is the total of all HAP
emission points in the pulping and
bleaching systems; or
(2) For the processes specified in
paragraphs (a) (2) or (a) (3) of this section,
the affected source is the total of all
HAP emission points in the bleaching
system.
(c) The new source provisions of this
subpart apply to the total of all HAP
emission points at new or existing
sources as follows:
(1) Each affected source defined in
paragraph (b)(l) of this section that
commences construction or
reconstruction after December 17, 1993;
(2) Each pulping system or bleaching
system for the processes specified in
paragraph (a)(l) of this section that
commences construction or
reconstruction after December 17, 1993;
(3) Each additional pulping or
bleaching line at the processes specified
in paragraph (a)(l) of this section, that
commences construction after December
17, 1993;
(4) Each affected source defined in
paragraph (b) (2) of this section that
commences construction or
reconstruction after March 8, 1996; or
(5) Each additional bleaching line at
the processes specified in paragraphs
(a) (2) or (a) (3) of this section, that
commences construction after March 8,
1996.
(d) Each existing source shall achieve
compliance no later than April 16, 2001,
except as provided in paragraphs (d)(l)
through (d)(3) of this section.
(1) Each kraft pulping system shall
achieve compliance with the pulping
system provisions of § 63.443 for the
equipment listed in §63.443(a)(l)(ii)
through (a)(l)(v) as expeditiously as
practicable, but in no event later than
April 17, 2006 and the owners and
operators shall establish dates, update
dates, and report the dates for the
milestones specified in § 63.455(b).
(2) Each dissolving-grade bleaching
system at either kraft or sulfite pulping
mills shall achieve compliance with the
bleach plant provisions of § 63.445 of
this subpart as expeditiously as
practicable, but in no event later than 3
years after the promulgation of the
revised effluent limitation guidelines
and standards under 40 CFR 430.14
through 430.17 and 40 CFR 430.44
through 430.47.
(3) Each bleaching system complying
with the Voluntary Advanced
Technology Incentives Program for
Effluent Limitation Guidelines in 40
CFR 430.24, shall comply with the
requirements specified in either
paragraph (d)(3)(i) or (d)(3)(ii) of this
section for the effluent limitation
guidelines and standards in 40 CFR
430.24.
(i) Comply with the bleach plant
provisions of § 63.445 of this subpart as
expeditiously as practicable, but in no
event later than April 16, 2001.
(ii) Comply with all of the following:
(A) The owner or operator of a
bleaching system shall comply with the
bleach plant provisions of § 63.445 of
this subpart as expeditiously as
practicable, but in no event later than
April 15, 2004.
(B) The owner or operator of a
bleaching system shall not increase the
application rate of chlorine or
hypochlorite in kg of bleaching agent
per megagram of OOP. in the bleaching
system above the average daily rates
used over the three months prior to June
15, 1998 until the requirements of
paragraph (d) (3) (ii) (A) of this section are
met and record application rates as
specified in §63.454(c).
(C) Owners and operators shall
establish dates, update dates, and report
the dates for the milestones specified in
§63.455(b).
(e) Each new source, specified as the
total of all HAP emission points for the
sources specified in paragraph (c) of this
section, shall achieve compliance upon
start-up or June 15, 1998, whichever is
later, as provided in § 63.6(b) of subpart
A of this part.
(f) Each owner or operator of an
affected source with affected process
equipment shared by more than one
type of pulping process, shall comply
with the applicable requirement in this
subpart that achieves the maximum
degree of reduction in HAP emissions.
(g) Each owner or operator of an
affected source specified in paragraphs
(a) through (c) of this section must
comply with the requirements of
subpart A—General Provisions of this
part, as indicated in table 1 to this
subpart.

§63.441 Definitions.
All terms used in this subpart shall
have the meaning given them in the
CAA, in subpart A of this part, and in
this section as follows:
Acid condensate storage tank means
any storage tank containing cooking
acid following the sulfur dioxide gas
fortification process.
Black liquor means spent cooking
liquor that has been separated from the
pulp produced by the kraft, soda, or
semi-chemical pulping process.
Bleaching means brightening of pulp
by the addition of oxidizing chemicals
or reducing chemicals.
Bleaching line means a group of
bleaching stages arranged in series such
that bleaching of the pulp progresses as
the pulp moves from one stage to the
next.
Bleaching stage means all process
equipment associated with a discrete
step of chemical application and
removal in the bleaching process
including chemical and steam mixers,
bleaching towers, washers, seal (filtrate.,
tanks, vacuum pumps, and any other
equipment serving the same function as
those previously listed.
Bleaching system means all process
equipment after high-density pulp
storage prior to the first application of
oxidizing chemicals or reducing
chemicals following the pulping system,
up to and including the final bleaching
stage.
Boiler means any enclosed
combustion device that extracts useful
energy in the form of steam. A boiler is
not considered a thermal oxidizer.
Chip steamer means a vessel used for
the purpose of preheating or pretreating
wood chips prior to the digester, using
flash steam from the digester or live
steam.
Closed-vent system means a system
that is not open to the atmosphere and
is composed of piping, ductwork.
connections, and, if necessary, flow-
inducing devices that transport gas or
vapor from an emission point to a
control device.
Combustion device means an
individual unit of equipment, including
but not limited to, a thermal oxidizer,
lime kiln, recovery furnace, process
heater, or boiler, used for the thermal
oxidation of organic hazardous air
pollutant vapors.
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18618 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
Decker system means all equipment
used to thicken the pulp slurry or
reduce its liquid content after the pulp
washing system and prior to high-
density pulp storage. The decker system
includes decker vents, filtrate tanks,
associated vacuum pumps, and any
other equipment serving the same
function as those previously listed.
Digester system means each
continuous digester or each batch
digester used for the chemical treatment
of wood or non-wood fibers. The
digester system equipment includes
associated flash tank(s), blow tank(s),
chip steamer (s) not using fresh steam,
blow heat recovery accumulator^),
relief gas condenser (s), prehydrolysis
unit(s) preceding the pulp washing
system, and any other equipment
serving the same function as those
previously listed. The digester system
includes any of the liquid streams or
condensates associated with batch or
continuous digester relief, blow, or flash
steam processes.
Emission point means any part of a
stationary source that emits hazardous
air pollutants regulated under this
subpart, including emissions from
individual process vents, stacks, open
pieces of process equipment, equipment
leaks, wastewater and condensate
collection and treatment system units,
and those emissions that could
reasonably be conveyed through a stack,
chimney, or duct where such emissions
first reach the environment.
Evaporator system means all
equipment associated with increasing
the solids content and/or concentrating
spent cooking liquor from the pulp
washing system including pre-
evaporators, multi-effect evaporators,
concentrators, and vacuum systems, as
well as associated condensers, hotwells,
and condensate streams, and any other
equipment serving the same function as
those previously listed.
Flow indicator means any device that
indicates gas or liquid flow in an
enclosed system.
HAP means a hazardous air pollutant
as defined in § 63.2 of subpart A of this
part.
High volume, low concentration or
HVLC collection system means the gas
collection and transport system used to
convey gases from the HVLC system to
a control device.
High volume, low concentration or
HVLC system means the collection of
equipment including the pulp washing,
knotter, screen, decker, and oxygen
delignification systems, weak liquor
storage tanks, and any other equipment
serving the same function as those
previously listed.
Knotter system means equipment
where knots, oversized material, or
pieces of uncooked wood are removed
from the pulp slurry after the digester
system and prior to the pulp washing
system. The knotter system equipment
includes the knotter, knot drainer tanks,
ancillary tanks, and any other
equipment serving the same function as
those previously listed.
Kraft pulping means a chemical
pulping process that uses a mixture of
sodium hydroxide and sodium sulfide
as the cooking liquor.
Lime kiln means an enclosed
combustion device used to calcine lime
mud, which consists primarily of
calcium carbonate, into calcium oxide.
Low volume, high concentration or
LVHC collection system means the gas
collection and transport system used to
convey gases from the LVHC system to
a control device.
Low volume, high concentration or
LVHC system means the collection of
equipment including the digester,
turpentine recovery, evaporator, steam
stripper systems, and any other
equipment serving the same function as
those previously listed.
Mechanical pulping means a pulping
process that only uses mechanical and
thermo-mechanical processes to reduce
wood to a fibrous mass. The mechanical
pulping processes include, but are not
limited to, stone groundwood,
pressurized groundwood. refiner
mechanical, thermal refiner mechanical,
thermo-mechanical, and tandem
thermo-mechanical.
Non-wood pulping means the
production of pulp from fiber sources
other than trees. The non-wood fiber
sources include, but are not limited to,
bagasse, cereal straw, cotton, flax straw,
hemp, jute, kenaf, and leaf fibers.
Oven-dried pulp or ODP means a pulp
sample at zero percent moisture content
by weight. Pulp samples for
applicability or compliance
determinations for both the pulping and
bleaching systems shall be unbleached
pulp. For purposes of complying with
mass emission limits in this subpart,
megagram of ODP shall be measured to
represent the amount of pulp entering
and processed by the equipment system
under the specified mass limit. For
equipment that does not process pulp,
megagram of ODP shall be measured to
represent the amount of pulp that was
processed to produce the gas and liquid
streams.
Oxygen delignification system means
the equipment that uses oxygen to
remove lignin from pulp after high-
density stock storage and prior to the
bleaching system. The oxygen
delignification system equipment
includes the blow tank, washers, filtrate
tanks, any interstage pulp storage tanks,
and any other equipment serving the
same function as those previously
listed.
Primary fuel means the fuel that
provides the principal heat input to the
combustion device. To be considered
primary, the fuel must be able to sustain
operation of the combustion device
without the addition of other fuels.
Process wastewater treatment system
means a collection of equipment, a
process, or specific technique that
removes or destroys the HAP's in a
process wastewater stream. Examples
include, but are not limited to, a steam
stripping unit, wastewater thermal
oxidizer, or biological treatment unit.
Pulp washing system means all
equipment used to wash pulp and
separate spent cooking chemicals
following the digester system and prior
to the bleaching system, oxygen
delignification system, or paper
machine system (at unbleached mills).
The pulp washing system equipment
includes vacuum drum washers,
diffusion washers, rotary pressure
washers, horizontal belt filters.
intermediate stock chests, and their
associated vacuum pumps, filtrate
tanks, foam breakers or tanks, and any
other equipment serving the same
function as those previously listed. The
pulp washing system does not include
deckers, screens, knotters, stock chests.
or pulp storage tanks following the last
stage of pulp washing.
Pulping line means a group of
equipment arranged in series such that
the wood chips are digested and the
resulting pulp progresses through a
sequence of steps that may include
knotting, refining, washing, thickening,
blending, storing, oxygen
delignification, and any other
equipment serving the same function as
those previously listed.
Pulping process condensates means
any HAP-containing liquid that results
from contact of water with organic
compounds in the pulping process.
Examples of process condensates
include digester system condensates,
turpentine recovery system condensates,
evaporator system condensates, LVHC
system condensates, HVLC system
condensates, and any other condensates
from equipment serving the same
function as those previously listed.
Liquid streams that are intended for
byproduct recovery are not considered
process condensate streams.
Pulping system means all process
equipment, beginning with the digester
system, and up to and including the last
piece of pulp conditioning equipment
prior to the bleaching system, including
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Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations 18619
treatment with ozone, oxygen, or
peroxide before the first application of
a chemical bleaching agent intended to
brighten pulp. The pulping system
includes pulping process condensates
and can include multiple pulping lines.
Recovery furnace means an enclosed
combustion device where concentrated
spent liquor is burned to recover
sodium and sulfur, produce steam, and
dispose of unwanted dissolved wood
components in the liquor.
Screen system means equipment in
which oversized particles are removed
from the pulp slurry prior to the
bleaching or paper-making system
washed stock storage.
Secondary Tiber pulping means a
pulping process that converts a fibrous
material, that has previously undergone
a manufacturing process, into pulp
stock through the addition of water and
mechanical energy. The mill then uses
that pulp as the raw material in another
manufactured product. These mills may
also utilize chemical, heat, and
mechanical processes to remove ink
particles from the fiber stock.
Semi-chemical pulping means a
pulping process that combines both
chemical and mechanical pulping
processes. The semi-chemical pulping
process produces intermediate yields
ranging from 55 to 90 percent.
Soda pulping means a chemical
pulping process that uses sodium
hydroxide as the active chemical in the
cooking liquor.
Spent liquor means process liquid
generated from the separation of
cooking liquor from pulp by the pulp
washing system containing dissolved
organic wood materials and residual
cooking compounds.
Steam stripper system means a
column (including associated stripper
feed tanks, condensers, or heat
exchangers) used to remove compounds
from wastewater or condensates using
steam. The steam stripper system also
contains all equipment associated with
a methanol rectification process
including rectifiers, condensers,
decanters, storage tanks, and any other
equipment serving the same function as
those previously listed.
Strong liquor storage tanks means all
storage tanks containing liquor that has
been concentrated in preparation for
combustion or oxidation in the recovery
process.
Sulfite pulping means a chemical
pulping process that uses a mixture of
sulfurous acid and bisulfite ion as the
cooking liquor.
Temperature monitoring device
means a piece of equipment used to
monitor temperature and having an
accuracy of ±1.0 percent of the
temperature being monitored expressed
in degrees Celsius or ±0.5 degrees
Celsius (°C), whichever is greater.
Thermal oxidizer means an enclosed
device that destroys organic compounds
by thermal oxidation.
Turpentine recovery system means all
equipment associated with recovering
turpentine from digester system gases
including condensers, decanters, storage
tanks, and any other equipment serving
the same function as those previously
listed. The turpentine recovery system
includes any liquid streams associated
with the turpentine recovery process
such as turpentine decanter underflow.
Liquid streams that are intended for
byproduct recovery are not considered
turpentine recovery system condensate
streams.
Weak liquor storage tank means any
storage tank except washer filtrate tanks
containing spent liquor recovered from
the pulping process and prior to the
evaporator system.

§63.442 [Reserved]

§63.443 Standards for the pulping system
at kraft, soda, and semi-chemical
processes.
(a) The owner or operator of each
pulping system using the kraft process
subject to the requirements of this
subpart shall control the total HAP
emissions from the following equipment
systems, as specified in paragraphs (c)
and (d) of this section.
(1) At existing affected sources, the
total HAP emissions from the following
equipment systems shall be controlled:
(i) Each LVHC system;
(ii) Each knotter or screen system with
total HAP mass emission rates greater
than or equal to the rates specified in
paragraphs (a)(l)(ii)(A) or (a)(l)(ii)(B) of
this section or the combined rate
specified in paragraph (a)(l)(ii)(C) of
this section.
(A) Each knotter system with
emissions of 0.05 kilograms or more of
total HAP per megagram of ODP (0.1
pounds per ton).
(B) Each screen system with
emissions of 0.10 kilograms or more of
total HAP per megagram of ODP (0.2
pounds per ton).
(C) Each knotter and screen system
with emissions of 0.15 kilograms or
more of total HAP per megagram of ODP
(0.3 pounds per ton).
(iii) Each pulp washing system;
(iv) Each decker system that:
(A) Uses any process water other than
fresh water or paper machine white
water; or
(B) Uses any process water with a
total HAP concentration greater than
400 parts per million by weight; and
(v) Each oxygen delignification
system.
(2) At new affected sources, the total
HAP emissions from the equipment
systems listed in paragraphs (a)(l)(i),
(a)(l)(iii), and (a)(l)(v) of this section
and the following equipment systems
shall be controlled:
(i) Each knotter system;
(ii) Each screen system;
(iii) Each decker system; and
(iv) Each weak liquor storage tank.
(b) The owner or operator of each
pulping system using a semi-chemical
or soda process subject to the
requirements of this subpart shall
control the total HAP emissions from
the following equipment systems as
specified in paragraphs (c) and (d) of
this section.
(1) At each existing affected sources,
the total HAP emissions from each
LVHC system shall be controlled.
(2) At each new affected source, the
total HAP emissions from each LVHC
system and each pulp washing system
shall be controlled.
(c) Equipment systems listed in
paragraphs (a) and (b) of this section
shall be enclosed and vented into a
closed-vent system and routed to a
control device that meets the
requirements specified in paragraph (d)
of this section. The enclosures and
closed-vent system shall meet the
requirements specified in § 63.450.
(d) The control device used to reduce
total HAP emissions from each
equipment system listed in paragraphs
(a) and (b) of this section shall:
(1) Reduce total HAP emissions by 98
percent or more by weight; or
(2) Reduce the total HAP
concentration at the outlet of the
thermal oxidizer to 20 parts per million
or less by volume, corrected to 10
percent oxygen on a dry basis; or
(3) Reduce total HAP emissions using
a thermal oxidizer designed and
operated at a minimum temperature of
871 °C (1600 °F) and a minimum
residence time of 0.75 seconds, or
(4) Reduce total HAP emissions using
a boiler, lime kiln, or recovery furnace
by introducing the HAP emission stream
with the primary fuel or into the flame
zone.
(e) Periods of excess emissions
reported under § 63.455 shall not be a
violation of § 63.443 (c) and (d)
provided that the time of excess
emissions (excluding periods of startup,
shutdown, or malfunction) divided by
the total process operating time in a
semi-annual reporting period does not
exceed the following levels:
(1) One percent for control devices
used to reduce the total HAP emissions
from the LVHC system; and
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18620 Federal Register/Vol. 63, No. 72 / Wednesday, April 15, 1998/Rules and Regulations
(2) Four percent for control devices
used to reduce the total HAP emissions
from the HVLC system; and
(3) Four percent for control devices
used to reduce the total HAP emissions
from both the LVHC and HVLC systems.

§ 63.444 Standards for the pulping system
at sulfite processes.
(a) The owner or operator of each
sulfite process subject to the
requirements of this subpart shall
control the total HAP emissions from
the following equipment systems as
specified in paragraphs (b) and (c) of
this section.
(1) At existing sulfite affected sources,
the total HAP emissions from the
following equipment systems shall be
controlled:
(i) Each digester system vent;
(ii) Each evaporator system vent; and
(iii) Each pulp washing system.
(2) At new affected sources, the total
HAP emissions from the equipment
systems listed in paragraph (a)(l) of this
section and the following equipment
shall be controlled;
(i) Each weak liquor storage tank;
(ii) Each strong liquor storage tank;
and
(iii) Each acid condensate storage
tank.
(b) Equipment listed in paragraph (a)
of this section shall be enclosed and
vented into a closed-vent system and
routed to a control device that meets the
requirements specified in paragraph (c)
of this section. The enclosures and
closed-vent system shall meet the
requirements specified in § 63.450.
Emissions from equipment listed in
paragraph (a) of this section that is not
necessary to be reduced to meet
paragraph (c) of this section is not
required to be routed to a control
device.
(c) The total HAP emissions from both
the equipment systems listed in
paragraph (a) of this section and the
vents, wastewater, and condensate
streams from the control device used to
reduce HAP emissions, shall be
controlled as follows.
(1) Each calcium-based or sodium-
based sulfite pulping process shall:
(i) Emit no more than 0.44 kilograms
of total HAP or methanol per megagram
(0.89 pounds per ton) of ODP; or
(ii) Remove 92 percent or more by
weight of the total HAP or methanol.
(2) Each magnesium-based or
ammonium-based sulfite pulping
process shall:
(i) Emit no more than 1.1 kilograms of
total HAP or methanol per megagram
(2.2 pounds per ton) of ODP; or
(ii) Remove 87 percent or more by
weight of the total HAP or methanol.
§ 63.445 Standards for the bleaching
system.
(a) Each bleaching system that does
not use any chlorine or chlorinated
compounds for bleaching is exempt
from the requirements of this section.
Owners or operators of the following
bleaching systems shall meet all the
provisions of this section:
(1) Bleaching systems that use
chlorine;
(2) Bleaching systems bleaching pulp
from kraft, sulfite, or soda pulping
processes that uses any chlorinated
compounds; or
(3) Bleaching systems bleaching pulp
from mechanical pulping processes
using wood or from any process using
secondary or non-wood fibers, that use
chlorine dioxide.
(b) The equipment at each bleaching
stage, of the bleaching systems listed in
paragraph (a) of this section, where
chlorinated compounds are introduced
shall be enclosed and vented into a
closed-vent system and routed to a
control device that meets the
requirements specified in paragraph (c)
of this section. The enclosures and
closed-vent system shall meet the
requirements specified in § 63.450.
(c) The control device used to reduce
chlorinated HAP emissions (not
including chloroform) from the
equipment specified in paragraph (b) of
this section shall:
(1) Reduce the total chlorinated HAP
mass in the vent stream entering the
control device by 99 percent or more by
weight;
(2) Achieve a treatment device outlet
concentration of 10 parts per million or
less by volume of total chlorinated HAP;
or
(3) Achieve a treatment device outlet
mass emission rate of 0.001 kg of total
chlorinated HAP mass per megagram
(0.002 pounds per ton) of ODP.
(d) The owner or operator of each
bleaching system subject to paragraph
(a) (2) of this section shall comply with
paragraph (d)(l) or (d)(2) of this section
to reduce chloroform air emissions to
the atmosphere, except the owner or
operator of each bleaching system
complying with extended compliance
under §63.440(d)(3)(ii) shall comply
with paragraph (d)(l) of this section.
(1) Comply with the following
applicable effluent limitation guidelines
and standards specified in 40 CFR part
430:
(i) Dissolving-grade kraft bleaching
systems and lines, 40 CFR 430.14
through 430.17;
(ii) Paper-grade kraft and soda
bleaching systems and lines. 40 CFR
430.24(a) (1) and (e), and 40 CFR 430.26
(a) and (c);
(iii) Dissolving-grade sulfite bleaching
systems and lines, 40 CFR 430.44
through 430.47; or
(iv) Paper-grade sulfite bleaching
systems and lines, 40 CFR 430.54(a) and
(c),and430.56(a)and(c).
(2) Use no hypochlorite or chlorine
for bleaching in the bleaching system or
line.

§ 63.446 Standards for kraft pulping
process condensates.
(a) The requirements of this section
apply to owners or operators of kraft
processes subject to the requirements of
this subpart.
(b) The pulping process condensates
from the following equipment systems
shall be treated to meet the
requirements specified in paragraphs
(c), (d), and (e) of this section:
(1) Each digester system;
(2) Each turpentine recovery system;
(3) Each evaporator stage where weak
liquor is introduced (feed stages) in the
evaporator system;
(4) Each HVLC collection system: and
(5) Each LVHC collection system
(c) One of the following combinations
of HAP-containing pulping process
condensates generated, produced, or
associated with the equipment systems
listed in paragraph (b) of this section
shall be subject to the requirements of
paragraphs (d) and (e) of this section:
(1) All pulping process condensates
from the equipment systems specified in
paragraphs (b)(l) through (b)(5) of tiiis
section.
(2) The combined pulping process
condensates from the equipment
systems specified in paragraphs (b) (4)
and (b)(5) of this section, plus pulping
process condensate stream (s) that in
total contain at least 65 percent of the
total HAP mass from the pulping
process condensates from equipment
systems listed in paragraphs (b)(l)
through (b)(3) of this section.
(3) The pulping process condensates
from equipment systems listed in
paragraphs (b)(l) through (b)(5) of this
section that in total contain a total HAP
mass of 3.6 kilograms or more of total
HAP per megagram (7.2 pounds per ton)
of ODP for mills that do not perform
bleaching or 5.5 kilograms or more of
total HAP per megagram (11.1 pounds
per ton) of ODP for mills that perform
bleaching.
(d) The pulping process condensates
from the equipment systems listed in
paragraph (b) of this section shall be
conveyed in a closed collection system
that is designed and operated to meet
the requirements specified in
paragraphs (d)(l) and (d)(2) of this
section.
(1) Each closed collection system
shall meet the individual drain system
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Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations 18621
requirements specified in § 63.960,
63.961 , and 63.962 of subpart RR of this
part, except for closed vent systems and
control devices shall be designed and
operated in accordance with
§§ 63.443(d) and 63.450, instead of in
accordance with §63.693 as specified in
§63.962 (a)(3)(ii), (b) (3) (ii) (A) , and
(2) If a condensate tank is used in the
closed collection system, the tank shall
meet the following requirements:
(i) The fixed roof and all openings
(e.g., access hatches, sampling ports,
gauge wells) shall be designed and
operated with no detectable leaks as
indicated by an instrument reading of
less than 500 parts per million above
background, and vented into a closed-
vent system that meets the requirements
in § 63.450 and routed to a control
device that meets the requirements in
§63.443(d);and
(ii) Each opening shall be maintained
in a closed, sealed position (e.g.,
covered by a lid that is gasketed and
latched) at all times that the tank
contains pulping process condensates or
any HAP removed from a pulping
process condensate stream except when
it is necessary to use the opening for
sampling, removal, or for equipment
inspection, maintenance, or repair.
(e) Each pulping process condensate
from the equipment systems listed in
paragraph (b) of this section shall be
treated according to one of the following
options:
(1) Recycle the pulping process
condensate to an equipment system
specified in §63.443(a) meeting the
requirements specified in §63.443(c)
and (d), or
(2) Discharge the pulping process
condensate below the liquid surface of
a biological treatment system meeting
the requirement specified in paragraph
(e)(3) of this section; or
(3) Treat the pulping process
condensates to reduce or destroy the
total HAP's by at least 92 percent or
more by weight: or
(4) At mills that do not perform
bleaching, treat the pulping process
condensates to remove 3.3 kilograms or
more of total HAP per megagram (6.6
pounds per ton) of ODP, or achieve a
total HAP concentration of 210 parts per
million or less by weight at the outlet of
the control device; or
(5) At mills that perform bleaching,
treat the pulping process condensates to
remove 5. 1 kilograms or more of total
HAP per megagram (10.2 pounds per
ton) of ODP, or achieve a total HAP
concentration of 330 parts per million or
less by weight at the outlet of the
control device.
(f) Each HAP removed from a pulping
process condensate stream during
treatment and handling under
paragraphs (d) or (e) of this section,
except for those treated according to
paragraph (e) (2) of this section, shall be
controlled as specified in § 63.443(c)
and (d).
(g) For each steam stripper system
used to comply with the requirements
specified in paragraph (e) (3) of this
section, periods of excess emissions
reported under § 63.455 shall not be a
violation of paragraphs (d), (e), and (f)
of this section provided that the time of
excess emissions (including periods of
startup, shutdown, or malfunction)
divided by the total process operating
time in a semi-annual reporting period
does not exceed 10 percent.
(h) Each owner or operator of a new
or existing affected source subject to the
requirements of this section shall
evaluate all new or modified pulping
process condensates or changes in the
annual bleached or non-bleached ODP
used to comply with paragraph (i) of
this section, to determine if they meet
the applicable requirements of this
section.
(i) For the purposes of meeting the
requirements in paragraphs (c)(2), (e)(4).
or (e)(5) of this section at mills
producing both bleached and
unbleached pulp products, owners and
operators may meet a prorated mass
standard that is calculated by prorating
the applicable mass standards
(kilograms of total HAP per megagram of
ODP) for bleached and unbleached
specified in paragraphs (c)(2), (e)(4), or
(e) (5) of this section by the ratio of
annual megagrams of bleached and
unbleached ODP.

§63.447 Clean condensate alternative.
As an alternative to the requirements
specified in §63.443(a)(l)(ii) through
(a) (1) (v) for the control of HAP
emissions from pulping systems using
the kraft process, an owner or operator
must demonstrate to the satisfaction of
the Administrator, by meeting all the
requirements below, that the total HAP
emissions reductions achieved by this
clean condensate alternative technology
are equal to or greater than the total
HAP emission reductions that would
have been achieved by compliance with
§63.443(a)(l)(ii) through (a)(l)(v).
(a) For the purposes of this section
only the following additional
definitions apply.
(1) Clean condensate alternative
affected source means the total of all
HAP emission points in the pulping,
bleaching, causticizing, and
papermaking systems (exclusive of HAP
emissions attributable to additives to
paper machines and HAP emission
points in the LVHC system).
(2) Causticizing system means all
equipment associated with converting
sodium carbonate into active sodium
hydroxide. The equipment includes
smelt dissolving tanks, lime mud
washers and storage tanks, white and
mud liquor clarifiers and storage tanks,
slakers, slaker grit washers, lime kilns,
green liquor clarifiers and storage tanks,
and dreg washers ending with the white
liquor storage tanks prior to the digester
system, and any other equipment
serving the same function as those
previously listed.
(3) Papermaking system means all
equipment used to convert pulp into
paper, paperboard, or market pulp,
including the stock storage and
preparation systems, the paper or
paperboard machines, and the paper
machine white water system, broke
recovery systems, and the systems
involved in calendering, drying, on-
machine coating, slitting, winding, and
cutting.
(b) Each owner or operator shall
install and operate a clean condensate
alternative technology with a
continuous monitoring system to reduce
total HAP emissions by treating and
reducing HAP concentrations in the
pulping process water used within the
clean condensate alternative affected
source.
(c) Each owner or operator shall
calculate HAP emissions on a kilogram
per megagram of ODP basis and measure
HAP emissions according to the
appropriate procedures contained in
§63.457.
(d) Each owner or operator shall
determine the baseline HAP emissions
for each equipment system and the total
of all equipment systems in the clean
condensate alternative affected source
based on the following.
(1) Process and air pollution control
equipment installed and operating on or
after December 17, 1993, and
(2) Compliance with the following
requirements that affect the level of
HAP emissions from the clean
condensate alternative affected source:
(i) The pulping process condensates
requirements in § 63.446;
(ii) The applicable effluent limitation
guidelines and standards in 40 CFR part
430, subparts A, B, D, and E; and
(iii) All other applicable requirements
of local, State, or Federal agencies or
statutes.
(e) Each owner or operator shall
determine the following HAP emissior
reductions from the baseline HAP
emissions determined in paragraph (d)
of this section for each equipment
system and the total of all equipment
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18622 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
systems in the clean condensate
alternative affected source:
(1) The HAP emission reduction
occurring by complying with the
requirements of § 63.443(a)(l)(ii)
through (a)(l)(v); and
(2) The HAP emissions reduction that
occurring by complying with the clean
condensate alternative technology.
(f) For the purposes of all
requirements in this section, each owner
or operator may use as an alternative,
individual equipment systems (instead
of total of all equipment systems) within
the clean condensate alternative affected
source to determine emissions and
reductions to demonstrate equal or
greater than the reductions that would
have been achieved bv compliance with
§63.443(a)(l)(ii) through (a)(l)(v).
(g) The initial and updates to the
control strategy report specified in
§63 455(b) shall include to the extent
possible the following information:
(1) A detailed description of.
(i) The equipment systems and
emission points that comprise the clean
condensate alternative affected source;
(ii) The air pollution control
technologies that would be used to meet
the requirements of § 63.443(a) (1) (ii)
through (a)(l)(v);:
(iii) The clean condensate alternative
technology to be used.
(2) Estimates and basis for the
estimates of total HAP emissions and
emissions reductions to fulfill the
requirements paragraphs (d), (e), and (f)
of this section.
(h) Each owner or operator shall
report to the Administrator by the
applicable compliance date specified in
§63.440(d) or (e) the rationale,
calculations, test procedures, and data
documentauon used to demonstrate
compliance with all the requirements of
this section.

§§63.448-63.449 [Reserved]

§ 63.450 Standards for enclosures and
closed-vent systems.
(a) Each enclosure and closed-vent
system specified in §§ 63.443(c),
63 444(b), and 63.445(b) for capturing
and transporting vent streams that
contain HAP shall meet the
requirements specified in paragraphs (b)
through (d) of this section.
(b) Each enclosure shall maintain
negative pressure at each enclosure or
hood opening as demonstrated by the
procedures specified §63.457(e). Each
enclosure or hood opening closed
during the initial performance test
specified in §63.457(a) shall be
maintained in the same closed and
sealed position as during the
performance test at all times except
when necessary to use the opening for
sampling, inspection, maintenance, or
repairs.
(c) Each component of the closed-vent
system used to comply with
§§63.443(c), 63.444(b), and 63.445(b)
that is operated at positive pressure and
located prior to a control device shall be
designed for and operated with no
detectable leaks as indicated by an
instrument reading of less than 500
parts per million by volume above
background, as measured by the
procedures specified in §63.457(d).
(d) Each bypass line in the closed-
vent system that could divert vent
streams containing HAP to the
atmosphere without meeting the
emission limitations in §§ 63.443,
63.444, or 63.445 shall comply with
either of the following requirements:
(1) On each bypass line, the owner or
operator shall install, .calibrate,
maintain, and operate according to
manufacturer's specifications a flow
indicator that provides a record of the
presence of gas stream flow in the
bypass line at least once every 15
minutes. The flow indicator shall be
installed in the bypass line in such a
way as to indicate flow in the bypass
line; or
(2) For bypass line valves that are not
computer controlled, the owner or
operator shall maintain the bypass line
valve in the closed position with a car
seal or a seal placed on the valve or
closure mechanism in such a way that
valve or closure mechanism cannot be
opened without breaking the seal.

§§63.451-63.452 [Reserved]

§63.453 Monitoring requirements.
(a) Each owner or operator subject to
the standards specified in §§ 63.443(c)
and (d). 63.444(b) and (c), 63.445(b) and
(c), 63.446(c), (d), and (e), 63.447(b) or
§63.450(d), shall install, calibrate,
certify, operate, and maintain according
to the manufacturer's specifications, a
continuous monitoring system (CMS, as
defined in § 63.2 of this part) as
specified in paragraphs (b) through (m)
of this section, except as allowed in
paragraph (m) of this section. The CMS
shall include a continuous recorder.
(b) A CMS shall be operated to
measure the temperature in the firebox
or in the ductwork immediately
downstream of the firebox and before
any substantial heat exchange occurs for
each thermal oxidizer used to comply
with the requirements of §63.443(d)(l)
through (d) (3) Owners and operators
complying with the requirements in
§ 63.443(d)(2) or (d)(3) shall monitor the
parameter specified and for the
temperature and concentration limits
specified.
(c) A CMS shall be operated to
measure the following parameters for
each gas scrubber used to comply with
the bleaching system requirements of
§ 63.445(c) or the sulfite pulping system
requirements of § 63.444(c).
(1) The pH or the oxidation/reduction
potential of the gas scrubber effluent;
(2) The gas scrubber vent gas inlet
flow rate; and
(3) The gas scrubber liquid influent
flow rate.
(d) As an option to the requirements
specified in paragraph (c) of this
section, a CMS shall be operated to
measure the chlorine outlet
concentration of each gas scrubber used
to comply with the bleaching system
outlet concentration requirement
specified in §63.445(c)(2).
(e) The owner or operator of a
bleaching system complying with 40
CFR 430.24, shall monitor the chlorine
and hypochlorite application rates, in kg
of bleaching agent per megagram of
ODP, of the bleaching system during the
extended compliance period specified
in§63.440(d)(3).
(f) A CMS shall be operated to
measure the gas scrubber parameters
specified in paragraphs (c)(l) through
(c) (3) of this section or those site
specific parameters determined
according to the procedures specified in
paragraph (n) of this section to comply
with the sulfite pulping system
requirements specified in § 63.444 (c).
(g) A CMS shall be operated to
measure the following parameters for
each steam stripper used to comply with
the treatment requirements in
§ 63.446(e) (3), (4), or (5)'
(1) The process waste water feed rate:
(2) The steam feed rate; and
(3) The process wastewater column
feed temperature.
(h) As an option to the requirements
specified in paragraph (g) of this
section, a CMS shall be operated to
measure the methanol outlet
concentration to comply with the steam
stripper outlet concentration
requirement specified in §63.446 (e)(4)
or(e)(5).
(i) A CMS shall be operated to
measure the appropriate parameters
determined according to the procedures
specified in paragraph (n) of this section
to comply with the condensate
applicability requirements specified in
§63.446(c).
(j) Each owner or operator using a
biological treatment system to comply
with §63.446(e)(2) shall perform the
following monitoring procedures.
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18623
(1) On a daily basis, monitor the
following parameters for each biological
treatment unit:
(i) Composite daily sample of outlet
soluble BODs concentration to monitor
for maximum daily and maximum
monthly average;
(ii) Mixed liquor volatile suspended
solids;
(iii) Horsepower of aerator unit(s);
(iv) Inlet liquid flow; and
(v) Liquid temperature.
(2) Obtain daily inlet and outlet liquid
grab samples from each biological
treatment unit to have HAP data
available to perform quarterly percent
reduction tests specified in paragraph
(j)(2)(ii) of this section and the
compliance percent reduction tests
specified in paragraph (p)(l)(i) of this
section. Perform the following
procedures with the liquid samples:
(i) Store the samples for 5 days as
specified in §63.457(n). The 5 day
storage requirement is required since
the soluble BOD5 test requires 5 days to
obtain results. If the results of the
soluble BOD5 test are outside of the
range established during the initial
performance test, then the archive
sample shall be used to perform the
percent reduction test specified in
§63.457(1).
(ii) Perform the percent reduction test
procedures specified in § 63.457(1)
within 45 days after the beginning of
each quarter as follows
(A) The percent reduction test
performed in the first quarter (annually)
shall be performed for total HAP and the
percent reduction obtained from the test
shall be at least as great as the total HAP
reduction specified in §63.446(e)(2).
(B) The remaining quarterly percent
reduction tests shall be performed for
methanol and the percent reduction
obtained from the test shall be at least
as great as the methanol reduction
determined in the previous first-quarter
test specified in paragraph (j) (2) (ii) (A) of
this section.
(C) The parameter values used to
calculate the percent reductions
required in paragraphs (j) (2) (ii) (A) and
(j)(2)(ii)(B) of this section shall be
parameter values measured and samples
taken in paragraph (j)(l) of this section.
(k) Each enclosure and closed-vent
system used to comply with § 63.450(a)
shall comply with the requirements
specified in paragraphs (k)(l) through
(k) (6) of this section.
(1) For each enclosure opening, a
visual inspection of the closure
mechanism specified in §63.450(b)
shall be performed at least once every
30 days to ensure the opening is
maintained in the closed position and
sealed.
(2) Each closed-vent system required
by § 63.450(a) shall be visually
inspected every 30 days and at other
times as requested by the Administrator.
The visual inspection shall include
inspection of ductwork, piping,
enclosures, and connections to covers
for visible evidence of defects.
(3) For positive pressure closed-vent
systems or portions of closed-vent
systems, demonstrate no detectable
leaks as specified in § 63.450(c)
measured initially and annually by the
procedures in §63.457(d).
(4) Demonstrate initially and annually
that each enclosure opening is
maintained at negative pressure as
specified in §63.457(e).
(5) The valve or closure mechanism
specified in § 63.450(d)(2) shall be
inspected at least once every 30 days to
ensure that the valve is maintained in
the closed position and the emission
point gas stream is not diverted through
tine bypass line.
(6) If an inspection required by
paragraphs (k)(l) through (k)(5) of this
section identifies visible defects in
ductwork, piping, enclosures or
connections to covers required by
§ 63.450, or if an instrument reading of
500 parts per million by volume or
greater above background is measured,
or if enclosure openings are not
maintained at negative pressure, then
the following corrective actions shall be
taken as soon as practicable.
(i) A first effort to repair or correct die
closed-vent system shall be made as
soon as practicable but no later than 5
calendar days after the problem is
identified.
(ii) The repair or corrective action
shall be completed no later than 15
calendar days after the problem is
identified.
(1) Each pulping process condensate
closed collection system used to comply
with §63.446(d) shall be visually
inspected every 30 days and shall
comply with the inspection and
monitoring requirements specified in
§ 63.964 of subpart RR of this part,
except for the closed-vent system and
control device inspection and
monitoring requirements specified in
§63.964 (a) (2) of subpart RR of this part,
the closed-vent system and the control
device shall meet the requirements
specified in paragraphs (a) and (k) of
this section.
(m) Each owner or operator using a
control device, technique or an
alternative parameter other than those
specified in paragraphs (b) through (1) of
this section shall install a CMS and
establish appropriate operating
parameters to be monitored that
demonstrate, to the Administrator's
satisfaction, continuous compliance
with the applicable control
requirements.
(n) To establish or reestablish, the
value for each operating parameter
required to be monitored under
paragraphs (b) through (j). (1), and (m) of
this section or to establish appropriate
parameters for paragraphs (f), (i), and
(m) of this section, each owner or
operator shall use the following
procedures:
(1) During the initial performance test
required in § 63.457(a) or any
subsequent performance test,
continuously record the operating
parameter;
(2) Determinations shall be based on
tine control performance and parameter
data monitored during the performance
test, supplemented if necessary by
engineering assessments and the
manufacturer's recommendations;
(3) The owner or operator shall
provide for the Administrator's approval
the rationale for selecting the
monitoring parameters necessary to
comply with paragraphs (f), (i), and (m)
of tiiis section; and
(4) Provide for the Administrator's
approval the rationale for the selected
operating parameter value, and
monitoring frequency, and averaging
time. Include all data and calculations
used to develop the value and a
description of why the value,
monitoring frequency, and averaging
time demonstrate continuous
compliance with the applicable
emission standard.
(o) Each owner or operator of a
control device subject to the monitoring
provisions of this section shall operate
the control device in a manner
consistent with the minimum or
maximum (as appropriate) operating
parameter value or procedure required
to be monitored under paragraphs (a)
through (n) of this section and
established under this subpart. Except
as provided in paragraph (p) of this
section, §63.443(e), or §63.446(g),
operation of the control device below
minimum operating parameter values or
above maximum operating parameter
values established under this subpart or
failure to perform procedures required
by this subpart shall constitute a
violation of the applicable emission
standard of this subpart and be reported
as a period of excess emissions.
(p) Each owner or operator of a
biological treatment system complying
with paragraph (j) of this section shall
perform all the following requirement
when the monitoring parameters
specified in paragraphs (j)(l)(i) through
(j)(l)(iii) of this section are below
minimum operating parameter values or
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18624 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
above maximum operating parameter
values established in paragraph (n) of
this section.
(1) The following shall occur and be
recorded as soon as practical:
(i) Determine compliance with
§ 63.446(e) (2) using the percent
reduction test procedures specified in
§ 63.457(1) and the monitoring data
specified in paragraph (j)(l) of this
section that coincide with the time
period of the parameter excursion;
(ii) Steps shall be taken to repair or
adjust the operation of the process to
end the parameter excursion period; and
(iii) Steps shall be taken to minimize
total HAP emissions to the atmosphere
during the parameter excursion period.
(2) A parameter excursion is not a
violation of the applicable emission
standard if the percent reduction test
specified in paragraph (p)(l)(i) of this
section demonstrates compliance with
§63.446(e)(2), and no maintenance or
changes have been made to the process
or control device after the beginning of
a parameter excursion that would
influence the results of the
determination.

§63.454 Recordkeeping requirements.
(a) The owner or operator of each
affected source subject to the
requirements of this subpart shall
comply with the recordkeeping
requirements of § 63.10 of subpart A of
this part, as shown in table 1, and the
requirements specified in paragraphs (b)
through (d) of this section for the
monitoring parameters specified in
§63.453.
(b) For each applicable enclosure
opening, closed-vent system, and closed
collection system, the owner or operator
shall prepare and maintain a site-
specific inspection plan including a
drawing or schematic of the components
of applicable affected equipment and
shall record the following information
for each inspection:
(1) Date of inspection;
(2) The equipment type and
identification;
(3) Results of negative pressure tests
for enclosures;
(4) Results of leak detection tests;
(5) The nature of the defect or leak
and the method of detection (i.e., visual
inspection or instrument detection);
(6) The date the defect or leak was
detected and the date of each attempt to
repair the defect or leak;
(7) Repair methods applied in each
attempt to repair the defect or leak;
(8) The reason for die delay if the
defect or leak is not repaired within 15
days after discovery;
(9) The expected date of successful
repair of the defect or leak if the repair
is not completed within 15 days;
(10) The date of successful repair of
the defect or leak;
(11) The position and duration of
opening of bypass line valves and the
condition of any valve seals; and
(12) The duration of the use of bypass
valves on computer controlled valves.
(c) The owner or operator of a
bleaching system complying with
§63.440(d)(3)(ii)(B) shall record the
daily average chlorine and hypochlorite
application rates, in kg of bleaching
agent per megagram of ODP, of the
bleaching system until the requirements
specified in §63.440(d)(3)(ii)(A) are met.
(d) The owner or operator shall record
the CMS parameters specified in
§63.453 and meet the requirements
specified in paragraph (a) of this section
for any new affected process equipment
or pulping process condensate stream
that becomes subject to the standards in
this subpart due to a process change or
modification.

§63.455 Reporting requirements.
(a) Each owner or operator of a source
subject to this subpart shall comply
with the reporting requirements of
subpart A of this part as specified in
table 1 and all the following
requirements in this section. The initial
notification report specified under
§ 63.9(b) (2) of subpart A of this part
shall be submitted by April 15, 1999.
(b) Each owner or operator of a kraft
pulping system specified in
§63.440(d)(l) or a bleaching system
specified in §63 440(d)(3)(ii) shall
submit, with the initial notification
report specified under § 63.9(b)(2) of
subpart A of this part and paragraph (a)
of this section and update every two
years thereafter, a non-binding control
strategy report containing, at a
minimum, the information specified in
paragraphs (b)(l) through (b)(3) of this
section in addition to die information
required in § 63.9(b) (2) of subpart A of
tiiis part.
(1) A description of the emission
controls or process modifications
selected for compliance with the control
requirements in this standard.
(2) A compliance schedule, including
the dates by which each step toward
compliance will be reached for each
emission point or sets of emission
points. At a minimum, the list of dates
shall include:
(i) The date by which the major
study (s) for determining the compliance
strategy will be completed;
(ii) The date by which contracts for
emission controls or process
modifications will be awarded, or the
date by which orders will be issued for
the purchase of major components to
accomplish emission controls or process
changes;
(iii) The date by which on-site
construction, installation of emission
control equipment, or a process change
is to be initiated;
(iv) The date by which on-site
construction, installation of emissions
control equipment, or a process change
is to be completed;
(v) The date by which final
compliance is to be achieved;
(vi) For compliance with paragraph
§ 63.440(d) (3) (ii), the tentative dates by
which compliance with effluent
limitation guidelines and standards
intermediate pollutant load effluent
reductions and as available, all the dates
for the best available technology's
milestones reported in the National
Pollutant Discharge Elimination System
authorized under section 402 of the
Clean Water Act and for the best
professional milestones in the Voluntary
Advanced Technology Incentives
Program under 40 CFR 430.24 (b)(2);
and
(vii) The date by which the final
compliance tests will be performed.
(3) Until compliance is achieved.
revisions or updates shall be made to
the control strategy report required by
paragraph (b) of this section indicating
the progress made towards completing
the installation of the emission controls
or process modifications during the 2-
year period.
(c) The owner or operator of each
bleaching system complying with
§ 63.440(d)(3)(ii)(B) shall certify in the
report specified under § 63.10(e)(3) of
subpart A of this part that the daily
application rates of chlorine and
hypochlorite for that bleaching system
have not increased as specified in
§63.440(d)(3)(ii)(B) until the
requirements of § 63.440(d)(3)(ii)(A) are
met
(d) The owner or operatoi shall meet
the requirements specified in paragraph
(a) of this section upon startup of any
new affected process equipment or
pulping process condensate stream that
becomes subject to the standards of this
subpart due to a process change or
modification

§63.456 [Reserved]

§ 63.457 Test methods and procedures.
(a) Initial performance test. An initial
performance test is required for all
emission sources subject to the
limitations in §§63.443, 63.444, 63.445.
63.446, and 63.447, except those
controlled by a combustion device that
is designed and operated as specified in
§63.443(d)(3)or(d)(4).
(b) Vent sampling port locations and
gas stream properties. For purposes of
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Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations 18625
selecting vent sampling port locations
and determining vent gas stream
properties, required in §§ 63.443,
63.444, 63.445, and 63.447, each owner
or operator shall comply with the
applicable procedures in paragraphs
(b)(l) through (b)(6) of this section.
(1) Method 1 or 1A of part 60,
appendix A, as appropriate, shall be
used for selection of the sampling site
as follows:
(i) To sample for vent gas
concentrations and volumetric flow
rates, the sampling site shall be located
prior to dilution of the vent gas stream
and prior to release to the atmosphere;
(ii) For determining compliance with
percent reduction requirements,
sampling sites shall be located prior to
the inlet of the control device and at the
outlet of the control device;
measurements shall be performed
simultaneously at the two sampling
sites; and
(iii) For determining compliance with
concentration limits or mass emission
rate limits, the sampling site shall be
located at the outlet of the control
device.
(2) No traverse site selection method
is needed for vents smaller than 0.10
meter (4.0 inches) in diameter.
(3) The vent gas volumetric flow rate
shall be determined using Method 2,
2A, 2C, or 2D of part 60, appendix A.
as appropriate.
(4) The moisture content of the vent
gas shall be measured using Method 4
of part 60, appendix A.
(5) To determine vent gas
concentrations, the owner or operator
shall collect a minimum of three
samples that are representative of
normal conditions and average the
resulting pollutant concentrations using
the following procedures.
(i) Method 308 in Appendix A of this
part shall be used to determine the
methanol concentration.
(ii) Except for the modifications
specified in paragraphs (b) (5) (ii) (A)
through (b)(5)(ii)(K) of this section,
Method 26A of pan 60, appendix A
shall be used to determine chlorine
concentration in the vent stream.
(A) Probe/Sampling Line. A separate
probe is not required. The sampling line
shall be an appropriate length of 0.64
cm (0.25 in) OD Teflon* tubing. The
sample inlet end of the sampling line
shall be inserted into the stack in such
a way as to not entrain liquid
condensation from the vent gases. The
other end shall be connected to the
impingers. The length of the tubing may
vary from one sampling site to another,
but shall be as short as possible in each
situation. If sampling is conducted in
sunlight, opaque tubing shall be used.
Alternatively, if transparent tubing is
used, it shall be covered with opaque
tape.
(B) Impinger Train, Three 30 milliliter
(ml) capacity midget impingers shall be
connected in series to the sampling line.
The impingers shall have regular
tapered stems. Silica gel shall be placed
in the third impinger as a desiccant. All
impinger train connectors shall be glass
and/or Teflon11.
(C) Critical Orifice. The critical orifice
shall have a flow rate of 200 to 250 ml/
min and shall be followed by a vacuum
pump capable of providing a vacuum of
640 millimeters of mercury (mm Hg). A
45 millimeter diameter in-line Teflon®
0.8 micrometer filter shall follow the
impingers to project the critical orifice
and vacuum pump.
(D) The following are necessary for
the analysis apparatus:
(1) Wash bottle filled with deionized
water;
(2) 25 or 50 ml graduated burette and
stand;
(3) Magnetic stirring apparatus and
stir bar;
(4) Calibrated pH Meter;
(5) 150-250 ml beaker or flask; and
(6) A 5 ml pipette.
(E) The procedures listed in
paragraphs (b) (5) (ii) (£)(/) through
(b)(5)(ii)(E)(7) of this section shall be
used to prepare the reagents.
(1) To prepare the 1 molarity (M)
potassium dihydrogen phosphate
solution, dissolve 13.61 grams (g) of
potassium dihydrogen phosphate in
water and dilute to 100 ml.
{2) To prepare the 1 M sodium
hydroxide solution (NaOH), dissolve 4.0
g of sodium hydroxide in water and
dilute to 100 ml.
(3) To prepare the buffered 2 percent
potassium iodide solution, dissolve 20 g
of potassium iodide in 900 ml water.
Add 50 ml of the 1 M potassium
dihydrogen phosphate solution and 30
ml of the 1 M sodium hydroxide
solution. While stirring solution,
measure the pH of solution
electrometrically and add the 1 M
sodium hydroxide solution to bring pH
to between 6 95 and 7.05.
(4) To prepare the 0.1 normality (N)
sodium thiosulfate solution, dissolve 25
g of sodium thiosulfate, pentahydrate, in
800 ml of freshly boiled and cooled
distilled water in a 1-liter volumetric
flask. Dilute to volume. To prepare the
0.01 N sodium thiosulfate solution, add
10.0 ml standardized 0.1 N sodium
thiosulfate solution to a 100 ml
volumetric flask, and dilute to volume
with water.
(5) To standardize the 0.1 N sodium
thiosulfate solution, dissolve 3.249 g of
anhydrous potassium bi-iodate, primar
standard quality, or 3.567 g potassium
iodate dried at 103 +/ - 2 degrees
Centigrade for 1 hour, in distilled water
and dilute to 1000 ml to yield a 0.1000
N solution. Store in a glass-stoppered
bottle. To 80 ml distilled water, add,
with constant stirring, 1 ml
concentrated sulfuric acid. 10.00 ml
0.1000 N anhydrous potassium bi-
iodate, and 1 g potassium iodide. Titrate
immediately with 0.1 n sodium
thiosulfate titrant until the yellow color
of the liberated iodine is almost
discharged Add 1 ml starch indicator
solution and continue titrating until the
blue color disappears. The normality of
the sodium thiosulfate solution is
inversely proportional to the ml of
sodium thiosulfate solution consumed:
Normality of
SodiumThiosulfate
1
ml Sodium Thiosulfate Consumed
(G) To prepare the starch indicator
solution, add a small amount of cold
water to 5 g starch and grind in a mortar
to obtain a thin paste. Pour paste into
1 L of boiling distilled water, stir, and
let settle overnight. Use clear supernate
for starch indicator solution.
(7) To prepare the 10 percent sulfuric
acid solution, add 10 ml of concentrated
sulfuric acid to 80 ml water in an 100
ml volumetric flask. Dilute to volume.
(F) The procedures specified in
paragraphs (b) (5) (ii) (F) (1) through
(b)(5)(ii)(F)(5) of this section shall be
used to perform the sampling.
(1) Preparation of Collection Train.
Measure 20 ml buffered potassium
iodide solution into each of the first two
impingers and connect probe,
impingers. filter, critical orifice, and
pump. The sampling line and the
impingers shall be shielded from
sunlight.
(2) Leak and Flow Check Procedure.
Plug sampling line inlet tip and turn o
pump. If a flow of bubbles is visible in
either of die liquid impingers, tighten
fittings and adjust connections and
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18626 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
impingers. A leakage rate not in excess
of 2 percent of the sampling rate is
acceptable. Carefully remove the plug
from the end of the probe. Check the
flow rate at the probe inlet with a
bubble tube flow meter. The flow
should be comparable or slightly less
than the flow rate of the critical orifice
with the impingers off-line. Record the
flow and turn off the pump.
(3) Sample Collection. Insert the
sampling line into the stack and secure
it with the tip slightly lower than the
port height. Start the pump, recording
the time. End the sampling after 60
minutes, or after yellow color is
observed in the second in-line impinger.
Record time and remove the tubing from
the vent. Recheck flow rate at sampling
line inlet and turn off pump If the flow
rate has changed significantly, redo
sampling with fresh capture solution. A
slight variation (less than 5 percent) in
flow may be averaged. With the inlet
end of the line elevated above the
impingers, add about 5 ml water into
the inlet tip to rinse the line into the
first impinger.
(4) Sample Analysis. Fill the burette
with 0.01 N sodium thiosulfate solution
to the zero mark. Combine the contents
of the impingers in the beaker or flask.
Stir the solution and titrate with
thiosulfate until the solution is
colorless. Record the volume of the first
endpoint (TN, ml). Add 5 ml of the 10
percent sulfuric acid solution, and
continue the titration until the contents
of the flask are again colorless. Record
the total volume of titrant required to go
through the first and to the second
endpoint (TA, ml). If the volume of
neutral titer is less than 0 5 ml. repeat
the testing for a longer period of time.
It is important that sufficient lighting be
present to clearly see the endpoints,
which are determined when the
solution turns from pale yellow tc
colorless. A lighted stirring plate and a
white background are useful for this
purpose.
(5) Interferences. Known interfering
agents of this method are sulfur dioxide
and hydrogen peroxide Sulfur dioxide,
which is used to reduce oxidant
residuals in some bleaching systems.
reduces formed iodine to iodide in the
capture solution. It is therefore a
negative interference for chlorine, and
in some cases could result in erroneous
negative chlorine concentrations. Any
agent capable of reducing iodine to
iodide could interfere in this manner. A
chromium trioxide impregnated filter
will capture sulfur dioxide and pass
chlorine and chlorine dioxide.
Hydrogen peroxide, which is commonly
used as a bleaching agent in modern
bleaching systems, reacts with iodide to
form iodine and thus can cause a
positive interference in the chlorine
measurement. Due to the chemistry
involved, the precision of the chlorine
analysis will decrease as the ratio of
chlorine dioxide to chlorine increases.
Slightly negative calculated
concentrations of chlorine may occur
when sampling a vent gas with high
concentrations of chlorine dioxide and
very low concentrations of chlorine.
(G) The following calculation shall be
performed to determine the corrected
sampling flow rate:

BP-PWY 293
~ !| —-—^~^
760 A273 +
Where.
Sc=Corrected (dry standard) sampling flow
rate, liters per minute;
Su=Uncorrected sampling flow rate, L/min;
BP=Barometric pressure at time of sampling.
PW=Saturated partial pressure of water
vapor, mm Hg at temperature; and
t=Ambient temperature, °C

(H) The following calculation shall be
performed to determine the moles of
chlorine in the sample:

Cl2Moles = 1/8000 (5 TN-TA)xNmo
Where
TN=Volume neutral titer, ml,
TA=Volume acid titer (total), ml; and
NThio=Normality of sodium thiosulfate titrant

(I) The following calculation shall be
performed to determine the
concentration of chlorine in the sample:
Cl2ppmv =
3005(5 TN-TA)xNmo
Srxtc
Where
Sc=Corrected (dry standard) sampling flow
rate, liters per minute,
ts=Time sampled, minutes,
TN=Volume neutral titer, ml'
TA=Volume acid titer (total), ml, and
NThio=Normality of sodium thiosulfate titrant.

(D The following calculation shall be
performed to determine the moles of
chlorine dioxide in the sample:

C102 Moles = 1/4000 (TA - TN) x N^
Where.
TA=Volume acid titer (total), ml;
TN=Volume neutral titer, ml: and
NThio=Normahty ot sodium thiosulfate Utrant

(K) The following calculation shall be
performed to determine the
concentration of chlorine dioxide in the
sample:
C1O2 ppmv =

Where-
6010(TA-TN)xN
Scxts
Thio
Sc=Corrected (dry standard) sampling flow
rate, liters per minute,
ts=Time sampled, minutes;
TA=Volume acid titer (total), ml;
TN=Volume neutral titer, ml; and
NThi0=Normaliry of sodium thiosulfate titrant.

(iii) Any other method that measures
the total HAP or methanol concentration
that has been demonstrated to the
Administrator's satisfaction.
(6) The minimum sampling time for
each of the three runs per method shall
be 1 hour in which either an integrated
sample or four grab samples shall be
taken. If grab sampling is used, then die
samples shall be taken at approximately
equal intervals in time, such as 15
minute intervals during the run.
(c) Liquid sampling locations and
properties. For purposes of selecting
liquid sampling locations and for
determining properties of liquid streams
such as wastewaters, process waters,
and condensates required in §§63.444,
63.446, and 63.447, the owner or
operator shall comply with the
following procedures:
(1) Samples shall be collected using
the sampling procedures specified in
Method 305 of part 60, appendix A;
(i) Where feasible, samples shall be
taken from an enclosed pipe prior to the
liquid stream being exposed to the
atmosphere; and
(ii) When sampling from an enclosed
pipe is not feasible, samples shall be
collected in a manner to minimize
exposure of the sample to the
atmosphere and loss of HAP compounds
prior to sampling.
(2) The volumetric flow rate of the
entering and exiting liquid streams shall
be determined using the inlet and outlet
flow meters or other methods
demonstrated to the Administrator's
satisfaction. The volumetric flow rate
measurements to determine actual mass
removal shall be taken at the same time
as the concentration measurements;
(3) To determine liquid stream total
HAP or methanol concentrations, the
owner or operator shall collect a
minimum of three samples that are
representative of normal conditions and
average the resulting pollutant
concentrations using one of the
following:
(i) Method 305 in Appendix A of this
part, adjusted using the following
equation:
Where:
C=Pollutant concentration for the liquid
stream, parts per million by weight.
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18627
C,=Measured concentration of pollutant i in
the liquid stream sample determined
using Method 305. parts per million by
weight.
fm,=Pollutant-specific constant that adjusts
concentration measured by Method 305
to actual liquid concentration; the fm for
methanol is 0.85. Additional pollutant
fm values can be found in table 34,
subpart G of this part.
n=Number of individual pollutants, i,
summed to calculate total HAP
(ii) Any other method that measures
total HAP concentration that has been
demonstrated to the Administrator's
satisfaction.
(4) To determine soluble BOD5 in the
effluent stream from a biological
treatment unit used to comply with
§§63.446(e)(2) and 63.453(j), the owner
or operator shall use Method 405.1, of
part 136, with the following
modifications:
(i) Filter the sample through the filter
paper, into Erlenmeyer flask by
applying a vacuum to the flask sidearm.
Minimize the time for which vacuum is
applied to prevent stripping of volatile
organics from the sample Replace filter
paper as often as needed in order to
maintain filter times of less than
approximately 30 seconds per filter
paper. No rinsing of sample container or
filter bowl into the Erlenmeyer flask is
allowed.
(ii) Perform Method 405.1 on the
filtrate obtained in paragraph (c) (4) of
this section. Dilution water shall be
seeded with 1 milliliter of final effluent
per liter of dilution water. Dilution
ratios may require adjustment to reflect
the lower oxygen demand of the filtered
sample in comparison to the total BODs.
Three BOD bottles and different
dilutions shall be used for each sample.
(d) Detectable leak procedures To
measure detectable leaks for closed-vent
systems as specified in § 63.450 or for
pulping process wastewater collection
systems as specified in §63.446(d)(2)(i),
the owner or operator shall comply with
the following:
(1) Method 21, of part 60, appendix A;
and
(2) The instrument specified in
Method 21 shall be calibrated before use
according to the procedures specified in
Method 21 on each day that leak checks
are performed. The following calibration
gases shall be used:
(i) Zero air (less than 10 parts per
million by volume of hydrocarbon in
air); and
(ii) A mixture of methane or n-hexane
and air at a concentration of
approximately, but less than, 10,000
parts per million by volume methane or
n-hexane.
(e) Negative pressure procedures. To
demonstrate negative pressure at
process equipment enclosure openings
as specified in § 63.450(b), the owner or
operator shall use one of the following
procedures:
(1) An anemometer to demonstrate
flow into the enclosure opening;
(2) Measure the static pressure across
the opening;
(3) Smoke tubes to demonstrate flow
into the enclosure opening; or
(4) Any other industrial ventilation
test method demonstrated to the
Administrator's satisfaction.
(f) HAP concentration measurements.
For purposes of complying with the
requirements in §§63.443, 63.444, and
63.447, the owner or operator shall
measure the total HAP concentration as
one of the following:
(1) As the sum of all individual
HAP's; or
(2) As methanol.
(g) Condensate HAP concentration
measurement. For purposes of
complying with the kraft pulping
condensate requirements in §63.446,
the owner or operator shall measure the
total HAP concentration as methanol
except for the purposes of complying
with the initial performance test
specified in §63.457(a) for §63.446(e)(2)
and as specified in §63.4530)(2)(ii).
(h) Bleaching HAP concentration
measurement. For purposes of
complying with the bleaching system
requirements in § 63.445, the owner or
operator shall measure the total HAP
concentration as the sum of all
individual chlorinated HAP's or as
chlorine.
(i) Vent gas stream calculations. To
demonstrate compliance with the mass
emission rate, mass emission rate per
megagram of OOP, and percent
reduction requirements for vent gas
streams specified in §§ 63.443, 63.444.
63.445, and 63.447, the owner or
operator shall use the following:
(1) The total HAP mass emission rate
shall be calculated using the following
equation:
Where:
E=Mass emission rate of total HAP from the
sampled vent, kilograms per hour.
K2=Constant, 2 494v]0-« (parts per million
by volume) ~ ' (gram-mole per standard
cubic meter) (kilogram/gram) (minutes/
hour), where standard temperature for
(gram-mole per standard cubic meter) is
20 °C
Cj=Concentration on a dry basis of pollutant
j in parts per million by volume as
measured by the test methods specified
in paragraph (b) of this section.
Mj=Molecular weight of pollutant j, gram/
gram-mole
Q»=Vent gas stream flow rate (dry standard
cubic meter per minute) at a temperature
of 20 °C as indicated in paragraph (b) of
this section.
n=Number of individual pollutants, i,
summed to calculate total HAP.

(2) The total HAP mass emission rate
per megagram of OOP shall be
calculated using the following equation:
Where:
F=Mass emission rate of total HAP from the
sampled vent, in kilograms per
megagram of OOP
E=Mass emission rate of total HAP from the
sampled vent, in kilograms per hour
determined as specified in paragraph
(i)(l) of this section.
P=The production rate of pulp during the
sampling period, in megagrams of OOP
per hour.

(3) The total HAP percent reduction
shall be calculated using the following
equation:

R=E'~E° (100)
*-i
Where.
R=Efficiency of control device, percent
Ei=Inlet mass emission rate of total HAP from
the sampled vent, in kilograms of
pollutant per hour, determined as
specified in paragraph (i)(l) of this
section.
E0=Outlet mass emission rate of total HAP
from the sampled vent, in kilograms of
pollutant per hour, determined as
specified in paragraph (i)(l) of this
section

0) Liquid stream calculations To
demonstrate compliance with the mass
flow rate, mass per megagram of ODP,
and percent reduction requirements for
liquid streams specified in § 63.446, the
owner or operator shall use the
following:
(1) The mass flow rates of total HAP
or methanol entering and exiting the
treatment process shall be calculated
using the following equations:
Where
Eb=Mass flow rate of total HAP or methanol
in the liquid stream entering the
treatment process, kilograms per hour.
Ea=Mass flow rate of total HAP or methanol
in the liquid exiting the treatment
process, kilograms per hour.
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18628 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
K=Density of the liquid stream, kilograms per
cubic meter.
Vbl=Volumetric flow rate of liquid stream
entering the treatment process during
each run i, cubic meters per hour.
determined as specified in paragraph (c)
of this section.
Vu=Volumetric flow rate of liquid stream
exiting the treatment process during each
run i, cubic meters per hour, determined
as specified in paragraph (c) of this
section.
Cb,=Concentration of total HAP or methanol
in the stream entering the treatment
process during each run i, parts per
million by weight, determined as
specified in paragraph (c) of this section
Ca,=Concentration of total HAP or methanol
in the stream exiting the treatment
process during each run i, pans per
million by weight, determined as
specified in paragraph (c) of this section
n=Number of runs

(2) The mass of total HAP or methanol
per megagram ODP shall be calculated
using the following equation:
Where:
F=Mass loading of total HAP or methanol in
the sample, in kilograms per megagram
of ODP
Ea=Mass flow rate of total HAP or methanol
in the wastewater stream in kilograms
per hour as determined using the
procedures in paragraph (j)(l) of this
section
P=The production rate of pulp during the
sampling period in megagrams of ODP
per hour

(3) The percent reduction of total HAP
across the applicable treatment process
shall be calculated using the following
equation:
-xlOO
Wh«-,e
R=Control efficiency of the treatment
process, percent
Eb=Mass flow rate of total HAP in the stream
entering the treatment process, kilograms
per hour, as determined in paragraph
(j)(l) of this section
E,=Mass flow rate of total HAP in the stream
exiting the treatment process, kilograms
per hour, as determined in paragraph
(j)(l) of this section

(4) Compounds that meet the
requirements specified in paragraphs
{j) (4) (i) or (4) (ii) of this section are not
required to be included in the mass flow
rate, mass per megagram of ODP, or the
mass percent reduction determinations.
(i) Compounds with concentrations at
the point of determination that are
below 1 part per million by weight; or
(ii) Compounds with concentrations
at the point of determination that are
below the lower detection limit where
the lower detection limit is greater than
1 part per million by weight.
(k) Oxygen concentration correction
procedures. To demonstrate compliance
with the total HAP concentration limit
of 20 ppmv in § 63.443(d)(2). the
concentration measured using the
methods specified in paragraph (b) (5) of
this section shall be corrected to 10
percent oxygen using the following
procedures:
(1) The emission rate correction factor
and excess air integrated sampling and
analysis procedures of Methods 3A or
3B of part 60, appendix A shall be used
to determine the oxygen concentration.
The samples shall be taken at the same
time that the HAP samples are taken.
(2) The concentration corrected to 10
percent oxygen shall be computed using
the following equation:
C =C
\* r ^T
10.9
k20.9-%O2d
Where
Cc=Concentration of total HAP corrected to
10 percent oxygen, dry basis, parts per
million by volume
Cra=Concentration of total HAP dry basis.
parts per million by volume, as specified
in paragraph (b) of this section
%0:>d=Concentration of oxygen, dry basis,
percent by volume
(1) Biological treatment system
percent reduction calculation. To
determine compliance with an open
biological treatment system option
specified in § 63.446(e)(2) and the
monitoring requirements specified in
§63.453(j)(2), the percent reduction due
to destruction in the biological
treatment system shall be calculated
using the following equation:
R=fbloxlOO
Where
R=Destruction ot total HAP or methanol in
the biological treatment process, percent.
fb,0=The fraction of total HAP or methanol
removed in the biological treatment
system. The site-specific biorate
constants shall be determined using the
procedures specified and as limited in
appendix C of part 63.
(m) Condensate segregation
procedures. The following procedures
shall be used to demonstrate
compliance with the condensate
segregation requirements specified in
§63.446(c).
(1) To demonstrate compliance with
the percent mass requirements specified
in §63.446(c)(l), the procedures
specified in paragraphs (m)(l)(i) through
(m) (1) (iii) of this section shall be
performed.
(i) Determine the total HAP mass of
all condensates from each equipment
system listed in § 63.446 (b)(l) through
(b) (3) using the procedures specified in
paragraphs (c) and (j) of this section.
(ii) Multiply the total HAP mass
determine in paragraph (m)(l)(i) of this
section by 0.65 to determine the target
HAP mass for the high-HAP fraction
condensate stream or streams.
(iii) Compliance with the segregation
requirements specified in §63.446(c)(I)
is demonstrated if the condensate
stream or streams from each equipment
system listed in § 63.446 (b)(l) through
(b) (3) being treated as specified in
§ 63.446(e) contain at least as much total
HAP mass as the target total HAP mass
determined in paragraph (m)(l)(ii) of
this section.
(2) To demonstrate compliance with
the percent mass requirements specified
in §63.446 (c) (2), the procedures
specified in paragraphs (m)(2)(i) through
(m) (2) (ii) of this section shall be
performed.
(i) Determine the total HAP mass
contained in the high-HAP fraction
condensates from each equipment
system listed in § 63.446(b)(l) through
(b) (3) and the total condensates streams
from the equipment systems listed in
§ 63.446(b) (4) and (b)(5). using the
procedures specified in paragraphs (c)
and (j) of this section.
(ii) Compliance with the segregation
requirements specified in §63.446(c)(2)
is demonstrated if the total HAP mass
determined in paragraph (m) (2) (i) of this
section is equal to or greater than the
appropriate mass requirements specified
in§63.446(c)(2).
(n) Biological treatment system
monitoring sampling storage. The inlet
and outlet grab samples required to be
collected in § 63.453(j)(2) shall be stored
at 4° C (40° F) to minimize the
biodegradation of the organic
compounds in the samples.

§ 63.458 Delegation of authority.
(a) In delegating implementation and
enforcement authority to a State under
section 112(d) of the CAA, the
authorities contained in paragraph (b) of
this section shall be retained by the
Administrator and not transferred to a
State.
(b) Authorities which will not be
delegated to States:
(1) Section 63 6(g)—Use of an
alternative nonopacity emission
standard;
(2) Section 63.453(m)—Use of an
alternative monitoring parameter
(3) Section 63.457(b)(5)(iii)— Use of an
alternative test method for total HAP or
methanol in vents; and
(4) Section 63.457(c)(3)(ii)-Use of an
alternative test method for total HAP or
methanol in wastewater.
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Federal Register/Vol. 63. No. 72/Wednesday, April 15, 1998/Rules and Regulations
18629
§63.459 [Reserved]
TABLE 1 TO SUBPART S—GENERAL PROVISIONS APPLICABILITY TO SUBPART Sa
Reference
63.1(a)(1H3)
63 1 (a)(4)
63.1 (a)(5)
63.1(a)(6H8) ..
63.1 (a)(9)
63.1(a)(10)
63.1(a)(11)-(14)
63.1 (b)(1)
63.1{b)(2)-(3) -
63.1(c)(1)-{2)
63.1 (C)(3)
63 1(c)(4H5)
63.1(d)
63 1 (e) .
63.2
633
63.4(a)(1)
63.4(a)(3).
63.4(a)(4)
63.4(a)(5)
63.4(b)
63 4(c)
63.5(a)
63.5(b)(1)
63.5(b)(2)
63.5(b)(3)
63.5(b)(4H6)
63.5(c)
63 5(d)
63.5(e)
63.5(f)
63.6(a)
63 6(b)
63.6(c)
63.6(d)
63 6(e)
63.6(f) . ..
63.6(g)
63.6(h) .. .
63.6(i)
63.6Q) .. . .
63.7
63.8(a)(1) .. .
63.8(a)(2)
63.8(a)(3)
63.8(a)(4) .
63.8(b)(1)
63.8(b)(2) . .
63.8(b)(3)
63.8(C)(1)
63.8(c)(2)
63.8(c)(3)
63.8(c)(4)
63.8(c)(5)
63 8(c)(6)
63.8(c)(7)
63.8(c)(8)
63 8(d)
63.8(e)
63.8(f)(1)-(5)
63 8(fl(6)
63.8(q)
639(a)
63.9(b)
63.9(c)
63.9(d)
63.9(e)
63.9(f)
Applies to
Subpart S
Yes.
Yes
No
Yes
No
No
Yes.
No
Yes
Yes.
No
Yes
No
Yes
Yes.
Yes
Yes
No
Yes
Yes.
Yes
Yes
Yes.
No
Yes.
Yes
No
Yes
Yes
Yes.
Yes.
No
No
No
Yes
Yes
Yes.
No
Yes
Yes
Yes
Yes
Yes.
No
Yes
Yes
No
Yes
Yes.
Yes
Yes.
No
No
Yes
Yes.
Yes.
Yes
Yes.
Yes.
No
Yes
Yes
Yes
Yes
No
Yes.
No
Comment

Subpart S (this table) specifies applicability of each paragraph in subpart A to subpart S
Section reserved.

Section reserved.
Subpart S and other cross-referenced subparts specify calendar or operating day

Subpart S specifies its own applicability

Section reserved.

Section reserved

Section reserved.

Subpart S specifies compliance dates for sources subject to subpart S
Subpart S specifies compliance dates for sources subject to subpart S
Section reserved

Pertains to continuous opacity monitors that are not part of this standard

Section reserved

Subpart S specifies locations to conduct monitoring

Subpart S allows site specific determination of monitoring frequency in § 63.453(n)(4).
Pertains to continuous opacity monitors that are not part of this standard.

Subpart S does not specify relative accuracy test for CEM's

Initial notifications must be submitted within one year after the source becomes subject to the relevr
standard.
Special compliance requirements are only applicable to kraft mills.

Pertains to continuous ooacitv monitors that are not oart of this standard.
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18630 Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations

TABLE 1 TO SUBPART S—GENERAL PROVISIONS APPLICABILITY TO SUBPART Sa—Continued
Reference
63.9(g)(1)
63 9(a)(2)
63.9(g)(3)
639(h)
63.9(i)
639(i)
6310(a)
63.10(b)
63.10(c)
63.10(d)(1)
6310(d)(2) .
63 10(d)(3)
63.10(d)(4)
63.10(d)(5)
63.10(6)(1)
63.10(e)(2)(i)
63.10(e)(2)(ii)
6310(e)(3) ..
63.10(e)(4)
63.10(f)
63 11-63 15

Applies to
Subpart S
Yes.
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes.
Yes
No
Yes
Yes.
Yes.
Yes.
No
Yes
No
Yes.
Yes

Comment

Pertains to continuous opacity monitors that are not part of this standard
Subpart S does not specify relative accuracy tests, therefore no notification is required for an alternative

Pertains to continuous opacity monitors that are not part of this standard

' Wherever subpart A specifies "postmark" dates, submittals may be sent by methods other than the U.S. Mail (e.g., by fax or courier). Submit-
tals shall be sent by the specified dates, but a postmark is not required.
3. Appendix A of part 63 is amended
by adding Method 308 in numerical
order to read as follows:

Appendix A to Part 63—Test Methods
Method 308—Procedure for
Determination of Methanol Emission
From Stationary Sources

1.0 Scope and Applica tion
1.1 Analyte. Methanol. Chemical
Abstract Service (CAS) No. 67-56-1.
1.2 Applicability. This method
applies to the measurement of methanol
emissions from specified stationary
sources.

2.0 Summary of Method
A gas sample is extracted front the
sampling point in the stack. The
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 gas
chromatograph (GC) and is then
measured by a flame ionization detector
(FID). The fraction adsorbed on silica
gel is extracted with an aqueous
solution of n-propanol and is then
separated and measured by GC/FID.

3.0 Definitions [Reserved]
4.0 Interferences [Reserved]
5.0 Safety
5.1 Disclaimer. This method may
involve hazardous materials, operations,
and equipment. This test method does
not purport to address all of the safety
problems associated with its use. It is
the responsibility of the user of this test
method to establish appropriate safety
and health practices and to determine
the applicability of regulatory
limitations before performing this test
method.
5.2 Methanol Characteristics.
Methanol is flammable and a dangerous
fire and explosion risk. It is moderately
toxic by ingestion and inhalation.

6.0 Equipment and Supplies
6.1 Sample Collection. The
following items are required for sample
collection.
6.1.1 Sampling Train. The sampling
train is shown in Figure 308-1 and
component parts are discussed below.
6.1.1.1 Probe. Teflon®,
approximately 6-millimeter (mm) (0.24
inch) outside diameter.
6.1.1.2 Impinger. A 30-milliliter (ml)
midget impinger. The impinger must be
connected with leak-free glass
connectors. Silicone grease may not be
used to lubricate the connectors.
6.1.1.3 Adsorbent Tube. Glass tubes
packed with the required amount of the
specified adsorbent.
6.1.1.4 Valve. Needle valve, to
regulate sample gas flow rate.
6.1.1.5 Pump. Leak-free diaphragm
pump, or equivalent, to pull gas through
the sampling train. Install a small surge
tank between the pump and rate meter
to eliminate the pulsation effect of the
diaphragm pump on the rotameter.
6.1.1.6 Rate Meter. Rotameter, or
equivalent, capable of measuring flow
rate to within 2 percent of the selected
flow rate of up to 1000 milliliter per
minute (ml/min). Alternatively, the
tester may use a critical orifice to set the
flow rate.
6.1.1.7 Volume Meter. Dry gas meter
(DGM), sufficiently accurate to measure
the sample volume to within 2 percent,
calibrated at the selected flow rate and
conditions actually encountered during
sampling, and equipped with a
temperature sensor (dial thermometer,
or equivalent) capable of measuring
temperature accurately to within 3 °C
(5.4 °F).
6.1.1.8 Barometer. Mercury (Hg),
aneroid, or other barometer capable of
measuring atmospheric pressure to
within 2.5 mm (0.1 inch) Hg. See the
NOTE in Method 5 (40 CFR part 60,
appendix A), section 6.1.2.
6.1.1.9 Vacuum Gauge and
Rotameter. At least 760-mm (30-inch)
Hg gauge and 0- to 40-ml/min rotameter,
to be used for leak-check of the
sampling train.
6.2 Sample Recovery. The following
items are required for sample recovery:
6.2.1 Wash Bottles. Polyethylene or
glass, 500-ml, two.
6.2.2 Sample Vials. Glass, 40-ml,
with Teflon*-lined septa, to store
impinger samples (one per sample).
6.2.3 Graduated Cylinder. 100-ml
size.
6.3 Analysis. The following are
required for analysis:
6.3.1 Gas Chromatograph. GC with
an FID, programmable temperature
control, and heated liquid injection
port.
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Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
18631
6.3.2 Pump. Capable of pumping
100 ml/min. For flushing sample loop.
6.3.3 Flow Meter. To monitor
accurately sample loop flow rate of 100
ml/min.
6.3.4 Regulators. Two-stage
regulators used on gas cylinders for GC
and for cylinder standards.
6.3.5 Recorder. To record, integrate,
and store chromatograms.
6.3.6 Syringes. 1.0- and 10-
microliter (1) size, calibrated, for
injecting samples.
6.3.7 Tubing Fittings. Stainless steel,
to plumb GC and gas cylinders.
6.3.8 Vials. Two 5.0-ml glass vials
with screw caps fitted with Teflon®-
lined septa for each sample.
6.3.9 Pipettes. Volumetric type,
assorted sizes for preparing calibration
standards.
6.3.10 Volumetric Flasks. Assorted
sizes for preparing calibration
standards.
6.3.11 Vials. Glass 40-ml with
Teflon®-lined septa, to store calibration
standards (one per standard).

7.0 Reagents and Standards
Note: Unless otherwise indicated, all
reagents must conform to the specifications
established by the Committee on Analytical
Reagents of the American Chemical Society
Where such specifications are not available,
use the best available grade
7.1 Sampling. The following are
required for sampling:
7.1.1 Water. Deionized distilled to
conform to the American Society for
Testing and Materials (ASTM)
Specification D 1193-77, Type 3. At the
option of the analyst, the potassium
permanganate (KMnCu) test for
oxidizable organic matter may be
omitted when high concentrations of
organic matter are not expected to be
present.
7.1.2 Silica Gel. Deactivated
chromatographic grade 20/40 mesh
silica gel packed in glass adsorbent
tubes. The silica gel is packed in two
sections. The front section contains 520
milligrams (mg) of silica gel, and the
back section contains 260 mg.
7.2 Analysis. The following are
required for analysis:
7.2.1 Water. Same as specified in
section 7.1.1.
7.2.2 n-Propanol, 3 Percent. Mix 3
ml of n-propanol with 97 ml of water.
7.2.3 Methanol Stock Standard.
Prepare a methanol stock standard by
weighing 1 gram of methanol into a 100-
ml volumetric flask. Dilute to 100 ml
with water.
7.2.3.1 Methanol Working Standard.
Prepare a methanol working standard by
pipetting 1 ml of the methanol stock
standard into a 100-ml volumetric flask.
Dilute the solution to 100 ml with
water.
7.2.3.2 Methanol Standards For
Impinger Samples. Prepare a series of
methanol standards by pipetting 1, 2, 5,
10, and 25 ml of methanol working
standard solution respectively into five
50-ml volumetric flasks. Dilute the
solutions to 50 ml with water. These
standards will have 2. 4, 10, 20, and 50
Hg/ml of methanol, respectively. After
preparation, transfer the solutions to 40-
ml glass vials capped with Teflon®
septa and store the vials under
refrigeration. Discard any excess
solution.
7.2.3.3 Methanol Standards for
Adsorbent Tube Samples. Prepare a
series of methanol standards by first
pipetting 10 ml of the methanol working
standard into a 100-ml volumetric flask
and diluting the contents to exacdy 100
ml with 3 percent n-propanol solution.
This standard will contain 10 ng/ml o'
methanol. Pipette 5, 15, and 25 ml of
diis standard, respectively, into four 50-
ml volumetric flasks. Dilute each
solution to 50 ml witii 3 percent n-
propanol solution. These standards will
have 1, 3, and 5 ng/ml of methanol,
respectively. Transfer all four standards
into 40-ml glass vials capped with
Teflon^-lined septa and store under
refrigeration. Discard any excess
solution.
7.2.4 GC Column. Capillary column,
30 meters (100 feet) long with an inside
diameter (ID) of 0.53 mm (0.02 inch),
coated with DB 624 to a film thickness
of 3.0 micrometers, (urn) or an
equivalent column. Alternatively, a 30-
meter capillary column coated with
polyethylene glycol to a film thickness
of 1 urn such as AT-WAX or its
equivalent.
7.2.5 Helium. Ultra high purity.
7.2.6 Hydrogen. Zero grade.
7.2.7 Oxygen. Zero grade.

8.0 Procedure
8.1 Sampling. The following items
are required for sampling:
8.1.1 Preparation of Collection
Train. Measure 20 ml of water into thv
midget impinger The adsorbent tube
must contain 520 mg of silica gel in the
front section and 260 mg of silica gel in
the backup section. Assemble the train
as shown in Figure 308-1. An optional,
second impinger that is left empty may
be placed in front of the water-
containing impinger to act as a
condensate trap. Place crushed ice and
water around the impinger
BILLING CODE 6560-50-P
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18632
Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
UNHEATEO
TEFLON
INE
SLCAGEL
TUBE
(520060 mg)
VATERFJLLED
IWINSER
(20 nfl
Figure 308.1. Sampling train schematic
BILLING CODE 6560-50-C
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Federal Register/Vol. 63, No. 72/Wednesday, April 15. 1998/Rules and Regulations 18633
8.1.2 Leak Check. A leak check prior
to the sampling run is optional;
however, a leak check after the sampling
run is mandatory. The leak-check
procedure is as follows:
Temporarily attach a suitable (e.g., 0-
to 40-ml/min) rotameter to the outlet of
the DGM, and place a vacuum gauge at
or near the probe inlet. Plug the probe
inlet, pull a vacuum of at least 250 mm
(10 inch) Hg, and note the flow rate as
indicated by the rotameter. A leakage
rate not in excess of 2 percent of the
average sampling rate is acceptable.
Note: Carefully release the probe inlet plug
before turning off the pump.

8.1.3 Sample Collection. Record the
initial DGM reading and barometric
pressure. To begin sampling, position
the tip of the Teflon* tubing at the
sampling point, connect the tubing to
the impinger, and start the pump
Adjust the sample flow to a constant
rate between 200 and 1000 ml/min as
indicated by the rotameter. Maintain
this constant rate (±10 percent) during
the entire sampling run. Take readings
(DGM, temperatures at DGM and at
impinger outlet, and rate meter) at least
every 5 minutes. Add more ice during
the run to keep the temperature of the
gases leaving the last impinger at 20 °C
(68 °F) or less. At the conclusion of each
run, turn off the pump, remove the
Teflon* tubing from the stack, and
record the final readings. Conduct a leak
check as in section 8.1.2. finis leak
check is mandatory.) If a leak is found,
void the test run or use procedures
acceptable to the Administrator to
adjust the sample volume for the
leakage.
8.2 Sample Recovery. The following
items are required for sample recovery:
8.2.1 Impinger. Disconnect the
impinger. Pour the contents of the
midget impinger into a graduated
cylinder. Rinse the midget impinger and
the connecting tubes with water, and
add the rinses to the graduated cylinder.
Record the sample volume. Transfer the
sample to a glass vial and cap with a
Teflon* septum. Discard any excess
sample. Place the samples in an ice
chest for shipment to the laboratory.
8.2.2. Adsorbent Tubes. Seal the
silica gel adsorbent tubes and place
them in an ice chest for shipment to the
laboratory.

9.0 Quality Control

9.1 Miscellaneous Quality Control
Measures. The following quality control
measures are required:
Section
8.1.2,
8.1.3,
10.1.

10.2

Quality control
measure
Sampling equip-
ment leak
check and
calibration.
GC calibration ..

Effect
Ensures accu-
rate measure-
ment of sam-
ple volume.
Ensures preci-
sion of GC
analysis.
9.2 Applicability. When the method
is used to analyze samples to
demonstrate compliance with a source
emission regulation, an audit sample
must be analyzed, subject to availability.
9.3 Audit Procedure. Analyze an
audit sample with each set of
compliance samples. Concurrently
analyze the audit sample and a set of
compliance samples in the same manner
to evaluate the technique of the analyst
and the standards preparation. The
same analyst, analytical reagents, and
analytical system shall be used both for
the compliance samples and the EPA
audit sample.
9.4 Audit Sample Availability.
Audit samples will be supplied only to
enforcement agencies for compliance
tests. Audit samples may be obtained by
writing: Source Test Audit Coordinator
(MD-77B), Air Measurement Research
Division, National Exposure Research
Laboratory, U.S. Environmental
Protection Agency, Research Triangle
Park, NC 27711; or by calling the Source
Test Audit Coordinator (STAC) at (919)
541-7834. The audit sample request
must be made at least 30 days prior to
the scheduled compliance sample
analysis.
9.5 Audit Results. Calculate the
audit sample concentration according to
the calculation procedure provided in
the audit instructions included with the
audit sample. Fill in the audit sample
concentration and the analyst's name on
the audit response form included with
the audit instructions. Send one copy to
the EPA Regional Office or the
appropriate enforcement agency and a
second copy to the STAC. The EPA
Regional office or the appropriate
enforcement agency will report the
results of the audit to the laboratory
being audited. Include this response
with the results of the compliance
samples in relevant reports to the EPA
Regional Office or the appropriate
enforcement agency.
10.0 Calibration and Standardization
10.1 Metering System. The following
items are required for the metering
system.
10.1.1 Initial Calibration.
10.1.1.1 Before its initial use in the
field, first leak-check the metering
system (drying tube, needle valve,
pump, rotameter, and DGM) as follows:
Place a vacuum gauge at the inlet to the
drying tube, and pull a vacuum of 250
mm (10 inch) Hg; plug or pinch off the
outlet of the flow meter, and then turn
off the pump. The vacuum shall remain
stable for at least 30 seconds. Carefully
release the vacuum gauge before
releasing the flow meter end.
10.1.1.2 Next, remove the drying
tube, and calibrate the metering system
(at the sampling flow rate specified by
the method) as follows: Connect an
appropriately sized wet test meter (e.g.,
1 liter per revolution (0.035 cubic feet
per revolution)) to the inlet of the drying
tube. Make three independent
calibrations runs, using at least five
revolutions of the DGM per run.
Calculate the calibration factor, Y (wet
test meter calibration volume divided by
the DGM volume, both volumes
adjusted to the same reference
temperature and pressure), for each run,
and average the results. If any Y-value
deviates by more than 2 percent from
the average, the metering system is
unacceptable for use Otherwise, use the
average as the calibration factor for
subsequent test runs.
10.1.2 Posttest Calibration Check.
After each field test series, conduct a
calibration check as in section 10.1.1
above, except for the following
variations, (a) The leak check is not to
be conducted, (b) three, or more
revolutions of the DGM may be used,
and (c) only two independent runs need
be made. If the calibration factor does
not deviate by more than 5 percent from
the initial calibration factor (determined
in section 10.1.1), then the DGM
volumes obtained during the test series
are acceptable. If the calibration factor
deviates by more than 5 percent,
recalibrate the metering system as in
section 10.1.1, and for the calculations,
use the calibration factor (initial or
recalibration) that yields the lower gas
volume for each test run.
10.1.3 Temperature Sensors
Calibrate against mercury-in-glass
thermometers.
10.1.4 Rotameter. The rotameter
need not be calibrated, but should be
cleaned and maintained according to
the manufacturer's instruction.
10.1.5 Barometer. Calibrate against a
mercury barometer
10.2 Gas Chromatograph. The
following procedures are required for
the gas chromatograph'
10.2.1 Initial Calibration. Inject 1 nl
of each of the standards prepared in
sections 7.2.3.3 and 7.2.3.4 into the G'
and record the response. Repeat the
injections for each standard until two
successive injections agree within 5
percent. Using the mean response for
-------
18634 Federal Register/Voi. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations
each calibration standard, prepare a
linear least squares equation relating the
response to the mass of methanol in the
sample. Perform the calibration before
analyzing each set of samples.
10.2.2 Continuing Calibration. At
the beginning of each day, analyze the
mid level calibration standard as
described in section 10.5.1. The
response from the daily analysis must
agree with the response from the initial
calibration within 10 percent. If it does
not, the initial calibration must be
repeated.

11.0 Analytical Procedure
11.1 Gas Chromatograph Operating
Conditions. The following operating
conditions are required for the GC:
11.1.1 Injector. Configured for
capillary column, splitless. 200 °C (392
°F).
11.1.2 Carrier. Helium at 10 ml/min.
11.1.3 Oven. Initially at 45 °C for 3
minutes; then raise by 10 °C to 70 °C;
then raise by 70 °C/min to 200 °C.
11.2 Impinger Sample. Inject 1 )il of
the stored sample into the GC. Repeat
the injection and average the results. If
the sample response is above that of the
highest calibration standard, either
dilute the sample until it is in the
measurement range of the calibration
line or prepare additional calibration
standards. If the sample response is
below that of the lowest calibration
standard, prepare additional calibration
standards. If additional calibration
standards are prepared, there shall be at
least two that bracket the response of
the sample These standards should
produce approximately 50 percent and
150 percent of the response of the
sample.
11.3 Silica Gel Adsorbent Sample.
The following items are required for the
silica gel adsorbent samples:
11.3.1 Preparation of Samples.
Extract the front and backup sections of
the adsorbent tube separately. With a
file, score the glass adsorbent tube in
front of the first section of silica gel.
Break the tube open. Remove and
discard the glass wool. Transfer the first
section of the silica gel to a 5-ml glass
via) and stopper the vial. Remove the
spacer between the first and second
section of the adsorbent tube and
discard it. Transfer the second section of
silica gel to a separate 5-ml glass vial
and stopper the vial.
11.3.2 Desorption of Samples. Add 3
ml of the 10 percent n-propanol solution
to each of the stoppered vials and shake
or vibrate the vials for 30 minutes.
11.3.3 Inject a l-u,l aliquot of the
diluted sample from each vial into the
GC. Repeat the injection and average the
results. If the sample response is above
that of the highest calibration standard,
either dilute the sample until it is in the
measurement range of the calibration
line or prepare additional calibration
standards If the sample response is
below that of the lowest calibration
standard, prepare additional calibration
standards. If additional calibration
standards are prepared, there shall be at
least two that bracket the response of
the sample. These standards should
produce approximately 50 percent and
150 percent of the response of the
sample.
12.0 Data Analysis and Calculations

12.1 Nomenclature.
C»f=Concentration of methanol in the
front of the adsorbent tube, ug/ml.
Cab=Concentration of methanol in the
back of the adsorbent tube, tig/ml.
C,=Concentration of methanol in the
impinger portion of the sample
train, Hg/rnl.
E=Mass emission rate of methanol, jig/
hr (Ib/hr).
Mu>t=Total mass of methanol collected
in the sample train, |ig.
Pbar=Barometric pressure at the exit
orifice of the DGM, mm Hg (in. Hg).
Psui=Standard absolute pressure, 760
mm Hg (29.92 in. Hg).
Qstd=Dry volumetric stack gas flow rate
corrected to standard conditions,
dscm/hr(dscf/hr).
Tm=Average DGM absolute temperature,
degrees K (°R).
Tstd=Standard absolute temperature, 293
degrees K (528 °R).
Vaf= Volume of front half adsorbent
sample, ml.
Vab=Volume of back half adsorbent
sample, ml.
V,=Volume of impinger sample, ml.
Vm=Dry gas volume as measured by the
DGM, dry cubic meters (dcm), dry
cubic feet (dcf).
Vm(Std)=Dry gas volume measured by the
DGM, corrected to standard
conditions, dry standard cubic
meters (dscm), dry standard cubic
feet (dscf).
12.2 Mass of Methanol. Calculate the
total mass of methanol collected in the
sampling train using Equation 308-1.
Mtol = V,C, + VrfC., + VabCab Equation 308-1
12.3 Dry Sample Gas Volume, Corrected to Standard Conditions. Calculate the volume of gas sampled at standard
conditions using Equation 308-2
T P
i
Equation 308 - 2
12.4 Mass Emission Rate of Methanol. Calculate the mass emission rate of methanol using Equation 308-3.
E =
_ M,0,Qsd
Equation 308 - 3
'm(std)
13 0 Method Performance [Reserved]

14.0 Pollution Prevention [Reserved]

15.0 Waste Management [Reserved]

16.0 Bibliography

1. Rom, J.J. "Maintenance,
Calibration, and Operation of Isokinetic
Source Sampling Equipment." Office of
Air Programs, Environmental Protection
Agency. Research Triangle Park. NC.
APTD-0576 March 1972.
2. Annual Book of ASTM Standards.
Part 31. Water, Atmospheric Analysis.
American Society for Testing and
Materials. Philadelphia, PA. 1974. pp.
40-42.
3. Westlin, P R. and R.T. Shigehara.
"Procedure for Calibrating and Using
Dry Gas Volume Meters as Calibration
Standards." Source Evaluation Society
Newsletter. 3(1) : 17-30. February 1978.
4. Yu, K.K. "Evaluation of Moisture
Effect on Dry Gas Meter Calibration."
Source Evaluation Society Newsletter.
5(1) :24-28. February 1980.
5. NIOSH Manual of Analytical
Methods, Volume 2. U.S. Department of
Health and Human Services National
Institute for Occupational Safety and
Health. Center for Disease Control. 4676
-------
Federal Register/Vol. 63, No. 72/Wednesday, April 15, 1998/Rules and Regulations 18635
Columbia Parkway, Cincinnati, OH
45226. (available from the
Superintendent of Documents,
Government Printing Office,
Washington, DC 20402.)
6. Pinkerton, J.E. "Method for
Measuring Methanol in Pulp Mill Vent
Gases." National Council of the Pulp
and Paper Industry for Air and Stream
Improvement, Inc., New York, NY.
17 0 Tables, Diagrams, Flowcharts,
and Validation Data
[Reserved].
PART 261—[AMENDED]

1. The authority citation of part 261
continues to read as follows:
Authority: 42 U.S C 6905, 6912(a), 6921,
6922. and 6938
2. Section 261.4 is amended by
adding paragraph (a) (15) to read as
follows:

§261.4 Exclusions.
(a) * * *
(15) Condensates derived from the
overhead gases from kraft mill steam
strippers that are used to comply with
40 CFR 63.446(e). The exemption
applies only to combustion at the mill
generating the condensates.
* * # * *
1. Part 430 is revised to read as
follows:

PART 430—THE PULP, PAPER, AND
PAPERBOARD POINT SOURCE
CATEGORY

General Provisions
Sec
430 00 Applicability
43001 Genera] definitions
430.02 Monitoring requirements
430 03 Best management practices (BMPs)
for spent pulping liquor, soap, and
turpentine management, spill
prevention, and control.
Subpart A—Dissolving Kraft Subcategory
Sec
430 10 Applicability: description of the
dissolving kraft subcategory.
430.11 Specialized definitions.
430.12 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT).
430.13 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the best
conventional pollutant control
technology (BCT).
430.14 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT)
430.15 New source performance standards
(NSPS).
430.16 Pretreatment standards for existing
sources (PSES).
430.17 Pretreatment standards for new
sources (PSNS).

Subpart B—Bleached Papergrade Kraft and
Soda Subcategory
Sec.
430.20 Applicability: description of the
bleached papergrade kraft and soda
subcategory.
43021 Specialized definitions
430.22 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT).
430 23 Effluent limitations representing the
degree of effluent reduction attainable by
the best conventional pollutant control
technology (BCT)
430.24 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT).
430 25 New source performance standards
(NSPS)
430.26 Pretreatment standards for existing
sources (PSES)
430 27 Pretreatment standards for new
sources (PSNS)
430 28 Best management practices (BMPs)

Subpart C—Unbleached Kraft Subcategory
Sec
430.30 Applicability, description of the
unbleached kraft subcategory
430.31 Specialized definitions
430.32 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT)
430.33 Effluent limitations representing the
degree of effluent reduction attainable by
the best conventional pollutant control
technology (BCT)
430 34 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT).
430.35 New source performance standards
(NSPS)
430 36 Pretreatment standards for existing
(PSES).
430.37 Pretreatment standards for new
sources (PSNS)

Subpart D—Dissolving Sulfite Subcategory
Sec.
430 40 Applicability, description of the
dissolving sulfite subcategory.
430.41 Specialized definitions
430.42 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT)
430.43 Effluent limitations representing the
degree of effluent reduction attainable by
the best conventional pollutant control
technology (BCT).
430.44 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT).
430.45 New source performance standards
(NSPS).
430.46 Pretreatment standards for existing
sources (PSES).
430.47 Pretreatment standards for new
sources (PSNS).

Subpart E—Papergrade Sulfite Subcategory
Sec.
430.50 Applicability, description of the
papergrade sulfite subcategory
430.51 Specialized definitions.
430.52 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT)
430.53 Effluent limitations representing the
degree of effluent reduction attainable by
the best conventional pollutant control
technology (BCT)
430 54 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT)
430.55 New source performance standards
(NSPS)
430.56 Pretreatment standards for existing
sources (PSES).
430 57 Pretreatment standards for new
sources (PSNS)
430.58 Best management practices (BMPs)

Subpart F—Semi-Chemical Subcategory
Sec
430.60 Applicability; description of the
semi-chemical subcategory
430.61 Specialized definitions.
430 62 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT)
430.63 Effluent limitations representing the
degree of effluent reduction attainable by
the Kest conventional pollutant control
technology (BCT).
430 64 Effluent limitations representing the
degree of effluent reduction attainable by
the application of best available
technology economically achievable
(BAT).
430.65 New source performance standards
(NSPS).
430.66 Prerreatmeni: standards for existing
sources (PSES)
430.67 Pretreatment standards for new
sourres (PSNS)

Subpart G—Mechanical Pulp Subcategory
Sec.
430 70 Applicability: description of the
mechanical pulp subcategory.
430 71 Specialized definitions
430 72 Effluent limneations representing the
degree of effluent reduction attainable by
the application of best practicable
control technology currently available
(BPT).
-------
Appendix C

Flowchart Summary of the NESHAP
NOTE: The following eleven diagrams provide only a summary of the requirements of the
standards and do not supersede the standards in any manner. Compliance
determinations are based on the standards published in the Code of Federal Regulations.
-------
FIGURE 1. MILL APPLICABILITY (§63.440)
Does this facility produce pulp, paper, or
paperboard?
NO
Not subject to
this rule.
YES

Is this facility a major source of HAP ? (Does the facility
emit more than 10 tons per year of a single HAP or more
than 25 tons per year of aggregate HAPs?)
NO
YES
1
Applicability and compliance schedule (see Figure 2)

Kraft, semi-chemical, and soda pulping system standards (see Figure 3)

Sulfite pulping system standards (see Figure 4)

Bleaching system standards (see Figure 5)

Kraft pulping process condensate standards (see Figure 6)

Monitoring requirements (see Figure 8)

Monitoring parameters (see Figure 9)

Reporting and recordkeeping requirements (see Figure 10)

Reporting and recordkeeping requirements (Continued) (see Figure 11)
C-l
-------
FIGURE 2. APPLICABILITY AND COMPLIANCE SCHEDULE (§63.440)
KRAFT, SEMI-CHEMICAL,
SODA, AND SULFITE
PULPING MILLS
Existing Source Applicability
» Pulping and bleaching
systems

New Source Applicability
• Pulping and bleaching
systems constructed or
reconstructed after
December 17, 1993

• Additional pulping or
bleaching lines constructed
after December 17,1993
MECHANICAL, NON-WOOD
FIBER, AND SECONDARY
FIBER PULPING MILLS
Existing Source
Applicability
• Bleaching systems

New Source Applicability
• Bleaching systems
constructed or reconstructed
after March 8,1996

• Additional bleaching lines
constructed after March 8,
1996
New Sources Must Achieve Compliance Upon Startup or June 15, 1998
Whichever is Later.
Existing Sources Must Achieve Compliance by April 16, 2001 With the
Following Exceptions:
HVLC* Systems
At Kraft Mills
Compliance Within 8
Years After Promulgation
of This Rule.

Mill Must Provide and
Update Compliance
Milestones.
Bleaching Systems
at Dissolving-Grade
Kraft and Sulfite Mills
Compliance Within 3
Years After the
Promulgation of the
Effluent Limitations
Guidelines (expected
compliance date of
2003-2005).
High volume, low-concentration systems include knotters,
screens, deckers, pulp washers, oxygen delignification systems,
and weak liquor storage tanks.
Bleaching Systems in the
Voluntary Advanced Technology
Incentives Program
Compliance Within 6 Years After
Promulgation of The NESHAP

"No backsliding" provision in effect
3 years after promulgation (i.e., mill
must not increase the application
rate of chlorine of hypochlorite)

Mill Must Provide and Update
Compliance Milestones.
C-2
-------
FIGURE 3. PULPING SYSTEM STANDARDS FOR KRAFT, SEMI-CHEMICAL,
AND SODA PULPING MILLS (§63.443, §63.450)
KRAFT PULPING SYSTEMS*
Existing Sources
• LVHC systems"
• HVLC systems
- Knotter and screen systems with
• Knotter systems with emissions > 0.05 kg***/Mg OOP and
screen systems with emissions > 0.1 kg*"/Mg OOP
• Combined knotter and screen systems with emissions
> 0.15 kg"* /MgODP
- Pulp washing systems
- Decker systems that use any process water other than fresh
water, or paper machine white water; or process water with
total HAP*" >400 ppmw
- Oxygen dehgnification systems

New Sources
• Existing sources
* All knotter systems
«All screen systems
• All decker systems
• Weak liquor storage tanks
SEMI-CHEMICAL AND
SODA PULPING SYSTEMS
Existing Sources
• LVHC system"

New Sources
• LVHC system
• Pulp washing systems
HVLC SYSTEMS
VENT CONTROL OPTIONS
LVHC SYSTEMS
Choose One or a Combination of
the Following:
ROUTE VENTS TO A
CLOSED-VENT COLLECTION
SYSTEM
• Negative pressure at each
enclosure/hood opening

• No detectable leaks >500 ppmv***
(positive pressure systems only)

• Bypass vapor lines:
- Install flow indicator, or
- Secure bypass line

• Visually inspect every 30 days

• Repair leaks as soon as practicable
(begin repair within 5 days and
complete within 15 days after
identification)
Clean Condensate Alternative
(see Figure 7)
CONTROL OPTIONS
Choose One of the Following:
98% Reduction by
Weight-
Route to a Thermal Oxidizer At One of the
Following Conditions:
Introduce vent stream with primary fuel
or into flame zone of a boiler, lime kiln,
or recovery furnace.
Minimum temperature of 1600°F and
0.75 seconds residence time
20 ppmv*" outlet concentration
(corrected to 10% O2)
* Kraft pulping systems must also control pulping process condensates (see Figure 6).
' LVHC systems include digesters, turpentine recovery, evaporators, steam stripper systems, and any other
equipment serving the same function as those previously mentioned.
' All measurements as total HAP or methanol
C-3
-------
FIGURE 4. PULPING SYSTEM STANDARDS FOR SULFITE PULPING MILLS (§63.443, §63,450)
SULFITE PULPING SYSTEMS
Existing Sources:
• Digester system vents
• Evaporator system vents
• Pulp washing system vents

New Sources
• Same as existing sources, plus
• Weak liquor storage tank vents
• Strong liquor storage tank vents
• Acid condensate storage tank vents
Route Vents to a Closed-Vent Collection System
(see Figure 3)
Calcium-based and Sodium-based
Pulping Systems
Control Options
Choose One of the Following:
Ammonium-based and Magnesium-based
Pulping Systems
Control Options
Choose One of the Following:
E
Outlet Emission Levels
<0.44 kgVMg OOP
Remove 92%
by Weight*
Outlet Emission Levels
<1.1 kgVMgODP
Remove 87%
by Weight*
1 All values measured as total HAP or Methanol. Outlet emission level and percent reduction requirements
include emissions from regulated equipment systems and HAP releases from vents, condensates, and
wastewater streams from control devices used to reduce HAP emissions.
C-4
-------
FIGURE 5. BLEACHING SYSTEM STANDARDS (§63.445)
BLEACHING SYSTEMS
Are chlorine or chlorinated
compounds used?
NO
No Control Requirements
YES
KRAFT, SODA,* AND SULFITE
PULPING MILLS

Existing and New Sources
• Bleaching stages that use chlorine
or chlorinated compounds
SEMI-CHEMICAL MILLS

Existing and New Sources
• Bleaching stages that use
chlorine
MECHANICAL, NON-WOOD
FIBER, AND SECONDARY
FIBER PULPING MILLS
Existing and New Sources
* Bleaching stages that use
chlorine or chlorine dioxide
CHLOROFORM CONTROL OPTIONS
Choose One of the Following:
CHLORINATED HAP CONTROL OPTIONS
(excluding chloroform)

* Route vents to a closed-vent collection
system (see Figure 3) and choose one of
the following:*
_.
Comply With the
Effluent Limitations
Guidelines
Use No Chlorine or
Hypochlorite In Any
Bleaching Stage
99% :
Reduction ;
by Weight" !
Outlet
Concentration
<10 ppmv"
Total Outlet
Emission
Levels
<0.001
kg"/Mg OOP
' Enclosures and closed-vent systems are not required for
facilities that use process modifications to comply with the
concentration or total HAP mass emission limits.
"All values measured as total chlorinated HAP or chlorine.
C-5
-------
FIGURE 6. KRAFT PULPING PROCESS CONDENSATE STANDARDS (§63.446)
KRAFT PULPING PROCESS CONDENSATES
New and Existing Sources:
« Digester system
• Turpentine recovery system
» Condensates from weak liquor feed stage vapors in the
evaporator vacuum systems
• LVHC collection system
• HVLC collection system
Convey condensates in a closed collection system meeting the
requirements for individual drain systems as specified in Subpart RR (40
CFR 63.446(d)) until the condensates reach one of the treatment options.
CONTROL OPTIONS
Choose One of the Following:
CONTROL THE ENTIRE
VOLUME OF
CONDENSATES FROM
ALL LISTED SOURCES
VOLUME REDUCTION OPTIONS
(Condensate Segregation)

Segregate condensate streams into low-HAP and
high-HAP streams. Choose one of the following-
_£_
VOLUME REDUCTION OPTION 1:

Control the high-HAP streams that
collectively contain at least 65 percent of
the total HAP* mass from the digester,
turpentine recovery, and evaporator
systems and all condensates from the
LVHC and HVLC collection systems.
LOW-HAP STREAMS

• No further MACT
requirements
- Return to mill or sewer
TREATMENT OPTIONS
Choose One of the Following:
VOLUME REDUCTION OPTION 2:

Control the high-HAP streams that
collectively contain >3.6 kg'/Mg
ODP (unbleached mills) or

>5.5 kgVMg ODP
(bleached mills)
from all listed sources.
RECYCLE
_t
BIOLOGICAL TREATMENT
Route condensates to a
controlled piece of process
equipment meeting the
pulping vent standards.
Remove 92% of total HAPs by
weight in a biological
treatment system.
STEAM STRIPPING
(or other control devices)"
Choose One of the Following:
Reduce total HAP
by 92% by weight*
' Measured as total HAP or Methanol.

' HAPs removed from pulping process condensates by steam stripping (or other control
devices) must be controlled at levels required by the kraft pulping vent standards.
Bleached Mills:
• Remove at least 5.1 kgVMg ODP,
or
• Reduce total HAPs* to 330 ppmw

Unbleached Mills:
• Remove at least 3.3 kg'/Mg ODP,
or
« Reduce total HAPs* to 210 ppmw
C-6
-------
FIGURE 7. CLEAN CONDENSATE ALTERNATIVE FOR
KRAFT MILLS (§63.447)

CLEAN CONDENSATE ALTERNATIVE (CCA) |
1 Alternative for HVLC system vents standards in Figure 3
(for individual vents or combination of vents)

• Concept-Reduction of HAP emissions through reduction
of HAP concentration in process water

Resulting HAP emission reductions can be used as
partial or complete fulfillment of the emission reductions
required by the kraft pulping system standards
SOURCES AT KRAFT MILLS ELIGIBLE FOR
INCLUSION IN THE CCA

• Pulping systems
Bleaching systems
Causticizmg systems
Papermakmg systems
CALCULATE BASELINE EMISSIONS
Baseline emissions are to be measured after compliance has
been achieved with:
' Kraft pulping process condensate standards, and
• Revised effluent limitation guidelines and standards in 40
CFR 430 subpart B
MEASURE EMISSIONS REDUCTIONS ACHIEVED
THROUGH THE CCA
Emissions Reductions Achieved Through the CCA =

• Baseline Emissions minus emission levels
measured after the CCA has been implemented

• Excluding
- emission reductions attributable to control
technology required by local, State, or Federal
agencies
- control equipment installed and operating on
December 17, 1993
CALCULATE EMISSIONS REDUCTIONS
EXPECTED THROUGH COMPLIANCE WITH THE
KRAFT PULPING VENT STANDARDS
Compliance through the CCA is Determined by Proving That:
Emission Reductions
Achieved Through the CCA
(kg total HAP/Mg OOP)
Emission Reductions
Expected Through Compliance
With the Kraft PulpingVent System
Standards (kg total HAP/Mg OOP)
C-7
-------
FIGURE 8. MONITORING REQUIREMENTS (§63.453)
INSTALL AND OPERATE:
Continuous Monitoring System (CMS)
ALLOWABLE OPERATING/EMISSION PARAMETERS
FOR SPECIFIED SOURCES AND CONTROLS

• Use named parameters in Figure 9 for specified
sources and controls.

• Alternative parameters to those specified are allowed
only with EPA approval.
DETERMINING OPERATING/EMISSION PARAMETERS
FOR OTHER SOURCES AND CONTROLS
• Only for the sources and controls listed below:
- Sulfite pulping vent controls,
- Kraft condensate segregation techniques; and
- Kraft clean condensate alternative controls.
- Bleaching systems using process mode features

• Establish parameters:
- Monitor parameters during performance test; and
- Supplement the performance test results with
engineering assessment and manufacturer's
recommendations.
- Provide the rationale and data to Administrator
indicating that the chosen parameter(s) demonstrate
compliance with the emission standard.
SETTING PARAMETER:
VALUE, AVERAGING TIME, AND MONITORING FREQUENCY
• Establish parameter value:
- Continuous monitoring data collected during performance test, and
- Supplement the performance test results with engineering
assessment and manufacturer's recommendations.
Provide rationale and data to Administrator indicating that the chosen
parameter value demonstrates compliance with emission standard.
EXCEEDING THE MONITORING PARAMETER VALUES OR PROCEDURES
• Shall constitute a violation of the applicable emission standard, and

• Must be reported as excess emissions

« Except:
- Biological treatment systems that are tested and comply with percent reduction
standards
- Control devices (except biological treatment) excess emissions must not exceed
10% of operating time including startup, shutdown, or malfunction, and
- Kraft, soda, and semi-chemical vent controls must not exceed (excluding
startup, shutdown, or malfunction):
• 1% for LVHC systems controls
• 4% for HVLC or combined LVHC and HVLC system controls
C-8
-------
FIGURE 9. MONITORING PARAMETERS (§63.453)
PULPING
SYSTEMS
Thermal Oxidizer
• For compliance with the 98 percent reduction option; measure, maintain,
and record fire box temperature with a CMS*
• For compliance with the 20 ppmv outlet option; measure, maintain, and
record fire box temperature or outlet HAP concentration with a CMS
• For compliance with the 1600°F design temperature option; measure,
maintain, and record fire box temperature with a CMS
• No monitoring requirements for pulping vent system vents routed to a
power boiler, lime kiln, or recovery furnace
BLEACHING
SYSTEMS
PULPING
PROCESS
CONDENSATES
CLOSED VENT
SYSTEMS
-and-
CLOSED
COLLECTION
SYSTEMS
(Condensates)
Bleaching Vent Scrubbers
• Measure and record the following parameters using a CMS:
- pH or oxidation/reduction potential of scrubber effluent,
- gas scrubber fan speed, and
- gas scrubber liquid influent flowrate
-or-
- Chlorine outlet concentration

Systems participating in the extended compliance time of the
Voluntary Advanced Technology Incentives Program:
• Monitor chlorine and hypochlorite application rates (kg/Mg OOP) during
extended compliance period
Steam Strippers
* Measure and record the following parameters using a CMS:
- Process water feed rate,
- Steam feed rate, and
- Column feed temperature
-or-
- Outlet methanol concentration

Biological Treatment Systems
« Daily monitoring
- Outlet soluble BODS
- Mixed liquor volatile suspended solids
- Horsepower of aerator unit(s)
- Inlet liquid flow
- Liquid temperature
- Collect and store inlet and outlet grab samples

• Quarterly Monitoring
- Every 1st quarter: demonstrate percent reduction of total HAP
- Remaining quarters: percent reduction of total HAP (methanol can be measured
if a relationship between total HAP and methanol reduction is established and
maintained at levels at least as great as those measured during the 1st quarter
Every 30 days:
• Visual inspection
• Inspect bypass line valve or closure mechanism

Initially and Annually
* Demonstrate no detectable leaks in positive pressure portions
• Demonstrate negative pressure at enclosure openings
* CMS = Continuous Monitoring System
C-9
-------
FIGURE 10. RECORDKEEPING AND REPORTING REQUIREMENTS (§63.454, §63.455)
INITIAL NOTIFICATION REPORT
Existing Major Sources: Within 1 year
after becoming subject to rule

New or Reconstructed Major Sources: No
later than 120 days after initial startup

• Name & address of owner or operator.

• Address of the source.

• Identification of the rule and source's
compliance date.

• Description of operations, design
capacity, and HAP emission points.

• Statement of whether a major or area
source.

• Notification of intent to construct or
startup date for new or reconstructed
sources.

• Control strategy report (HVLC systems
at kraft mills).

• Control strategy report (bleaching
systems participating in the Effluent
Incentives Program)
NOTIFICATION OF COMPLIANCE
STATUS REPORT
60 Days Following Compliance
Demonstration

• Methods used to determine compliance.

• Results of performance tests and/or
CMS performance evaluations.

• Methods to be used to determine
continuous compliance.

• Type and quantity of HAP emitted.

» Analysis demonstrating whether a major
or area source.

« Description of control equipment and
efficiencies.

• Statement as to whether source has
complied with standard.

* Data, calculations, engineering
assessments, and manufacturer's
recommendations used to determine
operating parameter value.
C-10
-------
FIGURE 11. RECORDKEEPING AND REPORTING REQUIREMENTS (§63.454, §63.455)

QUARTERLY
(Excess Emissions)
1
\
SEMI-ANNUALLY
(No Excess Emissions)
BI-ANNUALLY
PERIODIC REPORTS
• Requirements specified in Subpart A
• No additional requirements under Subpart S
• Requirements specified in Subpart A \
• Mills participating in the Voluntary Advanced Technology
Incentives Program must report daily application rates of
chlorine and hypochlorite :
• Mills with extended compliance schedules (some kraft
pulping systems and for mills participating in the Effluent
Incentives Program) must update control strategy reports
RECORDKEEPING
Comply with recordkeeping requirements specified in Subpart A

Mills with closed-vent systems and/or closed collection systems shall prepare
and maintain a site-specific inspection plan

Mills participating with the Voluntary Advanced Technology Incentives Program
shall record daily average chlorine and hypochlorite application rates (kg/Mg
OOP)

Mills shall record all CMS parameters included in the monitoring requirements
(see Figures 8 and 9)
C-]
-------
Appendix D

List of EPA Region Office Contacts
-------
Susan Lancey
EPA Region I (CAP)
J.F.K. Federal Building
Boston, MA 02203-2211
PH: (617) 565-3587
FAX: (617) 565-4940

Umesh Dholakia
EPA Region E
290 Broadway
New York, NY 10007-1866
PH: (212)637-4023
FAX: (212) 637-3901

Diane Walker
EPA Region ffl (SAP 11)
1650 Arch Street
Philadelphia, PA 19103-2029
PH: (215) 814-3297
FAX: (215) 814-2124

Lee Page
EPA Region IV (AR-4)
61 Forsyth St.
Atlanta, GA 30303-3415
PH: (404)562-9131
FAX: (404) 562-9095

Bruce Varner
EPA Region V(AE-17J)
77 W. Jackson Blvd.
Chicago, EL 60604-3590
PH: (312) 886-6793
FAX: (312)353-8289

Robert Todd
EPA Region VI (6PD-AP)
1445 Ross Avenue, Suite 700
Dallas. TX 75202-2733
PH: (214)665-2156
FAX: (214) 665-7263
REGIONAL AIR TOXICS CONTACTS

Richard Tripp
MC ARTD/APC
EPA Region VH
726 Minnesota Avenue
Kansas City, KS 66101
PH: (913) 551-7566
FAX: (913) 551-7065
Victoria Parker-Christensen (8P-AR)
Ann-Marie Patrie
Heather Rooney (8ENF-T)
EPA Region Vm
999 18th Street, Suite 500
Denver, CO 80202-2466
Victoria: (303) 312-6064
Ann Marie: (303) 312-6524
FAX: (303) 312-6064
Heather: (303)312-6971
FAX: (303) 312-6409

Mae Wang
AER-4
EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
PH: (415) 744-1200
FAX: (415)744-1076

Andrea Wullenweber
EPA Region X (OAQ-107)
1200 Sixth Avenue
Seattle, WA 98101
PH: (206) 553-8760
FAX: (206) 553-0404
D-l
-------
Appendix E

Equipment Diagrams For Pulp and Paper Mills
-------
List of Figures
Figure 1 Example Overview of a Kraft Pulping Mill with a Papermaking System

Figure 2 Example Kraft Pulping System
Figure 3 Example Kraft Digester System (batch)
Figure 4 Example Kraft Digester System (continuous)
Figure 5 Example Kraft Turpentine Recovery System
Figure 6 Example Kraft Knotter System
Figure 7 Example Kraft Pulp Washing System
Figure 8 Example Kraft Screen System and Decker System
Figure 9 Example Kraft Oxygen Delignification System (medium consistency)
Figure 10 Example Kraft Oxygen Delignification System (high consistency)
Figure 11 Example Kraft Weak Liquor Storage Tank
Figure 12 Example Kraft Evaporator System

Figure 13 Example Semi-Chemical Pulping System
Figure 14 Example Semi-Chemical Digester System (batch)
Figure 15 Example Semi-Chemical Digester System (continuous)
Figure 16 Example Semi-Chemical Pulp Washing System
Figure 17 Example Semi-Chemical Evaporator System

Figure 18 Example Soda Pulping System
Figure 19 Example Soda Digester System (batch)
Figure 20 Example Soda Pulp Washing System
Figure 21 Example Soda Evaporator System

Figure 22 Example Sulfite Pulping System
Figure 23 Example Sulfite Digester System (batch)
Figure 24 Example Sulfite Pulp Washing System
Figure 25 Example Sulfite Weak Liquor Storage Tank
Figure 26 Example Sulfite Evaporator System
Figure 27 Example Sulfite Strong Liquor Storage Tank
Figure 28 Example Sulfite Acid Condensate Storage Tank

Figure 29 Example Bleaching System

Figure 30 Example Steam Stripping System with Methanol Rectification

Figure 31 Example Biological Treatment System
E-l
-------
SUMMARY OF FIGURES

These figures are intended to serve as an overview of the various processes that
exist at kraft, semi-chemical, soda, and sulfite pulp and paper mills. Figure 1 provides an
overview of the entire pulp and papermaking process at a kraft mill. This general process
is followed at semi-chemical, soda, and sulfite mills, therefore, process overviews are not
repeated for those mills. Figures 2, 13, 18, and 22 illustrate the various processes within
pulping systems at kraft, semi-chemical, soda, and sulfite mills, respectively. Process
blocks in these figures that list collection systems indicate the processes that are subject
to the Pulp and Paper NESHAP. Alternatively, process blocks that do not list collection
systems are not subject to the Pulp and Paper NESHAP. The figures that follow
Figures 2, 13, 18 and 22 provide greater detail about the specific processes and equipment
in these pulping systems. Figures 29, 30, and 31 illustrate the processes and equipment
used in bleaching systems, steam stripper systems, and biological treatment systems,
respectively.
Disclaimer

The following figures are representations of pulping and bleaching systems and
processes for the purpose of clarifying the Pulp and Paper NESHAP. They are intended
to provide the reader with a general understanding of processes at pulp and paper mills;
not pulping and bleaching systems at specific mills.
E-2
-------
Figure 1
Example Overview of a Kraft Pulping Mill with a Papermaking System
Chemical Recovery System
Wood Chips
11<
f,.: i ';.
\ ' 1 I. '. ',. /
Digester System

Turpentine
Recovery
System

Evaporator
System
m
Ul
Knotter System
Screening
System
Weak Black l.lquor
Storage Tank
Papermaking System
Refiners/Cleaners
Oxygen
Delignification
System
iffi • w iii) wi , I, !^ - , U • 4, I 51 ,fj,
;('! iti'.iTjiir K tr |{
/4 ill ,«> Ip, ipi Mill .«(.

iB.'S'I.tJj
.
lint
M. I, ,fl 4T g j;« .. i
•j.1 Jii *, i|U • " • |nj • ;«1
ii!i • ii/,< K, •'»
Bleaching System
ipi Hwt KT
r r li' »
It 7 trll 'ilt htt
,
a!i|
Hi,!
l-Cook(ng Hquor added to wood chips to dissolve llgnin.
2-Retnuval of uncooked chips mid knots
3-Weak black liquor washed from pulp
4-Flber bundles and contaminants screened from pulp.
5-Pulp thickened for oxygen delignification.
&-Oxygen Delignification System for further delignification.
7-Pulp bleached to Increase whiteness.
8-Pulp is cleaned and prepared for papermaklng.
9-Paper sheet formed through dewatering
10-F.vauorator System removes excess water from the
weak black liquor.
11-Cliemical recovery system converts the concentrated liquor
into cookine liauor lor use in the dieester system.
-------
Figure 2 - Example Kraft Pulping System
Chips
s^)
Cooking
Liquor
Chemical
Recovery
System
Evaporator
System
(Figure 12)
Collection Systems:
•LVHC
• Condensates
Weak Liquor
Storage Tank*
(Figure 11)
Collection System:
• H\1C

Digester System
(Figure 3 St. 4)

Collection System:
•LVHC
• Condensates
ef v/TurpentineX.
Recovery System\
RGasf / Recovery System
(Figure 5)
Collection Systems:
•LVHC
1 Condensates
Knotter System
(Figure 6)
Collection System:
•HVLC
Pulp Washing System
(Figure 7)

Collection System.
•HVLC
I
Screen System
and Decker System
(Figure 8)
Collection System
• HVLC
Oxygen Delignification
System
(Figure 9 & 10)
Collection System:
• HVLC
1'Affected source only at new sources
Pulp to Pulp Dryers
or Papermaking System
pulp flow

liquid streams

gas streams
HVLC = high volume,
low concentration
LVHC = low volume,
high concentration
E-4
-------
Figure 3 - Example Kraft Digester System (batch)
m
Wood Chips
^ -^

Cooking Liquor
Relief Gas to
Turpentine Recovery
A
pulp flow

-*• liquid streams

•> gas streams
LVHC * low volume,
high concentration
Primary
Condenser
Blow Heat
Accumulator
Blow gas to combustion control device
(via LVHC collection system)

A
| Secondary
Condenser
LT
. Blow Condensate to
Steam Stripper (Figure 30) or
Biological treatment
System (Figure 31)
(via Condensate collection system)
-------
Rgure 4 - Example Kraft Digester System (continuous)*
Cooking Liquor
m
O\
pulp flow

->• liquid streams
•- >• gas streams

LVHC • low volume,
high concentration
x-^Pulpto \
\Knotter System/

VL
^r.* ** ^^
•W !fH MB "U KW
s |"r;l c
| k|"^ jj
^ o if , .; ;i
* Vj-.«j| (•( |»H
S at B U ••
lla hMI flttl >" WC
« Ji B • m Flash
C ft Tank
Y
Condenser
*'*.fi ?
* rtt .B u , *"
!••• la ICIl i:
uv.' i., ^ *
XjV\

i X! Secondary
2 E Flash >•
«" iM Tank
•»< u
Y
Flash Steam to
Turpentine Recovery
(via LVHC collection system)
Non-condensable gases
to control device
(via LVHC collection system)
Flash Steam Condensate
to Steam Stripper (Figure 30) or
Biological treatment
System (Figure 31)
(iria condemate collection system)
Weak Black Liquor to
Weak Black Liquor
Storage Tank
'Blow lank ontlnuous digester is not pictured.
-------
figure 5 - Example Kraft Turpentine Recovery System
Relief Gas from
Digester System
m
—*• liquid streams

•> gas streams

low volume,
hlflh concentration
Condenser
I-iquor Return
to Digester
^. Non-condensable
* gas to control device
(via LVHC collection system)
Turpentine
Decanter Underflow to
Steam Stripper (Figure 30}
or Biological treatment
System (Figure 31)
(yi
-------
Figure 6 - Example Kraft Knotter System
Knotter vent gases to control device
(via IIVLC collection system)
m
oo
Pulp from
Digester System
Knotter Drainer vent gases -<
to control device
(mil HVLCfnllfction systfm)
•^- Knots to Digester
Pulp to
Pulp Washing System ,
wmmm^m
HVLC =
^- pulp now
high volume,
low concentration
-------
Figure 7 - Example Kraft Pulp Washing System
m
Weak Liquor to Weak Liquor
Storage Tank
. .>. Washer vent gases to control device
Com HVLC collection system)
Water
Pulp to
Screen and Decker
System
pulp flow

-+- liquid stream!

-> gas streams
HVLC- high volume.
low concentration
-------
Figure 8 - Example Kraft Screen System and Decker System
Decker vent gases to control device
(via HV1.C cnlleelian system)
m
o
Screen vent gases to control device
(via HVLC collection system)
Pulp from
Pulp Washing System
Screen vent gases to control device
(inn HVLC fatlertmn »y»to/ij
Tailing Screen
Re)ected Pulp
to Digester
*• Interstage ]ik r:!
!j Chest '•'•
Screens
\
r
•*-

i fe fe !'/ :i| i
Accepts
Tank
i? ' .', a| if i ii It- 1
•<' \ , ,' Vf '
' "';l'' J 'i !* !i •''!
1 !' "; f " • liquid streams

->• gas streams
HVLC- high volume,
low concentration
-------
Rgure 9 - Example Kraft Oxygen Delignification System
(medium consistency)
,;!! Washer
{^MMHt,» V
j *Jjr , ;f t! *

'5 ? ] •''' S C !« '<
% «! M 1*1 N )* |» ; J, '• "l |
Kl "f «!f (V-l' ' ' ' 'r *'
., Filtrate
Tank
•"'l"' f i i .•,';
if a !: w V V. V i s> - ~,
Oxygen Delignification Washer
vent gases to control device
(via HVLC collection system)
Pulp to
Bleach System,
«^^- ( Pulp Dryers, or
Papermaking System
Weak Black Liquor to
Weak Black Liquor
Storage Tank
^
mm*m^*a
A

HVLC-
^- pulp flow

high volume,
low concentration
-------
Figure 10 - Example Kraft Oxygen Delignification System
(high consistency)
m
to
Press vent gases to control device
(via HVI.C collection system) ^
Pulp from
Screen and
Decker System
Storage,
Tank °
-»• Weak Black Liquor to
Weak Black Liquor
Storage Tank
NaOII
Washer vent gases to control device
(uiu //V7.C collection system) A
Reactor Blow Tank vent gases
to control device
(via HVLC collection system)
'
, „ Filtrate
Tank
Pulp to
Bleach System,
Pulp Dryers, or
Papermaking System
pulp flow

liquid streams

gas streams
high volume,
low concentration
NaOH = Sodium Hydro*
-------
Figure 11 - Example Kraft Weak Liquor Storage Tank*
m
OJ
from Pulp
^Washing System,
Weak Liquor Storage vent gas to control device
(via IIVI.C collectmn system)
A
• \ \ K :,' u ',> !(' i: i 'i! 'i! 1 ' i i'l iii In .' J.1 It, i, ',< ill j i! <] ill )!'! i ',
M ; f; '" " * ~ il 5 S I» B J 5 :" i
•" T •' Weak Liquor • " *
••"' J! :1 li '<; H ' i: Storase Tailk 5 :i: 5| fi S if § !i ;„ i;
' It i J ] ) ff1 I * 11 f " ''i
i J I* I *i f i t | t ii'i in 111 t I i It i (F } ii h i

•" !| ^ f 1} 1 » 'i !J| | » *» * » '* * *S H ^ »• V ' J F * Sl! !l '•

«„ !>-'-',> ^ . - 1 ,!,, ' ^ & H !A |h, li, [!?« 3), 'a nnr? p * "I " " hi ^
a ' y i, , • < '", (i* is ^ i >,i I 4 „; !,;, ^ 1,1 s= .'ji. A i. , -

,M 1.1 f. ],, y i. 11^ (i i, u ,1 !i i| j; .J;,, i v, i« n U! ,j |;i f; -i i, ;lj ii rl
Weak Liquor
to Evaporator
System

IIVLC*

high volume,
low concentration
-------
Figure 12 - Example Kraft Evaporator System
Non-condensable gases
to control device
(via LVIIC collection system)
i
Vacuum
Device
Condensers
m
Evaporator Condensates to
Steam Stripper (Figure 30) or
Biological treatment
System (Figure 31)
(via condensale collection system)
liquid streams

gas streams
l.VHC= lov 'ume,
h centration
'•!-- Steam
Weak Liquor
(rom Weak l.lquor
Storage Tank
-------
Figure 13 - Example Semi-chemical Pulping System
Chemical
Recovery
System
Evaporator
System
(Figure 17)
Weak Liquor
Storage Tank

Digester System
(Figure 14 & 15)
Refiners
Pulp Washing System*
(Figure 16)

Collection System:
•HVLC
Refiners
Pulp to Pulp Dryers
or Papermaking System.
pulp flow

liquid streams
HVLC= high volume,
low concentration
LVHC > low volume,
high concentration
E-15
Vt/feaec/ source only at new sources.
-------
Rgure 14 - Example Semi-Chemical Digester System (batch)
Relief gas to combustion control device
(via LVHC collection system)
Wood Chips

Cooking Liquor
m
i Digester
Blow
Tank
Primary
Condenser
Blow gas to combustion control device
(via I-vHC collection system)
A
Blow Heat
Accumulator
I Secondary
Condenser
-*• Blow Condensate
pulp flow

-»• liquid streams

-*• gas streams
LVHC- low volume,
'•'''h concentration
-------
Figure 15 - Example Semi-Chemical Digester System (continuous)"
Cooking Liquor
pulp flow

liquid streams

gas streams
LVHC'
low volume,
high concentration

ik i*m ic*
2 »*»,,*

Chip Steamer ^ *
;
k

Q
Wood
Flash gas to combustion
control device
(via LVHC collection system)
>. Non-condensable gases
to control device
("uiu LVWC collection system)
Flash Steam Condensate
>. Weak Liquor
'Blow tank For continuous digester is not pictured.
-------
Figure 16 - Example Semi-Chemical Pulp Washing System*
Washer vent gases to control device
(via HVI.C collection system)
Wash
Water
tfl
»—»
00
Pulp to
Screen and Decker
Refiners
•f^Tr U iS f O>\

; ','. f-j iji £
< ii''1 , jl ' '
'3 ^ S f '*
- -i', S I Seal P, fe (9'>
i*i,.fTanklU
" «>' ' »• ' 'l'l rt Fll lit ' »'• *<'!'
Pi ' '.! i,! F| !'!! If f i,1.

'
• A i" i <>

1 in -1! r ''-

i* ., ' •,) '• ;i> \
. . »i Seal ,
;,. „,, ,.;| Tank > :. '
1 * i ,•,*'' '

, , ' U 1 1 ' '

Weak Liquor to Weak Liquor
Storage Tank

^^ Mf '' ll" l'' '<
' ! i'i' '

, ,;l| ',; Tank
, ,'jf , , , !,

i|>! J'
| i

i''
,1
;'

>!:i ,.

)[

i!9
iN(
1 'r'' ,'|'l
' :b ^'
(i
|
< ri
Foa
\

, 1 1 „ S f?i t|,. jjl' ,i!.i i,'; ijf 1(1
pulp flow

-»• liquid streams

-*• gas streams
high volume,
low concentration
-------
Figure 17 - Semi-Chemical Evaporator System
Non-condensable gases
to control device
(via LVHC collection system}
Vacuum
Device
m
Condensers
<
iyi'ri(iil!ii
Weak Liquur
from Weak Liquor
Storage Tank
•''! : | *J I

• I ii >!
:;« W fill i
Ifcfa
i >:• w
? S;
•ispi.
!|^
' % !?
t ji H i:
li^i:
Evaporator Condensates

IVWC.

low volume,
high concentration
I
J

i,' fj ;>v ,
|r
•'j i ft '
-,' 51 U •
',1 1;l( .jll-
- ^1 H-
jjp 'j frf' '

ill ' ? lt 1
f
-------
Figure 18 - Example Soda Pulping System
Chip
pT])
Cooking
liquor
Chemical
Recovery
System
Evaporator
System
(Figure 21)
Collection System;
• IVWC
Weak Liquor
Storage Tank
Digester System
(Figure 19}

Collection System:
• LVHC
Knotter System
Pulp Washing System*
(Figure 20)

Collection System:
•HVLC
Screen System
and Decker System
pulp Bow

liquid streams

HVLC = high volume,
low concentration

LVHC - low volume,
high concentration
I
Oxygen Delignification
System
i
'Affected source only at new sources.
Pulp to Bleaching Systems, Pulp
Dryers, or Papermaking Systeiu
E-20
-------
Rgure 19 - Example Soda Digester System (batch)
Relief Gas to combustion control device
(via LVHC collection system)
Wood Chips
^ --'

Cooking Liquor
m
K>
\
Blow gas to combustion control device
(via IVHC collection system)
Secondary
Condenser
Blow Heat
! Accumulator
' ' "i \ '* ii f 3
, ' '„ ;,(i- *M!! ,.••
1 „„ '•' ..i 4' v

_ , ,. i fc
Blow Condensate
pulp flow

•*• liquid streams

•> g»s streams
I.VHC * low volume,
high concentration
-------
Figure 20 - Example Soda Pulp Washing System*
, ->. Washer vent gases to control device
(via llVf.C collection system)
a,*1' it g H jLiaJe-i'-.!
'i'Wa'sner!-'
Pulp (rom
Knotter
System
Weak Liquor to Weak Liquor
Storage Tank
'Affected sow at new sources
Water
^iSJSi^Sli
mi i, u i si a > •
i • IT , ' j >n Ft 1 E.

1
< Si
SI »

J * ^Ilis:
,1 f (l| V f! U |
, ,>. f1, >i> 4. n .

f
pulp flow

-*• liquid streams
> gas streams

HVLC- high volume,
low concentration
-------
Figure 21 - Example Soda Evaporator System
Nnn-condensable gases
to control device
(via LVHC collection system)
Vacuum
Device
m
N)
OJ
-)--- -I-- Steam
Weak Liquor
from Weak Liquor
Storage Tank
Strong Liquor to
Chemical Recovery
System
Evaporator Condensates

LVHC-
— *• liquid streams
low volume.
high concentration
-------
Figure 22 - Example Sulfite Pulping System
Chemical
Recovery
System
Strong Liquor
Storage Tank*
(Figure 27)
Evaporator System
(Figure 26)
Weak Liquor
Storage Tank
(Figure 25)
Acid Condensate
Storage Tank*
(Figure 28)
I
Digester System
(Figure 23)
Knotter
System
Vent
71 ^^X
X

Gases
Weak Liquor

I
1
Pulp Washing System
(Figure 24)

I
Screen System
and Decker System
pulp flow

liquid streams

— *• gas streams
"Affected source only at neu, sources
Pulp to Bleaching Systems, Pulp
Dryers, or Papermaking System.,
E-24
-------
Figure 23 - Example Sulfite Digester System (batch)
m
to
Relief Gas to Acid Making System
A
Wood Chips
^ '

Cooking Liquor
Digester
Blow
Tank
Primary
Condenser
Blow gas to Acid Making System
*
Blow Heat
Accumulator
ISencondary
Condenser
Blow Condensate
pulp flow

-»• liquid streams

•> gas streams
-------
Figure 24 - Example Sulfite Pulp Washing System
.->. Washer vent gases to
Acid Making System
m
K>
O\
T5iMM
Wash
Water
Pulp to
Screen and Decker
Refiners
Weak Liquor to Weak Liquor
Storage Tank
pulp flow

>• liquid streams

gas streams
-------
Figure 25 - Example Sulfite Weak Liquor Storage Tank*
Weak Liquor Storage to control device
A
m
to
Weak Liquor
from Pulp
.Washing System,

/: ^ M" "! i '*• "* '• if!" 3| ' i 1 ,'i " ' a '"
- ' .'.' i. ?! j * ;, ,(' »>, 4', i'j ', , !,! ' • it k i' ti M : . ,;
.^•iimtKH^^ •
', : ' • ' ," f » 7, 1? '" 1 l1 , .1

gas s reams

».

Weak Liquor
*•( to Evaporator
System
'Affected source only at new sources
-------
Figure 26 - Example Sulflte Evaporator System
Non-condensable gasrs
to control device
A
Condensers
Evaporator Condensates
liquid streams

gas streams
'•;-- Steam
We.ik Liquor
from Weak Liquor
Storage Tank
Strong Liquor to
Chemical Recovery
System
-------
Figure 27 - Example Sulfite Strong Liquor Storage Tank*
m
K)
Strong Liquor
from Pulp
^Washing System,
Tank vents to control device
A
Strong Liquor I
Storage Tank
-' ' a ;•
Strong Liquor to
~*^ Chemical Recovery)
System
* Affected source only at new sources.
liquid streams

gas streams
-------
Figure 28 - Example Sulfite Acid Condensate Storage Tank*
Cooking Liquor
from
Acid Making System
Tank vents to control device
A
I'l; $,'
Acid Condensate
'••• i ii ji ( ] Storage Tank j| j y . ij : j
Cooking Liquor
to Digester
System
-*• liquid streams
->• (>as streams
-------

W — "G 3
11*!
3 a 5"
I 3
o
3;
o
-
"
23
act"

(i
K9
(0
99

"
I
p-*
ere
r
sf 3 I"
•j :", =
' -t F
f Bleaching Tower * ^ ;| %
.- t.
=1 i-.
-------
Rgure 30 - Example Steam Stripping System
with Methanol Rectification
Stripper Off-gas to control device
(via LVHC collection system) j,
Condenser
Turpentine
Separator
Steam
Stripped Condensate to Sewer
or use for Wash Water
Turpentine
Metlianul-ilch
Distillate
-> liquid 51 reams

-»• gas streams
LVHC * low volume.
high concentration
-------
Figure 31 - Example Biological Treatment System
Pulping Process Condensates
Bar Screen
Grit Chamber
Primary Clarifier
pH Adjustment
Biological Treatment System
(e.g., activated sludge, aerated stabilization basin,
anaerobic system, pure 0:, etc.)
Secondary Settling
Discharge to
Receiving Stream
E-33
liquid streams
02 = Oxygen
-------
Appendix F

List of Equipment Affected by the NESHAP
-------
For Purposes of Determining Applicability to the NESHAP (Subpart S)
The Following System...
Decker
Digester
Evaporator
Knotter
Oxygen deiignification
Pulp washing
Screen
Steam stripper
Turpentine recovery
Includes...
decker vents, filtrate tanks, and vacuum pumps*
continuous or batch digester, associated flash
tanks, chip steamers not using fresh steam, blow
heat recovery accumulators, relief gas condensers.
and prehydrolysis units preceding the pulp
washing system*
pre-evaporators, multi -effect evaporators,
concentrators, vacuum systems, associated
condensers, hotwells, and condensate streams*
knotter, knot drainer tanks, and ancillary tanks*
blow tank, washers, filtrate tanks, and interstage
pulp storage tanks*
vacuum drum washers, diffusion washers, rotary
pressure washers, horizontal belt filters,
intermediate stock chests, associated vacuum
pumps, filtrate tanks, foam breakers or tanks*
equipment in which oversized particles are
removed from the pulp slurry prior to bleaching or
papermaking system washed stock storage*
stripper column, associated stripper feed tanks,
condensers, heat exchangers, methanol
rectification equipment (which includes rectifiers,
condensers, decanters, and storage tanks)*
condensers, decanters, and storage tanks*
and any other equipment serving the same function
F-l
-------
Appendix G

Pulp and Paper NESHAP Control Requirements
-------
Appendix G
Pulp and Paper NESHAP Control Requirements
If You Have...
Krali Pulping, Soda Pulping, or
Semi-chemical Pulping
Sulfile Pulping
• Calcium-based and sodium-
based pulping systems
• Ammonium-based and
sodium-based pulping
systems
Mechanical Pulping
Non-wood Pulping
Secondary Fiber Pulping
Bleaching
Kraft Pulping Process
Condensatcs
Then Control Your Operations By...
• 98% reduction by weight of total 1 IAP;" or
• introduce MAP emission stream with primary fuel or into flame 7.onc of a boiler, lime kiln, or recovery furnace; or
• minimum of I60()°F and 0 75 seconds in an incinerator, or
• reduction to 20 ppmv corrected to 10 percent oxygen outlet concentration of total HAP from an incinerator
• Outlet total HAP emission level of 0.89 Ib/ton ODP or less, or 92,% reduction by weight ol total HAP (includes air
vents, wastcwater and condensale streams from (he control device )
• Outlet total 1 IAP emission level of 2 2 In/Ion ODP or less, or 87% reduction by weight of total HAP (includes air
vents, wastewatcr and condensale streams Irom the control device1")
N/A (Bleaching requirements only)
N/A (Bleaching requirements only)
N/A (Bleaching requirements only)
99% reduction by weight of chlorinated HAPs,'' or achieve outlet chloimated HAP^'' concentration of 10 ppmv or less; or
achieve an outlet chlorinated HAP ' emission level of 0.002 Ib/lon ODP or less; and separate chloroform control options
Recycle to controlled piece of process equipment; or remove 92%) of total HAPs in biological treatment system; or meet
one of the following, such that the HAPs removed during treatment or handling arc controlled to meet krafl pulping
system vent standards:
• Reduce total HAP loading by at least 929!) by weight
• For unbleached mills: ,
remove a minimum of 6.6 Ib/ton ODP total HAPs
or.
reduce total HAPs to210ppmw
• For bleached mills.
remove a minimum of 10.2 Ib/ton ODP total HAPs'
orb
reduce total HAPs to 330 ppmw
And Monitor By-
Continuous parametric
monitoring, except for
pulping vent systems routed
to a power boiler, lime kiln, or
recovery furnace
Continuous parametric
monitoring
N/A
N/A
N/A
Continuous parametric
monitoring
Continuous parametric
monitoring
o
bAll components require monthly visual inspections for equipment leaks using Method 21.
cMeasured as total HAPs or methanol.
j Mass emission limit and percent reduction includes emissions from regulated equipment system and vents, wastewatcr, and condensate streams from the control device.
e Refer to Chapter 4 of this document for specific requirements for bleaching systems.
, Excluding chloroform.
Chlorine is used as a surrogate for chlorinated HAPs.
Excluding biological treatment system, which uses a combination of daily parameter monitoring and quarterly percent reduction tests.
-------
Appendix H

Compliance Milestones Timeline for Existing Sources
-------
Timeline of Applicable Notifications and Filings Pursuant
to the General Provisions and Pulp and Paper NESHAP
(Existing Sources)
APRIL 15, 1998
Effective Out ol Rule

APRIL 15, 1999
Initial notification

Control strategy report

APRIL 16, 2001
Control strategy report update

Startup, ihutdown. malfunction
plan completed
(LVHC. bleaching, condentatet)

Compliance deadline
(LVHC. bleaching, condensatei)

AUGUST 11. 2001
Notification of performance ten
(LVHC, bleaching, condematei)

AUGUST 29, 2001
Deques! for performance
audit samples
(IVHC. bleaching, condensales)
OCTOBER 13,2001
Deadline for conducting initial
performance test
(LVHC. bleaching, condensales)
Submission of tile-specific
lest plan
(IVHC. bleaching, condensates)

Notice of CHS performance
evaluation
(IVHC. bleaching, condensales)

DECEMBER 12. 2001
ttporl result! of
performance lest
(LVHC. bleaching, condensates)

Report CHS performance
evaluation results
(IVHC, bleaching, condensales)

Notification of
compliance status
(LVHC. bleaching, condensates)
-------
Timeline of Applicable Notifications and Filings Pursuant
to the General Provisions and Pulp and Paper NESHAP
(Existing Sources) continued
a
i
ro

JULY 12. 2002

Startup, shutdown, malfunction
report (part of luminary report)
Eictu emissions report
(part of summary report)
Summary report
JANUARY 1 1, 2003

Startup, shutdown, malfunction
report (part ol summary report)
Euess emissions report
(part of summary report)
Summary report
APRIL 16, 2003

Control strategy report update
JULY 12.2003

Startup, shutdown, malfunction
report (part ol summary report)
Excess emissions report
(part ol summary report)
Summary report
JANUARY 11.2004

Startup, shutdown, malfunction
report (part ol summary report)
Excess emissions report
(part ol summary report)
Summary report
APRIL IS. 2004

Startup, shutdown, malfunction
plan completed
(bleaching systems in Incentives
Program)
Compliance deadline
(bleachmf systems in Incentives
Program)
JULY 11,2004

Startup, shutdown, malfunction
report (part of summary report)
Eicess (missions report
(part of summary report)
Summary report
-------
Timeline of Applicable Notifications and Filings Pursuant
to the General Provisions and Pulp and Paper NESHAP
(Existing Sources) continued

re
oo

AUGUST 13, 2004
Notification ol performance ttil
(bleaching systems m Incentives
Program)
AUGUST 28. 2004
tapttil lor perfcmuna audit
samples (bleaching syueim in
Incentives Program)

OCTOBER 12, 2004
Deadline lor conducting initial
performance lest
(bleaching systems in Incentives
Program)
Submission of site-specific test
(bleaching systems in Incentives
Program)

Notice ol CHS performance
evaluation (beaching sytttim in
Incennm Program)

DECEMBER 1 1, 2004
deport results ol performance
test (bleaching systems in
Incenaves Program)

Report CHS performance
evaluation results
JANUARY 10, 200S
Startup, shutdown, malfunction
APRIL 15,2005
Control strategy report update
report (part of summary report)

Eicess emissions report
(part of summary report)

Summary report
JULY 11.2005
Startup, shutdown, malfunction
report (part ol summary report)

Eicess emissions report
(part of summary report)

Summary report
(bleaching systems in Incentives
Program)

Notification of compliance status
(bleaching systems in Incentives
Program)
-------
Timeline of Applicable Notifications and Filings Pursuant
to the General Provisions and Pulp and Paper NESHAP
(Existing Sources) continued
JANUARY 10. 2006
Startup, shutdown, malfunction
report (part of summary report)
Eicess emissions report
(part of summary report)
Summary report
APRIL 17,2006
Startup, shutdown, malfunction
plan completed (HVtC)
Compliance deadline (OTIC)
JULY 11,2006
Startup, shutdown, malfunction
report (part of summary report)
Eicess emissions report
(part of summary report)
Summary report
AUGUST IS, 2006
Notification of performance lest
(HVLQ
Submission of site-specific test
(HVU)
Nonce of CMS performance
evaluation (HVIC)
AUGUST 30, 2006
deques! for performance audit
samples (HVLC)
OCTOBER 14, 2006
Deadline for conducting jmoal
performance test (HVLC)
DECEMBER 13, 2006
deport results of performance
lest (HVIC)
deport CHS performance
evaluation results (HVIC)
Notiiation of compliance status
(HVLC)
-------
Timeline of Applicable Notifications and Filings Pursuant
to the General Provisions and Pulp and Paper NESHAP
(Existing Sources) continued
JANUARY 10, 2007
Startup, shutdown, malfunction
report (part of summary report)
Excess emissions report
(part of summary report)
Summary report
JULY 11,2007
Startup, shutdown, malfunction
report (part of summary report)
Excess emissions report
(part ol summary report)
Summary report
JANUARY 10, 2008
Startup, shutdown, malfunction
report (part of summary report)
Excess emissions report
(part of summary report)
Summary report
JULY 10, 2008
Startup, shutdown, malfunction
report (part of summary report)
Excess emissions report
(pan of summary report)
Summary report
-------
Appendix I

Summary of Effluent Limitations Guidelines for
Bleached Papergrade Kraft Mills
-------
Appendix I
Summary of Effluent Limitations Guidelines for Chlorinated Pollutants for Subpart B - Bleached Papergrade Kraft
Pollutant
TCDD
TCDF
Chloroform
trichlorosyringol
3,4,5-lrichlorocatechol
3,4,6-lrichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacol
4,5,6-trichloroguaiacol
2,4,5-trichlorophenol
2,4,6-trichlorophenol
tetrachlorocatechol
(etrachloroguaiacol
2,3,4,6-lelrachlorophenol
pentachlorophenol
AOX
COD
Effluent Limitations Guidelines and Standards
1 Day Maximum Monthly Average
-------
TECHNICAL REPORT DATA
1. REPORT NO
EPA 456/R-008
3. RECIPIENTS ACCESSION NO
4. TITLE AND SUBTITLE
Pulp and Paper NESHAP: A Plain English Description
5. REPORT DATE
November 1998

6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10 PROGRAM ELEMENT NO

11 CONTRACT/GRANT NO
68-D6-0011
12 SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
US EPA, RTP, NC27711
13 TYPE OF REPORT AND PERIOD COVERED
Final

14 SPONSORING AGENCY CODE
EPA/200/04
15 SUPPLEMENTARY NOTES
Project Officer is Carolyn Wigington, Mail Drop 13 (919-541-5374)
Work Assignment Manager is Gil Wood, Mail Drop 12 (919-541-5272)
16. ABSTRACT
This document summarizes the National emissions standards to control emissions of HAP from major
sources producing pulp and paper, as published in the April 15, 1998 Federal Register. This document
contains "plain english" information to help State and local agencies for air-pollution control, as well as
the regulated community, carry out these standards. This document is not legally binding and does not
replace the rule as published in the Federal Register for purposes of application of the rule to any
specific mill. This document refers to additional information on the Unified Air Toxics Webpage.
(www.epa.gov/ttn/uatw/pulp/pulppg.html)
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b IDENTIFIERS/OPEN ENDED TERMS
c. COSATI
Air pollution
Air pollution control
National emissions standards
Hazardous air pollutants
Pulp and Paper Industry
Title m
NESHAP
Compliance
Implementation
Air pollution control
Pulp and paper
Cluster Methanol
Dioxin
Chloroform
13B
18 DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Report}
Unclassified
21. NO. OF
PAGES
208
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
-------