& EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-456YR-01-003
September 2001
www.epa.gov/ttn/atw/pulp/pulppg.html
Air
PULP AND PAPER COMBUSTION SOURCES
NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS
(NESHAP) :
A PLAIN ENGLISH DESCRIPTION
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EPA-456/R-01-003
PULP AND PAPER COMBUSTION SOURCES
NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP)
A Plain English Description
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triancle Park. NC 27711
September 2001
U.S. Environmental Protection Agency
5 Library (PL. 12J)
-------
Disclaimer
This document has been reviewed and approved for publication by the Office of Air Quality
Planning and Standards 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 Chemical Recovery Combustion Sources
at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (January 12, 2001,
66 FR 3180) 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
without public notice.
Technical corrections to the final pulp and paper combustion sources NESHAP (July 19, 2001,
66 FR 37591) have been published. You should periodically check the Technology Transfer
Network (TTN) website at http://www.epa.gov/ttn/ for other technical corrections and/or other
relevant information.
11
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Contents
Chapter 1 -
Purpose of This
Document
Chapter 2 -
Background
Chapter 3 - Brief
Overview of the
Pulp and Paper
Combustion
Sources NESHAP
Chapter 4 -
NESHAP
Requirements
Page
1.1 Why should I use this document? 1-1
1.2 Is there anything I should know before using this document? .... 1-2
1.3 What information does this document include? 1-2
1.4 What is the purpose of the pulp and paper combustion sources
NESHAP? 1-3
1.5 How many sources does the NESHAP affect? 1-4
1.6 What if I have questions? 1-4
1.7 How do I get additional copies of this document? 1-5
1.8 Where can I find additional information about this NESHAP? ... 1-5
1.9 Where can I find additional information about pulp and paper
combustion sources? 1-7
2.1
0 '
? 4
3.5
3.6
3.7
3.8
4.1
4.2
What is the background information for kraft and soda pulp mills? 2-1
What is the background information for sulfite pulp mills? .... 2-18
What is the background information for stand-alone semichemical
pulp mills? 2-22
Where can I find the references for this background information? 2-28
Which mills are subject to the NESHAP? 3-1
What affected sources must be controlled? 3-1
What are the emission control requirements? 3-2
Hovv do mills demonstrate initial and continuous compliance? . . . 3-3
What recordkeeping and reporting requirements apply? 3-5
When must mills comph ? 3-6
What is a new source? 3-6
What additional requirements apply to new sources? 3-7
What are the standards for kraft and soda combustion sources? .. 4-1
What are the standards for sulfite and semichemical combustion
sources? 4-13
in
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Contents (Continued)
Page
r»u n*i, 5.1 What other Federal air regulations currently affect pulp and paper
Chapter 5 — Other . „ - —
Federal Regulations mlls
Affecting Pulp and 5.2 What Federal water regulations currently affect pulp and paper
Paper'Mills mills? ". 5-4
5.3 What Federal hazardous waste regulations currently affect pulp and
paper mills? 5-6
5.4 What upcoming regulations will affect pulp and paper mills and
companies? 5-7
«•- * *. ««. 6.1 Who administers this regulation? 6-1
Chapter 6 - Other &
Requirements and 6.2 Do I need a Title V permit? 6-1
Information , . . , , , . , „ , ,
6.3 How do I change my permit to include this rule? 6-1
6.4 What parts of the NESHAP General Provisions apply? 6-2
Appendices A Final NESHAP and Technical Corrections A-1
B. List of U.S. Pulp and Paper Mills Subject to the NESHAP B-l
C. List of EPA Regional Office Contacts C-l
D. Responses to Commonly Asked Questions D-l
E. Glossary of Commonly Used Terms E-l
F. Equipment Diagrams for Chemical Recovers' Combustion Sources F-l
G. Example Calculations G-l
H. Compliance Timelines for Existing and New Sources H-l
I. Flowchart Summary of the NESHAP 1-1
J. Inspection Checklists for Pulp and Paper Mills Subject to the
NESHAP J-!
K. Example Notifications and Compliance Reports K- i
L. Technical Report Data Sheet L-1
List of Figures Figure F-l. Chemical Recovery Process (with DCE Recovery Furnace)
for the Kraft Pulping Process F-3
Figure F-2. NDCE Recovery Furnace and Associated Equipment . . . . F-4
Figure F-3. DCE Recovery Furnace and Associated Equipment F-5
IV
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Contents (Continued)
Page
Figure F-4. Smelt Dissolving Tank and Wet Scrubber F-6
Figure F-5. Two-Stage Air-Sparging Black Liquor Oxidation System F-7
Figure F-6. Lime Kiln and Wet Scrubber F-8
Figure F-7. Electrostatic Precipitator F-9
Figure F-8. Venturi Scrubber F-10
Figure F-9. Emission Sources for a DCE Recovery Furnace System . F-l 1
Figure F-10. Emission Sources for an NDCE Recovery Furnace F-l2
Figure F-11. Chemical Recovery Process for the Mg-Based Sulfite
Pulping Process F-l3
Figure F-12. Mg-Based Sulfite Recovery Furnace F-14
Figure F-13. Fluidized-Bed Reactor F-15
Figure F-14. Mg-Based Sulfite Fluidized-Bed Reactor System F-l6
Figure F-15. Chemical Recovery Process for the NH3-Based Sulfite
Pulping Process F-17
Figure F-16. NH3-Based Sulfite Recovery Furnace F-1S
Figure F-17. Chemical Recovery Process for the Semichemical
Pulping Process F-l9
Figure F-l8. Recovery Furnace F-20
Figure F-19. Rotary Liquor Kiln F-21
Figure F-20. Black Liquor Gasification System F-22
Figuie F-21. Regenerative Thermal Oxidizer F-23
Figuie H-l. Compliance Timeline for Existing Sources and Area
Sources That Become Major Sources H-3
Figuiv H-2. Compliance Timeline for New or Reconstructed Sources
With Startup After Promulgation Date H-4
Figure 1-1. Mill Applicability 1-3
Figure 1-2. Applicability and Compliance Schedule 1-4
Figure 1-3. Emission Limits 1-5
Figure 1-4. Initial Compliance Requirements 1-6
Figure 1-5. Continuous Compliance Requirements 1-7
Figure 1-6. Reporting Requirements 1-8
Figure 1-7. Recordkeeping Requirements 1-9
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List of Tables
Contents (Continued)
Page
Table 1. Hazardous Air Pollutants Emitted from Pulp and Paper
Combustion Sources 1-3
Table 2. Location of Pulp and Paper Mills Subject to the NESHAP 1 -4
Table 3. Affected Sources and Process Units Covered by the
NESHAP 3-2
Table 4. Formats of the Emission Limits 3-3
Table 5. Initial and Continuous Compliance Requirements 3-4
Table 6. Definition of a New Source 3-6
Table 7. Kraft and Soda Affected Sources 4-1
Table 8. Kraft and Soda Emission Limits 4-2
Table 9. Kraft and Soda Initial Compliance Requirements 4-3
Table 10. Kraft and Soda Continuous Compliance Requirements ... 4-5
Table 11. Kraft and Soda Recordkeeping Requirements 4-8
Table 12, Kraft and Soda Reporting Requirements 4-10
Table 13. Comparison of NSPS and NESHAP Requirements 4-11
Table 14. Sulfite and Semichemical Affected Sources 4-13
Table 15. Sulfite and Semichemical Emission Limits 4-14
Table 16. Sulfite and Semichemical Initial Compliance Requirements4-15
Table 17. Sulfite and Semichemical Continuous Compliance
Requirements 4-16
Table IS. Other Federal Air Regulations 5-2
Table 19. Federal Water Regulations 5-4
Table 20. Federal Hazardous Waste and Emergency Planning
Regulations 5-6
Table 21. Title V Permitting Requirements 6-1
Table B-l. Pulp and Paper Mills B-2
Table C-l. EPA Regional Office Contacts C-2
Table G-l. Results of Example Mill A G-9
Table G-2. Results of Example Mill B G-15
VI
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Tliis document does NOT
replace the NESHAP for
purposes of making
legal interpretations'
Chapter 1 - Purpose of This Document
The U.S. Environmental Protection Agency (EPA) published the final
national emission standards for hazardous air pollutants (NESHAP) for pulp
and paper combustion sources on January 12, 2001. Technical corrections to
the final rule were published on July 19, 2001. The NESHAP affects existing
and new major chemical recovery combustion sources at kraft, soda, sulfite,
and stand-alone semichemical pulp mills. The NESHAP requires these
sources to control hazardous air pollutant (HAP) emissions using the
maximum achievable control technology (MACT). This chapter discusses
the purpose of this document, the information it contains, the purpose of the
NESHAP, and sources of further information.
If You Need the Following Information...
Then Read.,
Why should I use this document?
Section 1.1
Is there anything I should know before using this document? Section 1.2
What information does this document include? Section 1.3
What is the purpose of the pulp and paper combustion Section 1.4
sources NESHAP?
How many sources does the NESHAP affect?
What if I ha\e questions?
Section 1.5
Section 1.6
How do I get additional copies of this document? Section 1.7
Where can I find additional information about this NESHAP? Section 1.8
Wnerc can I find additional information about pulp and paper Section 1.9
combustion sources?
1.1 Why should I use this document?
This document can help plant owners and operators (you) understand the
Pulp and Paper Combustion Sources NESHAP (also known as 40 CFR
pan 63. subpart MM) by helping you determine five main things:
1. If the rule applies to your plant and process;
2. What compliance options are available for different emission points;
3. How to set mill-specific emission limits under the bubble compliance
alternative;
4. What to monitor, record, and report; and
5. Dates by which you must meet requirements.
1-1
Chapter 1 - Purpose
-------
Stay informed about new
or revised requirements
by visiting "What's
New" pages of the OECA
and Air Toxics websites:
http://es.epa.gov/oeca/
wn2.html
and
http://www.epa.gov/ttn/
atw/atwnew.html
1.2 Is there anything I should know before using this
document?
When using this document, remember that it doesn't replace the final rule and
that it covers only requirements published on or before July 19, 2001. You
should keep up with new requirements printed after this date by periodically
checking the Federal Register and the Code of Federal Regulations (CFR).
You can download Federal Register notices by going to the Government
Printing Office (GPO) website at
http://www.access.gpo.gov/su_docs/aces/aces140.html.
We have included the final rule (January 12, 2001, 66 FR 3180) and the
technical corrections (66 FR 37591) in Appendix A, so that you can
reference the rule while using this document.
1.3 What information does this document include?
A list of information contained in this document is provided below.
Everyone should read Chapter 3 because it provides the overview of the
NESHAP. After reading Chapter 3, you should decide what other sections of
the document you need to read.
If You Need the Following Information...
Then Read.
The purpose of this document i Chapter 1
Background j Chapter 2
A brief overview of the NESHAP j Chapter 3
NESHAP requirements j Chapter 4
Other Federal regulations affecting pulp and paper mills j Chapter 5
Other requirements and information j Chaptei 6
Final NESHAP and technical corrections j Appendix A
List of U.S. pulp and paper mills subject to the NESHAP . j Append: -, B
List of EPA Regional Office contacts i Appendix C
Responses to commonly asked questions j Appendix D
Glossary of commonly used terms j Appendix F
Equipment diagrams for chemical recovery combustion sources j Appendix F
Example calculations, including how to use the PM bubble j Appendix G
compliance alternative i
Compliance timelines for existing and new sources j Appendix H
Flowchart summary of the NESHAP j Apperd;x I
Inspection checklists for pulp and paper mills subject to the i Appendi \ J
NESHAP }
Example notifications and compliance reports j Appendix K
1-2
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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 HAP.
1.4 What is the purpose of the pulp and paper combustion
sources NESHAP?
The purpose of this NESHAP is to reduce HAP emissions from chemical
recovery combustion sources at pulp and paper mills, thus reducing public
health hazards. The EPA regulated these chemical recovery combustion
sources because chemical pulp mills were judged to be major sources of
HAPs listed in section 112 of the Clean Air Act (CAA). Section 112(d) of
the CAA directs EPA to establish NESHAP for major stationary sources.
The CAA requires the NESHAP to reflect the maximum degree of emission
limitation that is achievable. This level of control is commonly referred to as
MACT. The "MACT floor" is the minimum control level allowed for
NESHAP as specified in section 112(d)(3) of the CAA. In determining
MACT, EPA may also consider control options more stringent than the
MACT floor, based on considerations of cost, human health impacts,
environmental impacts, and energy requirements.
Pulp and paper combustion sources emit 22,500 tons of HAP annually that
impact both air quality and public health. The pu'p and paper combustion
sources NESHAP will reduce 1997 emissions of HAP from pulp and paper
nvlls b\ 2.700 tons per year (a 12 percent reduction). Table 1 lists the HAP
emitted in the largest quantities from pulp and paper combustion sources and
also lists HAP metals that are emitted from pulp and paper combustion
sources. The NESHAP limits gaseous organic HAP emissions from new
recover, furnaces at kraft and soda mills and from new and existing
combustion sources at semichemical mills. The NESHAP also limits HAP
metals emissions from both existing and new combustion sources at kraft.
socL. and sulfite mills.
Table 1. Hazardous Air Pollutants Emitted from
Pulp and Paper Combustion Sources
• Acetaldehyde
• Benzene
• Formaldehyde
• Hydrochloric a
• Methanol
Gaseous HAP3
• Meth)l ethyl ketone
• Methyl isobutyl ketone
• Phenol
;id • Toluene
• Xylenes
HAP Metals
• Antimony • Lead
• Arsenic • Manganese
• Beryllium • Mercury
• Cadmium • Nickel
• Chromium • Selenium
These 10 compounds represent the most prevalent (highest emitted) HAP from pulp and
paper combustion sources; other gaseous HAP are also emitted from these sources, but
in lesser quantities.
1-3
Chapter 1 - Purpose
-------
The list of mills in
Appendix B is for
information only. The
list was based on the
available information
and is subject to change,
as mills may change
ownership or be shut
down. Hie list does not
represent an EPA
determination that any
specific mill is subject to
the A'ES/MP.
Identify your State and
local contacts using the
Membership Directory at
the STAPPA/ALAPCO
website at
http://www.4cleanair.org
The control techniques used to reduce HAP emissions will also reduce
emissions of other pollutants. For example, the NESHAP will reduce
paniculate matter (PM) emissions by 23,200 tons per year, volatile organic
•compound (VOC) emissions by 34,700 tons per year, and carbon monoxide
(CO) emissions by 61,500 tons per year. Emissions of PM, VOC, and CO
cause a variety of adverse health effects. Volatile organic compounds are
also precursors to the formation of tropospheric (ground level) ozone, which
causes adverse health effects.
1.5 How many sources does the NESHAP affect?
Table 2 shows the location of the pulp and paper mills in the United States
that are potentially affected by the pulp and paper combustion sources
NESHAP. Appendix B lists the pulp and paper mills (including facility
name, location, and type of pulping process) that were identified as
potentially affected sources at the time the final NESHAP was published.
Table 2. Location of Pulp and Paper Mills Subject to the NESHAP
State
Alabama
Arkansas
California
Florida
Georgia
Idaho
Indiana
Iowa
Kentuck)
Louisiana
No.
Mills
13
7
1
6
12
1
1
1
2
9
State
Maine
Maryland
Michigan
Minnesota
Mississippi
Montana
New Hampshire
New York
North Carolina
Ohio
No.
Mills
7
1
6
2
6
1
2
2
5
2
State
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Total
No. Mills
1
5
4
7
3
4
6
9
7
i?:-
1.6 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 the American Forest and Paper Association
(AF&PA) at http://www.afandpa.org; the Technical Association of the
1-4
-------
Copies are available
free of charge from the
EPA librae
NT IS M .'// charge a fee
for each document
requested
Pulp and Paper Industry at http://www.tappi.org; and the National
Council of the Paper Industry for Air and Stream Improvement, Inc.
(NCASI) at http://www.ncasi.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 :ncluded in
Appendix C. A list of commonly asked questions and responses is also
provided in Appendix D.
1.7 How do I get additional copies of this document?
You can get copies of this document from the following sources:
• EPA' s Technology Transfer Network (TTN) on the World Wide Web at
http://www.epa.gov/ttn/atw/index.html. Look under Rules and
Implementation.
• 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 or (800) 553-6947
Fax- (703)321-8547
• National Center for Publications and Information
Telephone: 1-800-490-9198
or http://vww.epa.gov/ncepihom/
1.8 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, technical support documents, and technical
memoranda. The technical support documents and memoranda are:
• Technical Support Document: Chemical Recovery Combustion Sources at
Kraft and Soda Pulp Mills. U. S. Environmental Protection Agency:
Office of Air Quality Planning and Standards. Research Triangle Park.
NC. Publication No. EPA-453/R-96-012. October 1996.
1-5
Chapter 1 - Purpose
-------
Check the ATWfor
further correction
notice.1: and
amendments
• Draft Technical Support Document: Chemical Recovery Combustion
Sources at Sulfite Pulp Mills. U. S. Environmental Protection Agency.
Office of Air Quality Planning and Standards.Research Triangle Park,
NC. June 22,1995.
• Memorandum from McManus, S., MRI, to Telander, J., EPA/MICG,
December 6,1996. Profile of U.S. Stand-Alone Semichemical Pulp
Mills.
• Memorandum from Telander, J., EPA/MICG, to Docket A-94-67.
November 20, 2000. Summary of Public Comments and Responses on the
Proposed NESHAP for Chemical Recovery Combustion Sources at Kraft,
Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills.
Federal Register notices pertaining to the NESHAP are:
• Notice of Proposed Rulemaking—NESHAP; Proposed Standards for
Hazardous Air Pollutants from Chemical Recovery Combustion Sources
at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills, Vol.
63, No. 72, Fed. Reg., 18754-18793, Wednesday, April 15, 1998.
• Notice of Final Rulemaking—NESHAP; Standards for Hazardous Air
Pollutants from Chemical Recovery Combustion Sources at Kraft, Soda,
Sulfite, and Stand-Alone Semichemical Pulp Mills, Vol. 66, No. 9, Fed.
Reg., 3180-3203, Friday, January 12, 2001.
• Technical Corrections—NESHAP; Standards for Hazardous Air
Pollutants from Chemical Recovery Combustion Sources at Kraft, Soda.
Sulfite. and Stand-Alone Semichemical Pulp Mills, Vol. 66. No. 139, Fed.
Reg.. 37591-37593, Thursday, July 19, 2001.
You can get these documents and other relevant documents from:
• EPA's Air Toxics website (ATW) at
http://www.epa.gov/ttn/atw/index.html
• What's New page of the ATW at
http://www.epa.gov/ttn/atw/atwnew.html for the most current
information
• The Air Docket (A-94-67) which is available for public inspection
between 8 a.m. and 4 p.m., Monday through Friday, except for Federal
holidays, at:
1-6
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Tlie Pulping and
Bleaching System
NESHAPfor the Pulp and
Paper Industry: A Plain
English Description
coven the requirements
in the Pulp and Paper
Production NESHAPfor
non-combustion sources.
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
1.9 Where can I find additional information about pulp and
paper combustion sources?
You can get additional information from:
• Smook, G. Handbook for Pulp and Paper Technologists. 2nd Edition.
Montreal, Quebec, Canada, Canadian Pulp and Paper Association.
Atlanta, GA, TAPPI Press. 1992.
• Someshwar, A. and J. Pinkerton. Wood Processing Industry. In: Air
Pollution Engineering Manual, Air and Waste Management Association.
Buonicore, A. and W. Davis (eds.). New York, Van Norstrand Reinhold.
1992.
• Ingruber, O., M. Kocurek, and A. Wong (eds.). Pulp and Paper
Manufacturer: Volume 4—Sulfite Science and Technology. Joint
Textbook Committee of the Paper Industry. 1985.
• Green, R. and G. Hough (eds.). Chemical Recovery in the Alkaline
Pulping Process. 3rd Edition. Prepared by the Alkaline Pulping
Committee of the Pulp Manufacture Division. Atlanta, GA, TAPPI Press.
1992.
• Lockwood Post's Directory of the Pulp. Paper and Allied Trades, 2001.
San Francisco, Miller Freeman Publications. 2001.
• 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.html#pulp. 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.
• EPA. 2001. Pulping and Bleaching System NESHAP for the Pulp and
Paper Industry: A Plain English Description. EPA-456/R-01-002. Office
of Air Quality Planning and Standards, Research Triangle Park, NC.
http://www.epa.gov/ttn/atw/pulp/pulppg.html.
1-7
Chapter 1 - Purpose
-------
Appendix B include! a list
of chemical pulp nulls
(including kraft and soda
pulp mills) in the L'.S
Mills that use 100 percent
recycled fiber or
mechanical]} pulp \\ood
(e.f . groundn ood mills t
are not included Tins hst
is subiec; to change, a;
mills nur\ change
ownership or be shut
Chapter 2 - Background
This chapter presents background information on the pulping processes and
chemical recovery processes for kraft, soda, sulfite, and stand-alone
semichemical pulp mills. A glossary of the terms and acronyms used in this
chapter and throughout the document is provided in Appendix I. The figures
referenced in this chapter are presented in Appendix F.
If You Need the Following Information.,
Then Read.,
Kraft and soda pulp mills
Section 2.1
Sulfite pulp mills
Stand-alone semichemical pulp mills-
References
Section 2.2
Section 2.3
Section 2.4
2.1 What is the background information for kraft and soda pulp
mills?
What is the U.S. population of kraft and soda pulp mills?
There are 111 kraft and 2 soda pulp mills currently operating in 27 States.
Appendix B lists the company names and locations for the 113 mills. The
kraft process is the dominant pulping process in the United States, accounting
for approximately 85 percent of all domestic pulp production.
One reason why the kraft process dominates the paper industry is because of
the ability of the kraft chemical recover}' process to recover approximately
95 percent of the pulping chemicals and at the same time produce energy in
the form of steam. Other reasons for the dominance of the kraft process
include its abiht> to handle a wide variety of wood species and the superior
strength of iK pulp.
What is the kraft and soda pulping process?
In the kraft pulping process, cooking liquor is introduced with wood chips
into digesters, where the wood chips are "cooked" under pressure. Cooking
liquor, which is referred to as "white liquor," is an aqueous solution of
sodium hydroxide (NaOH) and sodium sulfide (Na2S) that is used in the
pulping area of the mill. The soda pulping process is similar to the kraft
process, except that soda pulping is a nonsulfur process that does not use
Na:S
After the wood chips have been "cooked," the contents of the digester are
discharged under full digester pressure into the blow tank. As the mass of
2-1
Chapter 2 - Background
-------
Only kraft pulp mills that
operate DCE recovery-
furnaces have BLO
systems.
softened, cooked chips impacts on the tangential entry of the blow tank, the
chips disintegrate into fibers or "pulp." The pulp and spent cooking liquor
are subsequently separated in a series of brown stock washers.
At about 11 percent of kraft pulp mills, neutral sulfite semichemical (NSSC)
pulping or kraft green liquor pulping is also practiced. The NSSC process
involves pulping wood chips in a solution of sodium sulfite and sodium
bicarbonate, followed by mechanical defibrating. The kraft green liquor
process uses sodium carbonate (Na2CO3) plus Na2S .as the cooking liquor for
semichemical pulping.
The kraft and soda pulping processes are discussed in greater detail in
Pulping and Bleaching System NESHAP for the Pulp and Paper
Industry: A Plain English Description. The following sections describe
the chemical recovery process at kraft and soda pulp mills.
What is the kraft and soda chemical recovery process?
Spent cooking liquor, referred to as "weak black liquor," from the brown
stock washers is routed to the chemical recovery area at kraft and soda pulp
mills. A process flow diagram of the chemical recovery area at a kraft pulp
mill is shown in Figure F-1. The purpose of the chemical recovery process
at kraft and soda pulp mills is to recover cooking liquor chemicals from the
black liquor. The process involves concentrating weak black liquor.
combusting organic compounds, reducing inorganic compounds, and
reconstituting the cooking liquor.
Weak black liquor is a dilute solution (approximately 12 to 15 percent
solids) of wood lignins. organic materials, oxidized inorganic compound."
(sodium sulfate [Na2SO4]. Na:CO3), and white liquor (Na2S and NaOH). It.
the kraft and soda chemical recovery process, weak black liquor :- f;re-
directed through a series of multiple-effect evaporators (MEEO t; ncreasc
the solids content to about 50 percent.
In the kraft chemical recovery process, the "strong" (or "hea\ >" • Ma,.V lau: -
from the MEE system is either oxidized in the black liquor o^ idatmr (Bl_r
system if it is further concentrated in a direct contact evaporator : DCE <-
.routed directly to a nondirect contact evaporator (NDCE). also called a
concentrator. Oxidation of the black liquor prior to evaporation in a DCE
reduces emissions of total reduced sulfur (TRS) compounds, which an
stripped from the black liquor in the DCE when it contacts hot flue gases
from the recovery furnace. The solids content of the black liquor follow^
the final evaporator/concentrator typically averages 65 to 68 perren'. The
soda chemical recovery process is similar to the kraft process, except that tlic
soda process does not require BLO systems, since it is a nonsulfur process
that does not result in TRS emissions.
2-2
-------
The concentrated black liquor is sprayed into the recovery furnace, where
organic compounds are combusted, and the Na2SO4 is reduced to Na2S. The
black liquor burned in the recovery furnace has a high energy content (5,800
to 6,600 British thermal units per pound [Btu/lb] of dry solids), which is
recovered as steam for process requirements, such as cooking wood chips,
heating and evaporating black liquor, preheating combustion air, and drying
the pulp or paper products. Paniculate matter (primarily Na2SO4) exiting the
furnace with the hot flue gases is collected in an electrostatic precipitator
(ESP) and added to the black liquor to be fired in the recovery furnace.
Additional makeup Na2SO4, or "saltcake," may also be added to the black
liquor prior to firing.
Molten inorganic salts, referred to as "smelt," collect in a char bed at the
bottom of the furnace. Smelt is drawn off and dissolved in weak wash water
in the smelt dissolving tank (SDT) to form a solution of carbonate salts called
"green liquor," which is primarily Na2S and Na2CO3. Green liquor also
contains insoluble unburned carbon and inorganic impurities, called dregs,
which are removed in a series of clarification tanks.
Decanted green liquor is transferred to the causticizing area, where the
Na:CO3 is converted to NaOH by the addition of lime (calcium oxide
[CaO]'). The green liquor is first transferred to a slaker tank, where CaO
from the lime kiln reacts with water to form calcium hydroxide (Ca(OH)2).
From the slaker, liquor flows through a series of agitated tanks, referred to as
causticizers. that allow the causticizing reaction to go to completion (i.e.,
Ca(OH;: reacts with Na2CO~, to form NaOH and calcium carbonate
[CaCO.j).
The causticizing product is then routed to the white liquor clarifier. which
rerncnes CaCO3 precipitate, referred to as "lime mud." The lime mud is
\\ a^ned in the mud washer to remo\ e the last traces of sodium. The mud
from the mud washer is then dried and calcined in a lime kiln to produce
"reburned" lime, which is reintroduced to the slaker. The mud washer
filtra*-. known as weak wash, is used in the SDT to dissolve recover}'
furnace smelt. The white liquor (NaOH and Na2S) from the clarifier is
recycled to the digesters in the pulping area of the mill.
At the 11 percent of kraft mills where NSSC pulping is also practiced, the
NSSC and kraft processes often overlap in the chemical recovery process,
when the spent NSSC liquor, referred to as "pink liquor," is mixed with kraft
black liquor and burned in the recovery furnace. In such cases, the NSSC
chemicals replace most or all of the makeup chemicals. For Federal •
regulatory purposes, if the weight percentage of pink liquor solids exceeds
7 percent of the total mixture of solids fired and the sulfidity of the resultant
green liquor exceeds 28 percent, the recovery furnace is classified as a
"cross-recovery furnace."
2-3
Chapter 2 - Background
-------
What are the kraft and soda chemical recovery equipment?
This section focuses on the four pieces of equipment considered the primary
emission sources in the chemical recovery area. The equipment discussed in
this section include the recovery furnace, SDT, BLO system (kraft process
only), and lime kiln. These equipment are illustrated in Figures F-2 through
F-6. Air emissions from these equipment are expected to be similar for both
the kraft and soda processes, with the exception of TRS emissions. Because
the soda process does not use sulfur-containing compounds, no TRS
emissions are generated by soda mills.
Recovery furnace. The purpose of the kraft recovery furnace is to
(1) recover inorganic pulping chemicals (e.g., Na2S) and (2) produce steam.
Inputs to the furnace include concentrated black liquor, combustion air, and
auxiliary fuel (usually, auxiliary fuel is only used during shutdown or
startup). Outputs include molten smelt (primarily Na2S and Na2CO3), flue
gases, and steam. The smelt exits from the bottom of the furnace into an SDT,
where the recovery of cooking chemicals continues. Particulate matter
(primarily Na2SO4 and Na2CO3) entrained in the flue gases is also recovered
using an ESP and subsequently added to the concentrated black liquor. Steam
produced by the recovery furnace is used in other processes around the mill.
Prior to being fired in the recovery furnace, the black liquor is concentrated
using an NDCE or DCE. Figures F-2 and F-3 show the equipment
associated with NDCE and DCE recovery furnaces, respectively. The
NDCE is an indirect, steam-heated black liquor concentrator. Black liquor
typically enters the NDCE at a solids concentration of 50 percent and exits at
a concentration of 68 percent or higher. The DCE uses the hot combustion
gases exiting the furnace to increase the solids content of the black liquor
from about 50 percent to 65 percent.
Direct contact evaporators may be of the cascade or cyclone design The
cascade evaporator consists of a rotating assembly of tubes thai are
alternately submerged in black liquor and exposed to hot flue gases A
cyclone evaporator is a cylindrical vessel with a conical bottom Black
liquor is sprayed into the side of the evaporator, where it contacts the hot
combustion gases that are introduced tangentially, creating a "cyclone" effect.
The flue gases exit from the top of the evaporator, and the concentrated black
liquor drains down to and exits from the bottom of the evaporator.
To minimize the stripping of TRS compounds when the hot flue gases contact
the black liquor in the DCE, most DCEs are preceded by BLO systems,
which stabilize the sulfur compounds in the black liquor. Black liquor that is
concentrated in NDCEs does not contact the hot flue gases, and. therefore.
does not require oxidation. Because the NDCE recovery furnace typically
has lower TRS emissions than does the DCE recovery furnace, the NDCE
2-4
-------
recovery furnace is also referred to as the "low-odor" design. Since .the
1970s, most new recovery furnaces have been designed with NDCEs. An
estimated 60 percent of recovery furnaces currently in operation are NDCE
furnaces, and 40 percent are DCE furnaces.
Regardless of how the black liquor is concentrated, the chemical reactions
that take place inside an NDCE- or DCE-type furnace are the same. The
concentrated black liquor is sprayed into the furnace through fixed or
oscillating nozzles or "guns" mounted at openings in the furnace walls.
Depending upon the design and operation of the recovery furnace, the sprayed
black liquor may hit the opposing wall, where it dries and bums before
falling to the hearth, or may fall short of the opposing wall and dry and burn
in suspension. Combustion air is generally supplied to the furnace at three
levels, with two levels located below the black liquor nozzles and one
above. Some furnaces may have only two combustion air levels (i.e., one
above and one below the liquor nozzles).
The inorganic chemicals in the black liquor are recovered in three distinct
zones inside the recovery furnace: (1) the drying zone, (2) the reducing zone,
and (3) the oxidizing zone.
The dr>ing zone is the area of the furnace extending from the black liquor
spray to just above the molten smelt at the bottom of the furnace. The
purpose of the drying zone is to evaporate the water from the liquor droplets.
The reducing zone is just below the drying zone and includes the char bed.
The reduction of Na:SO4 to Na:S takes place in the reducing zone.
Volatile gases that are released in the drying and reducing zones of the
furnace travel to the highly turbulent upper section of the furnace, referred to
as the oxidizing zone, where the gases are combusted. The heat generated
from the combustion of these gases is then used to generate steam as the
combustion gases are drawn through the heat exchanger section of the furnace
(i.e.. superheater, boiler bank, and economizer).
For NDCE recovery furnaces, the design economizer exit gas temperature
ranges from 177C to 190°C(350C to375°F). For DCE recovery furnaces,
the heat from the recovery furnace is used to evaporate the black liquor.
Thus, the required economizer exit gas temperature for DCE recovery
furnaces, 370° to 430CC (700° to 800°F), is much higher than that for NDCE
recover)- furnaces. Because a large portion of the combustion heat from DCE
2-5
Chapter 2 - Background
-------
recovery furnaces is required for black liquor evaporation, less combustion
heat is available to produce steam.
Flue gases exiting the economizer are routed either directly to an add-on PM
control device (i.e., for NDCE recovery furnaces) or to a DCE followed by
an add-on PM control device (i.e., for DCE recovery furnaces). The
recovered PM (primarily Na2SO4 [saltcake] and Na2CO3) is subsequently
added to the concentrated black liquor, and the cleaned flue gas exits through
the stack. Approximately 95 percent of the Na2SO4 is recovered; additional
makeup saltcake is added to the concentrated black liquor as needed.
The inorganic chemical in the black liquor, Na2SO4, is reduced to Na2S, a
cooking liquor chemical, in the reducing zone (lower section) of the furnace.
The Na2S and other inorganic chemicals, predominantly Na2CO3, drain as
molten smelt from the furnace bottom to the SDT, where reprocessing into
cooking liquor continues.
Smelt dissolving tank. Molten smelt is one of the main products from the
combustion of biack liquor. Smelt, which is predominantly Na2S and
Na2CO3, is formed in the bottom of the furnace. Smelt, at approximately
1900° to, 2100 °F, filters through the char bed and is continuously discharged
through water-cooled smelt spouts into the SDT. In the SDT, smelt is mixed
with weak wash water from the recausticizing area to form green liquor, an
aqueous solution of Na2CO3 and Na2S in about a three-to-one ratio. The
green liquor is subsequently transferred to the recausticizing area for
reprocessing into cooking liquor (i.e., white liquor). A diagram of an SDT
with a wet scrubber is provided in Figure F-4.
The SDT is a large, covered vessel located below the recover)' furnace.
Green liquor is maintained in the tank at a level of about half the depth of the
tank. As the smelt exits the water-cooled smelt spouts and falls several feet
into the SDT, it is shattered by high-pressure steam or shatter sprays of
recirculated green liquor. The steam or shatter sprays break the smelt flow
into small droplets and cool the smelt before it falls into and reacts with the
liquid in the SDT to form green liquor. Large volumes of steam arc
generated when the molten smelt and liquid mix. The vapor space above the
liquid level provides an opportunity for water vapor and PM resulting from
the quenching of smelt to settle out of suspension into the green liquor. An
induced-draft fan constantly draws the vapor and entrained PM through an
add-on PM control device, generally a wet scrubber. Scrubber water is
sprayed into the scrubber and allowed to drain directly into the SDT, where
it reacts with smelt to form green liquor.
The SDT is constantly agitated to prevent formation of hot spots on the
surface of the liquor and to keep solids from accumulating in the bottom of
2-6
-------
The BLO system stabilizes
the sulfur compounds in
the black liquor so thar
they are less likely to be
volatilized when the hot
gases from the rcco\ er\
furnace pass through the
DCE
the tank. Surface liquor hot spots can contribute to the formation of explosive
hydrogen gas from the dissociation of water reacting with the hot smelt.
Green liquor formed in the SDT is sent to the green liquor clarifier in the
causticizing area. Green liquor is converted to white liquor (i.e., NaOH and
Na2S) in the causticizing area.
Black liquor oxidation system. The BLO system reduces malodorous TRS
emissions from DCE recovery furnaces at kraft pulp mills. Total reduced
sulfur compounds (primarily hydrogen sulfide [H2S]) are stripped from black
liquor when hot flue gases from the recovery furnace contact the black liquor
in the DCE. Hydrogen sulfide is stripped by the reaction between residual
Na2S in the black liquor and carbon dioxide (CO2) and water (H2O) in the
recovery furnace flue gas, as follows:
Na2S
sodium
sulfide
CO, + H,O -•
Na2CO3 + H2S
sodium hydrogen
carbonate sulfide
The BLO system minimizes the. stripping of TRS compounds in the DCE by
stabilizing the sulfur compounds in the black liquor prior to evaporation in
the DCE. The main reaction that takes place in the BLO system is the
oxidation of Na2S to nonvolatile sodium thiosulfate (Na2S:O3), as follows:
2Na;S
sodium
sulfide
20: + H20 --
Na:S2O?
sodium
thiosulfate
2NaOH
sodium
hydroxide
The oxidation efficiency of the BLO process is measured by the percent
con\ersion of Na:S to Na;S:O5 in the black liquor on a pound per gallon
(Ib'gal ) basis. Oxidation efficiencies greater than 99 percent are common.
Sulfid:.;\ levels of the black liquor entering the DCE are targeted to less than
0 002 Ib/gal in order to meet TRS emission limits for DCE recover)'
furnaces. Oxidizing black liquor results in a slight increase (2 to 3 percent)
in the solids content of the black liquor and reduces its heating value by 2 to
5 percent.
The BLO system is typically located after the MEE system, a process
referred to as "strong" black liquor oxidation. A small number of mills
oxidize black liquor prior to evaporation in the MEE system, which is
referred to as "weak" black liquor oxidation. Other options are to oxidize
both weak and strong black liquor or to oxidize the black liquor between
effects of the MEE system. With weak BLO systems, the effects of partial
reversing of the oxidation reaction (i.e., oxidized sulfur compounds reducing
to H2S) that occurs in the MEE system can be minimized by adding a second
oxidation step, such as oxygen (O2) polishing of strong black liquor.
2-7
Chapter 2 - Background
-------
Black liquor can be oxidized using either air or pure (molecular) O2.
Because of economic considerations, the majority of BLO systems use air as
the oxidant. Air BLO systems have higher capital costs than O2 systems, but
their operating costs are usually much lower.
Air-sparging systems are the predominant type of BLO equipment used at
kraft pulp mills. Figure F-5 shows a diagram of an air-sparging BLO
system. Air-sparging systems operate by bubbling air, which is sometimes
preheated, through the black liquor using multiple diffuser nozzles. Air
systems require residence times of several hours or more to obtain high
oxidation efficiencies. Because of this relatively long residence time, large
oxidation tanks—on the order of 30 feet (ft) in diameter and 40 ft high must
be used. Air-sparging systems have one to three tanks (or stages) that operate
in series. Air-sparging systems are equipped with mechanical foam breakers
for foam control; chemical defoamers (e.g., diesel oil, turpentine, and
kerosene) may also be used. Each oxidation tank is vented. Gases exiting the
BLO system flow through cyclone separators to have entrained water
droplets removed prior to being vented to the atmosphere. Add-on air
pollution control devices (APCDs) typically are not used with air oxidation
systems.
Oxygen BLO systems require only 30 seconds (sec) to 5 minutes (min)
residence time, which enables the use of in-line reactors. Since all the gas
(i.e.. pure O2) added to the system is consumed in the oxidation reaction, a
system vent is not needed.
Oxygen polishing is sometimes used as a supplement to air oxidation systems
to address (1) stricter TRS standards, (2) an overloaded BLO system
resulting from production increases, or (3) peaks in TRS emissions resulting
from process upsets or temporary production increases. In-line O: polishing
systems are used to oxidize strong liquor and may follow either a weak
liquor air system or a strong liquor air system.
Emissions from most air-based BLO systems (95 percent) are uncontrolled.
Based on available information. TRS emissions from 5 percent of air-based
BLO systems (two systems) are currently controlled by using a condenser or
mist eliminator to remove the water vapor and then venting the gas stream to
a power boiler for incineration. Molecular O2 systems do not require system
vents and, thus, have no emissions directly associated with the BLO system.
Lime kiln. The lime kiln is part of the causticizing process, in which green
liquor from the SDT is converted to white liquor. The function of the lime
kiln is to oxidize lime mud (CaCO3) to reburned lime (CaO), a process
known as calcining:
2-8
-------
Lime kiln:
CaCO3 + heat — »• CaO + CO2
lime mud/ lime/
calcium calcium
carbonate oxide
The CaO produced in the lime kiln is used in the causticizing reactions that
take place in the green liquor slaker and causticizers to produce the NaOH
used in the white liquor. The reactions are as follows:
Slaker:
CaO +
lime/
calcium
oxide
HO -
Ca(OH)2
calcium
hydroxide
CaustJcizer:
Ca(OH)2 + Na2CO3
calcium sodium
hydroxide carbonate
NaOH + CaCO3
sodium lime mud/
hydroxide calcium
carbonate
The lime kiln typically produces about 95 percent of the lime needed for the
causticizing reaction. Either make-up lime or limestone is purchased to
account for losses.
Prior to calcining, lime mud from the causticizing tanks is washed and
dev. atered. Lime mud washers reduce the sodium and sulfide content of the
hrne mud, which lowers TRS emissions from the lime kiln. The lime mud is
typical]} dewatered to about 70 percent solids using a rotary vacuum precoat
drum filter. (Newer precoat filters can achieve 75 to 85 percent solids.) The
precoat drum filter is partially submerged in the lime mud slurry; as it rotates,
a \ acuum draws air through the filter (screen), and a small layer of lime mud
deposits on the surface of the screen. The lime mud solids deposited on the
screer are then removed with a fixed blade. In addition to dewatering the
lime mud. the precoat filter also helps reduce TRS emissions by oxidizing
any remaining Na2S to Na;S2O3 using air that is pulled through the filter. The
precoat filter is backwashed periodically to prevent crusting of the lime on
the screens, which inhibits air passage.
Rotary lime kilns, as shown in Figure F-6, are typically used at kraft pulp
mills. In a rotary lime kiln, lime mud from the precoat filter is introduced at
the feed end (cold end) and flows downward towards the discharge end. (hot
end). Natural gas or fuel oil are the fuels typically used to fire the kiln.
2-9
Chapter 2 - Background
-------
Primary combustion air is introduced through a concentric tube around the
fuel pipe, and preheated secondary combustion air is introduced through the
bottom of the firing hood.
The majority of lime kilns at kraft pulp mills (66 percent) also burn
noncondensible gases (NCGs) from various process vents, such as digester
and evaporator vents. The NCG streams may be introduced into the kiln
through a dedicated nozzle or combined and fed with either primary or
secondary air. The components of the NCG stream include TRS compounds,
turpentine, methanol, acetone, alpha-pinene, water vapor, nitrogen, and O2.
To avoid excessive sulfur dioxide (SO2) formation in the lime kiln, the NCG
gas stream may be scrubbed prior to incineration to remove TRS compounds.
Packed columns with white liquor as the scrubbing fluid are commonly used.
The TRS removal efficiency is typically about 70 percent.
Rotary lime kilns have three internal zones: (1) the drying zone, (2) the
heating zone, and (3) the calcining zone.
In the drying zone, water is evaporated from the lime mud as it passes through
metal chains that are suspended from the kiln shell in a curtain or garland
arrangement. The lime mud is dried to about 95 percent or greater solids as
it passes through the chains, which are heated by the hot flue gases that flow
countercurrent to the lime mud. In addition to providing additional heat
transfer area for drying the lime mud, the chains also help reduce the amount
of lime dust exiting with flue gases.
In the heating zone, other heat transfer devices, such as tumblers and lifters.
are used to heat the dried mud uniformly in preparation for calcining.
In the calcining zone, the calcining reaction requires a minimum temperature
of 1500CF; temperatures greater than about 2100°F can cause everburning.
which leads to a less-reactive lime product. Ideally, calcination produces
lime pellets that are about 0.75 inches (in.) in diameter; however, if the lime
mud is improperly dried and heated, large lime balls may be produced The
hot lime product is cooled by incoming secondary air as it passes under the
burner towards the discharge end of the kiln. Newer kilns use integral tube-
coolers to preheat secondary combustion air while cooling the discharged
lime pellets. In this heat exchange process, the air is heated to about 600°F
and the lime is cooled to about 375 °F. The reburned lime product from the
integral tube coolers, or from the kiln discharge hoppers in the absence of
coolers, is transported to the lime storage bin and subsequently introduced
into the green liquor slaker.
Combustion gases exit the lime mud feed end of the kiln at temperatures of
approximately 300° to 400°F. The exhaust gases consist of combustion
products, TRS, CO2 released during calcination, water vapor evaporated
2-10
-------
from the mud, and entrained lime dust. Particulate matter in the exhaust gas is
mainly sodium salts, CaCO3 (lime mud), and CaO (lime).
Add-on PM control devices are required to meet Federal and State PM
standards. Venturi scrubbers are the most commonly used control device,
and water is typically used as the scrubbing fluid. The exhaust stream may be
scrubbed with a caustic solution with the added benefit of lowering TRS and
SO2 emissions. However, Federal and State TRS standards can be met
through good lime mud washing practices, which reduces the sulfide content
of the lime mud feed. If a wet scrubber is used, a cyclone separator may be
installed upstream. The dust collected by the separator is returned directly to
the lime kiln. In recent years, the use of ESPs has been more prevalent. The
ESP is generally mounted on top of the lime kiln feed building, and the
captured dry PM is rerouted to the kiln by gravity feed.
Rotary lime kilns are the most commonly used type of lime kiln at kraft and
soda pulp mills, accounting for about 98 percent of the kilns. Fluidized-bed
calciners are also used by the kraft pulp industry (2 percent).
What are the APCDs and equipment modifications?
This section describes the predominant APCDs and equipment modifications •
applied to sources in the chemical recovery areas at kraft and soda pulp
mills. The predominant APCDs include ESP and venturi scrubbers. The
equipment modifications include wet to dry ESP system conversions and
DCE to NDCE recover)' furnace system conversions.
Electrostatic precipitator. Electrostatic precipitators are a demonstrated
control technique for reducing PM emissions from kraft recovery furnaces
and lime kilns. The PM emitted from the recovery furnace is primarily
composed of Na:SO4 (saltcake) and Na:CO?. and the PM emitted from the
lime kiln is primarily composed of sodium salts, CaCO, (lime mud) and CaO
dime). While none of these compounds are HAPs. HAP metals are also
emitted in small quantities from the recovery furnace and lime kiln.
Electrostatic precipitators can control HAP metal emissions but provide no
control of gaseous HAP emissions. Properly designed and operated ESPs
used on kraft recovery furnaces and lime kilns routinely achieve PM removal
efficiencies of 99 percent or greater.
The ESPs used to control PM emissions from kraft recovery furnaces and
lime kilns are generally classified as plate-wire ESPs. In plate-wire ESPs,
the flue gas flows between parallel sheet metal plates and high-voltage
electrodes. The flue gas passes between collecting plates into a field of ions
that have been negatively charged by the high-voltage electrodes located
2-11 Chapter 2 - Background
-------
A dry ESP system refers to
an ESP with a dry bottom
(i.e., no black liquor,
water, or other fluid is
used in the ESP bottom)
and a dry paniculate
return system (i.e., no
black liquor, water, or
other fluid is used to
transport the collected PM
to the mix tank).
between the plates. Each paired set of electrodes and plates forms a separate
electrostatic field within the ESP.
Electrostatic precipitators used to control PM emissions from kraft recovery
furnaces typically have two parallel precipitator chambers (i.e., flue gas
passages) with three or four electrostatic fields per chamber. Lime kiln ESPs
typically have one chamber with two or three electrostatic fields.
As the flue gas passes through each electrostatic field, the particles
suspended in the flue gas are bombarded by the ions, imparting a negative
charge to the particles. The negatively charged particles then migrate
towards the positively charged or grounded "collecting" plates, where the
particles transfer a portion of their charge, depending upon their resistivity.
The particles are kept on the collecting plates by the electrostatic field and
the remaining charge. At periodic intervals, the collection plates are knocked
("rapped"), and the accumulated PM falls into the bottom of the ESP. The
recovered PM is subsequently recycled to the black liquor in recovery
furnace applications or, in lime kiln applications, fed back to the kiln.
The ESPs used on recovery furnaces may be designed with either a wet or
dry bottom. In wet-bottom ESPs, the collected PM falls directly into a pool
of liquid, which may be black liquor or water, in the bottom of the ESP. In
dry-bottom ESPs, the collected PM falls to the (dry) bottom of the ESP and is
transferred from the ESP bottom to a mix tank (containing black liquor) via
drag-chain or screw conveyors. Black liquor is sometimes used to transport
the dry collected PM to the mix tank. More recent ESP installations employ a
dry PM return system to transport the PM to the mix tank. Because the PM
removed by the ESP is recycled to the black liquor in the mix tank, the ESP is
an integral part of the chemical recovery loop as well as an APCD.
The design of the plate-wire ESP used to control PM emissions from
recover}' furnaces and lime kilns may include either weighted-wire
electrodes or rigid electrodes. With the weighted-wire design, the wire
electrodes are suspended inside the ESP, and weights are attached to the
wires to maintain tension. In the rigid-electrode design, the discharge
electrodes are rigid tubes with pointed corona emitters welded to the surface.
each tube replaces two weighted wires. Although the weighted-wire design
has been available for more than 50 years, rigid-electrode ESPs have only
been available since the late 1970s.
The rigid-electrode ESP represents the current stage of development in ESP
technology and offers the following advantages over the weighted-wire
design: a higher tolerance of in-service abuse (no wires to break), better
collection efficiencies, and better cleaning characteristics. Figure F-7 is a
diagram of a typical rigid-electrode, plate-wire ESP.
2-12
-------
TJie use of ESPs as
paniculate control devices
on lime kilns has steadily
increased in recent years
as mill managers have
chosen to equip new lime
kilns with ESPs and
replace some older venturi
scrubbers on existing lime
kilns with ESPs.
The size of the ESP is often expressed in terms of the specific collecting area
(SCA), which is defined as the total collecting plate surface area divided by
the flue gas flow rate. Specific collecting areas of the ESPs used to control
PM emissions from kraft recovery furnaces and lime kilns typically range
from about 200 to 800 square feet per 1,000 actual cubic feet per minute
(ft2/l,000acfm).
The SCAs of ESP used to control emissions from DCE recovery furnaces
tend to be somewhat lower than those associated with NDCE recovery
furnaces. The average SCA for ESP used to control emissions from DCE
recovery furnaces is approximately 15 percent lower than for NDCE
recovery furnaces. The primary reason for the difference is that the DCE
removes 20 to 40 percent of the PM before the ESP; therefore, the inlet
loading of PM to the ESP operating on a DCE recovery furnace is lower than
that of an NDCE recovery furnace. The lower SCAs for DCE recover}'
furnaces may also be because DCE recovery furnaces tend to be older than
NDCE recovery furnaces, and most are not subject to the New Source
Performance Standards (NSPS) for Kraft Pulp Mills.
The average lifetime of an ESP. in service on a kraft recovery furnace varies '..
depending upon the type of ESP bottom (i.e., wet vs. dry), the inlet
temperature of the gases, and maintenance practices. The lifetime of ESPs
used to control PM emissions from recovery furnaces with NDCEs, which
tend to operate with dry-bottom ESPs. typically ranges from 12 to 15 years.
After that point, major repairs or a rebuild may be required. Recovery
furnaces with DCEs tend to have cooler inlet gases and wet-bottom ESPs;
these two factors promote corrosion through condensation of acid gases and
shorten the life of the ESP. The lifetime of an ESP on a DCE recovery
furnace typically ranges from 7 to 10 years.
Lime kiln ESPs operate in a "milder" environment (i.e.. hotter temperatures
pre\ ent any acid gases from condensing and corroding the ESP, and the
pnmar> conrtituent of the PM collected is lime, which creates an alkaline
en\irunment that further protects the ESP from acid gas corrosion).
Therefore, lime kiln ESPs have fewer corrosion problems than do recover}'
furnace ESPs. The expected lifetime of a lime kiln ESP is typically more
than 15 years.
Although venturi scrubbers have traditionally been the most common add-on
PM control device used on kraft lime kilns, the use of ESPs to control PM
emissions from lime kilns has steadily increased since about 1980. The trend
towards ESPs as add-on PM control devices at new lime kiln installations
and as replacement control devices for older scrubbers is primarily related
to the lower energy costs, reduced maintenance, and increased reliability of
the ESPs in comparison to venturi scrubbers that provide equivalent control.
An added benefit is that lime kiln ESPs produce a dry product that can be
2-13
Chapter 2 - Background
-------
recycled directly to the kiln, whereas the wastewater produced by the venturi
scrubber is typically recycled to the mud washers before the kiln to recover
the lime paniculate in the spent scrubbing fluid. Additional energy is needed
to remove the excess water in the lime mud filter and to complete
evaporation in the kiln. (Additional information about venturi scrubbers is
provided in the following section.)
Venturi scrubber. Venturi scrubbers are a demonstrated control technique
for reducing PM emissions from lime kilns and SDTs. Venturi scrubbers are
also used on several recovery furnaces in combination with an ESP.
In addition to venturi scrubbers, the pulp and paper industry uses other types
of wet scrubbers, such as impingement plate, cyclone, flooded disc, and
packed-bed, to control PM emissions from lime kilns and SDTs. However,
venturi scrubbers are the most prevalent type of wet scrubber used to control
PM from these sources, and the other scrubber types do not control PM
emissions more effectively than venturi scrubbers.
Venturi scrubbers are designed to remove PM primarily by impaction through
high-energy contact between the scrubbing liquid and suspended PM in the
gas stream. A diagram of a typical venturi scrubbing system is shown in
Figure F-8. A venturi scrubbing system typically consists of a venturi
scrubbing vessel and cyclonic separator. The venturi scrubbing vessel has
three sections: (1) a converging section, (2) a throat section, and (3) a
diverging section.
The exhaust gas enters the converging section and, as the cross-sectional area
of the scrubber vessel decreases, gas velocity increases. Scrubbing liquid is
introduced either at the entrance to the converging section or at the throat.
The exhaust gas, which is pulled through the venturi vessel by the system's ID
fan and forced to move at extremely high velocities in the throat, shears the
scrubbing liquid from the walls, atomizing the liquid.
Paniculate matter and gaseous pollutants are transferred from the gas stream
to the liquid droplets via impaction and diffusive mass transfer in the throat
section as the exhaust stream turbulently mixes with the atomized scrubbing
liquid. The throat section may be constructed so that the size of the thioat
opening is adjustable. With an adjustable-throat (or variable-throat) venturi.
the gas velocity across the throat can be maintained at a constant speed as the
gas flow rate changes, thereby maintaining the desired PM collection
efficiency.
From the throat section, the exhaust stream passes through the diverging
section of the venturi scrubbing vessel, where the velocity decreases.
Diffusion, which is an effective collection mechanism for fine particles and
also the primary mechanism of gaseous pollutants transfer, usually occurs in
2-14
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the diverging section, where the velocities of the gas stream and liquid
droplets are almost equal. Collection of fine particles by the liquid droplets
is possible because the path of fine particles is influenced primarily by
Brownian motion rather than by the path of the gas stream. (Brownian motion
is the random displacement of gas molecules due to currents and eddies in the
atmosphere.)
An entrainment separator, typically a cyclonic separator, is needed to collect
the PM entrained in the droplets because the high velocity of the exhaust
stream from the venturi scrubbing vessel would have a tendency to exhaust
the droplets.
The performance of the venturi scrubber in terms of PM collection is strongly
affected by the pressure drop across the scrubber throat, the liquid-to-gas
(L/G) ratio, and the particle size distribution. Paniculate matter collection
efficiency generally increases as the throat velocity and turbulence of the gas
stream increase, as indicated by an increased pressure drop across the
scrubber.
Typical venturi scrubber L/G ratios for PM control range from 3 to
10 gallons per 1,000 actual cubic feet (gal/kacf). While L/G ratios up to
20 gal/kacf can be used, increasing the L/G ratio beyond 10 gal/kacf usually
does not significantly improve PM collection efficiency. However, venturi
scrubbers with L/G ratios ranging from 20 to 40 gal/kacf are used where
absorption of gaseous pollutants in addition to PM control is desired.
Liquid-to-gas ratios below 3 gal/kacf are usually not sufficient to cover the
throat section.
For lime kiln applications, PM collection efficiencies for venturi scrubbers
a\ erage 99 percent, based on data reported for four lime kiln scrubbers.
Van able-throat venturi scrubbers with pressure drops that range from 10 to
30 in. H:O and average 20 in. H2O are typically used for controlling PM
emissions from lime kilns. Typical L/G ratios are between 10 and
20 ga1 'kacf. Water is the typical scrubbing fluid for lime kilns, but caustic
and \\eak wash are also used. The scrubbing fluid is recirculated, and the
scrubber blowdown is recycled to the lime mud washer.
For SDT applications, reported PM removal efficiencies for venturi
scrubbers range from 97 to greater than 99 percent. The average pressure
drop for SDT venturi scrubbers is 8 in. H2O. Liquid-to-gas ratios range from
8 to 10 gal/kacf. Weak wash (from the lime mud washer) is the scrubbing
fluid for the majority of SDT venturi scrubbers.
Wet to dry ESP system conversion. When hot recovery furnace flue gases
come in contact with ESP control systems, gaseous organic HAPs (primarily
methanol) may be stripped from any black liquor or contaminated process
2-15
Chapter 2 - Background
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water present in the ESP system and emitted to the atmosphere. Electrostatic
precipitator control systems include the ESP plus the PM return system
associated with the ESP. One method of controlling gaseous organic HAP
emissions from ESP systems is to prevent their generation by eliminating the
black liquor or HAP-contaminated process water from the system.
Since the 1980s, the industry trend has been toward the use of dry-bottom
ESPs (i.e., no black liquor or water is used in the bottom of the ESP, which
eliminates the ESP bottom as a source of gaseous HAP emissions).
However, the older design dry-bottom ESP control systems sometimes use
black liquor in the PM return system to sluice and transport the PM captured
in the dry-bottom ESP back to the saltcake mix tank. As a result, gaseous
organic HAPs may be stripped from the black liquor as the hot recovery
furnace flue gases are pulled through the ESP by the induced draft fan. The
gaseous organic HAP emissions could be controlled by converting to a dry
PM return system. Dry PM return systems eliminate the use of black liquor in
the PM return system, so that the captured PM does not contact any black
liquor until it reaches the mix tank. These newer PM return systems also are
equipped with rotary valves (through which the dry captured PM passes) that
provide an air lock between the ESP and the remainder of the PM return
system and the mix tank (which contains black liquor).
Based on the available emission test data, eliminating the black liquor from
the ESP control system reduces total gaseous organic HAP emissions b\
approximately 72 percent. Methancl emission reductions account for mob,: cf
the estimated HAP emission reduction. In addition to their lower HAP
emission potential, NDCE recovery furnaces with dry-bottom ESPs and dr\
PM return also have lower TRS emissions than NDCE recover}' furnace?
\\ith black liquor in the ESP control system.
DCE to NDCE furnace conversion. The conversion from a DCE reco\er.
furnace system to an NDCE recovery furnace system (often referred to a^ &
"lov. -odor conversion") offers significant emission reduction and operation;-.
benefits.
As shown in Figures F-9 and F-10, DCE recovery furnace systems ha\ •;
more gaseous organic HAP emission points than NDCE recovery furnace
systems. (The HAP emission points are shaded in the figures.) By
eliminating two of these emission points, the DCE and BLO system, a DCE to
NDCE furnace conversion is an effective measure for reducing HAP
emissions from the recovery furnace system. Gaseous organic HAPs such as
methanol can be stripped off in the DCE and wet-bottom ESP b\ contaj;
between the hot flue gases and the black liquor. The BLO vents are also an
emission source for methanol and other gaseous organic HAPs because
gaseous organic HAPs can be stripped from the black liquor and vented as
the oxidizing air is forced up through the black liquor. The wet-bottom ESP
2-16
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commonly associated with DCE recovery furnaces can be converted to a dry-
bottom ESP with a dry PM return system, thereby eliminating the ESP system
as another emission source for methanol and other gaseous organic HAPs.
The conversion from a DCE recovery furnace system to an NDCE recovery
furnace system results in substantial reductions for all of the gaseous organic
HAP compounds. Based on the available emission test data, the conversion
from a DCE recovery furnace system to an NDCE recovery furnace system
reduces total gaseous organic HAP emissions by approximately 93 percent.
Methanol emissions reductions account for most of the estimated gaseous
organic HAP emission reduction. In addition to a lower HAP emission
potential, NDCE recovery furnaces have lower TRS emissions.
Conversion from a DCE recovery furnace system to an NDCE recovery
furnace system is a common modification; an estimated 24 percent of existing
NDCE recovery furnaces were originally installed as DCE recovery
furnaces. These conversions have been performed for several reasons,
including compliance with Federal and State TRS emission standards and
increased energy efficiency. Other factors influencing the decision to convert
a DCE recovery furnace to an NDCE design include the age of the existing
DCE recover)7 furnace system, the condition of the system, the cost of the
con\ersion. and whether additional capacity is needed at the mill.
The major modifications involved in converting a DCE recovery furnace
SNStem to an NDCE recovery furnace system are (1) replacing the DCE with
a concentrator and associated equipment. (2) extending or replacing the
economizer, (3) rebuilding or replacing the ESP, and (4) removing the BLO
system. Removal of the DCE is the driving force behind the latter three
major modifications.
The DCE is replaced with a concentrator, which can achieve the desired
black liquor solids content without direct contact between recovery furnace
exhaust gases and black liquor. Eliminating contact between the hot exhaust
gases and black liquor is desirable because the emissions that result from
stripping are also eliminated. Operational benefits of replacing the DCE
with a low-pressure, steam-driven concentrator include the higher solids
content achievable, improved energy utilization, and reduced energy costs.
The concentrator, which may be one of several types, including falling film
and forced circulation, is installed as part of the evaporator plant.
The economizer is modified to recover additional heat from the flue gas that
has become available with removal of the DCE. The additional heat
recovered in the economizer can be used to produce more low-cost, high-
pressure steam. Direct contact evaporator recovery furnaces typically
operate at thermal efficiencies of 53 to 58 percent, whereas NDCE recovery
furnaces typically operate at thermal efficiencies of 63 to 68 percent.
2-17 Chapter 2 - Background
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Auxiliary equipment that is required when expanding an economizer includes
additional soot blowers, hoppers, and conveyors, which collect and transport
the additional ash from the economizer.
The ESP is modified to handle the greater PM loading that results from the
removal of the DCE. The DCE acts as a PM control device, collecting 20 to
40 percent of PM emissions from the recovery furnace. Thus, removal of the
DCE, without upgrading the ESP, would likely result in increased PM
emissions from the recovery furnace stack. Because of the increased PM
emissions and a possible change in gas flow rate, the ESP may need to be-
either upgraded or replaced.
With the removal of the DCE, the BLO system is no longer needed; therefore.
the emissions associated with the air-sparging BLO systems are eliminated.
The operational benefits associated with removing an air-sparging BLO
system are the elimination of the high costs associated with operating this
system and the increased heating value of the black liquor.
2.2 What is the background information for sulfite pulp mills?
What is the U.S. population of sulfite pulp mills?
There are 10 sulfite pulp mills currently operating in 6 States. Over the
years, the number of sulfite mills has steadily declined; over 40 percent of
sulfite mills (7 mills) have shut down in the last 10 years. Of the 10 sulfite
mills currently operating, 8 mills have chemical recovery combustion
equipment to recover pulping chemicals, while the other 2 mills do not
recover pulping chemicals. These eight mills are discussed in the remamck ;
of this section. Appendix B lists the company names and locations for thf
eight mills.
What is the sulfite pulping process?
At the currently operating sulfite chemical pulp mills, an acid cooking ho<;.
is used to cook the wood chips. The sulfite pulping process currently used
U.S. mills can be classified as either acid sulfite or bisulfite. In the acid
sulfite process, the initial pH level of the cooking liquor is 1 to 2. In the
bisulfite process, the cooking liquor initial pH is 2 to 6. In addition to mitia1
pH level, sulfite cooking liquors are also classified by the chemical base. In
preparing sulfite cooking liquors, cooled SO2 gas is absorbed in water
containing one of four chemical bases—magnesium (Mg). ammonia (NH;
sodium (Na), or calcium (Ca). The following sections describe the cheimcv'
recovery processes at sulfite pulp mills.
2-18
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Flow diagrams for the
sulfite chemical recovery
process and associated
equipment can be found in •
Figures F-11 through F-16.
What is the sulfite chemical recovery process?
The function of the chemical recovery process at sulfite pulp mills is to
recover chemicals from spent sulfite cooking liquor (also called red liquor).
Sulfur dioxide in spent cooking liquor can be recovered for all four liquor
types (Mg, NH3, Na, and Ca). The bases Mg and Na can also be recovered.
However, it is not practical to recover Ca, and NH3 is destroyed when the
spent liquor is combusted.
Existing mills that use combustion equipment to recover cooking liquor
chemicals use either Mg- or NH3-based processes. At Ca-based sulfite
mills, by-products recovery (e.g., lignin chemicals and alcohol) is practiced,
but chemical recovery combustion equipment is not used. Additionally, there
are currently no Na-based sulfite mills operating in the United States.
There are five Mg-based sulfite mills and three NH3-based sulfite mills
currently operating, for a total of eight sulfite mills subject to the pulp and
paper combustion sources NESHAP. The system used to recover cooking
chemicals is particular to the base.
What is the Mg-based sulfite chemical recovery process?
Chemical recovery process. A simplified process flow diagram for Mg-
based sulfite mills is provided in Figure F-11. As shown in the figure, spent
liquor is burned in a recover}' furnace or fluidized-bed reactor. Combustion
of the spent liquor produces heat for steam generation and also exhaust gases
that contain magnesium oxide (MgC) paniculate and SO2 gas. If a recovery
furnace is used, the major portion of the MgO is recovered from the exhaust
gases as a fine white powder using multiple cyclones. If a fluidized bed
reacio; is used, MgO is collected in a cyclone and as pulverized bed
materic.]. The MgO is then slaked with water to form magnesium hydroxide
(Mg:OH):). which ic used as circulating liquid in a series of absorption
tov. ers and/or venturi scrubbers designed to recover SO: from the recovery
furnace exhaust gases.
Prior to passing through the absorption towers/venturi scrubbers, exit gases
fiom the MgO PM removal equipment enter a cooling tower. Cooling the
gases increases SO: absorption. In the absorption towers/venturi scrubbers,
SO; is recovered by reaction with Mg(OH)2 to form a magnesium bisulfite
solution. The magnesium bisulfite solution is then routed to a fortification
tower where it is fortified with makeup SO2 from a sulfur burner and
subsequently used as cooking liquor in a digester. The fortification tower
and sulfur burner area of the mill are typically referred to as the "acid plant."
However, the term acid plant is used loosely, and the acid plant may be
defined to include the SO2 absorption towers/venturi scrubbers. Some mills
have installed equipment downstream of the SO2 absorption equipment, such
2-19
Chapter 2 - Background
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as a fiber-bed mist elimination system or an educted venturi scrubber, to
further reduce PM and/or SO2 prior to discharge to the atmosphere.
Chemical recovery equipment. Three of the five Mg-based sulfite mills
operate recovery furnaces to recover MgO and SO2 from spent cooking
liquor and produce steam. A diagram of a Mg-based sulfite recovery furnace
is shown in Figure F-12.
As with kraft recovery furnaces, the furnaces may be a DCE furnace or an
NDCE furnace, depending upon the final evaporation equipment following
the MEE system. Alternatively, a mill may use neither a DCE nor NDCE. At
these mills, the desired red liquor solids content is achieved solely with the
MEE system. The magnesium-based sulfite recovery furnaces differ from
kraft and soda recovery furnaces in that there are no smelt beds. Red liquor is
fired at a solids content of between 52 and 60 percent.
Two of the six Mg-based sulfite mills operate fluidized-bed reactors. There
is one reactor at each of the two mills. Red liquor is fired at a solids content
of 50 percent in the first reactor and 45 percent in the second reactor. The
general features of a fluidized-bed reactor are shown in Figure F-13. A
diagram of a fluidized-bed reactor system for the Mg-based sulfite process is
shorn n in Figure F-14.
At these two mills, spent liquor is fed through the top of the reactor chamber.
Fluidizing gas at a carefully controlled flow rate passes up through the bed of
solid particles setting the bed in fluid motion. The fluidized bed resembles a
boiling liquid. The organic matter in the spent liquor is converted to carbon
dioxide and water, and the magnesium complexes formed during pulping are
decomposed to form MgO paniculate and SO2 gas. The MgO paniculate is
collected as pulverized bed material. Exhaust gases pass through a cyclone.
which collects MgO entrained in the exhaust gases, and then through a waste
heat boiler for steam production.
APCDs. All of the Mg-based sulfite mills have MgO paniculate remova1
equipment following the chemical recovery combustion device. With the
recover)' furnaces, multiple cyclones are used to remove the MgO particular.
from the recovery furnace flue gas. With the fluidized-bed reactors, MgO it
.collected in a cyclone and as pulverized bed material.
Of the four Mg-based sulfite mills for which information is available, all four
have installed SO2 recovery equipment downstream of the MgO recovery
system. The SO2 recovery equipment includes either absorption tower(s,»
and/or multiple-stage venturi scrubbers and uses Mg(OH)2, produced from
the recovered MgO, as the SO2 absorption fluid.
2-20
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Of the four Mg-based sulfite mills for which information is available, two
have installed an APCD downstream of the SO2 absorption equipment. At
one mill, an educted venturi scrubber provides additional control of air
pollutants. Gas streams from all three recovery furnaces operated at the mill
are routed to this scrubber. The second mill operates a packed-bed scrubber
and mist eliminator following the SO2 absorption equipment. Neither of the
two mills that have fluidized-bed reactors have additional equipment
downstream of the SO2 recovery equipment.
What is the NH3-based process sulfite chemical recovery process?
Chemical recovery process. A simplified process flow diagram for NH3-
based sulfite mills is included as Figure F-15. As shown in the figure, spent
liquor is fired in a recovery furnace. Combustion of the spent liquor
produces heat for steam generation and also combustion gases that contain
recoverable SO2. The NH3 base is consumed during combustion, forming
nitrogen and water. A small amount of ash is produced and periodically
removed from the furnace bottom. Sulfur dioxide is recovered from cooled
flue gas in an absorption tower/scrubbing system by reaction with fresh
aqueous NH3 to form an ammonium bisulfite solution. The ammonium
bisulfite solution is fortified with makeup SO2 from a sulfur burner and used
as cooking liquor in a digester. Exit gases from the absorption
tower/scrubbing system are typically routed to a fiber-bed mist eliminator
system for PM removal and mist elimination prior to being discharged to the
atmosphere. Some mills have installed a scrubber or mesh-pad mist
eliminator upstream of the fiber-bed mist eliminator system for additional
emission control.
Chemical recovery equipment. All three NH3-based sulfite mills operate
recovery furnaces to recover SO: from spent cooking liquor and produce
steam. There are a total of four NH3-based sulfite recovery furnaces—two
milii operate one recovery furnace and one mill operates two furnaces.
Figure F-16 is a diagram of an NH3-based sulfite recovery furnace. Spent
red liquor is fired at solids concentrations ranging from 50 to 60 percent.
The NH?-based sulfite recovery furnaces do not have smelt beds. However,
a small amount of ash is produced and is periodically removed from the
furnace bottom. Approximately 80 percent of the SO2 in the spent liquor can
be recovered.
APCDs. All of the NH3-based sulfite mills have some type of gas cooling
system and SO2 absorption system, typically a multi-sectioned tower with the
lower sections for cooling and the upper sections for SO2 absorption. Of the
two NH3-based sulfite mills for which equipment information is available.
both mills have fiber-bed mist eliminator systems for controlling PM
emissions located downstream of the absorption/cooling system. These
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Chapter 2 - Background
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systems consist of multiple tanks containing numerous filter elements (on the
order of 20/tank). The filter elements, also called "candles," are densely
packed with glass or polyester fibers. Liquid condensing from the stack
gases continually removes some of the captured PM from the filter elements.
In addition, the filter elements are periodically washed to remove PM. At
one mill, a reverse-jet scrubber precedes the fiber-bed mist eliminator
system, serving as a precleaner. This scrubber removes paniculate and
absorbs SO2.
2.3 What is the background information for stand-alone
semichemical pulp mills?
What is the U.S. population of stand-alone semichemical pulp mills?
There are 13 stand-alone semichemical mills currently operating in 10 States.
Twelve of these 13 mills have chemical recovery equipment to recover
pulping chemicals, while the other mill bums spent liquor in a power boiler
and does not have chemical recovery. These 12 mills are discussed in the
remainder of this section. Appendix B lists the company names and locations
for the 12 mills.
All of the stand-alone semichemical mills are currently producing corrugating
medium, which is the inside layer of corrugated containers. Corrugating
medium is also produced by semichemical pulping operations collocated at
kraft mills. Semichemical pulping operations that are collocated at kraft
mills are discussed under the kraft and soda pulp mills section.
What is the semichemical pulping process?
Semichemical pulp mills .use a combination of chemical and mechanical
methods to pulp wood. Hardwoods are typically pulped because the>
require fewer chemicals and less energy than softwoods. Wood chip^ fir-:
are partially softened in a digester with chemicals, steam, and heat. One.
chips are softened, mechanical methods complete the pulping process. The
pulp is washed after digestion to remove cooking liquor chemicals anJ
organic compounds dissolved from the wood chips. This virgin pulp is the;
mixed with 20 to 35 percent recovered fiber (e.g., double-lined kraft
clippings) or repulped secondary fiber (e.g., old corrugated containers) to
enhance machinabihty. Washer filtrate, called "black liquor," is routed to u
chemical recovery process to reclaim the remaining cooking chemicals foT
reuse in the digester.
At currently operating mills, the chemical portion of the semichemical
pulping process uses either a nonsulfur or NSSC process. The nonsulfur
process uses either Na2CO3 only or mixtures of Na2CO3 and NaOH for
cooking the wood chips. The NSSC process uses a sodium-based sulfite
2-22
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Flow diagrams of the
chemical recovery process
and associated equipment
used at stand-alone
semichemical mills can be
found in Figures F-17
through F-21
cooking liquor. The nonsulfur process is currently used at 11 of the.12 U.S.
stand-alone semichemical mills that practice chemical recovery, while the
NSSC process is used at the remaining mill. Many NSSC mills have
converted to the nonsulfur process because the nonsulfur process results in
less corrosion and odor than the NSSC process. The following sections
describe the chemical recovery process at stand-alone semichemical pulp
mills.
What is the semichemical chemical recovery process?
Figure F-17 contains a diagram of a typical chemical recovery process at a
stand-alone semichemical pulp mill. Black liquor from the pulping process
contains water, leftover cooking chemicals, and dissolved organic wood
compounds. By recovering cooking chemicals in black liquor for reuse in the
pulping process, the chemical recovery process reduces production costs and
adverse environmental impacts.
Black liquor is concentrated in a MEE system, then in a DCE and/or NDCE,
to between 39 and 60 percent solids. Semichemical black liquor containing
greater than 60 percent solids is too viscous to be pumped. At most mills,
black liquor solids have a solids content of 50 percent or less. The black
liquor is then fired in a chemical recovery combustion unit. In addition to
burning spent liquor, some chemical recovery combustion units also are
designed to produce steam for use in mill processes. Units that produce
steam produce no more steam than is needed to operate the combustion unit
and evaporate the liquor. These units require auxiliary fuels, such as natural
gas or fuel oil, to produce the energy required for steam production due to the
relatneh low energy content of semichemical spent liquor.
Cooking liquor chemicals from the chemical recovery combustion units are
reco\ ered as either smelt or ash. The recovered smelt or ash is mixed with
\\ ater in a dissolving tank. The recovered chemicals are combined with
makeup chemicals to form fresh cooking liquor, which is routed to the
digestei.
What are the semichemical chemical recovery equipment?
Four different types of chemical recovery combustion units are operated at
the 12 stand-alone semichemical pulp mills employing chemical
recovery—fluidized-bed reactors, recovery furnaces, smelters, and rotary
liquor kilns. Either ash or smelt dissolving tanks are also operated at these
mills.
Operating times vary for the different types of chemical recovery combustion
units currently in use. Recovery furnaces and rotary liquor kilns run almost
continuously; these units are shut down for an average of less than 20 days
2-23
Chapter 2 - Background
-------
per year. Fluidized-bed reactors and smelters require frequent cleaning and
maintenance; consequently, these units must be shut down more frequently
than other chemical recovery combustion units. Two smelters at one mill are
typically shut down for 131 days each per year. Each unit is in operation
approximately 65 percent of the time; the operating times of the smelters
overlap to maintain continuous production of smelt. Each smelter runs
continuously for 14 to 30 days, then is shut down for maintenance. Fluidized-
bed reactors average 14 shutdowns per year, with each shutdown lasting an
average of 11 days. During shutdowns, recovered chemicals stored in pellet
silos are used to produce fresh cooking liquor.
Fluidized-bed reactors. Five stand-alone semichemical mills (all
nonsulfur-based) use fluidized-bed reactors. The general design of a
fluidized-bed reactor is presented in Figure F-13.
Fluidized-bed reactors are used extensively because they recover chemicals
in solid pellets, which can be stored in silos until the chemicals are needed to
make fresh cooking liquor. This practice requires less storage space than
when recovered chemicals are routed directly to a dissolving tank and stored
in solution.
Five mills operate Copeland fluidized-bed reactors. The other two mills use
Dorr Oliver Fluosolids reactors, although one of the two mills modified its
Dorr Oliver reactor to operate similar to a Copeland reactor. No process
information was available for the NSSC mill, which operates a Copeland
fluidized-bed reactor.
At mills using Copeland fluidized-bed reactors, concentrated black liquor at
39 to 52 percent solids is fired into the Copeland reactor at 38 to 68 gallons
per minute (gal/min) from a single spray gun located at the top of the reactor.
As the liquor falls towards the bed, evaporation and some combustion
occurs, causing the liquor to pelletize. Fluidizing gas rises through the bed of
solid pellets, setting the bed in fluid motion.
Combustion temperatures reported by the mills average 1300CF. but can
reach a maximum of 1340°F. Sodium carbonate melts at approximately
1350°F; consequently, raising the combustion temperature above 1350°F
would result in slagging and fouling of the combustion chamber. Therefore,
for mills using the nonsulfur pulping process, 1350°F is the maximum
combustion temperature for combustion units that do not produce smelt (e.g..
fluidized-bed reactors). Water sprays located in the dome of the combustion
chamber keep the temperature below the melting point.
The soda ash (Na2CO3) pellets are recovered from the reactor and stored in
silos. The pellets are eventually routed to an ash dissolving tank (ADT) to
form a Na2CO3 solution. Then, makeup chemicals (NaOH and/or Na2CO3)
2-24
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are added to make cooking liquor. Information is available on supplemental
fuels for three of the four active Copeland fluidized-bed reactors; all three
reactors use natural gas.
The Dorr Oliver Fluosolids reactor operates by the same basic principles as
the Copeland fluidized-bed reactor. However, with the Dorr Oliver system,
concentrated black liquor (e.g., at 60 percent solids) is injected into the
lower section of the fluidized bed through multiple firing nozzles, while
Copeland fluidized-bed reactors fire black liquor from the top of the
combustion chamber through a single nozzle. Soda ash pellets are
continuously withdrawn by a transfer pipe and routed either to a silo or
directly to an ADT. The temperature in the bed averages 1300°F.
Recovery furnaces. Recovery furnaces are designed to recover cooking
liquor chemicals by burning concentrated black liquor and produce process
steam with the heat of combustion. The arrangement of a typical recover)'
furnace is presented in Figure F-18.
Before the black liquor enters the recovery furnace, the solids content of the
black liquor is increased to approximately 58 percent in a concentrator, a
heat exchanger in which steam is used to evaporate water in the black liquor.
The concentrated black liquor is sprayed into the furnace through fixed or
oscillating nozzles or "guns'" mounted on the walls of the furnace. Depending
on the design and operation of the recovery furnace, the sprayed black liquor
may hit the opposing wall, where it dries and burns before falling to the
hearth, or may fall short of the opposing wall and dry and burn in suspension.
Combustion air is generally supplied to the furnace at three levels, with two
levels located below the black liquor nozzles and one above.
The area of the furnace extending from the black liquor spray to just above
the molten smelt at the bottom of the furnace is called the drying zone. The
purpose of the drying zone is to evaporate water from the liquor droplets.
Volatile organic compounds released in the drying zone travel to the highly
turbulent upper section of the furnace, called the oxidizing zone, where they
are combusted at a temperature of approximately 1800CF.
Three recovery furnaces are currently operating at stand-alone semichemical
mills. At least two of these recovery furnaces use supplemental fuel to aid
combustion and produce steam. One furnace burns fuel oil with natural gas
as the backup fuel, while' the other furnace normally bums natural gas and
uses "residual oil" as the backup fuel. (No information is available on the
third recovery furnace.)
At least two of the recovery furnaces currently in use are of the NDCE
design. The two recovery furnaces are essentially identical, with the
exception of the type of liquor firing nozzle. One furnace has two oscillating
2-25 Chapter 2 - Background
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nozzles, while the other furnace has one stationary nozzle. The main cooking
liquor chemical (i.e., Na2CO3) is recovered as smelt, which forms in the
bottom of the furnace. The smelt flows into an SDT, where it is mixed with
water to form green liquor. From the SDT, the green liquor is sent to a
clarifier and then to a dregs washer for purification before it is mixed with
make-up chemicals and reused in the digester.
Smelters. Smelters operate in a'manner similar to recovery furnaces, except
that smelters do not produce excess steam for mill processes and are actually
net users of heat. For example, one smelter currently in operation requires
approximately 10,000 pounds per hour (Ib/hr) of steam to operate, while only
producing 7,000 to 8,000 Ib/hr of steam.
One nonsulfur-based semichemical mill operates two smelters to recover
Na2CO3 from spent liquor. These units are actually converted small kraft
recovery furnaces. The smelt produced in the furnaces flows into an SDT,
where it is combined with evaporator condensate to produce green liquor.
Green liquor is then sent to a clarifier for purification before it is mixed with
makeup chemicals (Na2CO3, NaOH) to produce fresh cooking liquor.
Each smelter fires black liquor at 57 percent solids, at an average feed rate
of 27 gal/min. Each smelter operates about 65 percent of the time: for
continuous production of cooking liquor, the startup of one smelter overlaps
the shutdown of the other smelter.
Rotary liquor kilns. A diagram of a rotary liquor kiln is presented in
Figure F-19. Number 2 fuel oil is burned in the lower end of the kiln An
induced-draft fan at the upper end draws combustion air into the lowei end
and draws combustion gases through the kiln. Approximate!) halfway
between the lower and upper ends, black liquor is fired into the kiln at abou1
50 percent solids. Sodium carbonate ash falls to the lower end. of the kiln
the ash then is routed to an ADT. Combustion gases are routed to a wa^t;
heat boiler to produce steam.
Two nonsulfur-based semichemical mills use rotary liquor kiln- foi cheni: .
recovery. The combustion temperature of the kiln averages 1200 T. but
reaches a maximum temperature of 1400°F. Black liquor is fired into .he-
kiln at an average of 18 gal/min. Number 2 fuel oil is used a? auxiliary fuel
Black liquor gasification system. In order to comply with the pulp and
paper combustion sources NESHAP, a mill which currently uses smelters i
handle the black liquor is investigating replacing its smelters with a biacl-
liquor gasification system. A diagram of the proposed black liq-jo;
gasification system is provided in Figure F-20. This technology use;.-
reforming to convert the organics in black liquor to a hydrogen-rich gas fuel
leaving the residual pulping chemicals (primarily Na2CO3) for reuse. The
2-26
o
ar/;
-------
gas can then be used as a clean-burning energy source for heat in the
gasification unit and as an alternative boiler fuel, replacing fossil-fuel based
(non-renewable) natural gas. The benefits of gasification are expected to
include increased efficiency in energy conversion and chemical recovery,
elimination of the smelt-water explosion hazard, reduced operation and
maintenance costs, and lower environmental emissions (including PM, HAP,
TRS, SO2, CO, CO2, VOC, and nitrogen oxides [NOX]).
Dissolving tanks. Inorganics recovered in the chemical recovery
combustion unit as smelt or ash are routed to a dissolving tank where the
recovered cooking chemicals are dissolved in water as the first step in
formulating fresh cooking liquor. The chemical solution is then sent to a
makeup tank where fresh liquor chemicals are added to the solution. At some
mills, the solution is first sent to a clarifier for purification. After make-up
chemicals are added, the fresh cooking liquor is stored in one or more tanks
until it is needed for pulping.
What are the APCDs?
Exhaust streams from chemical recovery combustion units are typically
routed through one or more APCDs before being exhausted to the atmosphere.
These devices were installed primarily to control either PM emissions or
mist present in the exhaust stream. Cyclones, venturi scrubbers, and wet and
dry ESPs are used to control PM emissions.
Some of these APCDs also function as process equipment. For example,
venturi scrubbers also serve as DCEs (which increase the solids content of
black liquor) for all but one of the semichemical mills that use venturi
scrubbers. Also, at some mills, the PM recovered in cyclones and dry ESPs
is collected and mixed with black liquor. Mesh pad and chevron mist
eliminators are used to remove moisture droplets from the exhaust stream.
As mentioned in a previous section, inorganics recovered in the combustion
unit a smelt or ash are routed to a dissolving tank where the recovered
cooking chemicals are mixed with water to form green liquor. When hot
smelt or ash (at 1000" to 1800CF) contacts the green liquor (at 160° to
190rFj. vapors are formed, which must be vented. These vapors contain
VOC as well as PM. Most dissolving tanks are vented directly to the
atmosphere, but three mills route tank vents to add-on PM control devices.
One of these mills controls PM emissions with a wet scrubber, another
controls PM emissions with a shower scrubber, and a third vents emissions
to a spray condenser and a chevron separator.
Two semichemical mills have recently installed regenerative thermal
oxidizers (RTO) to reduce HAP emissions from fluidized-bed reactors.
2-27
Chapter 2 - Background
-------
All of the references listed
in Section 2.4 can be
obtained from the Air
Docket (A-94-67) listed in
Section 1.8. The first two
references can be
downloaded from EPA's
website at
www.epa.gov/ttn/atw/pulp/
pulppg.html.
Figure F-21 shows a diagram of the RTO used in a pilot study at one of these
mills.
The RTO is a thermal oxidizer that recovers heat from oxidation of VOC.
The heat is recovered by passing the treated gas stream through a bed of
ceramic stoneware, prior to exhaust, which heats the bed close to or at the
oxidation temperature of the exhaust stream. The gas flow is then reversed
and the inlet gas stream is passed over the heated bed, which preheats the
stream prior to oxidation. Oxidation is completed in a central chamber,
where a burner system maintains a preset oxidation temperature.
In some cases, the concentration of VOC and/or CO in the inlet gas stream is
sufficient to cause the emission stream to autoignite in the ceramic bed. If the
VOC loading is sufficient, the RTO can operate in a self-sustaining mode, in
which the energy released provides all the heat required for complete
combustion. A wet ESP is also necessary because the RTO requires a high
degree of PM control for proper operation.
In a pilot study which preceded the RTO installation at one mill, the RTO
was found to reduce VOC emissions by an average of 97 percent and CO
emissions by 99 percent. The wet ESP reduced PM emissions by 90 percent.
2.4 Where can I find the references for this background
information?
You can find the references for the background information in this chapter
from the following sources:
• Technical Support Document: Chemical Recovery Combustion Sources at
Kraft arid Soda Pulp Mills. U. S. Environmental Protection Agency.
Office of Air Quality Planning and Standards. Research Triangle Park,
NC. Publication No. EPA-453/R-96-012. October 1996.
• Draft Technical Support Document: Chemical Recovery Combustion
Sources at Sulfite Pulp Mills. U. S. Environmental Protection Agency.
Office of Air Quality Planning and Standards. Research Triangle Park,
NC. June 22, 1995.
• Memorandum from McManus, S., MRI, to Telander, J., EPA/MICG.
December 6, 1996. Profile of U.S. Stand-Alone Semichemical Pulp
Mills.
• U.S. Environmental Protection Agency. Project XL Site-Specific
Rulemaking for Georgia-Pacific Corporation's Facility in Big Island, VA.
Direct final rule. 66 FR 16400. Washington, DC. U.S. Government
Printing Office. Monday, March 26, 2001.
• Presentation overheads. Georgia-Pacific, Big Island, VA. Project
XL-Full Scale Steam Reformer Black Liquor Gasification. November 4,
1999.
2-28
-------
When using this document,
remember that it is not
legally binding and does
not replace the pulp and
paper combustion sources
NESHAP for purposes of
application of the rule to
any specific mill.
The January 12, 2001
final NESHAP and the
July 19, 2001 technical
corrections to the final
NESHAP are included in
Appendix A Refer to the
ATW for further correction
nonces and amendments.
TJiis document is not
intended, nor can it bt
relied upon, to create am
riglits enforceable in am
party in litigation v,://; the
United States The EP\
ma\ change this document
at am time without publ.c
notice
The NESHAP co\ers
chemical recovery
combustion sources ar
kraft, soda, sulfite. and
stand-alone semichemical
pulp mill';. Stand-alone
semichemical mills are
those semichemical pulp
mills that are not
integrated with a kraft
pulp mill
Chapter 3 - Brief Overview of the Pulp and Paper
Combustion Sources NESHAP
This chapter presents a brief overview of the NESHAP for chemical
recovery combustion sources at kraft, soda, sulfite, and stand-alone
semichemical pulp mills. The overview includes a summary of NESHAP
provisions for applicability, emission control requirements, initial and
continuous compliance, recordkeeping and reporting, compliance dates, and
new source requirements.
If You Need the Following Information...
Then Read.,
Which mills are subject to the NESHAP?
Section 3.1
What affected sources must be controlled?
Wha; are the emission control requirements?
Section 3.2
Section 3.3
How do mills demonstrate initial and continuous compliance? Section 3.4
What recordkeeping and reporting requirements apply? Section 3.5
When must mills comply?
What is a ne\\ source?
What additional requirements apply to new sources?
Section 3.6
Section 3.7
Section 3.8
3.1 Which mills are subject to the NESHAP?
The pulp and paper combustion sources NESHAP applies to existing and
nev. major source kraft. soda, sulfite. and stand-alone semichemical pulp
mills \\ith chemical recover)' processes that involve the combustion of spent
pulping liquor. A major source is any mill that, emits, or has the potential to
emit (considering Federally enforceable controls) 10 tons per year or more
of an\ HAP. or 25 tons per year or more of any combination of HAP.
3.2 What affected sources must be controlled?
The NESHAP has separate emission limits for each affected source or each
process unit within an affected source. Process units include each existing
NDCE recovery furnace, DCE recovery furnace system, SDT, or lime kiln
within a chemical recovery system affected source. See Table 3 for the
affected sources and process units that are regulated by the NESHAP. The
control requirements for each affected source or process unit are explained in
detail in Chapter 4.
3-1
Chapter 3 - Overview
-------
For new sources, the
affected source is
defined as each
individual chemical
recovery combustion
unit; for existing
sources, the affected
source is defined as the
collection of chemical
recovery combustion
sources at the mill.
Sec Chapter 4 and
Appendix G for more
information on the PM
bubble compliance
alternate c.
Table 3. Affected Sources and Process Units Covered by the NESHAP
For this Type of
Mill...
i Affected Sources Are
Covered at
Existing Sources...
And these Affected
Sources Are Covered at
New Sources ..i :>>'
Kraft or soda
Chemical recovery system
• NDCE recovery furnace
• DCE recovery furnace
system
• SDT
• Lime kiln
• NDCE recovery furnace and
associated SDT
• DCE recover)' furnace system
and associated SDT
• Lime kiln
Sulfite
Stand-alone
semichemical
Sulfite combustion unit Sulfite combustion unit
Semichemical combustion unit Semichemical combustion unit
3.3 What are the emission control requirements?
Surrogate compounds were selected for each of the regulated HAP pollutants.
Particulate matter was selected as a surrogate for HAP metals for kraft. soda,
and sulfite combustion units; methanol was selected as a surrogate for
gaseous organic HAP compounds for kraft and soda NDCE recovery furnace'-
and DCE recovery furnace systems, and total hydrocarbon (THC) emissions
were selected as a surrogate for gaseous organic HAP emissions for
semichemical combustion units.
The NESHAP provides separate emissio i limits for each affected source or
process unit. For existing affected sources at kraft or soda pulp mills, a mill
can choose whether to comply with the individual PM emission limits for
each process unit (i.e., each NDCE recovery furnace. DCE recover, furnace
system. SDT, and lime kiln) or comply with a PM bubble compliance
alternative for the entire affected source (i.e., chemical recover s\sten.,
The format (e.g., outlet concentration, mass emission rate, or pci\ en
reduction) of the emission limits varies depending on the type of affecteo
source or process unit. See Table 4. The formats of the ems-MOH linrt- f••
kraft and soda affected sources and process units were chosen to tx
consistent with the NSPS for kraft pulp mills. The emission limits tor eac;
affected source or process unit are presented in Chapter 4.
3-2
-------
Only new kraft and soda
recovery furnaces and
new and existing
semichemical
combustion units arc
subject to gaseous
organic HAP emission
limits.
Table 4. Formats of the Emission Limits
i^Forthe Following
Affected Source
or Process Unit..
Chemical
recovery system
NDCE recovery
furnace
DCE recovery
furnace system
SDT
Lime kiln
Sulfite
combustion unit
Semichemical
combustion unit
TOeRegulated
Pollutant Is...
HAP metals
HAP metals
Gaseous organic
HAPs
HAP metals
Gaseous organic
HAPs
HAP metals
HAP metals
HAP metals
Gaseous organic
HAPs
And the Mill Is Subject to the following
-: Type of Emission Limit.. "*&£f.-.
Outlet concentration (grains per dry
standard cubic foot [gr/dscf])
Outlet concentration (gr/dscf)
Mass emission rate (pounds per ton of
black liquor solids [Ib/ton BLS])
Outlet concentration (gr/dscf)
Mass emission rate (Ib/ton BLS)
Mass emission rate (Ib/ton BLS)
Outlet concentration (gr/dscf)
Outlet concentration (gr/dscf)
• Mass emission rate (Ib/ton BLS) or
• Percent reduction
3.4 How do mills demonstrate initial and continuous
compliance?
In general, mills must conduct an initial performance test and then
continuously monitor opacity or control device operating parameters, as
applicable.
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.
Table 5 presents the surrogate pollutants that must be measured.
2. To establish the operating parameter values (e.g., pressure drop and
liquid flow rate for scrubbers) that must be monitored to demonstrate
continuous compliance with the standard.
3-3
Chapter 3 - Overview
-------
An initial performance
test is required for all
chemical recovery
combustion sources,
with one exception. A
performance test is not
required to demonstrate
compliance with the
gaseous organic HAP
emission limit for new
kraft and soda recovery-
furnaces if the recovery
furnace is an NDCE
furnace equipped with a
dry ESP system.
Table 5. Initial and Continuous Compliance Requirements
>Anda
For the -*;'•-?*&-•
Following
Affected Source r^r." The
.--, or Proce**^#iRegulated ;
unit.. . :
Chemical
recovery system
NDCE recovery
furnace
DCE recovery
furnace system
SDT
Lime kiln
Sulfue
combustion unit
Semichemical
combustion unit
Pollutant Is...
HAP metals
HAP metals
Gaseous.
organic
HAPs
HAP metals
Gaseous
organic
HAPs
HAP metals
HAP metals
RAP metals
Gaseous
organic
HAPs
Performance
Test Is
Required
is-s at this
, Frequency*...
Initially
Initially
Initially/
Nonec
Initially
Initially'
Initially
Initially
Initial!)
Initially
*-*&& -•-- , And these
And a Mill Must I; Parameters
Test" for this =^Must Be
., -,; Surrogate Continuously
Pollutant.. Monitored...
Paniculate matter
Paniculate matter
Methanol/
Nonec
Paniculate matter
Methanol
Paniculate matter
Paniculate matter
Paniculate matter
Total
hydrocarbon
Opacity or
operating
parameters
Opacity or
operating
parameters
Method
approved by the
Administrator/
Nonec
Opacity or
operating
parameter^
Method
approved b> the
Administrator
Operating
parameters
Opacity or
operating
parameter >
Operating
parameter
Operati^
The U.S EPA or the delegated authority may require an owner or operator u condL.
performance tests at the affected facility at any other time when the action i
authorized under Section 114 of the CAA (§63.7(a)(3) of the NESH AP Gener^
Provisions [40 CFR part 63, subpart A]).
Performance tests are conducted using the following methods: Method 5. 29, or 1"
(PM); Method 308 (methanol); and Method 25A (THC). If Method 17 is used, you
must add a constant value of 0.004 gr/dscf to the results, and the stack temperature
must be no greater than 400°F.
An initial performance for methanol is required for new NDCE reco\ ei> furnaco
equipped with a wet ESP system and new DCE recovery furnace systems but is not
required for new NDCE recovery furnaces equipped with a dry ESP system .Simila
continuous monitoring is also not required for new NDCE recoven furnaces
with a dry ESP system.
3-4
-------
The NESHAP specifies the required monitoring parameters for most control
devices. If a mill decides to use alternative monitoring parameters other than
those listed in the NESHAP, then the mill must submit for approval to the
Administrator the list of alternative parameters to be monitored.
If a mill decides to use an alternative control device other than those listed in
the NESHAP, then the mill must submit for approval to the Administrator a
monitoring plan that includes a description of the control device, test results
verifying its performance, the operating parameters .to be monitored, and the
frequency of measuring and recording to establish 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 pressure drop and liquid flow rate) that constitute
continuous 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 opacity or operating parameters, as applicable, and
report instances where the average values deviate from the values
established during the initial performance test.
The NESHAP includes a two-tiered monitoring approach. Each monitoring
tier specifies maximum opacity values (for ESPs only) and a maximum
frequency with which the opacity or monitoring parameters may exceed
established levels. If the conditions of the first monitoring tier are exceeded,
then mills would be required to implement corrective action to bring the
opacity or monitoring parameter levels back to established levels.
Exceedance of the conditions of the second monitoring tier would constitute a
violation of the standard.
3.5 What rscordkeeping and reporting requirements apply?
Mills must comply with the recordkeeping and reporting requirements of the
NESHAP General Provisions (40 CFR part 63, subpart A) and those of the
pulp and paper combustion sources 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 the
final rule in Appendix A identifies which sections of the NESHAP General
Provisions apply and which are overridden by this NESHAP.
3-5
Chapter 3 - Overview
-------
3.6 When must mills comply?
Existing affected sources must comply by March 13, 2004. New affected
sources must comply at startup or by March 13, 2001, whichever is later.
The initial notification is due by July 11, 2001 for existing sources.
Appendix H provides the detailed milestone compliance timelines for
existing and new sources.
3.7 What is a new source?
What constitutes a new or reconstructed source for each type of mill that is
subject to this NESHAP is defined in Table 6 below.
Table 6. Definition of a New Source
That
A New Source at this Is the Construction or Reconstruction of Commences
Type of Mill... Any One of the Following... After...
Kraft or soda • NDCE recovery furnace April 15, 1998
• DCE recovery furnace system
• SDT
• Lime kiln
Sulfite Sulfite combustion unit April 15. 1998
Stand-alone Semichemical combustion unit April 15. 199J;
semichemical
What does reconstruction mean? Reconstruction means replacement o*'
components to the extent that the fixed capital cost of the new component^
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 MAC"!
standards for new sources irrespective of any change in the emission of
HAPs. See §§63.2 and 63.5 of the NESHAP General Provisions (40 CFR
part 63. subpart A).
The pulp and paper combustion sources NESHAP defines each kraft. bOu.
sulfite, or semichemical combustion unit as the equipment to which the 5(
percent criterion is applied. For example, consider a mill that is convertm:.-
its existing DCE recovery furnace system (i.e., DCE recovery furnace and
BLO unit) to an NDCE recovery furnace. To determine if reconstruction
occurs, the replacement costs of the conversion would be compared to th;-
construction costs for a new NDCE recovery furnace. If the replacement cusi
if less than 50 percent, then the NDCE recovery furnace is treated as an
existing source and is subject to the same existing source emission limit a'
before. However, if the cost exceeds 50 percent, then the replacement
project would be deemed as a reconstruction of the recover)' furnace, and the
3-6
-------
NDCE recovery furnace would be subject to the new source emission limits,
even if emissions after the reconstruction are the same or decrease.
3.8 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 stringent emission limits. For kraft, soda, and sulfite combustion
sources, the emission limits are more stringent for new sources than for
existing sources.
• No PM bubble compliance alternative. New kraft and soda combustion
sources cannot use the PM bubble compliance alternative.
• Caseous organic HAP emission limit New kraft and soda recovery
furnaces are subject to a gaseous organic HAP emission limit, while
existing recovery furnaces are not.
• Opacity monitoring requirement. New kraft and soda recovery
furnaces are subject to a more stringent opacity monitoring requirement
than existing kraft and soda recover)' furnaces.
• Earlier compliance dates. New sources must comply at the date of
startup or on March 13, 2001. whichever is later.
• Preconstruction approval. The owner or operator of mills subject to the
pulp and paper combustion sources NESHAP must submit an application
to EPA for approval to construct any new source that is subject to this
rule The preconstructipn approval process applies only if 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 §63.5(e) and (f) of the
NESHAP General Provisions (40 CFR part 63, subpart A).
3-7 Chapter 3 - Overview
-------
When using this document,
remember that it is not
legally binding and does
not replace the pulp and
paper combustion sources '
NESHAP for purposes of
application of the rule to
any specific mill.
The final NESHAP and the
technical corrections are
provided in Appendix A,
and-a flowchart summary
of the NESHAP is provided
in Appendix I Inspection
checklists detailing /;oiv ro
comply with the NESHAP
are provided in
Appendix J
Tliis document is not
intended, nor can it be
relied tipon. to create any
rights, enforceable b\ any
party i>i litigation \\illi the
United Stales. The EPA
may change tins document
at any tinu without public
notice
Other on-site combi'snon
source \ not associatd.1
M itJi chemical reco\ ery
such a* poH cr boilers, arc
not co\ creel by tins
\ESH\F
Chapter 4 - NESHAP Requirements
The pulp and paper production source category includes three subcategories:
(1) kraft and soda pulp mills, (2) sulfite pulp mills, and (3) stand-alone
semichemical pulp mills. The NESHAP contains emission standards for
chemical recovery combustion sources in each of these subcategories. This
chapter presents a summary of these emission standards and the compliance
requirements (initial and continuous compliance, recordkeeping and
reporting) that are associated with them.
If You Need the Following Information...
Then Read-
Standards for kraft and soda combustion sources Section 4.1
Standards for sulfite and semichemical combustion sources Section 4.2
4.1 What are the standards for kraft and soda combustion
sources?
The NESHAP requires that mills control the HAP metal and/or gaseous
organic HAP emissions from their kraft and soda combustion sources. This
section describes the emission points that must be controlled, the emission
limits, and the compliance requirements.
Which kraft and soda combustion sources must be controlled?
The NESHAP specifies that each of the following kraft and soda affected
sources in Table 7 must be controlled:
Table 7. Kraft and Soda Affected Sources
The Following Emission Points Must Be Controlled...
Existing Sources
• Chemical recovery system"
New Sources
NDCE recovery furnace and associated SDT
DCE reco\ery furnace systemhand associated SDT
Lime kiln
J The chemical recovery system includes all existing NDCE and DCE recovery furnaces.
SDTs. and lime kilns at a kraft or soda pulp mill.
h The DCE recovery furnace system includes the DCE recovery furnace and any BLO
system, if present, at the kraft or soda pulp mill
4-1 Chapter 4 - NESHAP Requirements
-------
What are the emission limits for kraft and soda combustion sources?
The emissions from the kraft and soda combustion sources must meet the
emission limits shown in Table 8 below.
Table 8. Kraft and Soda Emission Limits
These-
Emission
Points... "" '"'Must Meet these Requirements...
Existing Sources
• Chemical * NDCE recovery furnace/DCE recovery furnace
recovery Reduce outlet PM emissions to sO.044 gr/dscf at 8% oxygen (O: i
system ' SDT
Reduce outlet PM emissions to sO.20 Ib/ton BLS
• Lime kiln
Reduce outlet PM emissions to <0.064 gr/dscf at 10% O.
OR
Th PM b bbl PM Dubble compliance alternative: Comply with mill-specific PM
,. ,, . limit (Ib/ton BLS) based on the calculated value of the sum of the
compliance alternative . : ...... t CTV_ ...
, ,. ,, individual emission limits for recovery furnaces. SDTs, and lime
. .' kilns. (See Appendix G for examples of how mills can use the PM
existing sources. , , , , ,. , • ^
bubble compliance alternative.)
New Sources
• NDCE Reduce outlet PM emissions to <0.015 gr/dscf at 8'7r O;
New sources are subject recovery and
to more stringent furnace/DCE Reduce outlet gaseous organic HAP emissions to <0.025 Ib/ton BLS
emission limits. recover.1 (as measured by methane!)
furnace
s\stem
• SDT Reduce outlet PM emissions to <0.12 Ib/ton BLS
• Lime kiln Reduce outlet PM emissions to <0.010 gr/dscf at 10f\ O:
When must mills comply with the kraft and soda combustion source
standards?
Existing combustion sources at kraft and soda pulp mills must compK with
the NESHAP by March 13, 2004. New combustion sources at kraft and soua
pulp mills that have a startup date after March 13, 2001 must comply with the
NESHAP immediately upon startup. New combustion sources at kraft and
soda pulp mills that have a startup date after April 15, 1998 but before
March 13, 2001 must comply with the NESHAP by March 13, 2001.
4-2
-------
For testing purposes, PM is
used as a surrogate for
HAP metals, and methanol
is used as a surrogate for
gaseous organic HAP.
EPA Methods 1-4,5. 17,
and 29 are described in
Appendix A to 40 CFR
pan 60.
How does a mill demonstrate initial compliance with the kraft and soda
combustion source standards?
A mill must demonstrate compliance through an initial performance test for
each kraft or soda combustion source, except for NDCE recovery furnaces
equipped with a dry ESP system. The initial performance test has two
objectives:
1. To demonstrate that the kraft or soda combustion source complies
with the emission limit. Refer to Table 9.
1. To establish the operating parameter values that must be
monitored to demonstrate continuous compliance. For example, for
kraft or soda combustion sources equipped with wet scrubbers, the test
would establish the minimum scrubber pressure drop and scrubbing liquid
flow rate that indicates compliance with the applicable PM standard
Table 9. Kraft and Soda Initial Compliance Requirements
To Demonstrate Initial
Compliance with this Emission
Limit...
Conduct an Initial
Performance Test
Following this
Method...
To Measure these
Parameters...
Existing Sources
• NDCE recovery furnace/
DCE recovery furnace
Reduce outlet PM emissions
to <0 044 gr/dscf at 87r O:
Method 5. 29. or IT
and
Methods 1 through 4
Particulate matter
concentration at the
control device outlet
corrected to 89t O2
SDT
Reduce outlet PM emissions
to := 0 20 Ib/ton BLS
Method 5, 29, or IT
and
Methods 1 through 4
and
Method of measuring
BLS firing rate
Particulate matter mass
emission rate at the control
device outlet
• Lime kiln
Reduce outlet PM emissions
to <0064 cr/dscf at 109? O~
Method 5, 29, or IT
and
Methods 1 through 4
Particulate matter
concentration at the
control device outlet
• Chemical recovery system
PM bubble compliance
alternative
Comph with mill-specific
PM limit (Ib/ton BLS) based
on the calculated value of the
sum of the individual
emission limits for recovery
furnaces, SDTs, and lime
kilns.
Method 5. 29, or IT
and
Methods 1 through 4
and
Methods of measuring
BLS firing rate and CaO
production rate
Particulate matter mass
emission rates at the
control device outlets for
all recovery furnaces.
SDTs, and lime kilns
included in the PM bubble.
4-3 Chapter 4 - NESHAP Requirements
-------
Table 9. (Continued)
EPA Method 308 is
described in Appendix A
to 40 CFR Pan 60.
Mills can use pre\ wus
performance tes: data to
- set the operating
parameter le\elsfor
monitoring as long as
the processes and
control equipment have
not changed since the
tests were conducted.
To Demonstrate Initial
Compliance with this Emission
Limit...
Conduct an Initial
Performance Test
Following this
Method...
To Measure these
Parameters-
New Sources
• NDCE recovery furnace/
DCE recovery furnace
Reduce outlet PM emissions
to <0.015 gr/dscf at 8% O2
Method 5,29, or 17"
and
Methods 1 through 4
Paniculate matter
concentration at the
control device outlet
corrected to 8% O2
NDCE recovery furnace/
DCE recovery furnace
system
Reduce outlet gaseous
organic HAP emissions to
<0.025 Ib/ton BLS (as
measured by methanol)
Method 308
and
Methods 1 through 4
and
Method of measuring
BLS firing rate
Methanol mass emission
rate at the control device
outlet
SDT
Reduce outlet PM emissions
to <0.121b/tonBLS
Method 5, 29, or 17"
and
Methods 1 through 4
and
Method of measuring
BLS firing rate
Particulate matter mass
emission rate at the control
device outlet
Lime kiln
Reduce outlet PM emissions
to < 0.010 gr/dscf at 109r O2
Methods, 29. or IT
and
Methods 1 through 4
Particulate matter
concentration at the
control device outlet
corrected to 10"7r O-
" If Method 17 is used, you must add a constant value of 0.004 gr/dscf to the results, and
the stack temperature must be no greater than 400 °F.
How does a mill demonstrate continuous compliance with the kraft and
sods combustion source standards?
Mills must install continuous monitoring systems to measure opacin ar,^
control device operating parameters. Mills must also establish a range o'
values for each operating parameter to be monitored based upon the value.-
recorded during the initial performance test or during previous qualifying
tests. The mill may conduct multiple performance tests to estaHhsh rar.ge < '
operating parameter values. The mills also may expand or replace the
operating parameter levels through subsequent performance tests. Table 10
presents the monitoring requirements for each emission limit.
Mills can monitor parameters other than those listed in Table 10 onh if the\
receive written approval from the Administrator. Also, mills that comph
with the NESHAP through operational changes or with control devices not
described in the NESHAP must submit a monitoring plan that propose-. \\ h ch
parameters will be monitored, the range of these parameters, and the
frequency with which these parameters will be monitored, subject to
approval by the Administrator.
4-4
-------
Pie NESHAP includes a
two-tiered monitoring
approach. If the
conditions of the first
tier are exceeded, then
corrective action must
be taken. Exceedance of
the second tier
conditions results in a
violation of the
standard.
Table 10. Kraft and Soda Continuous Compliance Requirements
To Demonstrate.;
Continuous
Compliance With
this Emission
Limit-
Then Continuously You Must Take
Monitor these Corrective Action You Are in Violation
Parameters... If... ' ; of the Standard If...
Existing Sources
• Recovery furnace
Reduce outlet PM
emissions to
<0.044 gr/dscf at
8%02
• SDT
Reduce outlet PM
emissions to
<0.20 Ib/ton BLS
• Lime kiln
Reduce outlet PM
emissions to
< 0064 gr/dscf at
10<7c O2
• Chemical
recovery system:
PM Bubble
Compliance
Alternative
(reccners
furnaces. SDTs.
and lime kilns)
When using an ESP,
monitor opacity at
least once every
10 seconds
or
When using a wet
scrubber, monitor
scrubber pressure
drop and scrubbing
liquid flow rate at
least once every
15 minutes
Average of ten
consecutive 6-
minute opacity
readings result in a
measurement
>20%
or
Any 3-hour
average scrubber
parameter value is
outside the range
of values
established during
the initial
performance test
Opacity >35% for
recovery furnaces or
>20% for lime kilns
*6% of the operating
time within any
quarterly period
or
Six or more 3-hour
average scrubber
parameter values are
outside the ranee of
values established
during the initial
performance test
within any 6-month
reporting period3
New Sources
Recovery furnace
Reduce outlet PM
emissions to
<0 015 gr/dscf at
Vc 0: "
SDT
Reduce outlet PM
emissions to
<0 121b/tonBLS
Lime kiln
Reduce outlet PM
emissions to
<0.010 gr/dscf at
O,
When using an ESP.
monitor opacity at
least once every
10 seconds
or
When using a wet
scrubber, monitor
scrubber pressure
drop and scrubbing
liquid flow rate at
least once every
15 minutes
Average of ten
consecutive 6-
minute opacity
readings result in a
measurement
>20<7c
or
Any 3-hour
•average scrubber
parameter value is
outside the range
of values
established during
the initial
performance test
Opacity >20% for
>6'7c of the operating
time within any
quarterly period
or
Six or more 3-hour
average scrubber
parameter values are
outside the range of
values established
during the initial
performance test
within any 6-month
reporting period"
4-5 Chapter 4 - NESHAP Requirements
-------
Table 10. (Continued)
To Demonstrate
Continuous
Compliance With
this Emission
Then Continuously You Must Take
Monitor these Corrective Action You Are in Violation
Parameters... H... of the Standard If...
Recovery furnace
Reduce outlet
gaseous organic
HAP emissions to
icO.025 Ib/ton
BLS (as measured
by methanol)
When using an
NDCE furnace with
dry ESP system, no
monitoring required
or
When using a non-
NDCE furnace or an
NDCE furnace with
wet ESP system,
monitor the
applicable
parameters subject
to prior written
approval by the
Administrator
Not applicable for
NDCE recovery
furnace equipped
with dry ESP
system
or
For any non-
NDCE furnace or
any NDCE furnace
with wet ESP
system, any 3-hour
average parameter
value is outside the
range of values
established during
the initial
performance test
Not applicable for
NDCE recovery
furnace equipped with
dry ESP system
or
For any non-NDCE
furnace or any NDCE
furnace with wet ESP
system, six or more
3-hour average
parameter values are
outside the range of
values established
during the initial
performance test
within any 6-month
reporting period2
scrubber) monitoring
any given 24-hour
a For the purposes of determining the number of nonopacity (e.g..
exceedances, no more than one exceedance will be attributed in
period.
Musi a mill comply at all times?
For kraft and soda combustion sources, tne NESHAP establishes an
allowable percent of operating time during which exceedances are not
considered to be a violation of the standard. Periods of exceedance include
v, hen opacity values exceed the specified levels in the NESHAP and when
operating parameter values established during the initial performance test
cannot be maintained at the appropriate level. The allowance is in additicr
to excused periods under the startup, shutdown, or malfunction provision-.
The exceedance allowances are:
• For opacity exceedances, anything less than 6 percent of the operating tmv.
within any quarterly period.
• For scrubber parameter exceedances, up to five 3-hour average scrubber
parameter values within any 6-month reporting period.
For the purposes of determining the number of nonopacity (e.g., scrubber,
parameter exceedances, the NESHAP states that no more than ont
exceedance will be attributed in any given 24-hour period. For example, if a
kraft pulp mill had six 3-hour average scrubber parameter values outside the
range of values established during the initial performance test within a
4-6
-------
particular 6-month reporting period, but two of those values occurred within
a 24-hour period, then only one of those two values would count as an
exceedance in determining a violation. Consequently, the mill would only
have five exceedances within the 6-month reporting period and would be
within its exceedance allowance.
Even though periods of exceedance may be exempt under the MACT
requirements, these periods of exceedance must still comply with NSPS
requirements (40 CFR part 60, subpart BB) and any applicable State
requirements.
To calculate the percent of periods of opacity exceedance in a quarterly
period, divide the number of hours in the period during which the 6-minute
average opacity exceedances occurred by the total number of process unit
operating hours in the period and multiply by 100 percent. For example, if
there were 223 6-minute average opacity exceedances during a quarterly
period, then the number of hours during which the exceedances occurred
would be 223 x 6/60 = 22.3 hours. If the total recover)' furnace operating
time for the quarterly period was 2,100 hours, then to calculate the quarterly
exceedance, divide 22.3 hours by 2,100 hours as follows:
Parameter exceedance period x 100%
total process operating time
22.3 hours x 100% = 1.06%
2,100 hours
What are the recordkeeping and reporting requirements for the kraft
and sodr combustion source standards?
Mills must also comply with recordkeeping and reporting requirements.
Tables 11 and 12 present the recordkeeping and reporting requirements for
the kraft and soda combustion source standards.
4-7 Chapter 4 - NESHAP Requirements
-------
Table 1 1 . Kraft and Soda Recordkeeping Requirements
Keepthe
Following
Records...
Which Contain the Following Information..
Startup, shutdown,
and malfunction
plan
NESHAP Genera]
Provisions records
Parameter
monitoring data
• Procedures for operating and maintaining the source during
periods of startup, shutdown, and malfunction (SSM)
• A program of corrective action for malfunctioning process
and air pollution control equipment used to comply wi^h the
standard
• Identification of all routine or otherwise predictable
continuous monitoring system (CMS) malfunctions.
• Procedures for responding to any parameter level
inconsistent with the level established during the initial
performance test, including the following:
• Procedures to determine and record the cause of a
parameter exceedance and the time the exceedance bega1
and ended
• Corrective actions to take in the event of a paramete;
exceedance, including procedures for recording the
actions taken to correct the exceedance
• A maintenance schedule for each control technique
consistent with manufacturer's instructions and
recommendations for routine and long-term maintenance
• An inspection schedule for each CMS to ensure, ai least
once in each 2.4-hour period, that each CMS is proper!}
functioning
All relevant information listed in §63.10(b) and u . of t!u
NESHAP General Provisions (40 CFR part 63. subpart A >
• Each successive 6-minute average opacity
• Scrubber pressure drop and scrubbing liquid *'K».V iv.;
'readings taken at least once even.1 successne } vmhv_;-.
period
• Scrubber pressure drop and scrubbing hquv'fi - .1.' "•>-
averages
Occurrences when
correcme action
required
Any period when the average of 10 consecun\<. i
opacity readings result in a measurement >1V;
Any 3-hour average scrubber parameter val . ,
range of values established during the initial pe; •
test
Brief explanation of the cause of the exceedarK
Time the exceedance occurred
Time correction was initiated and completed
Corrective action taken
4-8
-------
Table 11. (Continued)
Keep the
Following
Records...
Which Contain the Following Information.^ -:"
Occurrences when
violation noted
Black liquor solids
firing rate records
• Opacity >35% for existing recovery furnaces for 26% of the
operating time within any quarterly period
• Opacity >20% for new recovery furnaces or existing or new
lime kilns for 26% of the operating time within any
quarterly period
• Six or more 3-hour average scrubber parameter values are
outside the range of values established during the initial
performance test within any 6-month reporting period2
Black liquor solids firing rates in tons per day for all kraft or
soda recovery furnaces and all semichemical combustion units
CaO production
rate records
CaO production rates in tons per day for all kraft or soda lime
kilns
Monitoring
parameter records
Monitoring parameter ranges established during initial
performance test
NDCE recovery
furnace
certification
Certification that an NDCE recovery furnace equipped with a
dry ESP system is used to comply with the gaseous organic
HAP emission limit for new recovery furnaces
For the purposes of determining the number of nonopacity (e.g., scrubber) monitoring
exceedances. no more than one exceedance will be attributed in any given 24-hour
period.
4-9 Chapter 4 - NESHAP Requirements
-------
See Appendix Kfor
example notifications
and compliance reports.
Table 12. Kraft and Soda Reporting Requirements
Submit the Following ;*' ,' f»^*^
Reports..; Which.Contain the Following Information...
Initial notifications All relevant information listed in §63.9(b) of the
NESHAP General Provisions'
Request for extension of All relevant information listed in §63.9(c) of the
compliance NESHAP General Provisions'
Notification that source All relevant information listed in §63.9(d) of the
is subject to special NESHAP General Provisions2
compliance requirements
Notification of All relevant information listed in §63.9(e) of the
performance test NESHAP General Provisions'
Additional notifications All relevant information listed in §63.9tg) of the
for sources v. ith CMS NESHAP General Provisions'
Notification of • All relevant information listed in §63.9(h) of the
compliance status NESHAP General Provisions'
• PM emission limits determined in §63.865(a)dKii >
of subpart MM
• Calculations and supporting documentation for PM
emission limits determined in §63.865fa)i 1 )(u) ol
subpart MM
Notification of changes • Modifications to or replacement of air pollution
(PM bubble compliance control system
alternatiNe) • Shutdown of recovery furnace, SDT. or lime bin ;;.
chemical recovery system for more than 60 days
• Change in continuous monitoring pa- ameter or th-
value or range of values for continue „:- monitonr-L
parameter
• Increase in black liquor solids firing rate for ar\
recovery furnace more than 10 perce-' above int. :•:
measured during the most recent pert. .:rnan^e re--'
during any 24-hour averaging pencv
Quarterly report of
excess emissions
All relevant information listed in §t. •'' .. of" n -
NESHAP General Provisions3
Number and duration of occurrence * he: the
met or exceeded the conditions requiring correct .
action
Number and duration of occurrences when the sour
met or exceeded the conditions indicating a violate
Semiannual report of no
excess emissions
All relevant information listed in §6.- !0.eK'3>i'\i
the NESHAP General Provisions3
Statement that no excess emissions occurred du/'t
the reporting period
' The NESHAP General Provisions can be found in 40 CFR part 63, subpan A.
4-10
-------
Existing NSPS sources
that choose to comply
with the PM standards
using the PM bubble
compliance alternative
must continue to comply
with the NSPS limits for
kraft pulp mills.
Compliance with the
NESHAP does no!
always ensure
compliance with the
NSPS.
How do the requirements for the NSPS and NESHAP compare?
Table 13 compares the NSPS for kraft pulp mills and the NESHAP for
combustion sources at kraft pulp mills. Note that demonstrating compliance
with a NESHAP emission limit does not necessarily mean that NSPS
requirements are automatically met.
If sources comply with the surrogate PM emission limits for kraft combustion
sources in the NESHAP, which are no less stringent than the PM emission
limits in the NSPS (and for lime kilns and new sources are more stringent),
then compliance with both the NSPS and NESHAP is assured. Sources
subject to the NSPS that use the PM bubble compliance alternative to
establish mill-specific PM limits would have to establish PM limits no less
stringent than the NSPS limit in order to demonstrate compliance with both
the NSPS and NESHAP. (See Appendix G for examples of how the PM
bubble compliance alternative is applied when the mill has existing
combustion sources already subject to the NSPS.)
If sources comply with the gaseous organic HAP emission limit for new
recovery' furnaces in the NESHAP, there is no guarantee that the sources will
also demonstrate compliance with the TRS emission limit in the NSPS.
However, reductions in TRS and gaseous organic HAP emissions would
occur by the same mechanism (e.g., elimination of stripping from the black
liquor in the BLO unit, DCE, wet-bottom ESP, or wet PM return system).
Table 13. Comparison of NSPS and NESHAP Requirements
Does NESHAP
Compliance
For this And the NESHAP Ensure NSPS
Equipment... The NSPS Requires... Requires... Compliance?
Existing Sources Subject to NSPS
Recover}' PM: <0.044 gr/dscf at 8<7c
furnace O:
and
Opacity: <35<7c for >94%
of operating time within
quarterly period
PM: <0.044 gr/dscf at
8% O:
and
Opacity: <357r for
>949e of operating time
within quarterly period
Yes
SDT
TRS: <5 ppmdv at 8% O2
PM: <0.20 Ib/ton BLS
TRS: <0.033 Ib/ton BLS
No requirement
PM: sO.20 Ib/ton BLS
No requirement
No
Yes
No
4-11 Chapter 4 - NESHAP Requirements
-------
Table 13. (Continued)
o; Forth!*
Equipment..
Lime kiln
Chemical
recovery
system: PM
bubble
compliance
alternative
New Sources
Recovery
furnace
SDT
The NSPS Requires...
PM: 50.067 gr/dscf at
10% O2, when natural gas
burned
or
PM: *0.13 gr/dscf at 10%
O2, when fuel oil burned
No opacity requirement
TRS: <8 ppmdv at 10% O2
PM and TRS emission
limits listed above for
recovery furnaces, SDTs,
and lime kilns
and
Opacity standard listed
above for recovery
furnaces
PM: < 0.044 gr/dscf at 8<7r
02
and
Opacity: <35<7c for>947c
of operating time within
any quarterly period
TRS: <5 ppmdv at 89c O2
PM: <0.20 Ib/ton BLS
-K^^^SS1--
And the NESHAP
Requires...
PM: <. 0.064 gr/dscf at
10% O2
Opacity: s20% for
>94% of operating time
within quarterly period
(lime kiln with ESP)
No requirement
Mill-specific PM limits
based on calculated
value of sum of
individual emission
limits for recovery
furnaces, SDTs, and
lime kilns.
and
Opacity requirements
listed above
PM: < 0.0 15 gr/dscf at
8<7r O2
and
Opacity: <207c for
>947c of operating time
within any quarterly
period
Gaseous organic HAP.
<0.025 Ib/ton BLS (as
measured by methane!)
PM: < 0.1 2 Ib/ton BLS
Does NESHAP
Compliance
Ensure NSPS
Compliance?
Yes
Not applicable:
NSPS does not
have opacity
requirement for
lime kilns
No
Only if mill-
specific limits
no less stringent
than NSPS
limits
Yes
Only if
reductioi, m
gaseou1- organs^
HAP emissions
also results in
reduction in
TRS emissions
below NSPS
limit
Yes
4-12
-------
Table 13. (Continued)
Reco\ cry furnaces 94% of operating time
within quarterly period
(lime kiln with ESP)
Not applicable;
NSPS does not
have opacity
requirement for
lime kilns
TRS: <8 ppmdv at 10<7r O2 No requirement
No
4.2 What are the standards for sulfite and semichemical
combustion sources?
Which sulfite and semichemical combustion sources must be
controlled?
The NESHAP specifies that each of the following sulfite and semichemical
affected sources in Table 14 must be controlled:
Table 14. Sulfite and Semichemical Affected Sources
The Following Emission Points Must Be Controlled...
Sulfite Combustion Sources
• Recover, furnace
• Fluidized-bed reactor
Semichemical Combustion Sources
• Fluidized-bed reactor
• Recovers' furnace
Smelter
Rotary liquor kiln
Black liquor gasifier
4-13 Chapter 4 - NESHAP Requirements
-------
For testing purposes,
PM is used as a
surrogate for HAP
metals, and THC is used
as a surrogate for
gaseous organic HAP.
What are the emission limits for sulfite and semichemical combustion
sources?
The emissions from the sulfite and semichemical combustion sources must
meet the emission limits shown in Table 15 below.
Table 15. Sulfite and Semichemical Emission Limits
These Emission Points...
Must Meet these Requirements...
Sulfite Combustion Sources
• Existing sources Reduce outlet PM emissions to $0.040 gr/dscf at 8% O:
New sources
Reduce outlet PM emissions to <0.020 gr/dscf at 8f;<- 0;
Semichemical Combustion Sources
Existing and new
sources
Reduce outlet gaseous organic HAP emissions to s2.9"
Ib/ton BLS (as measured by THC [as carbon] i
or
Reduce outlet gaseous organic HAP emissions by 909c
When must mills comply with the sulfite and semichemical combustion
source standards?
Existing combustion sources at sulfite and semichemical pulp mills must
comply with the NESHAP by March 13, 2004. New combustion sources at
sulfite and semichemical pulp mills that have a startup date after March 1?.
2001 must comply with the NESHAP immediately upon startup New
combustion sources at sulfite and semichemical pulp mills that have a startup
date after April 15, 1998 but before March 13, 2001 must comply with the
NESHAP by March 13,2001.
How does a mill demonstrate initial compliance with the sulfite and
semichemical combustion source standards?
A mil! must demonstrate compliance through an initial performance test for
each sulfite or semichemical combustion source. The initial perron<:an, o to--'
has two objectives:
1. To demonstrate that the sulfite or semichemical combustion
source complies with the emission limit. Refer to Table 16.
2. To establish the operating parameter values that must be
monitored to demonstrate continuous compliance. For example fo«
sulfite combustion sources equipped with wet scrubbers., the test would
establish the minimum scrubber pressure drop and scrubbing liquid ftou
rate that indicates compliance with the applicable PM standard.
4-14
-------
EPA Methods 1-4, 5, 17,
29, and 25A are
included' in Appendix A
to 40 CFR pan 60.
Table 16. Sulfite and Semichemical Initial Compliance Requirements
Parameters^.
- -.>
To Demonstrate Initial Compiiahce erformance Test
with this Emission Umlt... Following this Method...
Sulfite Combustion Sources
Existing sources
Reduce outlet PM emissions to
s 0.040 gr/dscf at 8% O2
Newsouices
Reduce outlet PM emissions to
<0.020 gr/dscf at 8% O,
Method 5,29, or 17"
and
Methods 1 through 4
Paniculate matter
concentration at the
control device
outlet corrected to
Semichemical Combustion Sources
Exist'ng and new sources
Reduce outlet gaseous organic
HAP emissions to <2.97 Ib/ton
BLS (as measured by THC [as
carbon];
or
Reduce outlet gaseous organic
HAP emissions by 90<7r
Method 25A
and
Methods 1 through 4
and
Method of measuring
BLS production
THC mass emission
rate at the control
device outlet
or
THC mass emission
rate at both the inlet
and outlet of the
control device
" If Method 17 is used, you must add a constant value of 0.004 gr/dscf to the results, and
the stack temperature must be no greater than 400°F.
How does a mill demonstrate continuous compliance with the sulfite
and Semichemical combustion source standards?
Mills must install a continuous monitoring system to measure control device
operating parameters. Mills must also establish a range of values for each
operating parameter to be monitored based upon the values recorded during
the initial performance test or during previous qualifying tests. If previous
test outa are used, the mill must certify that the control devices and processes
ha\ e not be modified subsequent to the date of testing. The mill may conduct
multiple performance tests to establish ranges of operating parameter values.
The mills also may expand or replace the operating parameter levels through
subsequent performance tests. Table 17 presents the monitoring
requirements for each emission limit.
Mills can monitor parameters other than those listed in Table 17 only if they
receive written approval from the Administrator. Also, mills that comply
with the NESHAP through operational changes or with control devices not
described in the NESHAP must submit a monitoring plan that proposes which
parameters will be monitored, the range of these parameters, and the
frequency with which these parameters will be monitored, subject to
approval by the Administrator.
4-15 Chapter 4 - NESHAP Requirements
-------
Table 17. Sulfite and Semichemical Continuous Compliance Requirements
"™. " .
To Demonstrate
Continuous Compliance
with this Emission Limit..
Then
Continuously
Monitor these
. Parameters...
•-?
You Must Take
Corrective
Action If...
You Are in Violation
of the Standard If...
Sulfite Combustion Sources
• Existing sources
Reduce outlet PM
emissions to sO.040
gr/dscf at 8% O2
• New sources
Reduce outlet PM
emissions to sO.020
gr/dscf at 8% O2
Monitor.
scrubber
pressure drop
and scrubbing
liquid flow rate
at least once
every
15 minutes
Any 3-hour
average scrubber
parameter value
is outside the
range of values
established
during the initial
performance test
Six or more 3-hour
average scrubber
parameter values are
outside the range of
values established
during the initial
performance test
within any 6-month
reporting period"
Semichemical Combustion Sources
• Existing and new
sources
Reduce outlet gaseous
organic HAP
emissions to ^2.97
Ib/ton BLS
or
Reduce outlet gaseous
organic HAP
emissions by 90Tr
When using an
RTO, monitor
RTO operating
temperature at
least once every
15 minutes
Any 1-hour
average
temperature
value falls below
the value
established
during the initial
performance test
Any 3-hour average
temperature value
falls below the value
established during
the initial
performance test
within any 6-month
reporting period"
a For the purposes of determining the number of nonopacity (e.g., scrubber or RTO)
monitoring exceedances, no more than one exceedance will be attributed in any given
24-hour period.
Must a mill comply at all times?
For sulfite and Semichemical sources, the NESHAP establishes an allowabk
percent of operating time during which exceedances are not considered to tv
a violation of the standard. Periods of exceedance include when operating
parameter values established during the initial performance test cannot K
maintained at the appropriate level. The allowance is in addition to excu.sec
periods under the startup, shutdown, or malfunction provisions.
The exceedance allowances are:
• For existing and new sulfite combustion sources, up to five 3-hour average
scrubber parameter values that are outside the range of values established
during the initial performance test within any 6-month reporting period
4-16
-------
For the purposes of determining the number of nonopacity (e.g., scrubber)
parameter exceedances, the NESHAP states that no more than one
exceedance will be attributed in any given 24-hour period. For example, if a
sulfite pulp mill had six 3-hour average scrubber parameter values outside
the range of values established during the initial performance test within a
particular 6-month reporting period, but two of those values occurred within
a 24-hour period, then only one of those two values would count as an
exceedance in determining a violation. Consequently, the mill would only
have five exceedances within the 6-month reporting period and would be
within its exceedance allowance.
Even though periods of exceedance may be exempt under the MACT
requirements, these periods of exceedance must still comply with any
applicable State requirements. (Sulfite pulp mills are not subject to the
NSPS requirements in 40 CFR part 60, subpart BB.)
What are the recordkeeping and reporting requirements for the sulfite
and semichemical combustion source standards?
Sulfite and stand-alone semichemical mills must also comply with
recordkeeping and reporting requirements. The recordkeeping
requirements for sulfite and semichemical combustion sources are the same
as those presented in Table 11 for kraft and soda combustion sources, with
the following exceptions. Records of black liquor solids firing rates for kraft
and soda recover}' furnaces and CaO production rates for kraft and soda lime
kilns would not be applicable. Additional records would include black
liquor solids firing rates for semichemical combustion sources, RTO
operating temperature readings. 1-hour and 3-hour averages of RTO
operating temperature, RTO operating temperature limit established during
the initial performance test, and occurrences when corrective action is
required or a violation is noted for an RTO.
The reporting requirements for sulfite and semichemical combustion
sources are the same as those presented in Table 12 for kraft and soda
combustion sources, except that the following reports would not be
applicable: reports of kraft and soda PM emission limits established under
the PM bubble compliance alternative, calculations and supporting
documentation for these PM emission limits, and reports of any changes after
these PM emission limits have been approved by the Administrator.
4-17 Chapter 4 - NESHAP Requirements
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Chapter 5 - Other Federal Regulations
Affecting Pulp and Paper Mills
The pulp and paper combustion sources NESHAP does not represent all of
the pollution regulation of the pulp and paper industry. Pulp and paper mills
are subject to additional air requirements under the CAA, water requirements
under the Clean Water Act (CWA), and other Federal, State and local laws
not associated in any way with the pulp and paper combustion sources
NESHAP. This chapter discusses the other Federal regulations, current and
future, that also affect the pulp and paper industry.
Other Federal regulations currently affecting the pulp and paper industry
include the following:
• Pulp and Paper Production NESHAP (40 CFR part 63, subpart S)
• National Ambient Air Quality Standards (NAAQS)
• Kraft Mill NSPS (40 CFR part 60, subparts B and BB)
• Industrial Boilers NSPS (40 CFR part 60, subparts D, Db, and DC)
• Gas-Fired Turbines NSPS (40 CFR part 60, subpart GG)
• Volatile Organic Liquid Storage Vessels NSPS (40 CFR part 60, subpart
Kb)
• Prevention of Significant Deterioration (PSD)/New Source Review
(NSR)
• Pulp and Paper Effluent Limitations Guidelines and Standards,
Pretreatment Standards, and NSPS (40 CFR part 430, subparts A-L)
• National Pollutant Discharge Elimination 'System (NPDES) Related
Statutes and Regulations
• Spill Prevention Control and Countermeasure (SPCC) Plans
(40 CFR part 112)
• Notice of Discharge of Reportable Quantities of Hazardous Substances
(40 CFR parts 116 and 117)
• Resource Conservation and Recovery Act (RCRA)
• Emergency Planning and Community Right-to-Know Act
(EPCRA)/Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)
5-1 Chapter 5 - Other Regulations
-------
if You Need the Following Information...
Then Read..
Other Federal air regulations affecting the pulp and paper industry Section 5.1
Federal water regulations affecting the pulp and paper industry
Federal hazardous waste regulations affecting the pulp and paper
industry
Section 5.2
Section 5.3
Upcoming regulations that will affect pulp and paper mills and Section 5.4
companies
5.1 What other Federal air regulations currently affect pulp and
paper mills?
Other Federal air regulations currently affecting the pulp and paper industry
are shown in Table 18 below:
Table 18. Other Federal Air Regulations
The Following Air
Regulation...
Affects...
By...
NF.SHAP Pulping and bleaching Controlling HAP
40 CFR pan 63, subpart S systems at pulp and
paper mills
NAAQS Energ) generation at Controlling PM. CO. and
pulp and paper mills SO2 and ozone precursors
(VOC and NOxi as part of
the state implementation
plans
NSPS
1 40 CFR p?rt 60. subpart Kraft pulp mills .Controlling PM .md TRS .
BL existing source.1 unde; Sts'-
regulation- St. •.
regulations arc base j or,
EPA guidelines.
2. 40 CFR part 60, Kraft pulp mills Controlling PM and TRS
subpart BB
3. 40 CFR part 60, Industrial boilers Controlling PV NO., and
subparts D, Db, and DC SO2
4. 40 CFR part 60, Gas-fired turbines Controlling MX and SO
subpart GG
5-2
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Table 18. (Continued)
The Pulp and Paper
Producnon NESHAP
(40CFRpan63,
subpan S> regulates
emissions from non-
combustion sources at
pulp and pqper milb
The Following Air
Regulation...
Affects...
By...
5. 40 CFR part 60, subpart
Kb
Volatile organic liquid
storage vessels
Controlling VOC
PSD/NSR
Pulp and paper mills
installing new or
modified equipment
Requiring a preconstruction
permit that imposes
emission limitations based
on best available control
technology (BACT) or
lowest achievable emission
rate (LAER) for criteria
pollutants for which there is
a significant increase
Pulp and Paper Production NESHAP (40 CFR part 63, subpart S).
The pulp and paper production 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
which employ chlorine or chlorine dioxide for bleaching. The NESHAP
requires mills to reduce HAP emissions by collecting and incinerating
pulping process vent emissions, collecting and controlling bleaching process
vent emissions with a caustic scrubber, eliminating the use of certain
bleaching chemicals, and collecting and treating process condensate streams
to remove HAPs through biological treatment or stripping (kraft mills only).
Another option in the NESHAP for treatment of HAPs in kraft mill
condensate systems is to recycle the condensates to an enclosed process unit.
The NESHAP is written to encourage pollution prevention techniques.
NAAOS have been established for six criteria pollutants. Pulp and paper
mills are potential sources of PM. CO, SO2, and ozone precursors (VOC and
NOA Each State must develop a State Implementation Plan (SIP) to identify
sources of air pollution and to determine what actions are necessary to
achie\e 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 preconstruction permitting
requirements (e.g., NSR, PSD).
Kraft Mill NSPS (40 CFR part 60, subpart BB). All 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 lll(d) of
the Act (40 CFR 60, Subpart B). The kraft mill NSPS sets emission limits
for PM and TRS for recovery furnaces, SDTs, and lime kilns and sets
emission limits for TRS only for digester systems, brown stock washer
systems, multiple effect evaporators, black liquor oxidation systems, and
5-3
Chapter 5 - Other Regulations
-------
condensate stripper systems. See Chapter 4 for a more detailed discussion
of the kraft mill NSPS, as this regulation applies to kraft mills only.
Industrial Boilers NSPS (40 CFR part 60, subparts D, Db, and DC) and
Gas-Fired Turbines NSPS (40 CFR part 60, subpart GG). Almost all pulp
and paper mills 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 PM, NOX, and SO2. (Note that
subpart DC does not regulate NOX, and subpart GG does not regulate PM;
Volatile Organic Liquid Storage Vessels NSPS (40 CFR part 60, subpart
Kb). Pulp and paper mills with storage vessels containing a volatile organic
liquid which emits VOCs into the atmosphere would be subject to regulation
under the Volatile Organic Liquid Storage Vessels NSPS (40 CFR part 60,
subpart Kb).
5.2 What Federal water regulations currently affect pulp and
paper mills?
Federal water regulations currently affecting the pulp and paper industn arc
shown in Table 19 below:
Table 19. Federal Water Regulations
The Following Water
Regulation...
Affects...
By...
Effluent limitations
Pretreatment standards
NSPS
40 CFR pan 430, subparts A-L
Indirect-discharging of
pollutants to publicly-
owned treatment works
(POTWs) and direct-
discharging into
navigable waters via
the NPDES program
Setting effluent limitations
and pollutant discharge
limits to POTWb. ais^.
includes Best Manageme' •
Practices (BMP
regulations and trt.
Voluntar-. ;< 1\anc-c^
Technojot". incentive.,
program
Section 402 of CWA
NPDES: Technology and water
quality-based limitations
Direct-discharging of
pollutants into
navigable waters
Setting effiii.Mi Jirmtr.Kir
on pollutant based or
available ttcnnolog) aiK
intended use of receiving
waterbod\ also seb
monitoring and reporunr
requiremerr.
Pretreatment program
Indirect-discharging of
pollutants to POTWs
Setting po'.iti'an; disc nan •
limits to POTV,
5-4
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Table 19. (Continued)
Slay informed aboui
or revised
visiting the EPA
Office of Water's
Pulp and Paper
website'
http://www.epa. gov/
ost/pulppaper/
The Following Water
Regulation...
Affects..,
By...
Storm water permit application Any facility
Establishing pollution
prevention plans and BMP
Section 110 of CWA
40 CFR part 110
Any facility
Prohibiting oil discharges
SPCC
40 CFR part 112
Oil storing/ consuming
facilities
Requiring a spill prevention
and control plan, reporting.
plan updates, and training
obligations
Notice of Discharge of
Reportable Quantities of
Hazardous Substances 40 CFR
parts 116 and 117
Any facility
Requiring reporting of
designated hazardous
substance discharges to U.S.
government following the
Department of
Transportation regulations
Pulp and Paper Effluent Limitations Guidelines and Standards,
Pretreatment Standards, and NSPS (40 CFR part 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.. POTWs). The effluent limitations guidelines and standards are applied
to the mills that directly discharge into receiving water via the NPDES
program. In addition, the effluent limitations guidelines and standards
include best management practices (BMP) regulations designed to prevent or
contain leaks and spills of pulping liquor, soap, and turpentine, and to control
an;, intentional diversions of these substances. They also include the
Voluntary Advanced Technology Incentives Program, which is designed to
entourage direct discharging bleached papergrade kraft mills to install more
pollution prevention technology than required by the regulations.
NPDES Program (CWA 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.
SPCC Plans (40 CFR part 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 parts 116 and 117). This regulation defines the discharges into
5-5
Chapter 5 - Other Regulations
-------
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.
5.3 What Federal hazardous waste regulations currently affect
pulp and paper mills?
Federal hazardous wastes and emergency planning regulations currently
affecting the pulp and paper industry are shown in Table 20 below:
Table 20. Federal Hazardous Waste and Emergency Planning Regulations
The Following
Hazardous Waste
Regulation... Affects.'.. - By... -
RCRA Black liquor at Requiring reclamation and reuse of black
pulp mills 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 pollutant?
Requiring mills to provide information on
chemicals used in the bleach plant
Requiring mills to report emergency
soills or off-site releases (air, water, or
solid wastes)
RCRA. Most RCRA requirements are not industry specific but apply to am
company that transports, .treats, stores, or disposes of hazardous wastes Tht
pulping process generally does not generate significant RCRA-relatec
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 part 261.2(e) and Table 1, §261.4(a)(6). but only if the
black liquor is reclaimed in a recover}' furnace and reused in the pulping
process. Therefore, potential liquor spills that are not reused in the proces-.
such as leaks from surface impoundments used to store black liquor prior to
recovery will be an issue for RCRA compliance assessment.
EPCRA/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 thar
threshold quantities. This report, referred to as the Form R, covers release*
and transfer of toxic chemicals to various facilities and environmental media,
5-6
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Check the AT\V for the
latest information on
other NESHAP affecting
pulp and paper mills
and companies
and allows EPA to compile the national Toxics Release Inventory (TRI) data
base.
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.
5.4 What upcoming regulations will affect pulp and paper mills
and companies?
Pending regulations that will affect the pulp and paper industry include the
following:
Effluent Limitations Guidelines and Standards. EPA plans to publish
revised effluent limitations guidelines and standards for additional
subcategories in the near future, such as dissolving kraft, dissolving sulfite,
and secondary fiber deink. Pending water regulations consist of EPA
proposing effluent limitations guidelines and standards for the pulp and paper
industn subparts that have not already been promulgated. EPA is also
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.
NESHAP. EPA plans to publish NESHAP in the near future for plywood and
composite wood products facilities, surface coating operations at flatwood
panel facilities, paper and other web coating operations at paper products
facilities, industrial boilers, and gas turbines.
5-7
Chapter 5 - Other Regulations
-------
See Appendix Cfor a list of
EPA Regional contacts.
Chapter 6 - Other Requirements and Information
This chapter includes information about who regulates you, your permitting
requirements, and how the NESHAP General Provisions apply to mills
subject to the pulp and paper combustion sources NESHAP.
If You Need the Following Information...
,._ .,..
Then Read..
Who administers this regulation?
Section 6.1
Do I need a Title V permit?
How do I change my permit to include this rule?
What parts of the NESHAP General Provisions apply?
Section 6.2
Section 6.3
Section 6.4
6.1 Who administers this regulation?
Your State or local agency for air pollution control, or your EPA Regional
Office, will regulate you. If your plant is in Indian country, then your Tribe
or your EPA Regional Office will regulate you. You will be regulated by
more than one agency if a state, local or tribal agency has been granted
delegation of this rule.
Not all States have been granted delegation, or, if they have been granted
delegation, they may not have been delegated all portions of the rule. EPA
Regional Offices may also have retained certain rights even after delegation
(for example, you may continue to have dual reporting requirements). You
should check with your EPA Regional Office or State for the latest
information.
6.2 Do I need a Title V permit?
Yoi: will need a Title V permit if you are subject to the pulp and paper
combustion sources NESHAP.
6.3 How do I change my permit to include this rule?
Your options are outlined in Table 21 as follows:
6-1 Chapter 6 - Other Requirements
-------
See Table 1 of the final rule
(located in Appendix A of
this document) to sec which
NESHAP General
Provisions requirements
apply to you.
Table 21. Title V Permitting Requirements
As of March 13,2001, If You Have... Then You Must..
Not been issued a final Title V
permit
Update your permit application or draft permit.
Less than three years left on your
Title V permit
Update your Title V permit during renewal.
Three or more years left on your
Title V permit
Your permitting authority will reopen your
permit within 18 months after the publication
date of the final rule or final amendments.
Title V permitting rules may change after the publication of this document.
Keep abreast of any changes by checking the Federal Register or visit the
Title V websites at http://www.epa.gov/ttn/oarpg/t5main.html and
http://www.epa.gov/oar/oaqps/permits.
6.4 What parts of the NESHAP General Provisions apply?
The NESHAP General Provisions were published in the Federal Register on
March 16, 1994 (59 FR 12408) and apply to all NESHAP, including the pulp
and paper combustion sources NESHAP. This means that when you became
subject to this rule, you also became subject to the NESHAP Genera!
Provisions. Some sections in this rule override the NESHAP General
Provisions. You will find that Table 1 of the final rule shows you which
sections of the NESHAP General Provisions apply to this rule and which do
not. Requirements of the NESHAP General Provisions, except for
notification, recordkeeping. and reporting requirements, are not addressed in
this document. The NESHAP General Provisions can be found in 40 CFR
part 6?, subpart A.
6-2
-------
Appendix A
Final NESHAP and Technical Corrections
-------
Final NESHAP
(January 12, 2001)
A-3
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Friday,
January 12, 2001
Part IV
Environmental
Protection Agency
40 CFR Part 63
National Emission Standards for
Hazardous Air Pollutants for Chemical
Recovery Combustion Sources at Kraft,
Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills; Final Rule
A-5
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3180
Federal Register/Vol. 66, No. 9/Friday, January 12, 2001/Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40CFRPart63
[FRL-«919-9]
RIN206O-AKM
National Emission Standards for
Hazardous Air Pollutants for Chemical
Recovery Combustion Sources at
Kraft, Soda, Sulflte, and Stand-Alone
Semtehemlcal Pulp Mills
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule.
SUMMARY: This action promulgates
national emission standards for
hazardous air pollutants (NESHAP) for
new and existing sources used in
chemical recovery processes at kraft,
soda, sulfite, and stand-alone
semi chemical pulp mills. Hazardous air
pollutants (HAP) that are regulated by
this final rule include gaseous organic
HAP and HAP metals. The adverse
health effects of exposure to these HAP
can include cancer, reproductive and
developmental effects, gastrointestinal
effects, damage to the nervous system,
and irritation to the eyes, skin, and
respiratory system. Emissions of other
pollutants from these sources include
particulate matter (PM), volatile organic
compounds (VOC), carbon monoxide
(CO), sulfur dioxide (SOi), and nitrogen
oxides (NOx).
This final rule implements section
112(d) of the Clean Air Act (CAA) and
is based on the Administrator's
determination that chemical recovery
combustion sources at kraft, soda,
sulfite, and stand-alone semiehemical
pulp mills are major sources of HAP
emissions. The final rule is intended to
protect public health by requiring
chemical recovery combustion sources
to meet standards reflecting the
application of the maximum achievable
control technology (MACT) to control
HAP emissions from these sources.
Implementation of this rule will reduce
emissions of HAP by approximately
2,500 megagrams per year (Mg/yr)
(2,700 tons per year (tpy)) and emissions
of other pollutants by approximately
107,900 Mg/yr (118,900 tpy).
EFFECTIVE DATE: March 13, 2001.
ADDRESSES: Docket No. A-94-67,
containing information considered by
EPA in developing the promulgated
standards, is available for public
inspection between 8:00 a.m. and 5:30
p.m., Monday through Friday, excluding
Federal holidays, at the following
address: U.S. EPA, Air and Radiation
Docket and Information Center (6102),
401 M Street SW, Washington, DC '
20460, telephone (202) 260-7548. The
docket is located at the above address in
room M-1500, Waterside Mall (ground
floor). A reasonable fee may be charged
for copying docket materials.
FOR FURTHER MFORUATON CONTACT: For
further information concerning
applicability and rule determinations,
contact the appropriate State or local
agency representative. If no State or
local representative is available, contact
the EPA Regional Office staff listed in
the SUPPLEMENTARY INFORMATION section
of this preamble. For information
concerning the analyses performed in
developing this rule, contact Mr. Jeff
Telander, Minerals and Inorganic
Chemicals Group, Emission Standards
Division (MD-13), Office of Air Quality
Planning and Standards, U.S. EPA,
Research Triangle Park, North Carolina
27711, telephone number (919) 541-
5427, facsimile number (919) 541-5600,
electronic mail address
telander.jeff@epa.gov.
SUPPLEMENTARY INFORMATION:
Regulated Entities
Categories and entities potentially
regulated by this action are those kraft.
soda, sulfite, and stand-alone
semiehemical pulp mills with chemical
recovery processes that involve the
combustion of spent pulping liquor
Categories and entities potentiallv
regulated by this action include'
Category
SIC cede
2611 2621 2631
NAICS code
32211 32212 32213
Examples of regulated entities
mills.
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likrly to be
regulated by this action To determine
whether your faciht;, i? regulated by this
action, you should examine tm
applicability criteria in § 63 860 of the
final rule. If you have questicr.5
regarding the applicabilit) of this action
to a particular entity, consult the
appropriate EPA Regional Office
representative listed be.uv
U S EPA Region I—Direc'.cr. Ajr
Compliance Program. 1 Congress Stree', Suite
1100 (SEA), Boston, MA 0:114-2C23, Phone
(617) 918-1650; Fax: (617) 918-1505
U.S. EPA Region II—Air Compliance
Branch; 290 Broadway, New York, NY 10007;
Phone: [212) 637-4080; Fax (212) 63^-3998
U.S. EPA Region HI—Chief, Air
Enforcement Branch (3AP12) 1650 Arch
Street; Philadelphia, PA 19103-2029. Phone
(215) 814-3438; Fax. (215) 814-2134, Region
HJ Office Website http://www epa gev/
regSartd/hazpollut/hazairpol htir..
U S. EPA Region IV—Air and Radiation
Technology Branch; Atlanta Federal Center,
61 Forsyth Street; Atlanta, Georgia 30303-
3104; Phone: (404) 562-9105, Fax (404) 562-
9095
U S. EPA Region V—Air Enforcement and
Compliance Assurance Branch (AE— 17J), 77
West Jackson Boulevard, Chicago, IL 60604-
3590; Phone (312) 353-2088; Fax. (312) 353-
8289
U.S EPA Region VI—Chief, Toxics
Enforcement Section (6EN-AT), 1445 Ross
Avenue; Dallas, TX 75202-2733; Phone.
(214) 665-7224, Fax (214) 665-7446; Region
VI Office Website' www epa gov/regioaS
U.S EPA Region VD—901 N. 5th Street,
Kansas City, KS 66101: Phone- (913) 551-
7020; Fax: (913) 551-7844; http-//
www.epa.gov/region07/programs/artoVair/
toxics/airtoxl.htm
U.S EPA Region vm—Air Enforcement
Program (8ENF-T); 999 18th Street Suite 500;
Denver, CO 80202; Phone- (303) 312-6312:
Fax: (303) 312-6409.
U.S. EPA Region IX—Air Division; 75
Hawthorne Street; San Francisco, CA 94105;
Phone: (415) 744-1219, Fax: (415) 744-1076.
U.S EPA Region X—Office of Air Quality
(OAQ-107); 1200 Sixth Avenue; Seattle, WA
98101; Phone- (206) 553-4273, Fax: (206)
553-0110.
Judicial Review
The NESHAP for chemical recovery
combustion sources at kraft, soda,
sulfite, and semiehemical pulp mills
was proposed on April 15. 1998 (63 FK
18783). Today's action announce.* EPA's
final decisions on the rule L'adrr
section 307{b)(l) of the CAA JUCKI-
review of the final rule is available !•_>
filing a petition for review in the U.S
Court of Appeals for the Dis'.ric' c.r
Columbia Circuit by March l *, 20.
Only those objections tc th.i run wh c ;
were raised with reasonable sper.ficiN
during the period for public commer,'
may be raised during judicial review
Under section 307(b)(2) of the CAA, th-
requirements that are the subject of
today's final rule may not be challenged
later in civil or criminal proceedings
brought by EPA to enforce thcsr
requirements.
A-6
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Federal Register/Vol. 66. No. 9/Friday. January 12, 2001/Rules and Regulations
3181
World Wide Web (WWW)
In addition to being available in the
docket, an electronic copy of today's
final rule will also be available on the
WWW through the Technology Transfer
Network (TTN). Following the
Administrator's signature, a copy of the
rule will be posted on the TTN s policy
and guidance page for newly proposed
or final rules at http://www.epa.gpv/ttn/
oarpg/tSpfpr.html. The TTN provides
information and technology exchange in
various areas of air pollution control. If
more information regarding the TTN is
needed, call the TTN HELP line at (919)
541-5384.
Outline
The following outline is provided to
aid in reading this preamble to the final
rule.
I. Background and Public Participation
H. Summary of Final Rule
A. Applicabiht\
B. Standaids
C. Performance Test Requirements
D. Monitoring Requirements
E. Recordkeeping and Reporting
Requirements
IE Summary of Changes Since Proposal
A Applicability
B. Definitions
C Standards
D Performance Test Requirements
E. Monitoring Requrerrer.'s
F Reporting Requirements
G Delegation of Author.:;,
IV. Summar\ of Responses to Major
Comments
V. Sununan of Impacts
A Air Qiiahn Impacts
B Cos; Impocf-
C Economic Impacts
D. Benefits Anah s-.s
E Non-Air Enviroarcenta1 Imparts
F Energy Impact'
VI Administrative Rfq-irfcmE-"'^
A ExecatneOrdt: 1286C Regulator)
Planning and Reviev.
B Executive Oidei i3;;: Fedfrsl sr.
C Executive Orde: 130b4 Cc is-Jta'.iOC
and Coordinator. w.Lh Lnd.ar. Tr.Dal
Government
D Executive Order 13tMf Protecticn of
Children from Ervironmental Health
Risks and Safe:-, Risks
E. Unfunded Mandates Refer- .'.:' of 1995
F Regulatory Flexib.r", Ac' :KrA'.ES
amended by the Small Business
Regulatory Enforcemcr;' Fairness Act of
1995 (SBREFA), 5 U S C 60: e: seq
C Paperwork Reducticr. Ac'
H. National Technolog-. Transfer and
Advancemen: Act o! 1995
I. Congressional Reviev. Ac'
I. Background and Public Participation
Section 112 of the CAA requires EPA
to list categories and subcategones of
major sources and area sources of HAP
and to establish NESHAP for the listed
source categories and subcategones.
Major sources of HAP are those that
have the potential to emit greater than
9.07 Mg/yr (10 tpy) of any one HAP or
22.68 Mg/yr (25 tpy) of any combination
of HAP.
Section 112 of the CAA requires that
we establish NESHAP for the control of
HAP from both new and existing major
sources. The CAA requires the NESHAP
to reflect the maximum degree of
reduction in emissions of HAP that is
achievable. This level of control is
commonly referred to as MACT.
The MACT floor is the minimum
control level allowed for NESHAP and
is defined under section 112(dX3) of the
CAA. In essence, the MACT floor
ensures that the standard is set at a level
that assures that all major sources
achieve the level of control at least as
stringent as that already achieved by the
better-controlled and lower-emitting
sources in each source category or
subcategory. For new sources, the
MACT floor cannot be less stringent
than the emission control that is
achieved in practice by the best-
controlled similar source. The MACT
standards for existing sources can be
less stringent than standards for new
sources, but they cannot be less
stringent than the average emission
limitation achieved by the best-
performing 12 percent of existing
sources in the category or subcategory
(or the best-performing 5 sources for
categories or subcategones with fewer
than 30 sources) (CAA section
.
In developing MACT, we also
consider control options that are more
stringent than the floor. We may
establish standards more stringent than
the floor based on the consideration of
the cost of achieving the emissions
reductions, any non-air quality health
and environmental impacts, and energy
requirements (CAA section 112(d)(2)).
On July 16, 1992 (57 FR 31576), we
published a list of source categories
slated for regulation under section
112(c). That list included the pulp and
paper production source category
regulated by the standards being
promulgated today. We proposed
standards for chemical recovery
combustion sources at kraft, soda,
sulfite, and stand-alone semichemical
pulp mills covered by this rule on April
15,1998 (63 FR 18783).
As in the proposal, the final standards
give existing sources 3 years from the
date of promulgation to comply. Sources
that begin construction or
reconstruction after April 15, 1998 must
comply with the standards for new
sources by March 13, 2001 or upon
startup, whichever is later. We believe
these standards to be achievable by
affected sources within the time
provided.
Emissions limits, as well as
monitoring, performance testing,
recordkeeping, and reporting
requirements are included in the final
rule. All of these components are
necessary to ensure that sources comply
with the standards both initially and
over time. However, we have made
every effort to simplify the requirements
in the rule.
The preamble for the proposed
standards described the rationale for the
proposed standards. Public comments
were solicited at the time of proposal.
The public comment period lasted from
April 15,1998 to June 15,1998.
Industry representatives, regulatory
agencies, environmental groups, and the
general public were given the
opportunity to comment on the
proposed rule and to provide additional
information during and after the public
comment period. Although we offered at
proposal the opportunity for oral
presentation of data, views, or
arguments concerning the proposed
rule, no one requested a hearing, and a
hearing was not held.
We received a total of 35 letters
containing comments on the proposed
rule during and after the public
comment period. Commenters included
individual pulp and paper companies.
an industry trade association, an
environmental group, a local regulatory
agency, an association of State and local
regulatory agencies, and an association
of air pollution control vendors Today's
•final rule reflects our full consideration
of all of the comments received, Major
public comments on the proposed rule,
along with our responses to those
comments, are summarized in this
preamble. See the Summary of Public
Comments and Responses memorandum
for a more detailed discussion of public
comments and our responses (docket
No. A-94-67).
n. Summary of Final Rule
A. Applicability
The final rule applies to all existing
and new kraft, soda, sulfite, and stand-
alone semichemical pulp mills with
chemical recovery processes that
involve the combustion of spent pulping
liquor. Specifically, the affected sources
that are regulated by today's final rule
are each new nondirect contact
evaporator (NDCE) recovery furnace and
associated smelt dissolving tank (SDT)
located at a kraft or soda pulp mill, each
new direct contact evaporator PCE)
recovery furnace system and associated
SDT located at a kraft or soda pulp mill,
each new lime kiln located at a kraft or
A-7
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001 /Rules and Reguktions
soda pulp mill, each new or existing
sulfite combustion unit located at a
sulfite pulp mill, each new or existing
semichemical combustion unit located
at a stand-alone semichemical pulp
mill, and each existing chemical
recovery system located at a kraft or
soda pulp milt. The chemical recovery
system is defined as all existing DCE
and NDCE recovery furnaces, SDT, and
lime kilns at a kraft or soda pulp mill.
All existing kraft and soda pulp mills
have chemical recovery processes that
involve the combustion of spent pulping
liquor. However, several existing sulfite
and stand-alone semichemical pulp
mills do not recover pulping chemicals
by combusting spent liquor. Three of the
11 sulfite mills use a calcium-based
sulfite process and do not have
chemical recovery combustion units
and, thus, are not impacted by this final
rule. One of the 13 stand-alone
semichemical pulp mills burns spent
liquor in a power boiler and does not
have chemical recovery; therefore, that
mill also is not impacted by this final
rule.
B. Standards
Today's final rule regulates HAP
metals emissions and/or gaseous organic
HAP emissions for chemical recovery •
combustion sources in the pulp and
paper production source category. The
promulgated standards are summarized
in Table 1.
A-8
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TABLE 1. SUMMARY OF PROMULGATED STANDARDS'
Subcatrqory
Kraft
and
soda
Sulfite
Stand-alone
aerai-chemical
Rm 13*5 Inn point
Serovpr y
furnarei !NDCE
inrt DOE)
SDT
Lime kilns
Sulfite
combustion
units
SemichpmicaL
combustion
units
HAP petals standard
Fx i st inq
'H <• 0.1"
Tt/dscm (0.044
gr/dicf) at fl»
oxyq<*n
PM 4 0.10 kg/Kg
(O.?0 Ib/ton)
RLS
PM s 0.15
g/dscm (0.064
gr/d!!cf> at 10»
oxygen
PM « 0.09?
q/dscm (0.040
gr/dscf) at B»
oxygen
No standard
New
PM <0.n.14
g/dscm (0.015
gr/dscf)
it R* oxygen
PM s 0.06 kg/Mq
(0.12 Ib/ton)
BLS
PM 5 0.023
g/dscm (0.01
gr/dscf)
at 10% oxygpn
PM 1 0.046
g/dscm (0.0?0
gr/dscf)
at 8% oxygen
!"Q standard
Alternate HAP metals standard
("bubble" )
Existing
Mill-specif ic
PM emission
limit (kg/Mg
(Ib/ton) BLS)
>ased on
calculated
value of the
sum of the
individual
emissions
limits for
recovery
furnaces, SDT,
and lime kilns.
See equation 1
in
$63.865(a) (1)
of the final
rule .
Not applicable
Not applicable
New
No "bubble"
alternate
standard for
new sources
Not applicable
Hot applicable
Gaseous organic HAP standard
Existing
No standard
No standard
No standard
No standard
Gaseous organic
HAP f 1.49
kg/Mg (2.97
Ib/ton) BLS lag
measured by
THC)
OR
90» reduction
New
Gaseous organic
HAP <. 0.012
kq/Mg (0.025
Ib/ton) BLS (as
masured by
methanol)
lo standard
No standard
No standard
Gaseous organic
HAP < 1.49
kg/Mg (2.97
Ib/ton) BLS (as
measured by
THC>
OR
90% 'reduction
3
fr
f
I
00
w
g/dscm - grams per dry standard cubic m«ter, gr/dscf • grains
Ib/ton m pounds p*r ton, BLS - black liquor solids, and THC m
Emissions of gaseous organic HAP from these sources arc rcgul
paper mills.
per dry standard cubic foot, kg/Mg - kilograms per megagram,
total hydrocarbons.
ated as part of the NCSHAP for noncombustion sources at pulp and
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001 /Rules and Regulations
The standards for each subcategory
are discussed in the following sections
by the pollutant regulated.
1. HAP Metals Standards for Kraft and
Soda Pulp Mills
Today's rule promulgates PM
emissions limits as a surrogate for HAP
metals for new and existing recovery
furnaces, SDT, and lime kilns at kraft
and soda pulp mills. The PM emissions
limits are established at the MACT floor
level. For existing kraft and soda
recovery furnaces and SDT, the MACT
floor level corresponds (coincidentally)
to the promulgated PM emissions limits
in the new source performance
standards (NSPS) for kraft pulp mills
(43 FR 7568, February 23,1978). We
believe this level best represents the
level of performance achievable by the
average of the best-performing 12
percent of sources, considering normal
process and operating variability. For
existing kraft and soda lime kilns, the
MACT floor level is more stringent than
the NSPS because data indicate that the
average of the best-performing 12
percent of sources can achieve a more
stringent level.
The final rule also allows the use of
a "bubble compliance alternative" for
determining compliance with the HAP
metals standards for existing process
units (i.e., recover)' furnaces, SDT, and
Ijme kilns) in the chemical recover)'
system at kraft and soda pulp mills. The
bubble compliance alternative allows
mills to set PM emissions limits for each
existing process unit in the chemical
recovery system at the mill such that, if
these limits are met, the total emissions
from all existing process units are less
than or equal to a mill-specific bubble
limit. This mill-specific bubole limit is
calculated based on the promulgated
emissions standards (referred to ic the
rule as reference concentratior.5 or
reference emissions rates) for each
process unit and mill-specific gas flow
rates and process rates Equation 1 in
§63.865(a)(l) of the final rule will be
used to calculate the bubble limit based
on PM emissions.
As in the proposed rule, the bubble
. compliance alternative is not applicable
to new affected sources under thk
rulemakmg. Thus, all new affected
sources at kraft and soda pulp mills are
required to meet the individual
emissions limitations set for those
sources. Also, owners or operators of
existing process units subject to the
NSPS for kraft pulp mills are required
to continue to meet the PM emissions
standards of that rule, regardless of
which option they choose for complying
with today's HAP metals standards
(because that standard is a separate
regulatory requirement which remains
in place).
Owners or operators that choose to
comply with the HAP metals standards
using the bubble compliance alternative
are required to submit PM emissions
limits to the Administrator for approval
for each existing kraft or soda recovery
furnace, SDT, and lime kiln at the mill.
Before the PM emissions limits are
approved, the owner or operator must
submit documentation demonstrating
that if the PM emissions limits for each
emission source are met, the entire
group of process units in the chemical
recovery system are in compliance with
the millwide allowable PM emission
level. The allowable PM emission level
is determined from the applicable
bubble equation using the reference PM
concentrations and reference PM
emissions rates for each process unit
and source-specific factors for exhaust
gas flow rates and process rates. Once
approved by the Administrator, the PM
emissions limits are incorporated in the
operating permit for the mill. Thereafter,
the owner or operator of the kraft or
soda pulp mill demonstrates
compliance with the standards by
demonstrating that each recovery
furnace, SDT, and lime kiln emits less
than or equal to the approved PM
emission limit for that process unit. In
addition, the PM emissions limits for
any existing recovery furnace, SDT, or
lime kiln subject to the 1978 NSPS for
kraft pulp mills must be at least as
stringent as the PM emissions limits
established in the NSPS. An example of
how the bubble compliance alternative
can be used to establish PM emissions
limits for process units in a chemical
recovery system at an example mill is
provided in the administrative record
Pocket No. A-94-67).
With one exception, owners or
operators that choose to comply with
the HAP metals standards using the
bubble compliance alternative must
include all existing process units in a
chemical recovery1 system in the bubble
Any existing process unit that can be
classified as a stand-by unit (;' e., a
process unit that operates for less than
6,300 hours during any calendar year)
cannot be included as part of a bubble
Owners or operators of stand-by units
must accept the promulgated PM
emissions limits shown in Table 1 for
those units.
2. Gaseous Organic HAP Standards for
Kraft and Soda Pulp Mills
Today's rule promulgates a gaseous
organic HAP standard for new recovery
furnaces using methanol as a surrogate
for gaseous organic HAP. All new
recovery furnaces at kraft and soda pulp
mills must meet a gaseous organic'HAP
limit, as measured by methanol, of 0.012
kilogram per megagram (kg/Mg) (0.025
pound per ton (lb/ton)) of black liquor
solids (BLS) fired. There are no gaseous
organic HAP standards under today's
rule for existing NDCE recovery
furnaces or DCE recovery furnace
systems.
3. HAP Metals Standards for Sulfite
Pulp Mills
Today's rule promulgates PM
emissions limits as a surrogate for HAP
metals for new and existing sulfite
combustion units. Existing sulfite
combustion units must meet e PM
emission limit of 0.092 gram per dry
standard cubic meter (g/dscm) (0,040
grain per dry standard cubic foot (gr/
dscO) corrected to 8 percent oxygen
New sulfite combustion units must meet
a PM emission limit of 0.046 g/dscm
(0.020 gr/dscf) corrected to 8 percent
oxygen.
4. Gaseous Organic HAP Standards for
Stand-Alone Semichemical Pulp Mills
Today's rule promulgates gaseous
organic HAP standards for existing and
new semichemical combustion units
using total hydrocarbon (THC) as a
surrogate for gaseous organic HAP. All
stand-alone semichemical pulp mills
with existing or new chemical recover,'
combustion units must reduce gaseous
organic HAP emissions (as measured b\
THC reported as carbon) from these
units by 90 percent, or meet a gaseou;
organic HAP emission limit (as
measured by THC reported as carbon) of
1.49 kg/Mg (2.97 lb/ton) of BLS Bred
C. Performance Test Requirements
The following discussion identifies
the test methods to be used for
compliance determination^
Test Method 5, "Determmatic:: of
Participate Emissions from Station."
Sources" (40 CFR part 60, apper.un
A)—in conjunction with e mi- iMjrprr1'
of oxygen concentration in '.I" 'i. '..- t
using either Test Method 3A
"Determination of Oxygen ard Carbcr
Dioxide Concentrations in EmiiSior.-
from Stationary Sources (i^t*-. r.cnt
Analyzer Procedure)" (40 CF K p^;t 6^
appendix A) or Test MethoJ 3£, "Ga
Analysis for the Detenrun an c. of
Emission Rate Correction factor o:
Excess Air" (40 CFR part 6P appends
A)—is the test method for dete-imn.nc
compliance with the PM emissions
limits for new and existing Ijaft and
soda recovery furnaces, SUT, and linv
kilns and for new and existing sulfite
combustion units. Test Method 2 j
"Determination of Metals En.issior.
from Stationary Sources" (40 CFR pir
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3185
60, appendix A) may be used as an
alternative to Test Method 5 for
measuring PM emissions. Test Method
17, "Determination of Particulate
Emissions from Stationary Sources (In-
Slack Filtration Method)" (40 CFR part
60, appendix A) may also be used as an
alternative to Test Method 5 if a
constant value of 0.009 g/dscm (0.004
gr/dscf) is added to the results of Test
Method 17, and the stack temperature is
no greater than 205 degrees Centigrade
(°C) (400 degrees Fahrenheit (°F)).
Test Method 308, "Procedure for
Determination of Methanol Emissions
from Stationary Sources" (40 CFR part
63, appendix A) is the test method for
determining compliance with the
gaseous organic HAP emission limit for
new kraft and soda NDCE recovery
furnaces that are not equipped with dry
electrostatic precipitator (ESP) systems
and for DCE recovery furnace systems
Test Method 25A, "Determination of
Total Gaseous Organic Concentration
using a Flame lonization Analyzer" (40
CFR part 60, appendix A) is the test
method for determining compliance
with the gaseous organic HAP emission
limit for new and existing combustion
units at stand-alone semichemical pulp
mills.
\D Monitoring Requiremeris
Each owner or operator of an affected
, source or process unit must install.
operate, calibrate, and maintain a
continuous monitoring system for each
affected source or process unit The
owner or operator also must establish a
range of values for each operating
parameter (associated with a process
operation or with an emission control
device) to be monitored based upon
values recorded dunng the init!?.":
performance test or during qualify ing
previous performance tests using the
required test methods. If values from
previous performance tests are Ufi tc
establish the operating parameter range,
the owner or operator must certify that
the control devices and processes had
not been modified subsequent to ir,e
testing upon which the data us d to
establish the operating ranges wer*
obtained. Tne owner or operator msy
conduct multiple performance tests to
establish ranges of operating parameters
The owner or operator also mc\
establish expanded or replacement
ranges during subsequent performance
tests An exceedance of the operating
parameters occurs when tne measured
operating parameter levels, averaged
over a specified time period, are outside
the established range for a
predetermined duration However, with
the exception of opacity exceedanc.es,
no more than one exceedance would be
attributed to an affected source or
process unit during any given 24-hour
period. The following paragraphs
describe the operating parameters to be
monitored, the averaging periods and
frequency with which these parameters
should be monitored, when corrective
action is required to return operating
parameters to levels that are within the
established range, and when operating
parameter exceedances constitute a
violation of the emissions standards.
Owners or operators of existing kraft
or soda recovery furnaces that are
equipped with an ESP for PM control
must install, calibrate, maintain, and
operate continuous opacity monitoring
systems (COMS). The COM3 must
perform at least one cycle of sampling
and analysis for each successive 10-
second period and one cycle of data
recording for each successive 6-minute
period. If the average often consecutive
6-minute average values of opacity
exceeds 20 percent, the owner or
operator must initiate the corrective
actions contained in the mill's startup,
shutdown, and malfunction (SSM) plan.
A violation of the applicable emissions
standards would occur when opacity is
greater than 35 percent for 6 percent or
more of the operating time during any
quarterly period.
Owners or operators of new kraft or
soda recovery furnaces and new or
existing kraft or soda lime kilns that are
equipped with ESP for PM control must
also install, calibrate, maintain, and
operate COMS. The COMS must
perform at least one cycle of sampling
and analysis for each successive 10-
second period and one cycle of data
recording for each successive 6-minute
period. If the average often consecutive
6-minute average values of opacity
exceeds 20 percent, the owner or
operator must initiate the corrective
actions contained in the facility's SSM
plar.. A violation of the applicable
emission1; standards would occur when
opacity is greater than 20 percent for 6
percent or more of the operating time
dunng any quarterly period.
Owners or operators using wet
scrubbers to meet the PM emissions
limits for any kraft or soda recover)1
furnace, SDT, or lime kiln or any sulfite
combustion unit must install, calibrate,
maintain, and operate a continuous
monitoring system capable of
determining and recording the pressure
drop and scrubbing liquid flow rate at
least once for each successive 15-minute
period. If any 3-hour average of the
pressure drop or scrubbing liquid flow
rate falls outside the established range,
the owner or operator must initiate the
corrective actions included in the
facility's SSM plan. A violation of the
applicable emissions standards occurs
when six or more 3-hour average values
of either parameter are outside the
established range during any 6-month
reporting period.
Owners or operators using
regenerative thermal oxidizers (RTO) to
comply with the gaseous organic HAP
emission standard for chemical recovery
combustion units at stand-alone
semichemical mills must establish a
minimum RTO operating temperature
that indicates at least a 90 percent
reduction in HAP emissions (as
measured by THC reported as carbon),
or outlet HAP emissions (as measured
by THC reported as carbon) of less than
or equal to 1.49 kg/Mg (2.97 Ib/ton) of
BLS fired. To ensure ongoing
compliance, the owner or operator must
install, calibrate, maintain, and operate
a monitoring system to measure and
record the RTO operating temperature
for each successive 15-minute period. If
any 1-hour average of the operating
temperature falls below the minimum
established temperature, the owner or
operator must initiate the corrective
actions contained in the facility's SSM
plan. A violation of the applicable
emissions standards occurs when any 3-
hour average of the RTO operating
temperature fails below the minimum
established temperature.
The owner or operator of an affected
source or process unit that uses a wet
scrubber, ESP, or RTO to comply with
today's standards may monitor
alternative operating parameters subject
to prior written approval by the
Administrator, as specified in §63.8(f).
The owner or operator of an affected
source or process unit that is complying
with today's standards through
operational changes or by a control
device other than those described above
must submit a plan proposing
parameters to be monitored, parameter
ranges, and monitoring frequencies to be
used to determine ongoing compliance,
subject to approval by the
Administrator. If any 3-hour average
value of a monitored parameter falls
outside the established range, the owner
or operator must initiate the corrective
actions included in the facility's SSM
plan. A violation of the emissions
standards occurs when six or more 3-
hour average values of a monitored
parameter are outside the established
range during any 6-month reporting
perrod.
Owners or operators complying with
the gaseous organic HAP standard for
new kraft and soda recovery furnaces
through the use of an NDCE recovery
furnace equipped with a dry ESP system
are not required to perform any
continuous parameter monitoring for
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Federal Register /Vol. 66, No. 9/Friday, January 12. 2001/Rules and Regulations
gaseous organic HAP. However, each
owner or operator must maintain onsite
a certification statement signed by a
responsible mill official that an NDCE
recovery furnace equipped with a dry
ESP system is in use.
E. hecordkeeping and Reporting
Requirements
In addition to all of the recordkeeping
and reporting requirements outlined in
§ 63.10. owners or operators of kraft.
soda, sulfite, and stand-alone
semichemical pulp mills must maintain
the following records for each affected
source or process unit: Records of the
BLS firing rates for all recovery furnaces
at kraft and soda pulp mills and spent
liquor solids firing rates for all chemical
recovery combustion units at sulfite and
stand-alone semichemica! pulp mills,
records of the lime production rates
(calculated as calcium oxide) for all
kraft and soda lime kilns, records of all
parameter monitoring data, records and
documentation of supporting
calculations for compliance
determinations, records of the
established monitoring parameter ranges
for each affected source or process unit,
and records of all certifications made in
order to determine compliance with the
gaseous organic HAP standards
Consistent with requirements in the
NESHAP General Provisions in subpart
A of 40 CFR part 63 and the operating
permit program in 40 CFR part 70. all
records must be maintained for a
minimum of 5 years.
m. Summary of Changes Since
Proposal
A Applicability
At proposal, we defined affected
source as each kraft and soda NDCE
recovery furnace and associated SDT,
each kraft and soda DCE recover)
furnace and associated SDT. each kraft
and soda lime kiln, each sulfite
combustion unit, and each
semichemical combustion unit
However, this definition would ha\ e
prevented mills from averaging
emissions of HAP metalr or the PM
surrogate for HAP metals across their
existing recovers1 fjrnaces. SDT, and
lime kilns (a bubble compliance
alternative which we proposed) To
allow averaging across these existing
emission points, we have revised the
definition of affected source to include
existing NDCE recovery furnaces, DCE
recovery furnaces, SDT, and lime kilns
as process units within a chemical
recovery system affected source.
As in the proposed rule, new sources
are not eligible for the bubble
compliance alternative under this
rulemaking, given that state-of-the-art
equipment design and add-on controls
can be integrated and installed most
cost-effectively during construction of
new sources. New sources can be
designed and constructed with
maximized compliance in mind. Abo,
sources classified as new by vjrtue of
being reconstructed can be
reconstructed with maximized
compliance in mind. Therefore, we have
not revised the definition of affected
source for new sources. Each new kraft
and soda recovery furnace and
associated SDT, and each new kraft and
soda lime kiln will continue to be
defined as an affected source by itself.
B. Definitions
Because of the changes in definition
of affected source in the final rule, we
have added definitions for "chemical
recovery system" and "process unit" to
§63.861 in the final rule. Chemical
recovery system is defined as all
existing DCE and NDCE recovery
furnaces, SDT, and lime kilns at a kraft
or soda pulp mill. Process unit is
defined as an existing DCE or NDCE
recovery furnace, SDT, or lime kiln in
a chemical recovery system at a kraft or
soda pulp mill.
To take into account the development
of gasification technology as a
replacement for conventional recovery
furnace systems, we have added a
definition for "black liquor gasification"
to § 63.861 in the final rule. Black liquor
gasification is defined as the
thermochemical conversion of black
liquor into a combustible gaseous
product. For the same reason, we also
have revised the definitions for
"recovery furnace," "kraft recovery
furnace," "semichemical combustion
unit," and "soda recover,' furnace" to
include black liquor gasification.
In order to eliminate any confusion
with the term "PM," we have replaced
the term "PM HAP" with "HAP metals"
throughout the final rule. Therefore, the
definition for "HAP metals" in § 63.861
of today's rule replaces the definition
for "PM HAP."
C Standards
In the proposed rule, we included a
standard whereby existing kraft and
soda lime kilns must ensure that the
concentration of PM in the exhaust
gases discharged to the atmosphere is
less than or equal to 0.15 g/dscm (0.067
gr/dscf) corrected to 10 percent oxygen.
We have decided not to promulgate this
PM standard because this proposed
standard does not reflect the
performance of MACT (i.e., the
surrogate PM emissions levels
achievable by the best-performing lime
kirns, which are controlled by ESP). We
have revised the PM standard for
existing lime kilns in the final rule to be
equivalent to the revised HAP metals
MACT floor PM level of 0.15 g/dscm
(0.064 gr/dscf) corrected to 10 percent
oxygen. (There is also a bubble
compliance alternative, whereby, as
explained earlier, PM emissions from
the recovery furnace, SDT, and lime kiln
could in essence be summed so long as
the summed emissions are no greater
than the sum of the otherwise-
applicable MACT emission standard for
each unit,)
The proposed rule included a
compliance option whereby existing
kraft and soda recovery furnaces, SDT,
and lime kilns could meet a standard for
individual HAP metals, rather than for
the PM surrogate for HAP metals (63 FR
18758,18765, and 18769, April 15,
1998; proposed $63.862). We have
decided not to promulgate this
alternative HAP metals standard
because this proposed standard does not
reflect the performance of MACT (i.e.,
the HAP metals emissions levels
achievable by the best-performing
sources) and also because it would have
other significant technical deficiencies.
(See docket No. A-94-67.) (Necessarily.
we also are not promulgating the bubble
compliance alternative associated with
this HAP metals option.)
D. Performance Test Requirements
To correct an oversight in the
proposed rule, we have added an
oxygen correction equation for
volumetric gas flow rates to the final
rule under new § 63.865(b)(4). The
equation will be used to correct gas
streams to the same oxygen content as
the associated emission limit (e g , 8
percent oxygen for recover)' furnaces, 10
percent oxygen for lime kilns) For the
same reason, we also revised the PM
emission limit equations for the bubble
compliance alternative in paragraphs
(a)(l), (2)(i), and(2)(iii)of§63 865 for
the final rule to reflect the oxygen
correction for volumetric gas flow rates
Because SDT exhaust conditions already
approximate ambient air conditions, v.c
have removed the oxygen correction ;:.
the PM emission limit equation for SI;.
in § 63.865(a)(2)(ii) from the fine rult
We have also clarified the oxygen
correction equation in § 63 865(b)(2),
which is used to correct PM
concentrations, for the final rult
E. Monitoring Requirements
In order to account for any recovery
furnaces that might use a wet scrubber.
we have revised the wet scrubber
monitoring provisions in § 63.864(a)[21.
(c)(l)(ii), and (c)(2)(ii) for the final rule
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3187
to include kraft or soda recovery
furnaces. We have clarified the opacity
. corrective action provisions in
§ 63.864(c)(l)(i) of the final rule to state
that affected sources or process units are
required to implement corrective action
when the average often consecutive 6-
minute averages results in a
measurement greater than 20 percent
opacity. We also have revised the
opacity violation provisions in
§ 63.864(c)(2)(i) and (ii) to clarify in the
final rule that a violation of the
applicable emission standard would
occur when the opacity is greater than
the specified level for 6 percent or more
of the operating time in any quarterly
period.
F. Reporting Requirements
We have revised the excess emissions
reporting provisions of § 63.867(c) for
the final rule to clarify that reporting
excess emissions below the violation
thresholds of §63.864(c) does not
constitute a violation of the applicable
standard.
G. Delegation of Authont)
We have revised the delegation of
authority provisions in g 63 868 for the
final rule to include the following
authorities which will be retained by
the Administrate: and no! transferred to
a State. Approval of alternatives to
standards in §63.862 under §63 6(g),
approve! of major alternatives to test
methods under § 63 7(e}(2][i;) and (f)
and as defined in §63.90, approval of
major alternative? to monitoring under
§63.8(f) and as defined in §63.90, and
approval of major alternative? to
recordkeeping and reporting under
§ 63 10(f) and as defined in § 63 9?
These authorities are retained because
an) requests by sources for alternative
standards must be considered bv EPA
and acted upon ir. a notice ar.d
comment rulemakinp \\ecan-.c!
delegate authorities that ma> alter the
stringency of the standard that require
Federal oversight for np'.iona!
consistency, or that may require Federal
rulemaking Requests to revise
standards for the source categc-y (or
portions thereof) must be addressed
through the subpart E rulemaking
process for alternative standards
IV. Summary of Responses to Major
Comments
This section summarizes the major
comments we received on the proposed
rule and our responses to those
comments. A more comprehensive
summary of comments and responses
can be found in docket No A-94-67.
Comment• Commenters questioned
the proposed MACT Door of "no
control" for gaseous organic HAP
emissions from existing NDCE recovery
furnaces and stated that the
performance of dry ESP systems should
be the basis of the MACT floor for
gaseous organic HAP emissions from
existing NDCE recovery furnaces. One
commenter provided a list of 13 NDCE
recovery furnaces equipped with dry
ESP systems, which is a sufficient
number of recovery furnaces to define
the MACT floor. A commenter also
noted that wet to dry ESP system
conversion is a cost-effective control
option.
Response: We are not basing the
MACT floor for existing NDCE recovery
furnaces on this technology for the
following reasons. We have concluded
that existing NDCE recovery furnaces do
not represent the "best" or "maximum
achievable" technology. It is possible
that black liquor gasification is a means
of reducing gaseous organic HAP
emissions from chemical recovery
operations that provides environmental
benefits (notably energy savings) which
are superior to those provided by NDCE
recovery furnaces (whether equipped
with wet or dry ESP systems).
Compared with NDCE recovery furnace
performance, development of the
proposed gasification technology
promises reduced consumption of fossil
fuel, increased efficiency in energy
conversion and chemical recovery,
elimination of the smelt-water explosion
hazard (inherent to the operation of
conventional recovery furnaces),
reduced maintenance costs, and
significantly lower environmental
emissions of criteria pollutants (PM,
SOj, NO*, VOC precursors to ozone,
and CO) and greenhouse gases (63 FR
26607, May 8, 2000, Proposed Final
Project Agreement for Georgia-Pacific
XL Project)
Because gasification systems do not
require the use of an ESP, the costs that
would be incurred by converting a wet
ESP system to a dry ESP system are not
recoverable if the NDCE recovery
furnace is replaced with a gasification
system. Therefore, if we require existing
NDCE recover)' furnaces with wet ESP
systems by virtue of a MACT floor to
retrofit to dry ESP systems, we would
tend to eliminate the incentive for the
industry to replace the NDCE recovery
furnaces with gasification systems
before the end of the useful life of the
dry ESP systems. Thus, it is our view
that a MACT floor requirement which
results in retrofitting to dry ESP systems
would create disincentives that would
discourage possible conversion to the
even more promising gasification
technology, so that such a requirement
need not be considered to be "MACT."
See Portland Cement Ass'n v, EPA, 486
F.2d 375, 365 (D.C. Cir. 1973); Essex
Chemical Corp. v. Ruckelshaus, 466
F.2d 427,439 (D.C. Cir. 1973) (in
establishing technology-based
standards, EPA must consider counter-
productive effects of a control
technology in determining whether it is
a "best" technology).
In a related matter, there is a further
question as to whether existing DCE
recovery furnaces should be subject to
MACT floor or beyond-the-floor
standards for gaseous organic HAP. We
considered whether to require
conversion of DCE recovery furnace
systems to NDCE recovery furnaces with
dry ESP systems as a beyond-the-floor
standard. The capital costs of this
retrofitting would be in the billions of
dollars and would not be justified by the
amount of HAP removed. Moreover, we
do not view NDCE recovery furnaces
with dry ESP systems as MACT for
existing DCE recovery furnaces because
it would create the same disincentives
for conversion to gasification just
discussed, including potentially
foregoing significant energy-saving
opportunities. (See CAA section
112(d)(2), which includes energy
impacts as a relevant consideration in
beyond-the-floor determinations.)
Consequently, we are not adopting a
beyond-the-floor standard for DCE
recovery furnaces.
It would also be highly anomalous to
adopt a MACT floor based on the
performance of NDCE recovery furnaces
with dry ESP systems, for the following
.reason. As explained above, we are not
adopting a beyond-the-floor standard for
existing DCE recovery furnaces, and the
MACT floor for existing DCE recovery
furnaces is "no control." This would
yield the result that a MACT floor
determination would apply only to
NDCE recovery furnaces—the better-
performing furnace type. Hence the
anomaly—the only type of existing
recovery furnace to incur regulators-
costs would be the better-performing
NDCE recovery furnaces. Although, as
also explained above, we currently do
not view gaseous organic HAP control of
existing NDCE or DCE recovery furnaces
as MACT in order to preserve incentives
for conversion of the furnaces tj
gasification systems, in determining that
there should be no further control of
these units under CAA section 112(d) at
the present time, we are also swayed by
avoiding the anomaly of controlling
only NDCE recovery furnaces.
We also note that the new source
standard for recovery furnaces reflects
the performance of NDCE recovery
furnaces equipped with dry ESP
systems. We could not base the standard
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on the performance of gasification at
this time because accurate data
documenting performance on pulp and
paper combustion sources do not yet
exist. Obtaining accurate performance
data on gasification systems is one of
the purposes of the proposed Final
Project Agreement for the Georgia-
Pacific XL Project (63 FR 26607, May 8.
2000). In any case, we also do not
believe that this standard poses the
same potential to discourage use of
gasification. First, we expect that
sources using gasification technology
will be able to meet the standard.
Second, we are prepared to exercise
flexibility as to compliance dates for any
new source basing its compliance on
use of gasification technology,
consistent with the statute (63 FR
26607, May 8, 2000).
Comment: Several commenters
objected to the proposed beyond-the-
floor MACT standard for gaseous
organic HAP emissions from existing
semichemical combustion units that are
not fluidized-bed reactors. Commenters
also claimed that the proposed emission
limit is not supportable for some types
of chemical recovery combustion units,
such as recovery furnaces.
Response: We disagree with the
commenters Based on available
emissions data and our RTO cost
estimates, RTO represent a cost-effective
control strategy for meeting the
proposed gaseous organic HAP
emissions limits. (See docket No. A—94—
67)
Comment- A commenter provided
data for Icraft and soda recovery
furnaces, SDT, and lime kilns which the
commenter believes show a lack of
correlation between outlet emissions of
PM and outlet emissicas of HAP metals.
According to the commenter, variations
in raw materials and processes have a
greater effect or, uncontrolled HAP
metals emissions, and. therefore,
controlled emissions, than the type of
control device used. According to the
commenter, there is not A straight
correlation between reducing PK and
reducing HAP metals
Response- Regarding the commenter's
suggestion that there is a lack of
statistical correlation between HAP
metals emissions and PM emissions, we
agree that the ratio of the mass of HAP
metals to the total mass of PM emitted
varies from source to source
Additionally, the amount of HAP metals
in PM at each source varies. We do not
agree with the commenters' assertion
that PM is an inappropriate surrogate for
paniculate HAP metals emissions
Hazardous air pollutant metals are a
component of PM, and control devices
designed for PM removal also remove
particulate HAP metals at a similar rate.
Therefore, emission control efficiencies,
determined by measuring emissions at
both the inlet and the outlet of the
control device, are similar for both PM
and particulate HAP metals. Outlet PM
emissions are a good indicator of the
performance of the control device, and
there is no doubt that PM is an
appropriate surrogate for particulate
HAP metals.
Also, after reviewing available HAP
metals emissions data, we conclude that
there are insufficient data to establish
numerical HAP metals emissions limits
that reflect MACT. Consequently, we
have chosen not to promulgate the
proposed numerical HAP metals
emissions limits and the associated HAP
metals bubble compliance alternative.
Comment: A number of commenters
objected to the proposed emissions
limits for PM (as a surrogate for HAP
metals) for existing sources. •
Commenters suggested that the PM
emissions limits be recalculated using
additional PM emissions data because
they believe that many units operate
well below the emissions levels selected
for the proposed MACT floors.
Commenters also took issue with our
using the PM standards in the NSPS for
Kraft Pulp Mills as the basis for the HAP
metals MACT floors for existing kraft
and soda combustion sources and noted
that we failed to account for the fact that
the technology reflected in the NSPS for
Kraft Pulp MilU is an old technology
and that numerous sources are
achieving emissions reductions well
beyond the NSPS,
Response: We disagree with the
commenters regarding their objections
to the proposed PM emissions limits for
existing kraft and soda recovery
furnaces and SDT. We believe that the
MACT floor PM emissions limits for
recovery furnaces and SDT are justified
due to the variability in PM emissions
from these sources and the uncertainties
about why the same types of control
equipment perform at different levels
under comparable circumstances.
Therefore, we believe that the standards
in the final rule reasonably reflect the
level of performance achievable in
practice by the average of the best-
performing 12 percent of sources.
For existing lime kilns, the control
devices that we thought were
representative of the HAP metals MACT
floor were ESP, high-efficiency venturi
scrubbers, and ESP and scrubbers in
combination. However, lime kilns
equipped with ESP consistently show
lower PM emissions than lime kilns
equipped with scrubbers, and it is
apparent that there are a sufficient
number of lime kilns equipped with
ESP to be representative of the HAP
metals MACT floor. (That is, sufficient
numbers of sources are equipped with
ESP such that the level of performance
of a lime kiln equipped with an ESP
represents the level of performance
achievable by'the average of the best-
performing 12 percent of existing kraft
and soda lime kilns.) Therefore, today's
action corrects that error and
recalculates the PM emission limitation
achievable by the technology that
represents the MACT floor for existing
lime kirns based on the performance of
a lime kiln equipped with a properly
designed and operated ESP.
Based on available data from monthly
and annual compliance tests, lime kilns
equipped with ESP can achieve PM
emissions as low as 0.0023 g/dscm
(0.001 gr/dscf) and as high as 0.15 g/
dscm (0.064 gr/dscf) at 10 percent
oxygen. To account for this variability
in PM emissions from lime kiln ESP, we
are setting the HAP metals MACT floor
for existing lime kilns at 0.15 g/dscm
(0.064 gr/dscf) at 10 percent oxygen,
which is slightly less than the proposed
HAP metals MACT floor of 0.15 g/dscm
(0.067 gr/dscf) at 10 percent oxygen.
The best-performing lime kiln ESP
(which represents MACT for HAP
metals for new lime kilns) is more than
twice the size (i.e., has twice the specific
collecting area) of typical lime kiln ESP,
and its performance remains the basis
for the new source MACT standard
Therefore, today's action does not differ
from the proposed standard for HAP
metals for new lime kilns
V, Summary of Impacts
A. Air Quality Impacts
At the current level of control,
emissions of HAP (HAP metals and
gaseous organic HAP) are approximately
20,400 Mg/yr (22,500 tpy). and
emissions of other pollutants (PM. VOC,
CO, SOj, NOx) are approximately
507,100 Mg/yr (559,000 tpy)
Implementation of today's final rule i:
expected to reduce emissions of HAF,
PM, VOC, CO, and SO2, and slightly
increase emissions of NOx The EFA
estimates that emissions of HAP will bf
reduced by approximate!} 2.500 Mg/y.
(2,700 tpy) and emissions of other
pollutants by approximately 107,900
Mg/yr (118,900 tpy).
B. Cost Impacts
The estimated capital cost of control
for today's final rule is $241 million
(1997$) and includes the cost to
purchase and install both the control
equipment and monitoring equipment.
Most (89 percent) of the capital cost car-
be attributed to the PM controls for
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3189
kraft, soda, and sulfite combustion
units
The estimated annual cost of the rule
is $32.2 million/yr (1997$) and accounts
for the year-to-year operating expenses
associated with the control equipment
and the monitoring equipment, in
addition to the capital recovery expense
associated with the equipment
purchases. Most (79 percent) of the
annual cost can be attributed to the PM
controls for kraft, soda, and sulfite
combustion units.
The total average costs for annual
recordkeeping and reporting activities
required by the final rule are estimated
to be $962,600/yr (1997$) through the
third year after the effective date and
$5.4 million/yr (1997$) through the
third year after the compliance date.
These capital and annualized cost
estimates are intended to represent the
maximum expected costs of the
NESHAP and do not account for the
potential cost savings achieved by mills
that will successfully use the bubble
compliance alternative.
C. Economic Impacts
This section presents a summary of
EPA's evaluation of the economic
impacts of today's final rule. A more
detailed analysis of the economic
impacts of this rule, as well as the
recent!) promulgated NESHAP for
noncombustion pulp and paper sources
(i e , MACT 1 and MACT III) and
promulgated effluent limitation
guidelines, is discussed in the Economic
Analysis for the National Emission
Standards for Hazardous Air Pollutants
for Source Category Pulp and Paper
Production, Effluent Limitations
Guidelines Pretreetmerit Standards, and
New Source Performance Standards
Pulp, Paper, and Paperboard Category —
Phase 1 (DCN 14649, hereafter, the
Economic Analysis, or EA) The EPA
estimates that the pulp and paper
industry will incur total capita; costs of
$240 million (1997$) under the final
rule Overall. EPA projects tola.
annualized compliance expenditures of
$30 million (1997$!
Price increases of less than 0.5
percent are anticipated for bleached
papergrade kraft and soda, dissolving
kraft, dissolving sulfite, papergrade
sulfite, and sermchemical pulps and
products A price increase of 1 4 percent
is expected for unbleached kraft pulps.
Based on our economic modeling of the
impacts of such changes, we do not
anticipate any facility closures nor firm
failures as a result of compliance with
this final rule. In addition, we expect
that production decreases, employment
changes, and impacts on international
trade will be minimal
D. Benefits Analysis
Implementation of today's final rule is
expected to reduce emissions of HAP,
PM, VOC, CO. and SOj, while it is
expected to slightly increase emissions
of NOX. Such pollutants can potentially
cause adverse health effects and can
have welfare effects, such as impaired
visibility and reduced crop yields. In
the benefits analysis, we have not
conducted detailed air quality modeling
to evaluate the magnitude and extent of
the potential impacts from individual
pulp and paper facilities. Nevertheless,
to the extent that emissions from these
facilities cause adverse effects, this final
rule would mitigate such impacts.
1. Qualitative Description of Pollutant
Effects
This final rule is designed to reduce
the emissions of HAP, as defined in
section 112 of the CAA. Several of these
HAP are classified as known, probable,
or possible human carcinogens. They
have also been shown to cause other
adverse health effects, such as damage
to the eye, central nervous system, liver,
kidney, and respiratory system
depending upon the exposures to these
emissions. The types of studies in
which these various effects have been
reported include: (1) Epidemiological
studies of health effects occurring in
human populations (e.g., the general
population, or workers exposed in the
workplace), (2) case reports that
document human exposure incidents
(e g., accidental releases or poisonings),
(3) carefully controlled laboratory-
exposures of volunteer human subjects,
and (4) laboratory studies on animals.
Emissions of VOC and NOx interact in
the presence of sunlight to create
ground-level ozone. Recent scientific
evidence shows an association between
elevated ozone concentrations and
increases in hospital admissions for a
variety of respiratory illnesses and
indicates that ground-level ozone not
only affects people with impaired
respiratory systems (such as asthmatics),
but healthy adults and children as well.
Adverse welfare effects of ozone
exposure include damage to crops, tree
seedlings, ornamentals (shrubs, grass,
etc.), and forested ecosystems.
The reactions between VOC and NOx
to form ozone depend on the balance in
concentrations of each pollutant found
in the ambient air. For example, when
the concentration of NOx is high
relative to the concentration of VOC,
VOC reductions are effective in limiting
ozone formation, while NOx reductions
in that situation are ineffective. This
rule is expected to increase NOX
emissions slightly, but also decrease
VOC emissions. The increase in NOx
under this rule is not expected to cause
significant adverse health or welfare
impacts becau&e the magnitude of the
NOx increase (less than 500 Mg/yr) is
very small relative to the total NOx
inventory.
The VOC emission reductions from
this rule occur primarily in rural
attainment areas. These areas tend to be
NOx limited: therefore, VOC reductions
are not expected to affect ozone
concentrations. The low-end estimate of
VOC benefits relates to emissions
reductions (3,400 Mg/yr) occurring in
ozone nonartainment areas. Since ozone
nonattainment areas are typically urban
areas that are VOC limited, these
emissions reductions are likely to be
effective in limiting ozone formation.
The high-end of the range of VOC
benefits includes all VOC emissions
reductions (31,000 Mg/yr) expected to
occur for this rule. This estimate is
included to account for the uncertainty
as to whether specific rural areas are
NOx limited.
Exposure to PM has been associated
with the following adverse human
health effects: Premature mortality,
aggravation of respiratory and
cardiovascular disease, changes in lung
function and increased respiratory
symptoms, alterations in lung tissue and
structure, and altered respiratory tract
defense mechanisms. In general,
exposed populations at greater risk from
these effects are the following:
individuals with respiratory disease and
cardiovascular disease, individuals with
infectious disease, elderly individuals,
asthmatic individuals, and children.
Reduced welfare is associated with
elevated concentrations of fine particles,
which reduce visibility, damage
materials, and cause soiling. The
reductions in PM emissions under this
rule (approximately 21,000 Mg/yr) are
intended to decrease the adverse effects
of PM, to the extent that populations or
scenic destinations are located within
pollutant transport distance of pulp and
paper facilities,
Carbon monoxide is a colorless,
odorless gas that is toxic to mammals.
When inhaled, it combines with
hemoglobin, which reduces the oxygen-
carrying capacity of blood and results in
less oxygen being transported to vital
organs of the body. This can have
detrimental effects on the
cardiovascular and centra] nervous
systems. There are numerous studies
that support the association between
ambient CO levels and adverse health
effects which have been cited in the Air
Quality Criteria Document for Carbon
Monoxide (EPA Document No. 600/P-
99/001F, June 2000). The reduction cf
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CO emissions under this rule is
intended to diminish these potential
effects.
Sulfur dioxide oxidizes in water to
form both sulfurous and sulfuric acids.
When SOi dissolves in the atmosphere
in rain, fog, or snow, the acidity of the
deposition can corrode various
materials and cause damage to both
aquatic and terrestrial ecosystems.
Sulfur dioxide can also transform into
PMu, (i.e., participate matter with an
aerodynamic diameter less than or equal
to 2.5 micrometers). Emissions of SOj
are reduced slightly (20 Mg/yr) under
this rule.
2. Monetized Air Quality Benefits
We used a benefit transfer method to
value a subset of the emissions
reductions for the MACT II rule
Monetized benefit values are estimated
for only VOC, SO2, and PM emissions
reductions expected to result from this
rule. This method relies on a benefits
analysis conducted for the Ozone and
PM national ambient air quality
standards (NAAQS) The benefits
analysis conducted for the NAAQS
involves the same pollutants that are
impacted by this pulp and paper
rulemaking, and we assume the values
from the NAAQS analysis are ipplicable
to this final rule. The NAAQS analysis
valued the national-level benefits
achieved from a single, "representative"
year under a new set of standards. The
benefits (in dollars] per ton of reduction
of each pollutant were then applied to
the projected reductions of the same
pollutants under this final rule.
We assume that the relationship of
emission changes with the health and
welfare effects associated with the
NAAQS-estimated ozone and PM
concentrations correspond to the
projected changes in emissions from
pulp and paper mills No air quatit)
modeling was conducted to evaluate
potential changes in human exposure
under the rule, so the actual rmgnitudc
and riming of human health benefits are
unknown
In some cases, we did conside- the
location of mills when applying the
NAAQS benefits per ton figures For
VOC monetized benefits, a low-end
estimate included emissions only in
ozone nonattainment areas, which was
compared to a high-end estimate that
used all VOC emissions. For SO;, the
benefit transfer values differed between
mills located in the eastern and western
portions of the United States. Some
benefit categories were not monetized at
all, due to a lack of sufficient data
Nevertheless, the largest monetized
benefits are derived from PM
reductions, for which we used
nationwide emission estimates and
assume that the distributions of exposed
populations from the ozone and PM
studies are similar to those exposed to
pulp and paper mill emissions.
The EPA estimates that the rule
would reduce HAP emissions by
approximately 2.500 Mg/yr; VOC
emissions by approximately 31,000 Mg/
yr (3,400 Mg/yr in ozone nonattainment
areas); CO emissions by 56,000 Mg/yr;
PM emissions by approximately 21,000
Mg/yr; and SOj emissions by 20 Mg/yr;
and increase NOx emissions by
approximately 500 Mg/yr. Based upon
the previously discussed emissions
reductions, we estimate that the
monetary benefits of the rule range
between $280 million and $370 million
(1997$) for a representative year.
This rule is expected to result in
reductions in PM emissions for particles
of varying sizes. We expect most PM
reductions to be in the size range of
PMio and below. This assumption is
based upon the fact that existing
cherried recovery process sources
typically have PM controls in place
which have removed most of the large
particles associated with uncontrolled
emissions. However, it is likely that a
small fraction of emissions reductions
will be for particles above PM|<>.
Reductions in emissions of particle sizes
greater than 10 micrometers may not
result in the same benefits as particles
of sizes less than 10 micrometers. As
such, PM-related benefits reported for
this rule represent an upper-bound
estimate on the applicable PM
emissions reductions.
These figures suggest that the benefits
of today's final rule may be significantly
greater than the projected costs. Chapter
4 of the EA presents a detailed
description of the methodology used to
monetize the benefits of the rule.
E Non-Air Environmental Impacts
The quantity of PM collected will
increase when recovery furnace PM
control devices are upgraded or
replaced to comply with today's final
HAP metals standards. However, no
increases in solid waste disposal are
expected because existing mills have
sufficient capacity within the chemical
recovery process to recycle the
additional PM collected.
If owners or operators choose to
replace wet scrubbers with ESP to
comply with the HAP metals standard
for lime kilns, the generation of
wastewater will be reduced. The
significance of the reduction in
wastewater will depend on whether the
scrubber discharge had previously been
recycled and reused. If wet scrubbers
are replaced by ESP (and there was no
prior recycle or reuse of scrubber
discharge), EPA estimates that
wastewater discharge will decrease
nationwide by about 35 billion liters per
year (9.3 billion gallons per year)
following implementation of the rule.
F. Energy Impacts
The overall energy demand (i.e.,
electricity plus natural gas) is expected
to decrease by about 13,700 megawatt-
hours per year (MWh/yr) nationwide
under today's final rule. Electricity
requirements are expected to decrease
by about 17,800 MWh/yr under the final
rule. This net decrease in electricity
requirements includes an expected
increase of about 39,600 MWh/yr when
PM control devices on kraft and soda
recovery furnaces and SDT and sulfite
combustion units are upgraded or
replaced, an expected increase of 16,400
MWh/yr when gaseous organic HAP
controls (i.e., RTO) are added to
semichemical combustion units, and an
expected decrease of about 75,900
MWh/yr if wet scrubbers are replaced
by ESP to provide increased control of
PM emissions from kraft and soda lime
kilns. Natural gas requirements are
expected to increase by about 4,100
MWh/yr when gaseous organic HAP
controls are added to semichemica]
combustion units. This estimate is based
on an increase of 0.4 million cubic
meters per year (14 million cubic feet
per year) of natural gas, assuming 1,024
British thermal units per cubic foot of
natural gas.
VI. Administrative Requirements
A. Executive Order 12866, Regulatory
Planning and Review
Under Executive Order 12866 (58 FR
51736, October 4, 1993), EPA must
determine whether the regulatory action
is "significant" and, therefore, subject to
review by the Office of Management and
Budget (OMB) and the requirements of
the Executive Order. The Executive
Order defines "significant regulatory
action" as one that is likely to result in
a rule that may:
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material wa\ the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
State, local, or tribal governments or
communities;
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another agency;
(3) Materially alter the budgetary
impact of entitlements, grants, user fees,
or loan programs or the rights and
obligations of recipients thereof; or
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(4) Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in the Executive Order.
Pursuant to the terms of Executive
Order 12866, OMB has notified EPA
that this action is a "significant
regulatory action" because it will have
an annual effect on the economy of $100
million or more. Consequently, this
action was submitted to OMB for review
under Executive Order 12866 Any
written comments from OMB and
written EPA responses are available in
the docket (see ADDRESSES section of
this preamble).
B. Executive Order 13132, Federalism
Executive Order 13132, entitled
"Federalism" (64 FR 43255, August 10,
1999), requires EPA to develop an
accountable process to ensure
"meaningful and timely input by State
and local officials in the development of
regulatory policies that have federalism
implications." "Policies that have
federalism implications" is defined in
the Executive Order to include
regulations that have "substantial direct
effects on the States, on the relationship
between the national government and
the States, or on the distribution of
power and responsibilities among the
Various levels of govemme. t " Under
Executive Order 13132, EPA may not
issue a regulation that has federalism
implications, that imposes substantial
direct compliance costs, and that is not
required by statute, unless the Federal
government provides the funds
necessary to pay the direct compliance
costs incurred by State and local
governments, or EPA consults with
State and local officials ear'v in the
process of developing the regulation
The EPA also ma\ not issue a rcculatior.
that has federalism implications ar.c
that preempts State IPW unlesc EFA
consults with State and !oco'. official
early in the process of developing the
regulation
This final rule does not ha-, r
federalism implications It will not have
substantial direct effects on th: ,~*^",c;
on the relationship between the nat.^r.a1
government and the States, or on tht
distribution of power and
responsibilities among the various
levels of government, as specified HI
Executive Order 13132 Thus, the
requirements of section 6 of the
Executive Order do not apply to this
rule.
C. Executive Order 13084, Consultation
and Coordination With Indian Tnbal
Governmen ts
Under Executive Order 13084, EPA
may not issue a regulation that is no!
required by statute, that significantly or
uniquely affects the communities of
Indian tribal governments, and that
imposes substantial direct compliance
costs on those communities, unless the
Federal government provides the funds
necessary to pay the direct compliance
costs incurred by the tribal
governments, or EPA consults with
those governments. If EPA complies by
consulting, Executive Order 13084
requires EPA to provide to OMB, in a
separately identified section of the
preamble to the rule, a description of
the extent of EPA's prior consultation
with representatives of affected tribal
governments, a summary of the nature
of their concerns, and a statement
supporting the need to issue the
regulation. In addition, Executive Order
13084 requires EPA to develop an
effective process permitting elected
officials and other representatives of
Indian tribal governments to "provide
meaningful and timely input in the
development of regulatory policies on
matters that significantly or uniquely
affect their communities " Today's final
rule does not significantly or uniquely
affect the communities of Indian tribal
governments. No tribal governments
own or operate kraft, soda, sulEte, or
stand-alone semichemical pulp mills.
Accordingly, the requirements of
section 3(b) of Executive Order 13084
do not apply to this rule.
D. Executive Order 13045, Protection of
Children From Environmental Health
Risks and Safety Risks
Executive Order 13045 (62 FR 19885,
April 23, 1997) applies to any rule that:
(1) Is determined to be "economically
significant" as defined under Executive
Order 12866, and (2) concerns an
environmental health or safety risk that
EPA has reason to believe may have a
disproportionate effect on children If
the regula'ory action meets both criteria,
EPA must evaluate the environmental
health or safety effects of the planned
rule on children, and explain why the
planned rule is preferable to other
potentially effective and reasonabl)
feasible alternatives that EPA
considered
The EPA interprets Executive Order
13045 as applying only to those
regulatory actions that are based on
health or safety risks, such that the
analysis required under section 5—501 of
the Executive Order has the potential to
influence the rule. This final rule is not
subject to Executive Order 13045
because it is based on technology
performance and not on health or safety
risks.
E. Unfunded Mandates Reform Act of
1995
Title n of the Unfunded Mandates
Reform Act of 1995 (UMRA), Pub. L.
104—4, establishes requirements for
Federal agencies to assess the effects of
their regulatory actions on State, local,
and tribal governments and the private
sector. Under section 202 of the UMRA,
EPA generally must prepare a written
statement, including a cost-benefit
analysis, for proposed and final rules
with 'Tederal mandates" that may
result in expenditures by State, local,
and tribal governments, in the aggregate,
or by the private sector, of $100 million
or more in any 1 year. Before
promulgating an EPA rule for which a
written statement is needed, section 205
of the UMRA generally require* EPA to
identify and consider a reasonable
number of regulatory alternatives and
adopt the least costly, most cost
effective, or least burdensome
alternative that achieves the objectives
of the rule. The provisions of section
205 do not apply when they are
inconsistent with applicable law.
Moreover, section 205 allows EPA to
adopt an alternative other than the least
costly, most cost effective, or least-
burdensome alternative if the
Administrator publishes with the final
rule an explanation why that alternative
was not adopted. Before EPA establishes
any regulatory requirements that may
significantly or uniquely affect small
governments, including tribal
governments, it must have developed
under section 203 of the UMRA a small
government agency plan. The plan must
provide for notifying potentially
affected small governments, enabling
officials of affected small governments
to have meaningful and timely input in
the development of EPA regulatory
proposals with significant Federal
intergovernmental mandates, and
informing, educating, and advising
small governments on compliance with
the regulatory requirements.
The EPA has determined that this rule
(in conjunction with the MACT 1 and
MACT III rules and the effluent
guidelines recently promulgated for the
pulp and paper industry) contains a
Federal mandate that may result in
estimated costs of $100 million or more
to either State, local, or tribal
governments, in the aggregate, or to the
private sector in any 1 year. According.
EPA has prepared under section 202 of
the UMRA a written statement, which is
summarized below.
1. Statutory Authority
The statutory authority for this
rulemakingis section 112 of the CAA.
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001/Rules and Regulations
Title in of the CAA Amendments was
enacted to reduce the amount of
nationwide air toxic emissions. Section
H2(b) lists the 189 chemicals.
compounds, or groups of chemicals
deemed by Congress to be HAP. These
toxic air pollutants are to be regulated
by NESHAP. Hazardous air pollutant
emissions from the pulp and paper
production source category are being
regulated under section 112(d) of the
CAA. The NESHAP requires existing
and new major sources to control
emissions of HAP using MACT.
The pulp and paper production
source category includes all mills that
produce pulp and/or paper. The
NESHAP for the source category are
being developed in phases. This final
NESHAP, referred to as MACT D,
regulates chemical recovery combustion
sources at kraft, soda, sulfite, and stand-
alone semichemical pulp mills. The
final NESHAP for noncombustion
sources (i.e., MACT I and MACT HI)
regulates noncombustion processes at
mills that (1) chemically pulp wood
fiber (using kraft, sulfite, soda, and
semi-chemical methods) (MACT I), and
(2) mechanically pulp wood fiber (e.g.,
groundwood, thennomechanical,
pressurized), pulp secondary fibers
(deinked and nondeinked), and pulp
nonwood (MACT HI).
Regarding EPA's compliance with
section 205(a), EPA did identify and
consider a reasonable number of
alternatives. A summary of these
alternatives and their costs and
environmental impacts is provided in
the preamble to the proposed rule (63
FR 18773, April 15,1998). Additional
information on the costs and
environmental impacts of the regulatory
alternatives is presented in the Revised
Nationwide Costs, Environmental
Impacts, and Cost Effectiveness of
Regulator)' Alternatives for Kraft, Soda,
Sulfite, and Semichemical Combustion
Sources Memo (docket No. A-94—67).
The chosen alternative represents the
MACT floor for chemical recovery
combustion sources at kraft, soda, and
sulfite pulp mills and is the least costly
and least burdensome alternative for
those sources The chosen alternative
also includes an option more stringent
than the MACT floor for chemical
recovery combustion sources at stand-
alone semichemical pulp mills.
However, EPA considers the cost
effectiveness of the more stringent
option for semichemical chemical
recovery combustion sources (less than
$2,900/Mg of HAP reduced) acceptable,
especially when measured against the
environmental benefits of reducing
emissions of both HAP and non-HAP.
Therefore, EPA concludes that the
chosen alternative is the least costly and
least burdensome alternative that
achieves the objectives of section 112, as
called for in section 205(a).
2. Social Costs and Benefits
The regulatory impact analysis
prepared for MACT I, including the
EPA's assessment of costs and
environmental benefits, is detailed in
the "Regulatory Impacts Assessment of
Proposed Effluent Guidelines and
NESHAP for the Pulp, Paper, and
Paperboard Industry," (EPA-821/R-93-
020). The regulatory impacts assessment
document was updated for the final rule
for MACT I and III and the proposed
rule for MACT II and is referred to as
the Economic Analysis Document
(docket No. A-94-67).
3. Future and Disproportionate Costs
The EPA does not believe that there
will be any disproportionate budgetary
effects of the rule on any particular
areas of the country, particular
governments or types of communities
(e.g., urban, rural), or particular industry
segments.
4. Effects on the National Economy
The estimated direct cost to the pulp
and paper industry of compliance with
this rule is approximately $30 million
(1997$) annually. Indirect costs of the
rule to industries other than the pulp
and paper industry-, governments, tribes,
and other affected entities are expected
to be minor. The estimated annual cost
of this rule is minimal when compared
to the nominal gross domestic product
of $8,318.4 billion reported for the
Nation in 1997. This rule is expected to
have little impact on domestic
productivity, economic growth, full
employment, creation of productive
jobs, and on the international
competitiveness of the U.S. goods and
services.
5. Consultation With Government
Officials
Although this rule does not affect any
State, local, or tribal governments, EPA
has consulted with State and local air
pollution control officials. The EPA also
has held numerous meetings on the
proposed integrated rules with many of
the stakeholders from the pulp and
paper industry, including the AF&PA,
the National Council of the Paper
Industry for Air and Stream
Improvement, numerous individual
companies, vendors, and other
interested parties. The EPA has added
materials to the docket to document
these meetings.
F. Regulatory Flexibility Act (RFA), as
Amended by the Small Business
Regulatory Enforcement Fairness Act of
1996 (SBREFA). 5 V.S.C. 601 et seq.
The RFA generally requires an agency
to prepare a regulatory flexibility
analysis of any rule subject to notice
and comment rulemaking requirements
under the Administrative Procedure Act
or any other, statute unless the agency
certifies that the rule will not have a
significant economic impact on a
substantial number of small entities.
Small entities include small businesses,
small organizations, and small
governmental jurisdictions.
For purposes of assessing the impacts
of today's rule on small entities, small
entity is defined as: (1) A small business
that has fewer than 750 employees for
NAICS codes 32211, 32212, and 32213
(pulp, paper, and paperboard mills), (2).
a small governmental jurisdiction that is
a government of a city, county, town,
school district or special district with a
population of less than 50,000, and (3)
a small organization that is any not-for-
profit enterprise which is independently
owned and operated and is not
dominant in its field.
After considering the economic
impacts of today's final rule on small
entities, it has been determined that this
action will not have a significant
economic impact on a substantial
number of small entities. The EPA has
determined that three companies met
the definition of small entity at the time
of proposal. These three companies own
only three of the 136 mills subject to
today's final rule. The small business
analysis reported in the EA shows that
the affected mills have costs as a
percentage of sales ratios of less than 1
percent, that these mills are not
expected to close, nor are the owning
companies expected to encounter
financial distress as a result of this rule.
An analysis of mergers and acquisitions
subsequent to the baseline year of th-
analysis indicates that these three
companies no longer meet the definition
of small business.
C. Paperwork Reduction Ac'
The information collection
requirements in this final rule will be
submitted for approval to OMB under
the Paperwork Reduction Act, 44 U.S.C.
3501 et seq. The EPA has prepared an
Information Collection Request (ICR)
document OCR No. 1805.01), and a copy
may be obtained from Sandy Farmer by
mail at Office of Environmental
Information, Collection Strategies
Division (2822), U.S. EPA. 1200
Pennsylvania Avenue NW, Washington.
DC 20460, by electronic mail at
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3193
fanner.sandy@epa.gov, or by calling
(202) 260-2740. A copy may also be
downloaded off the Internet at http://
www.epa.gov/icr. The information
requirements are not effective until
OMB approves them.
The information requirements in the
final rule include mandatory
notifications, records, and reports
required by the NESHAP General
Provisions. These information
requirements are needed to confirm the
compliance status of major sources, to
identify any non-major sources not
subject to the standard and any new or
reconstructed sources subject to the
standards, to confirm that emission
control devices are being properly
operated and maintained, and to ensure
that the standards are being achieved.
Based on the recorded and reported
information, EPA can decide which
facilities, records, or processes should
be inspected. These recordkeeping and
reporting requirements are specifically
authorized under section 114 of the
CAA. All information submitted to EPA
for which a claim of confidentiality is
made is safeguarded according to EPA's
policies in 40 CFR part 2, subpart B.
The annual public recordkeeping and
reporting burden for this collection of
information (averaged over the first 3
years after the effective date of this rule)
is estimated to total 21,500 labor hours
per year, at a total annual cost of
$958.300(19975) This estimate
includes initial notifications, one-time
performance test and report (with repeat
tests where needed), one-time purchase
and installation of monitoring system,
one-time preparation of a startup.
shutdown, and malfunction plan with
immediate reports f^r an}' e\ ent \\hen
the procedures in the plan were not
followed compliance reports and
recordkeeping Tola! capital costs
associated with these requirements over
the 3-year period of the ICK LP;
estimated at $14,700, with annuahzed
capita] costs of S1.600 (1997S) Total
operation and maintenance costs
associated with these requirements are
estimated at S2.700 (1997SJ
Burden means the total time, effort, or
financial resources expended by persons
to generate, maintain, retain, or disclose
or provide information to or for a
Federal agency This includes the time
needed to review instructions, develop,
acquire, install, and utilize technology
and systems for the purposes of
collecting, validating, and verifying
information, processing and
maintaining information, and disclosing
and providing information; adjust the
existing ways to comply with any
previously applicable instructions and
requirements; train personnel to be able
to respond to a collection of
information; search data sources;
complete and review the collection of
information; and transmit or otherwise
disclose the information.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a currently valid OMB
control number. The OMB control
numbers for EPA's regulations are listed
in 40 CFR part 9 and 48 CFR chapter 15.
H. National Technology Transfer and
Advancement Act of1995
Section 12(d) of the National
Technology Transfer and Advancement
Act (NTTAA) of 1995 (Pub. L. 104-113;
15 U.S.C. 272 note) directs EPA to use
voluntary consensus standards in its
regulatory and procurement activities
unless to do so would be inconsistent
with applicable law or otherwise
impractical. Voluntary consensus
standards are technical standards (e.g.,
materials specifications, test methods,
sampling procedures, business
practices) developed or adopted by one
or more voluntary consensus bodies.
The NTTAA directs EPA to provide
Congress, through annual reports to
OMB, with explanations when an
agency does not use available and
applicable voluntary consensus
standards.
This rulemaking involves the
following technical standards: EPA
Methods 1, 2, 3, 3A, 3B, 4, 5,17, 25A,
29, and 308 (40 CFR part 60, appendix
A; 40 CFR part 61, appendix B; 40 CFR ,
part 63, appendix A). Consistent with
the NTTAA, EPA conducted searches to
identify voluntary consensus standards
in addition to these EPA methods. For
EPA Methods 3B and 308, no applicable
voluntary consensus standards have
been found at this time. The search and
review results have been documented
and are placed in the docket for this rule
(Docket No. A-94-67).
The search for emissions testing
procedures identified 19 voluntary
consensus standards. The EPA
determined that 15 of these 19 standards
identified for measuring emissions of
the HAP or surrogates subject to
emissions limits in the rule would not
be practical due to lack of equivalency,
detail, and/or quality assurance/quality
control requirements. Therefore, we did
not use these voluntary consensus
standards in this rulemaking. Four of
the 19 consensus standards identified
are under development or under EPA
review. Therefore, we did not use these
voluntary consensus standards in this
rulemaking.
Section 63.865 of the rule lists the
EPA test methods included in the rule.
Most of these methods have been used
by States and industry for more than 10
years. Nevertheless, under
§ 63.7(e)(2)(ii) and (f), the rule also
allows any State or source to apply to
EPA for permission to use an alternative
method in place of any of the EPA test
methods listed in §63.865.
/. Congressional Review Act
The Congressional Review Act, 5
U.S.C. 801 et seq., as added by the Small
Business Regulatory Enforcement
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. The EPA will
submit a report containing this rule and
other required information to the U.S.
Senate, the U.S. House of
Representatives, and the Comptroller
General of the United States prior to
publication of the rule in the Federal
Register. A major rule cannot take effect
until 60 days after it is published in the
Federal Register. This action is a "major
rule" as denned by 5 U.S.C. 804(2). This
rule will be effective March 13, 2001.
List of Subjects in 40 CFR Part 63
Environmental protection.
Administrative practice and procedure,
Air pollution control, Hazardous
substances, Intergovernmental relations,
Pulp and paper mills, Reporting and
recordkeeping requirements.
Dated: December 15, 2000.
Carol M. Browner,
Administrutor
For the reasons set out in the
preamble, title 40, chapter 1, part 63 of
the Code of Federal Regulations is
amended as follows
PART 63—{AMENDED]
1. The authority citation for part 63
continues to read as follows-
Authority: 42 U.S.C. 7401 et seq
2. Part 63 is amended by adding
subpart MM to read as follows:
Subpart MM—National Emission
Standards for Hazardous Air Pollutants
for Chemical Recovery Combustion
Sources at Kraft, Soda, Sutflte, and
Stand-Alone Semlchemlcal Pulp Mills
Sec.
63.860 Applicability and designation of
affected source.
63.861 Definitions.
63.862 Standards
63.863 Compliance dates
63.864 Monitoring requirements
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63.865 Performance test requirements and
test methods.
• 63.866 Recordkeeping requirements.
63.867 Reporting requirements.
63.868 Delegation, of authority.
Table 1 to Subpart MM—General Provisions
Applicability to Subpart MM
563360 Applicability MX) designation of
affected cource.
(a) The requirements of this subpart
apply to the owner or operator of each
kraft, soda, sulfite, or stand-alone
semichemical pulp mill that is a major
source of hazardous air pollutants
(HAP) emissions as defined in § 63.2.
(b) Affected sources The
requirements of this subpart apply to
each new or existing affected source
listed in paragraphs (b)(l) through (6) of
this section:
(1) Each existing chemical recovery
system (as defined in §63.861) located
at a kraft or soda pulp mill.
(2) Each new nondirect contact
evaporator (NDCE) recovery furnace and
associated smelt dissolving tank(s)
located at a kraft or soda pulp mill.
(3) Each new direct contact evaporator
(DCE) recovery furnace system (as
defined in § 63.861) and associated
smelt dissolving tank(s) located at a •
kraft or soda pulp mill
(4) Each new lime kiln located at a
kraft or soda pulp mill
(5) Each new or existing sulfite
combustion unit located at a sulfite pulp
mill.
(6) Each new or existing semichemical
combustion unit located at a stand-alone
semichemical pulp mill.
(c) The requirements of the General
Provisions in subpart A of this part that
apply to the owner or operator subject
to the requirements of this subpart are
identified in Table I to this subpart.
$63.861 Definitions.
All terms used in Ur.s subpart are
defined in the Clean Air Act in subpart
A of this part, or in this section For the
purposes of this subpait, if the same
term is defined in subpart A or any
other subpart of this part and in this
section, it mu.ct have the meaning given
in this section
Black liquor means spent cooking
liquor that has been separated from the
pulp produced by the kraft, soda, or
semichemical pulping process.
Black liquor gasification means the
thermochemical conversion of black
liquor into a combustible gaseous
product.
Black liquor oxidation (BLO) system
means the vessels used to oxidize the
black liquor, with air or oxygen, and the
associated storage tank(s).
Black liquor solids (BLS) means the
dry weight of the solids in the black
liquor that enters the recovery furnace
or semichemical combustion unit.
Black liquor solids filing rate means
the rate at which black liquor solids are
fed to the recovery furnace or the
semichemical combustion unit.
Chemical recovery combustion source
means any source in the chemical
recovery area of a kraft, soda, sulfite or
stand-alone semichemical pulp mill that
is an NDCE recovery furnace, a DCE
recovery furnace system, a smelt
dissolving tank, a lime kiln, a sulfite
combustion unit, or a semichemical
combustion unit.
Chemical recovery system means all
existing DCE and NDCE recovery
furnaces, smelt dissolving tanks, and
lime kilns at a kraft or soda pulp mill.
Each existing recovery furnace, smelt
dissolving tank, or lime kiln is
considered a process unit within a
chemical recovery system..
Direct contact evaporator (DCE)
recovery furnace means a kraft or soda
recovery furnace equipped with a direct
contact evaporator that concentrates
strong black liquor by direct contact
between the hot recovery furnace
exhaust gases and the strong black
liquor.
Direct contact evaporator (DCE)
recovery furnace system means a direct
contact evaporator recovery furnace and
any black liquor oxidation system.'if
present, at the pulp mill.
Dry electrostatic precipitator (ESP)
system means an electrostatic
precipitator with a dry bottom (j'.e., no
black liquor, water, or other fluid is
used in the ESP bottom) and a dry
particulate matter return system (i.e., no
black liquor, water, or other fluid is
used to transport the collected PM to the
mix tank).
Hazardous air pollutants (HAP)
metals means the'sum of all emissions
of antimony, arsenic, beryllium,
cadmium, chromium, cobalt, lead,
manganese, mercury, nickel, and
selenium as measured by EPA Method
29 (40 CFR part 60, appendix A) and
with all nondetect data treated as one-
half of the method detection limit.
Kraft pulp mill means any stationary
source that produces pulp from wood by
cooking (digesting) wood chips in a
solution of sodium hydroxide and
sodium sulfide. The recovery process
used to regenerate cooking chemicals is
also considered part of the kraft pulp
mill.
Kraft recovery furnace means a
recovery furnace that is used to burn
black liquor produced by the kraft
pulping process, as well as any recovery
furnace that burns black liquor
produced from both the kraft and
semichemical pulping processes, and
includes the direct contact evaporator, if
applicable. Includes black liquor
gasification.
Lime kiln means the combustion unit
(e.g.. rotary lime kiln or fluidized-bed
calciner) used at a kraft or soda pulp
mill to calcine lime mud, which
consists primarily of calcium carbonate,
into quicklime, which is calcium oxide
(CaO).
Lime production rate means the rate
at which dry lime, measured as CaO, is
produced in the lime kiln.
Method detection limit means the
minimum concentration of an analyte
that can be determined with 99 percent
confidence that the true value is greater
than zero.
Modification means, for the purposes
of §63.862(a)(l)(ii)(E)(I). any physical
change (excluding any routine part
replacement or maintenance) or
operational change (excluding any
operational change that occurs during a
start-up, shutdown, or malfunction) that
is made to the air pollution control
device that could result in an increase
in PM emissions.
Nondetect data means, for the
purposes of this subpart, any value that
is below the method detection limit.
Nondirect contact evaporator (NDCE)
recovery furnace means a kraft or soda
recovery furnace that burns black liquor
that has been concentrated by indirect
contact with steam.
Particulate matter (PM) means total
particulate matter as measured by EPA
Method 5, EPA Method 17
(§ 63.865(b)(l)), or EPA Method 29 (40
CFR part 60, appendix A).
Process unit means an existing DCE or
NDCE recovery furnace, smelt
dissolving tank, or lime kiln in a
chemical recovery system at a kraft or
soda mill.
Recovery furnace means an enclosed
combustion device where concentrated
black liquor produced by the kraft or
soda pulping process is burned to
recover pulping chemicals and product
steam. Includes black liquor
gasification.
Regenerative thermal oxidizer (RTO<
means a thermal oxidizer that transfer'
heat from the exhaust gas stream to th(
inlet gas stream by passing the exhaus*
stream through a bed of ceramic
stoneware or other heat-absorbing
medium before releasing it to the
atmosphere, then reversing the gas flow
so the inlet gas stream passes through
the heated bed, raising the temperature
of the inlet stream close to or at its
ignition temperature.
Semichemical combustion unit means
any equipment used to combust or
pyrolyze black liquor at stand-alone
semichemical pulp mills for the purpose
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3195
of chemical recovery. Includes black
liquor gasification.'
Similar process units means all
existing DCE and NDCE recovery
furnaces, smelt dissolving tanks, or lime
kilns at a kraft or soda pulp mill.
Smelt dissolving tanks (SDT) means
vessels used for dissolving the smelt
collected from a kraft or soda recovery
furnace.
Soda pulp mill means any stationary
source that produces pulp from wood by
cooking (digesting) wood chips in a
sodium hydroxide solution. The
recovery process used to regenerate
cooking chemicals is also considered
part of the soda pulp mill.
Soda recovery furnace means a
recovery furnace used to burn black
liquor produced by the soda pulping
process and includes the direct contact
evaporator, if applicable. Includes black
liquor gasification
Stand-alone semichemical pulp mill
means any stationary source that
produces pulp from wood by partially
digesting wood chips in a chemical
solution followed by mechanical
defibrating (grinding), and has an onsite
chemical recovery process that is not
integrated with a kraft pulp mill.
Sulfite combustion unit means a
combustion device, such as a recovery
furnace or fluidized-bed reactor, where
spent liquor from the sulfite pulping
process (i e., red liquor) is burned to
recover pulping Lhemicals
Sulfite pulp mill means any stationary
source that produces pulp from wood by
cooking (digesting^ wood chips in a
solution of sulfurous acid and bisulfite
ions The recover) process used to
regenerate cooking chemicals is also
considered part of the suifcte pulp mill
Total hydrocarbons (THCl means the
sum of organic compounds measured as
carbon using EPA Method 25A (40 CFR
part 60, appendix A),
$63.862 Standards.
(a) Standards for HAP metals existing
sources (I) Each owner or operator of
an existing kraft or soda pulp mill must
comply with the requirements of either
paragraph (a);l)(i) or (ii) of this section.
(i) Each ownei or operator of a kraf.
or soda pulp mill must comply with the
PM emissions limits in paragraphs
(a)(l)(i)(A) through (C) of this section.
(A) The owner or operator of each
existing kraft or soda recovery furnace
must ensure that the concentration of
PM in the exhaust gases discharged to
the atmosphere is less than or equal to
0.10 gram per dry standard cubic meter
(g/dscm) (0.044 grain per dry standard
cubic foot (gr/dscf)) corrected to 8
percent oxygen
(B) The owner or operator of each
existing kraft or soda smelt dissolving
tank must ensure that the concentration
of PM in the exhaust gases discharged
to the atmosphere is less than or equal
to 0.10 kg/Mg (0.20 Ib/ton) of black
liquor solids fared.
(C) The owner or operator of each
existing kraft or soda lime kiln must
ensure that the concentration of PM in
the exhaust gases discharged to the
atmosphere is less than or equal to 0.15
g/dscm (0.064 gr/dscf) corrected to 10
percent oxygen.
(ii) As an alternative to meeting the
requirements of §63.862(a)(l)(i). each
owner or operator of a kraft or soda pulp
mill may establish PM emissions limits
for each existing kraft or soda recovery
furnace, smelt dissolving tank, and lime
kiln that operates 6,300 hours per year
or more by:
(A) Establishing an overall PM
emission limit for each existing process
unit in the chemical recovery system at
the kraft or soda pulp mill using the
methods in §63.865(a)(l) and (2).
(B) The emissions limits for each kraft
recovery furnace, smelt dissolving tank,
and lime kiln that are used to establish
the overall PM limit in paragraph
(a)(l)(ii)(A) of this section must not be
less stringent than the emissions
limitations required by § 60.282 of part
60 of this chapter for any kraft recovery
furnace, smelt dissolving tank, or lime
kiln that is subject to the requirements
of §60.282.
(C) Each owner or operator of an
existing kraft or soda recovery furnace,
smelt dissolving tank, or hme kiln must
ensure that the PM emissions
discharged to the atmosphere from each
of these sources are less than or equal
to the applicable PM emissions limits,
established using the methods in
§ 63.865(a)(l), that are used to establish
the overall PM emissions limits in
paragraph (a)(l)(ii)(A) of this section,
(D) Each owner or operator of an
existing kraft or soda recovery furnace,
smelt dissolving tank, or lime kiln must
reestablish the emissions limits
determined in paragraph (a)(l)(ii)(A) of
this section if either of the actions in
paragraphs (a)(l)(ii)(D)(J) and (2} of this
section are taken:
(J) The air pollution control system
for any existing kraft or soda recovery
furnace, smelt dissolving tank, or lime
kiln for which an emission limit was
established in paragraph (a)(l)fii)(A) of
this section is modified (as defined in
§63.861) or replaced; or
(2) Any kraft or soda recovery furnace,
smelt dissolving tank, or lime kiln for
which an emission limit was established
in paragraph (a)(l)(ii)(A) of this section
is shut down for more than 60
consecutive days.
(iii) Each owner or operator of an
existing kraft or soda recovery furnace,
smelt dissolving tank, or lime kiln that
operates less than 6,300 hours per year
must comply with the applicable PM
emissions limits for that process unit
provided in paragraph (a)(l)(i) of this
section.
(2) The owner or operator of each
existing sulfite combustion unit must
ensure that the concentration of PM in
the exhaust gases discharged to the
atmosphere is less than or equal to 0.092
g/dscm (0.040 gr/dscf) corrected to 8
percent oxygen.
(b) Standards for HAP metals: new
sources. (I) The owner or operator of
any new kraft or soda recovery furnace
must ensure that the concentration of
PM in the exhaust gases discharged to
the atmosphere is less than or equal to
0.034 g/dscm gr/dscf) corrected to 8
•percent oxygen.
(2) The owner or operator of any new
kraft or soda smelt dissolving tank must
ensure that the the concentration of PM
in the exhaust gases discharged to the
atmosphere is less than or equal to 0.06
kg/Mg (0.12 Ib/ton) of black liquor
solids fired.
(3) The owner or operator of any new
kraft or soda lime kiln must ensure that
the concentration of PM in the exhaust
gases discharged to the atmosphere is
less than or equal to 0.023 g/dscm
(0.010 gr/dscf) corrected to 10 percent
oxygen.
(4) The owner or operator of any new
sulfite combustion unit must ensure that
the concentration of PM in the exhaust
gases discharged to the atmosphere is
less than or equal to 0.046 g/dscm
(O.020 gr/dscf) corrected to 8 percent
oxygen.
(c) Standards for gaseous organic
HAP. (1) The owner or operator of any
new recovery furnace at a kraft or soda
pulp mill must ensure that the
concentration or gaseous organic HAP,
as meauared by methanol, discharged to
the atmosphere is no greater than 0 012
kg/Mg (0.025 Ib/ton) of black liquor
solids fired.
(2) The owner or operator of each
existing or new semichemical
combustion unit must ensure that:
(i) The concentration of gaseous
organic HAP, as measured by total
hydrocarbons reported as carbon,
discharged to the atmosphere is less
than or equal to 1.49 kg/Mg (2.97 Ib/ton)
of black liquor solids fired; or
(ii) The gaseous organic HAP
emissions, as measured by total
hydrocarbons reported as carbon, are
reduced by at least 90 percent prior to
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001 /Rules and Regulations
discharge of the gases to the
atmosphere.
163.863 Compliance date*.
(a) The owner or operator of an
existing affected source or process unit
must comply with the requirements in
this subpart no later than January 12,
2004.
(b) The owner or operator of a new
affected source that has an initial
startup date after January 12, 2001, must
comply with the requirements in this
subpart immediately upon startup of the
affected source, expect as specified in
§63.6(b).
§63.864 Monitoring requirements.
(a) General. (1) The owner or operator
of each affected kraft or soda recovery
furnace or lime kiln equipped with as
ESP must install, calibrate, maintain,
and operate a continuous opacity
monitoring system that can be used to
determine opacity at least once every
successive 10-second period and
calculate and record each successive 6-
minute average opacity using the
procedures in §§63.6(h) and 63.8.
(2) The owner or operator of each
affected kraft or soda recovery furnace,
kraft or soda lime kiln, sulfite
Combustion unit, or kraft cr soda smelt
Dissolving tank equipped with a wet
scrubber must install, calibrate,
maintain, and operate a continuous
monitoring system that can be used t j
determine and record the pressure drop
across the scrubber and the scrubbing
liquid flow rate at least once every
successive 15-minute period using the
procedures in §63.8(c), as well as the
procedures in paragraphs (a)(2)(i) and
(ii) of this section'
(i) The monitoring device used for the
continuous measurement of the pressure
drop of the gas stream across the
scrubber must be certified by the
manufacturer to the accurate to within
a gage pressure of ±500 pascals (±2
inches of water gage pressure), and
(ii) The monitoring device used for
continuous measurement of the
scrubbing liquid flow rate must be
• certified by the manufacturer to be
accurate within ±5 percent of the design
scrubbing liquid flow rate.
(3) The owner or operator of each
affected semichemical combustion unit
equipped with an RTO must install,
calibrate, maintain, and operate a
continuous monitoring system that can
be used to determine and record the
operating temperature of the RTO at
least once every successive 15-minute
period using the proceduifs in § 63.8(c).
The monitor must compute and record
the operating temperature at the point of
incineration of effluent gases that are
emitted using a temperature monitor
accurate to within ±1 percent of the
temperature being measured.
(4) The owner or operator of each
affected source or process unit that uses
a control device listed in paragraphs
(a)(l) through (3) of this section may
monitor alternative control device
operating parameters subject to prior
written approval by the Administrator.
(5) The owner or operator of each
affected source or process unit that uses
an air pollution control system other
than those listed in paragraphs (a)(l)
through (3) of this section must monitor
the parameters as approved by the
Administrator using the methods and
procedures in § 63.865(f).
(6) The owner or operator of each
affected source or process unit
complying with the gaseous organic
HAP emissions limitations of
§ 63.862(c)(l) through the use of an
NDCE recovery furnace equipped with a
dry ESP system is not required to
conduct any performance testing or any
continuous monitoring to demonstrate
compliance with the gaseous organic
HAP emission limitation.
(b) Initial compliance determination.
(1) The owner or operator of each
affected source or process unit subject to
the requirements of this subpart is
required to conduct an initial
performance test using the test methods
and procedures listed in §§ 63.7 and
63.865, except as provided in paragraph
tb)(3) of this section.
(2) Determination of operating ranges.
(i) During the initial performance test
required in paragraph (b)(l) of this
section, the owner or operator of any
affected source or process unit must
establish operating ranges for the
monitoring parameters in paragraphs
(a)(2) through (5) of this section, as
appropriate; or
(ii) The owner or operator may base
operating ranges on values recorded
during previous performance tests or
conduct additional performance tests for
the specific purpose of establishing
operating ranges, provided that test data
used to establish the operating ranges
are or have been obtained using the test
methods required in this subpart. The
owner or operator of the affected source
or process unit must certify that all
control techniques and processes have
not been modified subsequent to the
testing upon which the data used to
establish the operating parameter ranges
were obtained.
(iii) The owner or operator of an
affected source or process unit may
establish expanded or replacement
operating ranges for the monitoring
parameter values listed in paragraphs
(a)(2) through (5) of this section and
established in paragraph (b)(2)(i) or (ii)
of this section during subsequent
performance tests using the test
methods in § 63.865.
(3) An initial performance test is not
required to be conducted in order to
determine compliance with the
emissions limitations of §63.862(c)(l) if
the affected source or process unit
includes an NDCE recovery furnace
equipped with a dry ESP system.
(4) After the Administrator has
approved the PM emissions limits for
each kraft or soda recovery furnace,
smelt dissolving tank, and lime kiln, the
owner or operator complying with an
overall PM emission limit established in
§ 63.862(a)(l)(ii) must demonstrate
compliance with the HAP metals
standard by demonstrating compliance
with the approved PM emissions limits
for each affected kraft or soda recovery
furnace, smelt dissolving tank, and lime
kiln, using the test methods and
procedures in § 63.865(b).
(c) On-going compliance provisions.
(1) Following the compliance date.
owners or operators of all affected
sources or process units are required to
implement corrective action, as
specified in the startup, shutdown, and
malfunction plan prepared under
§63.866(a) if the monitoring
exceedances in paragraphs (c)(l)(i)
through (v) of this section occur:
(i) For a new or existing kraft or soda
recovery furnace or lime kiln equipped
with an ESP, when the average of ten
consecutive 6-minute averages result in
a measurement greater than 20 percent
opacity;
(ii) For a new or existing kraft or soda
recovery furnace, kraft or soda smelt
dissolving tank, kraft or sotia lime lain,
or sulfite combustion unit equipped
with a wet scrubber, when any 3-hour
average parameter value is outside the
range of values established in paragraph
(b)(2) of this section
(iii) For a new or existing
semichemical combustion ur,.'
equipped.with an RTO, when any \
hour average temperature falls below
the temperature established i-
paragraph (b)(2) of this sp'tr.::
(iv) For an affected source or proces?
unit equipped with an alternative
emission control system approved by
the Administrator, when any 3-hour
average value is outside the range o;
parameter values established in
paragraph (b)(2) of this section; and
(vj For an affected source or process
unit that is monitoring alternative
operating parameters established n,
paragraph (a)(4) of this section, when
any 3-hour average value is outside the
range of parameter values established in
paragraph (b)(2) of this sectic..
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3197
(2) Following the compliance date,
owners or operators of all affected
sources or process units are in violation
of the standards of § 63.862 if the
monitoring exceedances in paragraphs
(c)(2)(i) through (vi) of this section
occur:
(i) For an existing kraft or soda
recovery furnace equipped with an ESP,
when opacity is greater than 35 percent
for 6 percent or more of the operating
time within any quarterly period,
(ii) For a new kraft or soda recovery
furnace or a new or existing lime kiln
equipped with an ESP, when opacity is
greater than 20 percent for 6 percent or
more of the operating time within any
quarterly period;
(iii) For a new or existing kraft or soda
recovery furnace, kraft or soda smelt
dissolving tank, kraft or sods lime kiln,
or sulfite combustion unit equipped
with a wet scrubber, when sbt or more
3-hour average parameter values within
any 6-month reporting period are
outside the range of values established
in paragraph (b)(2) of this section;
(iv) For a new or existing
semichemical combustion unit
equipped with an RTO, when any 3-
hour average temperature falls below
the temperature established in
paragraph (b)(2) of this section;
(v) For an affected source or process
unit equipped with an alternative air
pollution control system approved by
the Administrator, when six or more 3-
hour average values within any 6-month
reporting period are outside the range of
parameter values established in
paragraph fb)(2) of this section; and
(vij For an affected source or process
unit that is monitoring alternative
operating parameters established in
paragraph (a)(4) of this section, when
six or more 3-hour average values
within any 6-month reporting period are
outside the range of parameter values
established in paragraph (b){2) of this
section.
(3) For purposes of determining the
number of nonopacity monitoring
exceedances, no more than one
exceedance will be attributed in any
given 24-hour period.
$ 63.865 Performance test requirements
•nd test methods.
(a) The owner or operator of a process
unit seeking to comply with a PM
emission limit under
§ 63.862(a)(l](ii)(A) must use the
procedures in paragraphs (a)(l) through
(4) of this section:
(1) Determine the overall PM emission
limit for the chemical recovery system
at the mill using Equation 1 of this
section as follows:
ELp« =
(Eq.
Where-
w^overall PM emission limit for a!3
existing process units in the chemical
recovery system at the kraft or soda pulp
mill, kg/Mg (Ib'ton) of bla Jc liquor sohds
fired
t tip=reference concentration of 0 1C g./
dscrn (0.044 gr/dscf) corrected to e
percent oxygen for existing krafl or soda
recovery furnaces
of the average volumetric gas
flow rates measured during the
performance test and corrected tc 6
percent oxygen for all existing recovery
furnaces in the chemical r?cc\ ?-. s\s:?rri
at the kraf: or soda pulp TT::, d~
standard cubic meter? per rr..r.'-'^ i'd?cnr
min) (dry standsrc crub.c fe^' r>t: nuru'.e
[dscf/min];
f LK=reference coacentrauc" ';' T !: g
dscm (0 064 gr/dscf) coirec'fc t- 1C
percent oxygen for existing kraft or soda
lime kilns.
Qjjcui=siim of the average volumetric gas
flow rates measured dunng the
performance test and corrected to 10
percent oxygen foi all existing lime kilns
in the chemical recov ery system at the
kraft or soda pulp mill, dscm/min (dscf/
min).
Fl=conversion factor, 1 44
minutes«;kilogram/day»gram (rmn«kg/
d«g) (0.206 minutes«pound,'day»grain
(min«lh/d«grl).
BLS»<=sum of the average black liquor solids
firing rates of all existing recovery
furnaces in the chemical recovery system
at the kraft or soda pulp mill measured
during the performance test, rnegagrams
per day (Mg/d) (tons per day (tons/d]) of
black liquor solids fired
EKlre; sr>T=reference emission rate of 0 10 kg-'
Mg (0 20 ib/ton) of black liquor solids
fired for existing kraft or soda smelt
dissolving tanVv
(2) Establish an emission limit for
each kraft or soda recovery furnace,
smelt dissolving tank, and lime kiln,
and, using these emissions limits,
determine the overall PM emission rate
for the chemical recovery systen, at the
mill using the procedures in paragraphs
(a)(2)(i) through (v) of this section, such
that the overall PM emission rate
calculated in paragraph (a)(2)(v) of this
section is less than or equal to the
overall PM emission limit determined in
paragraph (a)(l) of this sector., as
appropriate.
(i) The PM emission rate from each
affected recovery furnace must be
determined using Equation 2 of this
section as follows:
EKRi:=(Fl)(CEL,Rf)(QRFXBLS) (Eq 2)
Where.
ERRF=emission rate from each reco\ f>
furnace. kg/Mg (Ib.'tor.) of black Uq-jo:
solids
Fl=conversion factor, 1.44 min«kg/d«g (0 206
Tnin»/H»gr)
Cm- RF=PM emission limit proposed b}
owner or operator for the ,-ecov er\
furnace, g/dscm (gr/dscf) corrected to 8
percent oxygen
Qm«=average volumetric gas flow rate from
tie recovery furnace measured dunng
the performance test and corrected to 6
percent oxygen, dscm/min (dscf/nun)
BLS=average black liquor solids firing rale of
the recovery furnace measured during
the performance test, Mg'd (ton/d) of
black hquor solids
(ii) The PM emission rate from each
affected smelt dissolving tank must be
determined using Equation 3 of this
section as follows:
= (HI)(CEL,SDT)(QSDT)/(BLS) (Eq. 3)
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001 /Rules and Regulations
Where:
ERstrr~emission rate from each SDT, kg/Mg
(Ib/ton) of black liquor solids Bred.
Fl=conversion factor, 1.44 min«kg/d«g (0.206
min»lb/d«gr).
CBU strr-PM emission limit proposed by
owner or operator for the smelt
dissolving tank, g/dsum (gr/dscf).
Qstrr^average volumetric gas flow rate from
the smelt dissolving tank measured
during the performance test, dscm/min
(dsd/min).
BLSxverage black liquor solids firing rate of
the associated recovery furnace
measured during the performance test,
Mg/d (ton/d) of black liquorsolids Bred.
If more than one SDT is used to dissolve
the smelt from a given recovery furnace,
then the black liquor solids firing rate of
the furnace must be proportioned
according to the size of the SDT.
(iii) The PM emission rate from each
affected lime kiln must be determined
using Equation 4 of this section as
follows:
(FlXCEULK)(Qix)(CaOto(/BLSlol)/(CaOLX) (Eq. 4)
Where:
ERi_K=emission rate from each lime kiln, kg/
Mg Ob/ton) of black liquor solids.
Fl«conversion factor, 1 44 mir;«kg/d«g (0 206
min»lb/d«gr).
CB_JJC«PM emission limit proposed by owner
or operator for the lime kiln, g/dson (gr/
dscf) corrected to 50 percent oxygen
Qm=average volumetric gas flow rate from
the lime kiln measured during the
performance test and corrected to 10
percent oxygen, dscm/min (dscf/min)
CaOijt-lime production rate of the lime kiln,
measured as CaO during the performance
test, Mg/d (ton/d) of CaO.
CaO,o<=sum of the average lime production
rates for all existing lime kilns in the
chemical recovery system at the mill
measured as CaO during the performance
test, Mg/d (ton/d)
BLSnH'Sum of the average black liquor solids
firing rates of all recovery furnaces in the
chemical recovery system at the mill
measured during the performance test,
Mg/d (ton/d) of black liquor solids.
(iv) If more than one similar process
unit is operated in the chemical
recovery system at the kraft or soda pulp
mill, Equation 5 of this section must be
used to calculate the overall PM
emission rate from all similar process
units in the chemical recovery system at
the mill and must be used in
determining the overall PM emission
rate for the chemical recovery system at
the mill:
uu* =ERPU1(PRPU1/PRDI)-f . . . +(ERPU1X"W*R»)
. 5
Where-
ERro«x=overall PM emission rate from al!
v similar process units, kg/N.g (Ib/ton) of
: black liquor solids fired.
§Rpvi=PM emission rate from process unit
No. 1, kg/Mg (Ib/ton) of black liquor
solids fired, calculated using Equation 2,
3, or 4 in paragraphs (a)(2)[i) through (iii)
of this section.
PRpui=black liquor solids firing rate in Mg/
d (ton/d) for process unit No. 1, if
process unit is a recovery furnace or
SDT. The CaO production rate in Mg/d
(ton/d) for process unit No. 1, if process
unit is a lime kiln.
PRn=total black liquor solids firing rate in
Mg/d (ton/d) for all recovery furnaces in
the chemical recovery system at the kraft
or soda pulp mill if the similar process
units are recovery furnaces or SDT, or
the total CaO production rate in Mg/d
(ton/d) for all lime kilns in the chemical
recovery system at the mill if the similar
process units are lime kilns
ERru.-PM emission rate from process unit
No. i, kg/Mg (Ib/ton) of black liquor
solids Ered
PRpu,*black liquor solids firing rate in Mg/
d (ton/d) for process unit No. i, if process
unit is a recovery furnace or SDT. The
CaO production rate in Mg/d (ton/d) for
process unit No. i, if process unit is a
limekiln.
i=number of similar process units located in
the chemical recovery system at the kraf
or soda pulp mill.
(v) The overall PM emission rate for
the chemical recovery system at the mill
must be determined using Equation 6 of
this section as follows:
= ERRF,^4ERc
,4ER,
(Eq 6)
Where.
ERux=overall PM emission rate for the
chemical recover}- system at the mill, kg-'
Mg (Ib/ton) of black liquor sobds fired
ERnpK*=PM emission rate from a'! k-. ft or
soda recovery furnaces, caicuJaied us_ng
Equation 2 or 5 in paragraphs (a)(2)!i'
and (iv) of this section, where applicable,
kg/Mg (Ib/ton) of black liquor solids
fired
ERsDT««=PM emission rate from all smelt
dissolving tanks, calculated using
Equation 3 or 5 in paragraphs (a)(2)(n)
and (iv) of this section, where applicable,
kg/Mg Ob/ton) of black liouor solids
fired
ERuck><«PM emission rate from all lime kilns,
calculated using Equation 4 or 5 in
paragraphs (a)(2)(iii) and (iv) of this
section, where applicable, kg/Mg (Ib/ton)
of blade liquor sobds fired.
(3) For purposes of determining the
volumetric gas flow rate used in this
section for each kraft or soda recovery
furnace, smelt dissolving tank, and lime
kiln, Methods 1 through 4 in appendix
A of 40 CFR part 60 must be used.
(4) Process data measured during the
performance test must be used to
determine the black liquor solids firing
rate on a dry basis and the CaO
production rate.
(b) The owner or operator seeking to
determine compliance with § 63.862(a)
must use the procedures in paragraphs
(b)(l) through (4) of this section
(1) For purposes of determining the
concentration of PM emitted from each
kraft or soda recovery furnace, sulfite
combustion unit, smelt dissolving tank
or lime kiln, Method 5 or 29 in
appendix A of 40 CFR part 60 must be
used, except that Method l~ in
appendix A of 40 CFR part ftO ma> b'
used in lieu of Method 5 or Sletii'j -.
if a constant value of 0.009 g/dscrr.
(0.004 gr/dscf) is added tn the res_.t« c''
Method 17, and the stark tempers' • •. .
no greater than 205°C (400 "j Tr.
sampling time and sample \c!.*me fo.
each run must be at least 60 minute -
and 0.90 dscm (31.8 dscf). Water must
be used as the cleanup solvent instead
of acetone in the sample recoven
procedure.
(2) For sources complying with
paragraph (a)(l)or(2) of §63 862, thr
PM concentration must be corrected to
the appropriate oxygen concentrati?'1
using Equation 7 of this section as
follows:
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3199
Ctorr=CnlMx(21-X)/(21-Y) (Bq.7)
Where:
Ccnr"the measured concentration corrected
for oxygen, g/dscm (gr/dscf).
Cm=the measured concentration
uncorrecled for oxygen, g/dscrn (gr/dscf).
X»the corrected volumetric oxygen
concentration (8 percent for kraft or soda
recovery furnaces and sulfite combustion
units and 10 percent for kraft or soda
lime kilos).
Y*the measured average volumetric oxygen
concentration.
(3) Method 3A or 3B in appendix A
of 40 CFR part 60 must be used to
determine the oxygen concentration.
The gas sample must be taken at the
same time and at the same traverse
points as the participate sample.
(4) For purposes of complying with
paragraph (a)(l) or (2) of § 63.862, the
volumetric gas flow rate must be
corrected to the appropriate oxygen
concentration using Equation 8 of this
section as follows:
(Eq.8)
Where.
Qpon * the measured volumetric gas flow rate
corrected for oxygen, dscm/min (dscf/
min),
tie measured volumetric gas flow
rate uncorrected for oxygen, dscn/mm
(dscf/min).
s the corrected volumetric oxygen
concentration (8 percent for kraft or soda
recoverv furnaces and sulfke combustion
units and 10 percent for kraft or soda
lime kilns).
Y - the measured average volumetric oxygen
concentration.
(c) The owner or operator seeking to
determine compliance with the gaseous
organic HAP standard in § 63.862(c)(l)
without using an NDCE recovery
furnace equipped with a dry ESP system
must use Method 308 in appendix A of
this part The sampling time and sample
volume for each run must be at least 60
minutes and 0.014 dscm (0.50 dscf),
respectively.
(1) The emission rate from any new
NDCE recovery furnace must be
determined using Equation 9 of this
section as follows:
ER
NDCE
(MRmeM)/(BLS) (Eq. 9)
Where
ERf*xicE = methanol emission rate from the
rVDCE recover}' furnace, kg Mg [id/ton)
of black liquor sokds fired
measured methauo] mass emission
rate from the NDCE recovery furnace, kg/
hi (Jb/hr).
BLS = average black liquor solids firing rate
o/ the NDCE recovery furnace, Mg/hr
(ton/hr); determined using process data
measured during the performance test.
(2) The emission rate from any new
DCE recovery furnace system must be
determined using Equation 10 of this
section as follows:
(Eq. 10)
Wherf
EKn^t = methanol emission rate fr^n ecd.
DCE recovery hirnecf syjterr kg-'Mg tl^'
tor,; of black liquor solid* f.re-
MR«r«** RF = average measured n^'hanDi ma?<
emission rate from each DCE reco\er-
furnace, kg/hr Ob tr)
o = average measured meLh^nc!
mass emission rate from the black liquor
oxidation systerr., k£ 'hr (it r.:
BLSkF = average black liquor solids firing rate
for each DCE recovery furnace, Mg.'hr
(tontr), determined using process data
measured dunng tie performance tesi
BLSato = the average mass rate of black
liquor solids treated in the black liquor
oxidation system, Mg/hr (ton/hr),
determined using process data measured
during the performance test
(d) The owner or operator seeking to
determine compliance with the gaseous
organic HAP standards in §63.862(c)(2)
for semichemical combustion units
must use Method 25A in appendix A of
40 CFR part 60. The sampling time must
be at least 60 minutes
(1) The emission rate from any new or
existing semichemical combustion unit
must be determined using Equation 11
of this section as follows.
ERsccu=(THCmM,)/(BLS) (Eq. ll)
Where
ERsccu = THC emission rate from each
semichemjcal combustion unit, kg/Mg
(Ib/ton) of black liquor solids fired
= measured THC mass emission rate,
kg/hr flb/hr)
BLS = average black liquor sohds firing rate,
Mg/hr [ton/hr); determined using process
data measured during the performance
test.
(2) If the owner or operator of the
semichemical combustion unit has
selected the percentage reduction
standards for THC, under
§ 63.862(c)(2)(ii), the percentage
reduction in THC emissions is
computed using Equation 12 of this
section as follows, provided that Ei and
Eo are measured simultaneously:
A-25
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Federal Register/Vol. 66, No. 9/Friday, January 12, 2001/Rules and Regulations
(%R
rac =
Where:
%KTHC = percentage reduction of total
hydrocarbons emissions achieved.
E, = measured THC mass emission rate at the
THC control device inlet, kg/hr (lb/hr).
EC = measured THC mass emission rate at the
THC control device outlet, kg/hr (lb/hr).
(e) The owner or operator seeking to
comply with the continuous parameter
monitoring requirements of
§63.864(b)(2) must continuously
monitor each parameter and determine
the arithmetic average value of each
parameter during each 3-run
performance test. Multiple 3-run
performance tests may be conducted to
establish a range of parameter values.
(f) The owner or operator of an
affected source or process unit seeking
to demonstrate compliance with the
standards in § 63.862 using a control
technique other than those listed in
§ 63.864(a)(l) through (3) must provide
to the Administrator a monitoring plan
that includes a description of the
control device, test results verifying the
performance of the control device, the
appropriate operating parameters that
will be monitored, and the frequency of
measuring and recording to establish
continuous compliance with the
standards. The monitoring plan is
subject to the Administrator's approval.
The owner or operator of the affected
source or process unit must install,
calibrate, operate, and maintain the
moritoris) in accordance with the
monitoring plan approved by the
Administrator The owner or operator
must include in the information
submitted to the Administrator
proposed performance specifications
and quality assurance procedures for the
monitors. The Administrator may
request further information and will
approve acceptable test methods and
procedures.
§63.866 Recordkeeplng requirements.
(a) Startup, shutdown, and
malfunction plan. The owner or
operator must develop and implement a
written plan as described in §63 6(e)(3)
that contains specific procedures to be
followed for operating the source and
maintaining the source during periods
of startup, shutdown, and malfunction,
and a program of corrective action for
malfunctioning process and control
systems used to comply with the
standards. In addition to the
information required in § 63.6(e), the
plan must include the requirements in
paragraphs (a)(l) and (2) of this section.
(1) Procedures for responding to any
process parameter level that is
inconsistent with the level(s)
established under §63.864(b)(2),
including the procedures in paragraphs
(a)(l)(i) and (ii) of this section:
(ij Procedures to determine and
record the cause of an operating
parameter exceedance and the time the
exceedance began and ended; and
(ii) Corrective actions to be taken in
the event of an operating parameter
exceedance, including procedures for
recording the actions taken to correct
the exceedance.
(2) The startup, shutdown, and
malfunction plan also must include the
schedules listed in paragraphs (a)(2)(i)
and (ii) of this section:
(i) A maintenance schedule for each
control technique that is consistent
with, but not limited to, the
manufacturer's instructions and
recommendations for routine and long-
term maintenance; and
(ii) An inspection schedule for each
continuous monitoring system required
under § 63.864 to ensure, at least once
in each 24-hour period, that each
continuous monitoring system is
properly functioning.
(b) The owner or operator of an
affected source or process unit must
maintain records of any occurrence
when corrective action is required
under § 63.864(c)(l), and when a
violation is noted under §63.864(c)(2).
(c) In addition to the genera! records
required by §63.10(b)(2), the owner or
operator must maintain records of the
information in paragraphs (c){l) through
(6) of this section-
(1) Records of black liquor solids
firing rates in units of megagrams/day or
tons/day for all recovery' furnaces and
semichemical combustion units,
(2) Records of CaO production rates in
units of megagrams/day or tons/day for
all lime kilns;
(3) Records of parameter monitoring
data required under § 63.864, including
any period when the operating
parameter levels were inconsistent with
the levels established during the initial
performance test, with a brief
explanation of the cause of the
deviation, the time the deviation
occurred, the time corrective action was
initiated and completed, and the
corrective action taken;
(4) Records and documentation of
supporting calculations for compliance
determinations made under §§ 63.865(a)
through (e);
(5) Records of monitoring parameter
ranges established for each affected
source or process unit;
(6) Records certifying that an NDCE
recovery furnace equipped with a dry
ESP system is used to comply with the
gaseous organic HAP standard in
§63.862(c)(l).
$63.867 Reporting requirements.
(a) Notifications. The owner or
operator of any affected source or
process unit must submit the applicable
notifications from subpart A of this part,
as specified in Table 1 of this subpart.
(b) Additional reporting requirements
for HAP metals standards. (1) Any
owner or operator of a group of process
units in a chemical recovery system a*
a mill complying with the PM emissions
limits in § 63.862(a)(l)(ii) must submit
the PM emissions limits determined in
§ 63.865(a) for each affected kraft or
soda recovery furnace, smelt dissolving
tank, and lime kiln to the Administrator
for approval. The emissions limits mus1.
be submitted as part of the notification
of compliance status required under
subpart A of this part.
(2) Any owner or operator of a group
of process units in a chemical recovery
system at a mill complying with the PM
emissions limits in §63.862(a)(l)(ii)
must submit the calculations and
supporting documentation used in
§ 63.865(a)(l) and (2) to the
Administrator as part of the notification
of compliance status required under
subpart A of this part.
(3) After the Administrator has
approved the emissions limits for any
process unit, the owner or operator of a
process unit must notify the
Administrator before any of the actions
in paragraphs (b)(3)(i) through (iv', of
this section are taken:
(i) The air pollution control system for
any process unit is modified or
replaced;
(ii) Any kraft or soda re^cNcr,
furnace, smelt dissolving tank, cr lii:ic
kiln in a chemical recovery syslem at a
kraft or soda pulp mill complying will:
the PM emissions limits in
§63.862(a)(l)(ii) is shut down for more
than 60 consecutive days;
(iii) A continuous monitoring
parameter or the value or range of
values of a continuous monitoring
parameter for any process unit is
changed; or
(iv) The black liquor solids firing rat
for any kraft or soda recovery furnace
during any 24-hour averaging period is
A-26
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Federal Register/Vol. 66, No. 9/Friday. January 12, 2001/Rules and Regulations 3201
increased by more than 10 percent
above the level measured during the
most recent performance test.
(4) An owner or operator of a group
of process units'in a chemical recovery
system at a mill complying with the PM
emissions limits in §63.862(aj(l}(ii] and
seeking to perform the actions in
paragraph (b)(3)(i) cr (ii) of this section
must recalculate the overall PM
emissions limit for the group of process
units and resubmit the documentation
required in paragraph fb)(2) of this
section to the Administrator. All
modified PM emissions limits are
subject to approval by the
Administrator.
(c) Excess emissions report. The
owner or operator must report quarterly
if measured parameters meet any of *he
conditions specified in paragraph (c)(l)
or (2) of § 63.864. This report must
contain the information specified in
§ 63.10(c) of this part as well as the
number and duration of occurrences
when the source met or exceeded the
conditions in §63.864(c)(l), and the
number and duration of occurrences
when the source met or exceeded the
conditions in § 63.864(c)(2). Reporting
excess emissions below the violation
thresholds of § 63.664(c) does not
constitute a violation of the applicable
standard.
(1) When no exceedances of
parameters have occurred, the owner or
operator must submit a semiannual
report stating that no excess emissions
occurred during the reporting period.
(2) The owner or operator of an
affected source or process unit subject to
the requirements of this subpart and
subpart S of this part may combine
excess emissions and/or summary
reports for the mill.
S 63.868 Dttegctlon of «uthortty.
(a) In delegating implementation and
enforcement authority to a State under
section 112(d) of the Clean Air Act, the
authorities contained in paragraph flj) of
this section must be retained by the
Administrator and not transferred to a
State.
(b) The authorities which will not be
delegated to States are listed in
paragraphs (b)(l) through (4) of this
section:
(1) Approval of alternatives to
standards in § 63.862 under § 63.6(gJ.
(2) Approval of major alternatives to
test methods under § 63.7(e)(2)(ii) and
(0 and as defined in §63.90.
(3) Approval of major alternatives to
monitoring under § 63.8(f) and as
defined in § 63.90.
(4) Approval of major alternatives to
recordkeeping and reporting under
§ 63.10(f) and as defined in § 63.90.
TABLE 1 TO SUBPART MM—GENERAL PROVISIONS APPLICABILITY To SUBPART MM
Genera! provisions
reference
Summary of requirements
Applies to supbart
MM
Explanation
631-DV1'
63 1(b)iZ;
631(b>(3)
632
63.3
634
63.5(8! ...
63.5(b»(1)
63.5 . .
63 1(e
Applicability of subpa1! A of this part after a
relevant standard has been set.
| Trtte V permit requirement
Yes
Yes
[Reserved". .
Requirements for existing source that obtains
a<- exiersic" of compliance
j Notf c^'ucri requirements for an area source
i ma: increases HAP emissions to major
Appicasir-. o( permit program before a rel-
evav. standard has been set
D«firr:o-t
63.5(e)
Units and abbreviations
Prohibited activities and circumvention
Construction and reconstruction—applicability
Upcr. construction, relevant standards tor new
sources
[Reserved]
New constructJoa'reconstruction ,
Constructioa'reconstnjctoon notification
Construction/reconstruction compliance
Equipment addition or process change
[Reserved]
Application for approval of constructon/recon-
struct on.
Construction/reconstruction approval
NA
Yes
Yes
Yes
Yes
Yes
Yes.
Yes
Yes
NA.
Yes
Yes.
Yes.
Yes.
NA
Yes.
Yes.
Additional terms defined in §63.861; when
overlap between subparts A and MM of this
part, subpart MM takes precedence
Subpart MM specifies the applicability In
§63.860.
All major affected sources are required to ob-
tain a title V permit.
All affected sources are subject to subpart
MM according to the applicability definition
of subpart MM.
Subpart MM clarifies the applicability of each
paragraph' of subpart A of this part to
sources subject to subpart MM.
AH major affected sources are required to ob-
tain a title V permit There are no area
sources in the pulp end paper rrdll source
category.
Additional terms defined in §63.861; when
overlap between subparts A and MM of this
part occurs, subpart MM takes precedence
-------
3202
Federal Register/Vol. 66, No. 9 /Friday, January 12, 2001/Rules and Regulations
TABLE 1 TO SUBPART MM—GENERAL PROVISIONS APPLICABILITY To SUBPART MM—Continued
General provisions
reference
Summary of requirements
Applies to supoart
MM
Explanation
63.5(t)
63.6
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Federal Register/Vol. 66, No. 9/Friday. January 12, 2001 fRules and Regulations
3203
TABLE 1 TO SUBPART MM—GENERAL PROVISIONS APPLICABILITY To SUBPART MM—Continued
General provisions
reference
Summary of requirements
Applies to supbart
MM
Explanation
63.9(h)
63.9(i) ..
63.90) ....
63.10(a)
63 10{b)(1)
63.10
-------
Technical Corrections to Final NESHAP
(July 19, 2001)
A-31
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A-32
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Federal Register/Vol. 66, No. 139/Thursday, July 19, 2001/Rules and Regulations
37591
requirements, Sulfur oxides, Volatile
organic compounds.
Authority. 42 U.S.C. 7401 et teq.
Dated: May 25, 2001
Laura Yoehii,
Acting Regional Administrator, Region IX.
Part 52, chapter I, title 40 of the Code
of Federal Regulations is amended as
follows.
PART 52—[AMENDED!
1. The authority citation for part 52
continues to read as follows:
Authority: 4Z U.S.C. 7401 et seq
Subpart F—California
2. Section 52.220 is amended by
adding paragraphs (c)(260)(i)(B) and
(c)(266)(i)(B)(3) to read as follows
$52.220 Identification of plan.
(c)" * *
(260) * * *
(I)'''
(B) San Joaquin Vallcv Unified Air'
Pollution Control Distnc*
(3) Rule 2020 adopted on September
17,1998,
(266) ' ' *
(0* * *
(E)* ' *
(3) Rule 2201 adopted on Augus' 2C,
1996
[FRDoc c:-ir"C:. Fi'.cc •-IB-C: e 45 ami
BILLMO CODE
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 63
[AD-FHL-6997-8]
RIN2060-AI34
National Emission Standards for
Hazardous Air Pollutants for Chemical
Recovery Combustion Sources at
Kraft, Soda, Sulflte, and Stand-Alone
Semichemlcal Pulp Mills
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule; technical corrections.
SUMMARY: Under the Clean Air Act
(CAA), EPA promulgated the national
emission standards for hazardous air
pollutants (NESHAP) for chemical
recovery combustion sources at kraft,
soda, sulfite, and stand-alone
semichemical pulp mills on January 12,
2001. The promulgated rule requires
new and existing malor sources to
control emissions of hazardous air
pollutants (HAP) to the level reflecting
application of the maximum achievable
control technology. The technical
corrections in this action will not
change the standards established by the
rule or the level of health protection it
provides.
Section 553 of the Administrative
Procedure Act, 5 U.S.C. 553(b)(B),
provides that, when an agency for good
cause finds that notice and public
procedure ere impracticable,
unnecessary, or contrary' to the public
interest, the agency may issue a rule
without providing notice and an
opportunity for public comment. \Ve
have determined that there is good
cause for making today's rule final
without prior proposal and opportunity
for comment because the changes to the
rule are minor technical corrections
consisting largely of correcting
typographical errors and other misprints
and correcting minor errors in the rule's
effective dates, are noncontroversia!,
and do not substantive)}' change the
requirements of the rule In addition,
there has already been full opportunity
to comment on all of the provisions in
this Notice. Thus, notice and public
procedure are unnecessary. We find that
this constitutes good cause tinder 5
U.S.C. 553(b)(B) (see also the final
sentence of.section 307(d)(l) of the
Clean Air Act, 42 U.S.C. section
7607(d)(l), indicating that the good
cause provisions of the Administrative
Procedure Act continue to apply to this
type of rulemaking under the Clean Air
Act).
Section 553(d)(3) allows an agency,
upon a finding of good cause, to make
a rule effective immediately. Because
today's changes do not substantively
change the requirements of the rule, we
find good cause to make these technical
corrections effective immediately.
EFFECTIVE DATE: July 19, 2001.
ADDRESSES: Docket No. A-94-67
contains the supporting information for
the original NESHAP for chemical
recovery combustion sources at kraft,
soda, sulfite, and stand-alone
semichemical mills and this action. The
docket is located at the U.S. EPA in
room M-1500, Waterside Mall (ground
floor), 401 M Street SW., Washington,
DC 20460, and may be inspected from
8 a.m. to 5:30 p.m., Monday through
Friday, excluding legal holidays A
reasonable fee may be charged for
copying.
FOR FURTHER INFORMATION CONTACT: Mr.
Jeff Telander, Minerals and Inorganic
Chemicals Group, Emission Standards
Division (MD-13), Office of Air Quality
Planning and Standards, U.S. EPA,
Research Triangle Park, North Carolina
27711, telephone number (919) 541-
5427, facsimile number (919) 541-5600,
electronic mail address
teiander.jeff@epa go\.
SUPPLEMENTARY INFORMATION:
Regulated Entities. Categories and
entities potentially regulated by this
action are those kraft, soda, sulfite, and
stand-alone semichemical pulp mills
with chemical recovery processes that
involve the combustion of spent pulping
liquor. Categories and entities
potentially regulated by this action
include:
Caiejo-,
Industry
SIC coce
26'. 1,262' 2631 .
NAICS code
32211, 32212, 32213 ..
Examples of regulated entities
Kraft, soda, sulfite, and stand-alone semichemical pulp mills
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
regulated by this action. This table lists
the types of entities that EPA is now
aware could potentially be regulated by
this action.
To determine whether your facility is
regulated by this action, you should
carefully examine the applicability
criteria in §63.860 of the final rule. If
you have questions regarding the
applicability of this action to a
particular entity, consult the person
listed in the preceding FOR FURTHER
INFORMATION CONTACT section of this
document.
World Wide Web (WWW). In addition
to being available in the docket, an
electronic copy of today's document
will also be available on the WWW
A-33
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37592 Federal Register/Vol. 66, No. 139/Thursday, July 19, 2001/Rules and Regulations
through the Technology Transfer
Network (TTN). Following the
signature, a copy of this action will be
posted on the TTN's policy and
guidance page for newly proposed or
final rules at http://www.epa.gov/ttn/
oarpg/t 3 pfpr.html. The TTN provides
information and technology exchange in
various areas of air pollution control. If
more information regarding the TTN is
needed, call the TTN HELP line at (919)
541-5384.
L Background
The EPA, under 40 CFR part 63,
subpart MM, promulgated the NESHAP
for chemical recovery combustion
sources at kraft, soda, sulfite, and stand-
alone semichemical pulp mills on
January 12, 2001 (66 FR 3180). The final
rule includes emissions limits, as well
as monitoring, performance testing,
recordkeeping, and reporting
requirements.
n. Summary of Corrections
Today's changes are described below
for the convenience of the reader.
Citation
Change
§63.863(8)
§63.863(b)
§63.865(3)
§63.865(8X3), (aX4). (b)(5), and
(bM6).
§63.865(b)
§63.865(b)(2)
§63.865(b)(4)
§63.865(c)
§63.865(d)
Change the compliance date for existing affected sources to March 13, 2004.
Change the startup date, after which new affected sources must comply knmecfately upon startup, to
March 13,2001.
Reduce the number of referenced paragraphs from "(a)(1) through (4)" to >X1) and (2)" to reflect the
elimination of paragraphs (a)(3) and (4).
Remove paragraphs
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Federal Register/Vol. 66, No. 139/Thursday, July 19, 2001/Rules and Regulations
37593
determination must be supported by a
brief statement (5 U.S.C. 808(2)). As
stated previously, EPA has made such a
good cause finding, including the
reasons therefor, and established an
effective date of July 19, 2001. The EPA
will submit a report containing this rule
and other required information to the
U.S. Senate, the U.S. House of
Representatives, and the Comptroller
General of the United States prior to
publication of the rule in the Federal
Register. This action is not a "major
rule" as denned by 5 U.S.C. 804(2).
List of Subjects in 40 CFR Part 63
Environmental protection, Air
pollution control, Hazardous
substances, Pulp and paper mills.
Dated- June 8, 200:
Robert D. Brenner,
Acting Assistant Administrator for Air and
Radiation.
For the reasons set out in the
preamble, title 40, chapter I, part 63 of
the Code of Federal Regulations is
amended as follows:
PART 63—[AMENDED]
1. The authority citation for part 63
continues to read as follows
V Authority: 42 U S C 7401 ei «eq
Subpart MM—National Emission
Standards for Hazardous Air Pollutants
for Chemical Recovery Combustion
Sources at Kraft, Soda, Sulflte, and
Stand-Alone Semlchemlcal Pulp Mills
2, Section 63.863 is amended b\
revising paragraph (si and (b) to read as
fallows
§63.863 Compliance dales
(a) The owner cr opera'cr of an
existing affected source or process unit
must comph w:'v. tn«= rpq'j;u.- L~> ir
this subpart no later thar- Mar CM 13,
2004
fb) TOe owner or operator c: a nev>
affected source that has an initial
startup date after March 13, 200'. must
comply » ith the reouire-r ents i~ this
subpart immediate!) upon startup of the
affected source, except as specified in
§63.6(1;
*****
3 Section 63 865 is amended bv
a. Revising paragraph (a) introductory
text:
b. Removing paragraphs (a)(3) and (4);
c. Revising paragraphs fb)
introductory text, fb)!2j, and (b)(4);
d. Adding paragraphs fb)(5) and (6);
e. Revising paragraph (c) introductory
text, and
f. Revising paragraph (d) introductory
text
The revisions and additions read as
follows:
§ 63.885 Performance te»t requirements
•nd te*t methods.
(a) The owner or operator of a process
unit seeking to comply with a PM
emission limit under
§ 63.862(a)(l)(ii)(A) must use the
procedures in paragraphs (a)(l) and (2)
of this section:
(b) The owner or operator seeking to
determine compliance with §63.862(a)
or (b) must use the procedures in
paragraphs (b)(l) through (6) of this
section.
(2) For sources complying with
paragraph (a) or (b) of § 63,862, the PM
concentration must be corrected to the
appropriate oxygen concentration using
Equation 7 of this section as follows:
C^ = Cmeas x (21 - XVI21 - Y) (Eq
7)
Where.
CC^T = the measured concentration corrected
for oxygen, g'dscm (gr/dscf].
Cnvu = the measured concentrauon
uncorrected for oxygen, g/dscm (gr/dscf).
X = the corrected volumetric oxygen
concentration (8 percent for kraft or soda
recovery furnaces and sulfite combustion
units and 10 percent for kraft or soda
lime kilns)
Y =: the measured average volumetric oxygen
concentration
*****
(4) For purposes of complying with of
§63.862(a)(l)(ii)(A), the volumetric gas
flow rate must be corrected to the
appropriate oxygen concentration using
Equation 8 of this section as follows.
Qoor- = Qmeasx(21 - Y)/(21 - X) (Eq.
Sj
Where
Qcorr = the measured volumetric gas flew rate
corrected for oxygen, dscin'min (dsci'
mm)
Qnmi « the measured volumetric gas flov,
rate uncorrected for oxygen, dscm/mirj
(dsct'min).
Y =s the measured average volumetric oxygen
concentration
X = the corrected volumetric oxygen
concentration (8 percent for kraf. or soda
recovery furnaces and 10 percent for
kraft or soda lime kilns)
(5) For purposes of selecting sampling
port location and number of traverse
points, determining stack gas velocity
and volumetric flow rate, conducting
gas analysis, and determining moisture
content of stack gas, Methods 1 through
4 in appendix A of 40 CFR part 60 must
be used.
(6) Process data measured during the
performance test must be used to
determine the black liquor solids firing
rate on a dry basis and the CaO
production rate.
(c) The owner or operator seeking to
determine compliance with the gaseous
organic HAP standard in S 63.862(c){l)
without using an NDCE recovery
furnace equipped with a dry ESP system
must use Method 308 in appendix A of
this part, as well as Methods 1 through
4 in appendix A of part 60 of this
chapter. The sampling time and sample
volume for each Method 308 run must
be at least 60 minutes and 0.014 dscm
(0.50 dscf), respectively.
*****
(d) The owner or operator seeking to
determine compliance with the gaseous
organic HAP standards in § 63.862(c)(2)
for semichemical combustion units
must use Method 25A, as well as
Methods 1 through 4, in appendix A of
part 60 of this chapter. The sampling
time for each Method 25A run must be
at least 60 minutes.
(FR Doc. 01-17559 Filed 7-18-01; 8:45 am)
BRUNO CODE «S*0-W-P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 180
JOPP-301146 FRL-6793-8]
RiN 2070-AB78
Extension of Tolerances for
Emergency Exemptions (Multiple
Chemicals)
AGENCY: Environmental Protection
Agency (EPA)
ACTION: Final rule
SUMMARY: This regulation extends time-
limited tolerances for the pesticides
listed in Unit 11, of the SUPPLEMENTARY
INFORMATION. These actions are in
response to EPA's granting of emergency
exemptions under section 18 of the
Federal Insecticide, Fungicide, and
Rodentici'de Act authorizing use of these
pesticides. Section 408(1)(6) of the
Federal Food, Drug, and Cosmetic Act
(FFDCA) requires EPA to establish a
time-limited tolerance or exemption
from the requirement for a tolerance for
pesticide chemical residues in food thai
will result from the use of a pesticide
under an emergency exemption granted
by EPA.
DATES: This regulation is effective July
19, 2001. Objections and requests for
hearings, identified by docket control
number OPP-301146, must be received
by EPA on or before August 20, 2001. .
ADDRESSES: Written objections and
hearing requests may be submitted by
A-35
-------
Appendix B
List of U.S. Pulp and Paper Mills Subject to the NESHAP
-------
Table B-1. Pulp and Paper Mills
No.
Company name
City
State Pulping process
..1.
5
6
7
9
10
Alabama Pine Pulp Co., Inc.
Alabama River Pulp Co., Inc. Claiborne (Perdue Hill) AL
Boise Cascade Corp. Jackson AL
International Paper Co. Courtland AL
Georgia-Pacific Corp. Pennin|ton AL
Gulf States Paper Corp Demopolis AL
Internationa] Paper Co. Mobile AL
International Paper Co. Prattvilje AL
International Paper Co. S^lma AL
Weyerhaeuser Paper Co. Montgomery (Pine Hill) AL
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft (semichemical
collocated)
1 1 Mead Corp
12 Mead Corp
1 ? Smurfit-Stone Container Corp.
14 Gaylord Container Corp.
15 Georgia-Pacific Corp
16 Georgia-Pacific Corp
I"7 Green BJN Packaems: Inc.
lb International Paper Co
19 Internatior,;.! P^p^; Co
20 PotlaVnCorp
21 Louisiana-Pacific Corp
22 Bucke\e Technologies Inc.
23 International Paper Co.
24 Georgia-Pacific Corp.
25 Ravomer. Inc.
26 Smurfit-Stone Container Corp.
21 Smurfit-Stone Container Corp.
28 Georg,a-Pacif,c Corp.
Phenix Citv
Stevenson
Brewton
Pine Bluff
Ashdown
Crossett
Morrilton
Camden
Pine Bluff
McGehee
Samoa
Pern
Cantonment (Pensacola)
Palatka
Fernandina Beach
Fernandina Beach
Panama City
Brunswick
AL
AL
AL
AR
AR
AR
AR
AR
AR
AR
CA
FL
FL
FL
FL
FL
FL
GA
Kraft
Semichemical
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Sulfite
Kraft
Kraft
Kraft
B-3
-------
Table B-1. (Continued)
No.
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
Company name
Georgia-Pacific Corp.
Oilman Paper Co.
International Paper Co.
Interstate Paper Corp.
International Paper Co.
Ray/onier, Inc.
Riverwood International Corp.
Temple-Inland, Inc.
Tenneco Inc.
Weyerhaeuser Paper Co.
Willamette Industries Inc
Four M Corp.
Potlatch Corp
International Paper Co.
Westvaco Corp.
Willamette Industries Inc J
Boise Cascade Corp
Crown Yantaee Inc
Gaylord Container Corp
International Paper Co.
International Paper Co.
International Paper Co.
Riverwood International Corp.
Smurfit-Stone Container Corp.
Willamette Industries Inc.
City
Cedar Springs
St. Mary's .
Augusta
Riceboro
Savannah
Jesup
Macon
Rome
Valdosta
Oglethorpe
Port Wentworth
Fort Madison
Lev.iston
Terre Haute
Wickliffe
Hawesville
Dendder
St FrancisNille
Bogalusa
Bastrop
Mansfield
Pineville
West Monroe
Hodge
Campti
State
GA
GA
GA .
GA
GA
GA
GA
GA
GA
GA
GA
IA
ID
IN
KY
KY
LA
LA
LA
LA
LA
LA
LA
LA
LA
Pulping process
Kraft (semichemical
collocated)
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Kraft
Semichemical
Kraft
Semichemical
Kraft
Kraft (semichemical
collocated)
Kraft
Kraft
Kraft
Kraft
Kraft (semichemical
collocated]
Kraft
Kraft (semichemical
collocated >
Kraft (semichemical
collocated)
Kraft
B-4
-------
Table B-1. (Continued)
No.
Company name
City
State Pulping process
54 Westvaco Corp.
55 Bowater Inc.
56 Eastern Paper Co., Inc.
57 Georgia-Pacific Corp.
Luke
Millinocket
Lincoln
Old Town
Woodland
Jay
Rumford
Hinckley (Skowhegan)
Quinnesec (Norway)
Escanaba
Otsegp
MD Kraft
ME Sulfite -
ME Kraft
ME Kraft
ME Kraft
ME Kraft
ME Kraft
ME Kraft
MI Kraft
MI Kraft
MI Sernichemical
MI Kraft
MI Sernichernica]
MI Sernichernical
MN Kraft
_^MN Kraft
__MS Kraft
MS Kraft
MS Kraft
MS _ Kraft
MS Kraft
M_S Kra_ft
MT Kraft
NC Kraft
NC Kraft
NC Kraft
NC Kraft
59 Internationa] Paper Co.
60 Mead Corp
...................................1................................,....„.*
61 Sappi Fine Paper North America
62 International Paper Co.
63 Mead Corp
64 Menasha Corp
65 S.appi Fine Paper North America
66 Smurfit-Stone Container Corp.
67 Tenneco Inc
68 Boise Cascade Corp
69 Potlatch Corr
Muskegon
Ontonagpn
Fijer Cin
International Falls
Monticello
Ne\\ Augusta
Moss _Pomt
Natchez
71 Georcia-PaqfK' Corp
72 International Papei Q>
73 International Paper Co
74 Internationa! Paper Co
75 We\erhaeuser Paper Co
76 Smurfit-Stone Container Corp.
77 International Paper Co.
78 International Paper Co.
79 International Paper Co.
80
Redwood (Vicksbure)
Columbus
Missqula
Canton
Roanoke Rapids
Riegelwood
New Bern
B-5
-------
Table B-1. (Continued)
No.
"81
82
83
84
85
86
87
88
89
90
91
V
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
Company name
Weyerhaeuser Paper Co.
Crown Vantage Inc.
Wausau-Mosinee Paper Corp.
Finch. Pnryn. & Co.. Inc.
International Paper Co.
Mead Corp.
Smurfit-Stone Container Corp.
Weyerhaeuser Paper Co.
Boise Cascade Corp
Georgia-Pacific Corp.
Georgia-Pacific Corp.
Pope & Talbot. Inc.
We\erhaeuser Paper Co.
Appleton Papers Inc.
International Paper Co
P.H GlatfelterCo
Willamette Indjs'.ne-- Inc
Boxvatei Inc
International Paper Co
International Paper Co
Smurfit-Stone Container Corp.
Sonoco Products Co.
Westvaco Corp
Willamette Industries Inc.
Bowater Inc.
Tenneco Inc.
City
Plymouth
Berlin
Groveton
Glens Falls
Ticonderoga
Chillicothe
Coshocton
Valliant
St. Helens
Clatskanie
Toledo
Halsey
Springfield
Roaring Spring
Erie
Sprine Grove
Johnsonburg
Catavvba
Eastover
Georgetown
Florence
Hartsville
N. Charleston
Bennettsville
Calhoun
Counce
State
NC
NH
NH
NY
NY
OH
OH
OK
OR
OR
OR
OR
OR
PA
PA
PA
PA
SC
SC
SC
SC
SC
SC
SC
TN
TN
Pulping process
Kraft (semichemical
collocated)
Kraft
Semichemical
Sulfite
Kraft
Kraft
Semichemical
Kraft (semichemical
collocated)
Kraft
Kraft
Kraft '.vemichemical
collocated
Kraft
Kraft
Kraft
Sod^
Kra!;
Kraf-
Knit:
Krat-
Krat:
Kraft
Semichemical
Kraft
Kral'i
Kraft
Kraf i
B-6
-------
Table B-1. (Continued)
No.
Company name
City
State Pulping process
107
108
109
110
111
.UL
113
114
Willamette Industries Inc.
Donohue Inc.
Temple-Inland. Inc.
International Paper Co.
Temple-Inland. Inc.
Georsia-Pacific Corp
.v. r.
Greif Brothers Corp.
International Paper Co.
St Laurent Paperboard Inc
Smurfit-Stone Container Corp.
Westvacp Corp
Boise Cascade Corp
Kingsport
Lufkin
Evadale (SilSbee)
Texarkana (Domino)
Orange
Big Island
TN
TX
TX
TX
TX
VA
VA
VA
VA
VA
VA
WA
Soda
Kraft
Kraft
Kraft
Kraft
Semichemical
SemJchemical
Kraft
Kraft
Kraft
Kraft
ILL
Ul
118
Franklin
West Point
Hopewell
Covineton
Wallula
Kraft (semichemical
collocated)
119
120
121
122
Georiiia-Paufi,: Corp "
Georeid-PacilY. Corp- '
Kimbeil\ -Clark Corp
Long\ tew Fibre Co
Camas
Camas
E\'eren
Long\-ie\\
WA
WA
WA
WA
Kraft
Sulfite
Sulfite
Kraft (semichemical
collocated)
123
124
12?
126
Pon T(>\\j>end Paper Cor--
SimpNop, Pape' C\'
\\'e\erhaeu^ei Paper Co
^"e\erhaeuser Papei Co
Pon Tov, n^end
Taeoma
Cosmopolis
Long\ie\\
WA
WA
WA
WA
Kraft
Kraft
Sulfite
Kraft (semichemical
collocated)
129
130
131
132
Consolidated Paper.'-. Inc
Georgia-Pacific Corp
Georgia-Pacific Corp
Tenneco Inc.
International Paper Co
Wausau-Mosmee Paper Corp.
Wisconsin Rapids
Nekopsa
Port Edwards
Tomahawk
Kaukauna
Brokav,
WI
WI
WI
WI
WI
WI
_Kraft
Kraft
Sulfite
Sernichemical
Kraft
Sulfite
B-7
-------
Table B-1. (Continued)
No. Company name City State Pulping process
133 Wausau-Mosinee Paper Corp. Mosinee WI Kraft -
* This mill has both kraft and semichemical operations. The mill is counted as a single facility because there is
one chemical recovery operation for both pulping operations.
b This mill has both kraft and sulfite operations. The mill is counted as two facilities because there is a separate
chemical recovery operation for each pulping operation.
B-8
-------
Appendix C
List of EPA Regional Office Contacts
-------
Table C-1. EPA Regional Office Contacts
Region
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
States
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
New Jersey
New York
Puerto Rico
Virgin Islands
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Alabama
Florid..
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Illinois
Indian.:
Michigjr
Minnesota
Ohio
Wisconsin
Arkansas
Louisiana
Ne\\ Mexico
Oklahoma
Texas
Iowa
Kansas
Missouri
Nebraska
Address
Director, Air Compliance Program
1 Congress Street
Suite 11 00 (SEA)
Boston, MA 021 14-2023
Air Compliance Branch
290 Broadway
New York, NY 10007
Chief, Air Enforcement Branch
(3AP12)
1650 Arch Street
Philadelphia, PA 19103-2029
Air and Radiation Technology Branch
Atlanta Federal Center
61 Forsyth Street
Atlanta. Georgia 30303-3104
Air Enforcement and Compliance
Assurance Branch ( AE- 1 7J :
77 West Jackson Bou!e\ard
Chicago. 1L 60604-3590
Chief. Toxics Enforcement Section
(6EN-AT)
1445 Ross Avenue
Dallas. TX 75202-2733
901 N. 5th Street
Kansas City, KS 66101
Phone/Fax/Website
Phone:(617)918-1650
Fax:(617)918-1505
Website:
http://www.epa.goy/regionl
Phone:(212)637-4080
Fax:(212)637-3998
Website:
http://www.epa.gov/region2
Phone: (215) 814-3438
Fax:(215)814-2134
Website:
http://www.epa.gov/region3
Phone:(404)562-9105
Fax: (404) 562-9095
Website:
http://www.epa go\/region4
Phone:(312)353-2088
Fax:(312)353-8289
Website.
http://wwv>.epa,go\/region5
Phone- (214)665-7224
Fax: (214)665-7446
Website:
http://www.epa.gov/region6
Phone: (913)551-7020
Fax:(913)551-7844
Website:
http://www.epa.goN/region7
C-3
-------
Table C-1. (Continued)
Region
Region VHI
States
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Address
Air Enforcement Program (8ENF-T)
999 18th Street Suite 500
Denver, CO 80202
Phone/Fax/Website
Phone:(303)312-6312
Fax:(303)312-6409
Website:
http://www.epa.gov/region8
Region IX
American Samoa
Arizona
California
Guam
Hawaii
Ne\ada
Air Division
75 Hawthorne Street
San Francisco, CA 94105
Phone:(415)744-1219
Fax:(415)744-1076
Website:
http://www.epa go\/regicn9
Region X
Alaska
Idaho
Oregon
Washington
Office of Air Quality (OAQ-107)
1200 Sixth Avenue
Seattle. WA 98101
Phone: (206) 553-4273
Fax:(206)553-0110
Website:
http://www.epa.gov/region 10
C-4
-------
Appendix D
Responses to Commonly Asked Questions
-------
1. If my recovery furnace is a cross-recovery furnace (i.e., it combusts spent liquor from
both kraft and semichemical pulping processes), which standards apply to my mill?
Cross-recovery furnaces are considered kraft recovery furnaces for the purposes of this
• NESHAP. Therefore, your recovery furnace and associated SDT must comply with the
applicable requirements for kraft recovery furnaces and SDTs.
2. Does the NESHAP for Pulp and Paper Combustion Sources supersede the NSPS for
Kraft Pulp Mills?
No, not in all cases. See Table 13 of this document for a comparison of the NSPS and
NESHAP requirements for kraft pulp mills. The NSPS limits emissions of PM and TRS from
new sources at kraft pulp mills. The NSPS also includes an opacity limit for recovery
furnaces. The NESHAP limits emissions of HAP metals (using PM as a surrogate) from both
new and existing sources at kraft pulp mills and limits emissions of total gaseous organic HAP
(measured as methanol) for new recover)' furnaces at kraft pulp mills. The NESHAP does not
include opacity limits. However, opacity monitoring is required for recovery furnaces and
lime kilns equipped with ESPs. Therefore, PM is the only pollutant required to be controlled
by both rules. For existing sources, the NESHAP PM limits are the same as the NSPS PM
limits for reco\ery furnaces and SDTs and are more stringent than the NSPS PM limits for lime
kilns.
v
However, under the NESHAP, existing sources have the option of bubbling (averaging) the PM
Demissions from combustion sources at the mill, such that some sources will over-control PM
emissions while other sources ma\ under-control PM emissions. In these cases, the process
units thai are under-controlled may have calculated emission limits that are less stringent than
the established MACT PM limit and NSPS PM limit for that source. These less-stringent
limits are permissible onh if the process units are not already subject to the NSPS and the
limits dc not e vceed an\ State-imposed PM emission limit for that process unit. Example Mill
B in Appendix G sho\\ s ho\\ a mill with both NSPS and PSD sources can use the PM bubble
compliance alterr.; "'\ c
3. If I have already have performance test data from a previous compliance test (e.g., as
required as part of my State permit), can I use the test report and the associated
operating parameter data to set the compliant operating parameter levels for my
combustion source?
Previous or "historical" performance test data can be used to set the operating parameter
values for continuous monitoring purposes only if: (1) the performance test data show
compliance with the emission limits, (2) no changes have been made to the process equipment,
chemicals, or control devices since the date of the test. (3) the operating parameter values
were recorded during the period of testing, and (4) the performance test data used to establish
the operating parameter values were obtained using the test methods required in the NESHAP.
D-3
-------
4. Are there any restrictions on the use of the PM bubble compliance alternative for
meeting the PM standards for kraft and soda pulp mills?
Yes. Only existing sources (i.e., those process units that were in operation on or before April
15,1998) may use the PM bubble compliance alternative. New sources must comply with the
. emission limits for new sources. Also, stand-by units, defined as process units that operate for
less than 6,300 hours per year, cannot be included in a mill's PM bubble. In addition, as
explained in the response to question 2, above, existing process units already subject to the
NSPS PM limits must continue to meet those limits.
5. If I make changes to the chemical recovery system after the PM bubble limits have
been approved by the permitting authority, must I recalculate the bubble and the
associated emission limits?
Yes, depending on the nature of the changes. After the PM emission limits have been
approved, you must notify the permitting authority before you take any of the following actions:
1. Modify or replace any associated air pollution control equipment;
2. Shut down any process units included in the PM bubble calculations for more than
60 consecutive days;
3. Change a continuous monitoring parameter or the value or range of values of a continuous
monitoring parameter; or
4. Increase the 24-hour average black liquor solids firing rate for any recover} furnace b\
more than 10 percent above the level measured during the most recent performance test.
Of the four changes listed above, only 1 and 2 automatica'ly require that the PM bubble be
recalculated. Therefore, if you (1) modify or replace any of the associated air pollution
control systems or (2) shut down any of the process units included in the PM bubble
calculations for more than 60 consecutive days, you must recalculate the PM bubble
limits and resubmit them to your permitting authority for approval.
6. If I am complying with the PM standards using the PM bubble compliance alternative
and one of the process units in the bubble is shut down for more than 60 days, do I
have to retest all of the process units in the bubble when re-establishing the bubble
limits?
This decision will be up to the permitting authority. If production is shifted from one proces-
unit to another when one process unit shuts down, the emissions from the operating process unit
would presumably be increased, and, therefore, the affected process units should be retesteu,
If a process unit is being shut down and replaced with a new process unit, the ne\\ process unit
cannot be part of the PM bubble, and, therefore, the bubble must be recalculated (e.e . b\
substituting a "zero" into the bubble equation for the shutdown process unit). Howe\ ei
depending upon the other changes that are made when a process unit is shut do\\n. the
emissions from the existing process units may or may not be affected. In general, if the
D-4
-------
shutdown of the process unit is believed to affect emissions from other process units included
in the PM bubble, then the affected process units should be retested. Note that if the process
unit that was shut down was a source that was being over-controlled, then the bubble is
compromised because credit is being given for over-control of emissions that is no longer
taking place.
7. If I have a lime kiln that is sometimes fired using natural gas and sometimes fired
using fuel oil, can I establish two different bubble limits (and two different sets of
associated PM emission limits) to account for any potential performance differences
between the two lime kiln operating scenarios?
Yes. if the State permitting authority approves the bubble calculations and documentation.
Also, you must keep records on when the lime kilns are firing oil versus gas. You must also
establish the appropriate operating parameter levels for each operating scenario as part of the
continuous monitoring requirements. If a "dual bubble" approach is used, then the mill may
end up with t\vo permit limits and two sets of compliant operating parameter levels for each
process unit included in the PM bubble.
8. When complying with the PM standards using the PM bubble compliance alternative,
can we also establish the opacity levels for each process unit using a bubble
approach?
No. The final rule does not include any provisions for "opacity bubbling." Any recover}'
furnace or lime kiln equipped with an ESP must comph with the same continuous opacity
monitoring requirements that apply to existing process units that are not part of a PM bubble.
D-5
-------
Appendix E
Glossary of Commonly Used Terms
-------
Definitions
Air pollution control device (APCD): An add-on device used to remove air pollutants from gas
streams. Includes both PM and gaseous pollution control equipment, such as an ESP, venturi
scrubber, fiber-bed mist eliminator system, or RTO.
Ash dissolving tank (ADT): A vessel used for dissolving the ash collected from a fluidized-bed
reactor or rotary liquor kiln at a stand-alone semichemical pulp mill.
Black liquor: Spent cooking liquor that has been separated from the pulp produced by the kraft,
.soda, or semichemical pulping process.
Black liquor gasification: The thermochemical conversion of the organics in black liquor into a
combustible gaseous product, which can be used as an energy source for the gasification unit and
as an alternative boiler fuel, leaving the residual pulping chemicals (primarily Na2CO3) for reuse.
Black liquor gasification system: The reactor and associated equipment used to convert the
organics in black liquor into a combustible gaseous product.
Black liquor oxidation (BLO): The process of oxidizing black liquor with air or O2 prior to
evaporation in the DCE. thereby reducing the emissions of TRS compounds.
\
BLO system: A vessel used to oxidize the black liquor, with air or O:, and the associated
storage tank(s).
Black liquor solids (BLS): The dry weight of the solids in the black liquor that enters the
recovery furnace or semichemical combustion unit.
BLS firing rate: 1 he rate at \\hich black liquor solids are fed to the recover) furnace or the
semichemical combustion ur.it
Calcining: The proee^ ot converting lime mud (CaCO-,) from the causticizing area to reburned
lime(CaO)
Causticizing: The process of converting the decanted green liquor (Na:CO3) from the SDT to
NaOH and lime mud (CaCO;) by the addition of Ca(OH)2, which is generated in the slaker tank by
the reaction of water and lime (CaO) from the lime kiln.
Chemical recovery combustion source: Any source in the chemical recovery area of a kraft,
soda, sulfite or stand-alone semichemical pulp mill that is an NDCE recovery furnace, a DCE
recover)' furnace system, an SDT. a lime kiln, a sulfite combustion unit, or a semichemical
combustion unit.
E-3
-------
Chemical recovery system: All existing recovery furnaces, SDTs, and lime kilns at a kraft or
soda pulp mill. Each existing recovery furnace, SDT, or lime kiln is considered a process unit
within a chemical recovery system.
Cross-recovery furnace: A kraft recovery furnace which, on a quarterly basis, contains more
than 7 weight percent of the total pulp solids from the NSSC process and has a green liquor
sulfidity of more than 28 percent.
Direct contact evaporator (DCE): A vessel which concentrates spent liquor by direct contact
between the hot recovery furnace exhaust gases and the spent liquor.
DCE recovery furnace: A recover}' furnace equipped with a DCE.
DCE recovery furnace system: A DCE recovery furnace and any BLO system, if present, at the
pulp mill.
DCE to NDCE furnace conversion: The process of converting a DCE recovery furnace system
to an NDCE recover)' furnace, which includes replacing the DCE with a concentrator and
associated equipment, extending or replacing the economizer, rebuilding or replacing the ESP, and
removing the BLO system.
Dry ESP system: A recovery furnace ESP with a dry bottom (i.e.. no black liquor or HAP-
contaminated process water is used in the ESP bottom) and a dry PM return system (i.e.. no black
liquor or HAP-contaminated process water is used to transport the collected PM to the mix tank).
Electrostatic precipitator (ESP): An APCD which recovers PM from the flue gas by first
charging the particles using high-voltage electrodes and tnen collecting them on oppositely charged
collecting plates.
Fiber-bed mist eliminator system: An APCD \\hich removes PM from the flue gas using
numerous filter elements densely packed \\ith glass or polyester fibers.
Fluidized-bed reactor: An enclosed combustion device used to recover pulping chemicals at
sulfite or semichemical pulp mills by pelletizing the spent liquor as it falls toward the bed and
passing fluidizing gas up through the bed of solid pellets, setting the bed in fluid motion
Green liquor: A solution of carbonate salts (primarily Na2S and Na2CO3) and dregs (unburned
carbon and inorganic impurities) formed when smelt is drawn off from the SDT and dissolved in
weak wash water from the causticizing area.
Hazardous air pollutant (HAP) metals: The sum of all emissions of antimony, arsenic.
beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium as
measured by EPA Method 29 (40 CFR part 60, appendix A).
E-4
-------
Kraft pulp mill: Any stationary source that produces pulp from wood by cooking (digesting)
wood chips in a solution of sodium hydroxide and sodium sulfide. The recovery process used to
regenerate pulping chemicals is also considered part of the kraft pulp mill.
Kraft recovery furnace: A recovery furnace that is used to burn black liquor produced by the
kraft pulping process, as well as any recovery furnace that burns black liquor produced from both
the kraft and semichemical pulping processes, and includes the DCE, if applicable. •
Lime: Calcium oxide (CaO) produced in the lime kiln from the calcining of lime mud (CaCO3)
from the causticizing area.
Lime kiln: A enclosed combustion device (e.g., rotary lime kiln or fluidized-bed calciner) used at
a kraft or soda pulp mill to calcine lime mud, which consists primarily of CaCO3, into CaO.
Lime production rate: The rate at which dry lime, measured as CaO, is produced in the lime
kiln.
Multiple-effect evaporator (MEE) system: The evaporators and associated condensers used in
series to concentrate the black liquor prior to the DCE and/or NDCE.
Neutral sulfite semichemical (NSSC): A pulping process, used at stand-alone semichemica!
pulp mills and at kraft pulp mills collocated with semichemica] pulping operations, which cooks
the \\ood chips in a solution of sodium sulfite and sodium bicarbonate, followed by mechanical
defibrafng (grinding).
Noncondensible gases (NCGs): Gases from various process vents, such as digester and
evaporator vents, which include TRS compounds, turpentine, methanol. acetone, alpha-pinene.
\\ater \apor. nitrogen, and O:.
Nondirect contact evaporator (NDCE): An indirect, steam-heated spent liquor concentrator.
NDCE recovery furnace: A recovery furnace that burns spent liquor that has been concentrated
b\ indirect contact \\ith steam.
Particulate matter (PM): Total PM as measured by EPA Method 5, EPA Method 17
(§63.865(b)(l) of subpan MM), or EPA Method 29 (40 CFR part 60, appendix A).
Pink liquor: Spent cooking liquor that has been separated from the pulp produced by the NSSC
pulping process.
Process unit: An existing recovery furnace, SDT, or lime kiln in a chemical recovery system at a
kraft or soda mill.
E-5
-------
Recovery furnace: An enclosed combustion device where concentrated spent liquor produced
by the kraft, soda, sulfite, or semichemical pulping process is burned to recover pulping chemicals
and produce steam.
Red liquor: Spent cooking liquor that has been separated from the pulp produced by the sulfite
pulping process.
Red liquor solids (RLS): The dry weight of the solids in the red liquor that enters the sulfite
recovery furnace or fluidi zed-bed reactor.
Regenerative thermal oxidizer (RTO): A thermal oxidizer that transfers heat from the exhaust
gas stream to the inlet gas stream by passing the exhaust stream through a bed of ceramic
stoneware or other heat-absorbing medium before releasing it to the atmosphere, then reversing the
gas flow so the inlet gas stream passes through the heated bed, raising the temperature of the inlet
stream close to or at its ignition temperature.
Rotary liquor kiln: An enclosed combustion device used to recover pulping chemicals at two
stand-alone semichemical pulp mills by drawing combustion gases through from the lower end of
the kiln and firing the spent liquor halfway between the upper and lower ends, with the resulting
Na;CO3 ash falling to the lower end of the kiln.
Semichemical combustion unit: Any equipment, such as a fluidized-bed reactor, rotary liquor
kiln, or smelter, used to combust spent liquor at a stand-alone semichemical pulp mill to recover
pulping chemicals.
Smelter: An enclosed combustion device converted from a small kraft recovery furnace which
recovers pulping chemicals at a stand-alone semichemical pulp mill by burning spent liquor in a
manner similar to a recovery furnace, except that the smelter does not produce excess steam for
mill processes and is actually a net user of heat.
Smelt dissolving tank (SDT): A vessel used for dissolving the smelt collected from a reco\er\
furnace at a kraft. soda, or stand-alone semichemical pulp mill.
Soda pulp mill: Any stationary source that produces pulp from wood by cooking (digesting)
wood chips in a sodium hydroxide solution. The recovery process used to regenerate pulping
chemicals is also considered part of the soda pulp mill.
Soda recovery furnace: A recovery furnace used to bum black liquor produced by the soda
pulping process and includes the direct contact evaporator, if applicable.
Specific collecting area (SCA): A means of expressing the size of an ESP, defined as the total
ESP collecting plate surface area divided by the flue gas flow rate.
Stand-alone semichemical pulp mill: Any stationary source that produces pulp from wood b\
partially digesting wood chips in a chemical solution followed by mechanical defibrating
E-6
-------
(grinding), and has an onsite chemical recovery process that is not integrated with a kraft pulp
mill.
Sulfite combustion unit: An enclosed combustion device, such as a recovery furnace or
fluidized-bed reactor, used to burn spent liquor from the sulfite pulping process (i.e., red liquor) to
recover pulping chemicals.
Sulfite pulp mill: Any stationary source that produces pulp from wood by cooking (digesting)
wood chips in a solution of sulfurous acid and bisulfite ions. The recovery process used to
regenerate pulping chemicals is also considered part of the sulfite pulp mill.
Total hydrocarbons (THC): The sum of organic compounds measured as carbon using EPA
Method 25A (40 CFR part 60. appendix A).
Total reduced sulfur (TRS): The sum of the sulfur compounds H2S, methyl mercaptan, dimethyl
sulfide. and dimethyl disulfide that are released during the kraft pulping operation and measured by
EPA Method 16 (40 CFR part 60, appendix A).
Venturi scrubber: An APCD which removes PM from the flue gas by impaction through high-
energ\ contact between the scrubbing liquid and suspended PM in the gas stream. A venturi
scrubbing system typically consists of a venturi scrubbing vessel and cyclonic separator.
Wet ESP: A t\pe of ESP in which PM is removed by an intermittent or continuous stream of
water or other conducting fluid that flows down over the collection electrodes and into a receiving
sump. Among other uses, could be installed prior to an RTO since RTOs require a high degree of
PM control for proper operation
Wet ESP system: A reco\ er> furnace ESP with a wet bottom (i.e., black liquor or HAP-
comammated process \\ ater is used in the ESP bottom) and/or a wet PM return system (i.e.. black
hquoi or HAP-contaminatcd process water is used to transport the collected PM to the mix tank).
Wet to dry ESP system conversion: The process of converting a recovery furnace ESP system
to eliminate the black liquor or HAP-contaminated process water from the system, which includes
removing the existing agitator paddles and liquor piping: installing a perpendicular drag scraper
s\stem. shallo\\ fallout hoppers, drag chain conveyors, rotary valves, ash mixing tank, agitator.
and associated instrumentation: and making piping modifications.
White liquor: Cooking liquor used in the pulping area of a kraft or soda pulp mill, which is an
aqueous solution of NaOH and Na2S (kraft process only).
E-7
-------
Acronyms and Abbreviations
ADT
AF&PA
APCD
As
ATW
BACT
Be
BLO
BLS
BMP
Ca
Ca(OH)2
CAA
CaC03
CaO
Cd
GEMS
CERCLA
CFR
CH4
CMS
Co
CO
C02
COMS
Cr
CWA
DAS
DCE
EPA
EPCRA
ESP
FR
GPO
H2
ash dissolving tank
American Forest & Paper Association
air pollution control device
arsenic
Air Toxics Website (http://www.epa.gbv/ttn/atw/index.html)
best available control technology
beryllium
black liquor oxidation
black liquor solids
best management practices
calcium
calcium hydroxide
Clean Air Act as amended in 1990
calcium carbonate
calcium oxide
cadmium
continuous emissions monitoring system
Comprehensive Environmental Response, Compensation, and Liabilitx
Act
Code of Federal Regulations
methane
continuous monitoring system
cobalt
carbon monoxide
carbon dioxide
continuous opacity monitoring system
chromium
Clean Water Act
data acquisition system
direct contact evaporator
U. S. Environmental Protection Agency
Emergency Planning and Community Right-to-Kno\v Act
electrostatic precipitator
Federal Register
Government Printing Office
hydrogen
E-8
-------
H2O
H2S
HAP
HCI
Hg
UG
LAER
LK
MACT
MEE
Mg
Mg(OH)2
MgO
N2
Na
Na2CO3
Na2S
Na2S203
Na2S04
NAAQS
NaCI
NaOH
NCASI
NCG
NDCE
NESHAP
NH-
Ni
NOX
NPDES
NSPS
NSR
NSSC
NTIS
02
OAQPS
Pb
water
hydrogen sulfide
hazardous air pollutant
hydrochloric acid
mercury
liquid-to-gas
lowest achievable emission rate
lime kiln
maximum achievable control technology
multiple effect evaporator
magnesium
magnesium hydroxide
magnesium oxide
nitrogen
sodium
sodium carbonate
sodium sulfide
sodium thiosulfate
sodium sulfate
national ambient air quality standards
sodium chloride
sodium hydroxide
National Council of the Paper Industry for Air and Stream Improvement.
l!K
noncondensible gas
no:'direct contact evaporator
national emission standards for hazardous air pollutants
am m on ii'
nickel
nitrogen oxides
national pollutant discharge elimination system
new source performance standard
new source review
neutral sulfite semichemical
National Technical Information Services
oxygen
Office of Air Quality Planning and Standards
lead
E-9
-------
PM
POTW
PSD
RCRA
RF
RLS
RTO
Sb
SCA
SDT
Se
SIP
S02
SPCC
SSM
STAPPA/ALAPCO
THC
TRI
TRS
TSD
TIN
VOC
WWW
XL
paniculate matter
publicly-owned treatment works
prevention of significant deterioration
Resource Conservation and Recovery Act
recovery furnace
red liquor solids
regenerative thermal oxidizer
antimony
specific collecting area
smelt dissolving tank
selenium
State Implementation Plan
sulfur dioxide
spill prevention control and countermeasure
startup, shutdown, and malfunction
State and Territorial Air Pollution Program Administrators/Association
of Local Air Pollution Control Officials
total hydrocarbon
Toxics Release Inventor)'
total reduced sulfur
technical support document
Technology Transfer Network (http:/'www.epa.gov/ttn)
volatile organic compound
World Wide Web
Excellence in Leadership
E-10
-------
Appendix F
Equipment Diagrams for Chemical Recovery Combustion Sources
-------
PULPING
CHEMICAL RECOVERY
Wood Water
J L_
Digesters,
Blow tanks,
Washers,
Weak blnck liquor /
Nrv'COl. Na.'^O"!.,
Na.'S. and /
NaOH '
o
o.
-------
TO ATMOSPHERE
A
RECOVERY FURNACE
FEED WATER STEAM
STRONG BLACK LIQUOR
FROM CONCENTRATOR
(-68% SOLIDS)
HEAVY
BLACK
LIQUOR
STORAGE
TANK
KEY.
—- BLACK LIQUOR
GASFS
ESP
(DRY BOTTOM)
SALTCAKE
CHEMICAL
ASH TANK
Figure F-2. NDCFi Recovery Furnace and Associated Equipment.
-------
RECOVERY FURNACE
TO ATMOSPHERE
A
r— •-
s
T
A
C
K
A
/
„
^--
---
BIACKUOUOD
GASES
ESP
(WET BOTTOM)
\
^
V ^/
-
HEAVY
BLACK
LIQUOR
STORAGE
TANK
/"
\/
•*
"
(^-~
"~ ^_ ^
---
_--•
CHEMICAL
ASH TANK
--
/
/
\
i
j DCE L;-;_ '
c
Ecor
X ,»
/*n\\
(VY/lKnl
BOILER
mumn
'•,'•
BLO UNIT
/ '\
M
_,.
'
Na2SO4
1 ^J-~?
("
^~
/
;H
r
^
SALTCAKE
MIX TANK
, .
^ STRONG BLACK LIQUOR
(50% SOLIDS) FROM MULTIPLE
EFFECT EVAPORATORS "
6
*
4
^
^
^^^XX^CvvsX v Xvv>.
-------
WET SCRUBBER
TO STACK
A
OUTLET
DAMPER
FAN
SCRUBBER
BYPASS
VALVE
SMELT
WATER-COOLED
SPOUT
SHATTER
SPRAY NOZZLE
RECYCLED,
GREEN
;;!j:;il?!b LIQUOR
SCRUBBER WATER
DRAIN TO SDT
GREEN LIQUOR
TOCLARIFIER
AGITATOR
SMELT DISSOLVING TANK
Figure F-4. Smelt Dissolving Tank and Wet Scrubber.
F-6
-------
VENT GAS
T1
STRONG BLACK
LIQUOR STORAGE
TANK
BLACK
LIQUOR
PUMP
VENT GAS
Pi
CYCLONE
SEPARATOR
AIR
NO, 1 OXIDATION TANK
BLACK
LIQUOR
U-TVJ
NO. 2
OXIDATION
Figure F-5. Two-Stage Air-Sparging Black Liquor Oxidation System.
-------
VENT
GASES
oo
LIME MUD
VENTURI
SCRUBBER
/ \
FEED END/COLD END
FUEL
LIME
DISCHARGE END/HOT END
Figure F-6. Lime Kiln and Wet Scrubber.
-------
Figure F-7. Electrostatic Precipitator.
F-9
-------
Cyclonic
separator
Flooded
elbow
Figure F-8. Venturi Scrubber.
F-10
-------
AIR
HEAVY
BLACK
LIQUOR
STORAGE
TANK
STRONG BLACK LIQUOR FROM
MULTIPLE EFFECT EVAPORATORS
NOTE
SHADED AREAS INDICATE EMISSION SOURCES
BLACK AREAS INDICATE BLACK LIQUOR
Figure F-9. Emission Sources for a DCE Recovery Furnace System.
-------
KEY:
BLACK LIQUOR
GASES
1 SOLIDS
A
I
I
I
I
s
T
A
C
K
L
STRONG BLACK LIQUOR
FROM MULTIPLE EFFECT
EVAPORATORS
DRY-BOTTOM
ESP
SALTCAKE
CHEMICAL
ASH TANK
NOTE: SHADED AREAS INDICATE EMISSION SOURCES.
Figure F-10. Kmission Sources for an NDCF, Recovery Furnace.
-------
TO
ATMOSPHERE
71
£ SPENT SULFITE
LIQUOR (RED
LIQUOR) FROM
EVAPORATORS
RECOVERY
FURNACE
OR
FLUIDIZED
BED
REACTOR
MgO/SQjX
MULTIPLE /SQ
\CYCLONES^ 2
\-
C
0 T
0 0
L W
1 E
N R
G
SI AKPH |
I
i
I0OT
;
1 S02 '
ABSORPTION
TOWER OR
MULTI-STAGE
VENTURI
SCRUBBER
MAGNESIUM
BISULFITE
SOLUTION
Mg(OH)2
COOKING
LIQUOR
SCRUBBER
OR
DEMISTER
(OPTIONAL)
so
SULFUR
BURNER
IBIII GAS STREAM
LIQUID STREAM
Figure F-11. Chemical Recovery Pniccss for the Mg-Based Sulfite Pulping Process.
-------
Figure F-12. Mg-Based Sulfite Recovery Furnace.
F-14
-------
LIQUID WASTE FEED
ENTRAINED MATERIAL
FEED SPRAY DISPERSION
REACTION VESSEL
DILUTE PHASE
FLUID1ZED BED
DENSE PHASE
PLUIDIZED BED
SOLID PRODUCT
*- EXHAUST GASES
CYCLONE
SEPARATOR
DUST RETURN
ORIFICE PLATE
FLUIDIZING GAS
Figure 13. Fluidized-Bed Reactor.
F-15
-------
STORAGE
TANKS
LIQUID FLUlDfZED
WASTE FEED RED REACTOR
PRIMARY MILL
DUAL CYCLONE SCRUBBER WATER
SEPARATOR
VENT
WASTE
CONCENTRATED
WASTE LIQUOR
OENSEPHASE
F1UIDIZED BED
SECONDARY
SCRUBBER
EVAPORATORS
WEAK WASTE LIQUOR
FROM PULP MILL
CONTROL
PANEL
INORGANIC PRODUCT
TO STORAGE
Figure 14. Mg-Based Sulfite Fluidized-Bed Reactor System.
F-16
-------
V 'TO
ATMOSPHERE
1
SPENT SULFITE
LIQUOR (RED
LIQUOR) FROM
EVAPORATORS^
AMMONIA
ISO 2
JUtth*
imm^
SO 2
ABSORPTION/
COOLING
TOWER
r^
SPENT
5TEWATER
1 0ra^^^>
AMM(
BISU
SOLI
ks>
COOKING ^afe— ,_.
LIQUOR "^^Ml
DNIUM
LFITE
JTION
F
0
R
T
1 T
F 0
, W
C E
A R
I
TWBWJ5JW!
SCHUBBbH 1
OR |ii®t» FIBMSED!
MESH PAD ^ ™%.OR
(OPTIONAL) 1 . _
"^SiBI SULFUR
BURNER
nee i GAS STREAM
LIQUID STREAM
Figure F-15. Chemical Recovery Process for the NHrBased Sulfite Pulping Process.
-------
Figure F-16. NH3-Based Sulfite Recovery Furnace.
F-18
-------
CHIPS
1
STEAM
PRIMARY
TANK | PFFINERS
(Ml ' HANICAI )
HYCROPULPER
DEFIBRATOR
Q
STACK
TO PAPER
MACHINE
MULTIPLE EFFECT
EVAPORATORS
CHEMICAL
RECOVERY
COMBUSTION
UNIT
DCE
or
NCDE
COOKING
LIQUOR
ASH/SMELT
DISSOLVING
TANK
CHEMICAL RECOVERY PROCESS
GAS STREAM
LIQUID StREAM
Figure F-17. Chemical Recovery Process for the Semichemical Pulping Process.
-------
TO ATMOSPHERE
i
STACK
ESP
(DRY BOTTOM)
71
to
STRONG BLACK LIQUOR
FROM CONCENTRATOR
(58% SOLIDS)
HEAVY
BLACK
LIQUOR
STORAGE
TANK
RECOVERY FURNACE
FEED WATER STEAM
i
BOILERll
ECONOMIZER
O O
OL
%
X
a
LU
Q.
OXIDIZING ZONE
DRYING ZONE
SMELT TO
SMELT DISSOLVING
TANK
KEY:
BLACK LIQUOR
___ GASES
TERTIARY AIR
LIQUOR NOZZLES
SECONDARY AIR
PRIMARY AIR
Figure F-18. Recovery Furnace.
-------
to
T,
VENT GASES ' N
ci
WET ESP
VENTURI
SCRUBBER
y
WASTE HEAT
BOILER
GAS
STREAM , '
INDUCED
DRAFT FAN
BLACK LIQUOR
FIRING NOZZLE
. A
*>
. ._ /
/ll\
c
\
FUEL
COMBUSION
AIR
ASH TO
DISSOLVING
TANK
Figure F-19. Rotary Liquor Kiln.
-------
Product
Gas
71
KJ
Black
Liquor
Bed
Solids
H0S Absorber
Green Liquor
Na2CO3+Na2S
Mix Tank
Sodium Carbonate Solution
Wash/Filter
Dregs
Figure F-20. Black Liquor Gasification System.
-------
PILOT TEST SYSTEM
STONEWARE
BED
1
COLLECTING
TUBES
t*
/ OX.DATION
INLET
DUCT
T -I T' 'A ]' * T T-*~T fJT r*T X
* ^-^^ -»— *— ...*. • i • •.......»••..—•.—.i- in !•• i ii I /
OUTLET
DUCT
MAIN I.D
FAN
.STACK
LEGEND
/
© COPELAND REACTOR EXHAUST (5 percent of total flow)
(2) AFTER WET ESP
(3) EMISSION TO ATMOSPHERE
Figure F-21. Regenerative Thermal Oxidizer.
-------
Appendix G
Example Calculations
-------
Note
This appendix includes two examples of how kraft and soda mills can use the equations in the Pulp
and Paper Combustion Sources NESHAP to determine mill-specific PM emission limits for
existing recovery furnaces, SDTs, and lime kilns at their mill as part of the PM bubble compliance
alternative. Spreadsheet and data base programs (in Microsoft® Excel and Access) also have
been prepared based on these equations to assist mills in determining the emission limits. (These
programs are available for downloading at http://www.epa.gov/ttn/atw/pulp/pulppg.html.)
This appendix also includes examples of how kraft and soda mills can use the equations in the
NESHAP to determine methanol emission rates for their new recovery furnace systems and
determine oxygen corrections for their PM concentrations and gas flow rates. Finally, this
appendix includes an example of how stand-alone semichemical mills can use the equations in the
NESHAP to determine THC emission rates and percent THC reduction for their semichemical
combustion units.
G-3
-------
OXYGEN CORRECTION
EXAMPLE: MILL A
> PROCESS UNITS AT MILL A:
1 Recovery furnace (RF1)
1 Smelt dissolving tank (SDT1)
1 Lime kiln (LK1)
» RELEVANT DATA FROM RECENT STACK TESTS AT MILL A:
Recovery furnace test results:
Stack gas flowrate: 47.476 dscfm
Volumetric oxygen concentration: 6 percent oxygen
PM emissions: 0.053 gr/dscf
Lime kiln test results:
Stack gas flowrate: 6,295 dscfm
Volumetric oxygen concentration: 9 percent oxygen
PM emissions: 0.038 gr/dscf
Using emissions and process data from the recent stack test and Equations 7 and 8 provided
in the regulation (see Appendix A), calculate PM concentrations and gas flow rates corrected
for oxygen for Mill A as follows:
PM OXYGEN CORRECTION EQUATION:
Cco^ = Cm£JS*(21-X)/(21-Y) (Equation 7 in final rule)
Where:
CcorT = measured PM concentration corrected for oxygen, gr/dscf
Cmeas = measured PM concentration uncorrected for oxygen, gr/dscf
X • = corrected volumetric oxygen concentration, percent oxygen
Y = measured average volumetric oxygen concentration, percent oxygen
Constants in oxygen correction equation:
X =8 percent for kraft or soda recovery furnaces and sulfite combustion units
= 10 percent for kraft or s'oda lime kilns
Stack test/process data from Mill A:
Cmeas = 0.053 gr/dscf for RF1
0.038 gr/dscf for LK1
Y =6 percent oxygen for RF1
= 9 percent oxygen for LK1
G-4
-------
Therefore:
CCOITforRFl =
0.053 * (21 - 8)/(21 - 6)
0.046 gr/dscf at 8 percent oxygen
CcorTforLKl =
0.038* (21 -10)7(21-9)
0.035 gr/dscf at 10 percent oxygen
GAS FLOW RATE OXYGEN CORRECTION EQUATION:
Qmeas*(21-Y)/(21-X)
(Equation 8 in final rule)
Where:
Qco.
Qme.s
Y
X
measured volumetric gas flow rate corrected for oxygen, dscfm
measured volumetric gas flow rate uncorrected for oxygen, dscfm
measured average volumetric oxygen concentration, percent oxygen
corrected volumetric oxygen concentration, percent oxygen
Constants in oxygen correction equation:
X =8 percent for kraft or soda recovery furnaces and sulfite combustion units
= 10 percent for kraft or soda lime kilns
Stack test/process data from Mill A:
Qm.J5 - 47.476 dscfm for RF1
6.295 dscfm for LK1
Y =6 percent oxygen for RF1
- 9 percent oxygen for LK1
Therefore:
Qcpr.forRFl =
Qco;iforLKl =
47.476" (21 -6)/(21 -8)
54.780 dscfm at 8 percent oxvgen
6.295 * (21 -9)/(21 - 10)
6.867 dscfm at 10 percent oxygen
G-5
-------
PM BUBBLE COMPLIANCE ALTERNATIVE
EXAMPLE 1: MILL A ("SIMPLE" MILL)
PROCESS UNITS AT MILL A:
1 Recovery furnace (RF1)
1 Smelt dissolving tank (SDT1)
1 Lime kiln (LK1)
DATA FROM RECENT STACK TESTS AT MILL A:
Recovery furnace test results:
Stack gas flow rate: 54,780 dscfm @ 8 percent oxygen
Black liquor solids firing rate: 450 ton BLS/d
PM emissions: 0.046 gr/dscf @ 8 percent oxygen
Smelt dissolving tank test results:
Stack gas flow rate: 4,830 dscfm
PM emissions: 0.050 2r/dscf
Lime kiln test results:
Stack gas flow rate: 6.867 dscfm @ 10 percent oxygen
Lime production rate: 72tonCaO/d
PM emissions: 0.035 gr/dscf @ 10 percent oxygen
G-6
-------
Using emissions and process data from the recent stack test and equations provided in the
regulation (see Appendix A), calculate/develop proposed PM emission limits for Mill A as
follows:
STEP 1: Calculate the mill-specific (overall) PM bubble limit for Mill A.
STEP 2: Substitute PM data from recent stack tests into appropriate equations to determine
how close Mill A is to the PM bubble limit calculated in Step 1.
STEP 3: Propose PM emission limits for the recovery furnace, SDT, and lime kiln based on
the results of Step 2.
STEP 4: Substitute proposed PM emission limits for each recovery furnace, SDT, and lime
kiln into appropriate equations to determine if the total estimated PM emissions at
the proposed emission levels are less than or equal to the overall PM bubble limit
calculated in Step 1.
STEP 5: If the total estimated PM emissions calculated in Step 4 are less than or equal to the
overall PM bubble limit calculated in Step 1, Mill A can submit the proposed PM
emission limits and supporting documentation to the permitting authority for
approval: otherwise. Mill A repeats Steps 3 and 4 until the total estimated PM
emission- calculated in Step 4 are less than or equal to the overall PM emission
limit calculated in Step 1.
STEP 6: After the proposed PM emission limits are approved by the permitting authority for
each reco\er\ furnace. SDT, and lime kiln, the overall PM bubble "limit"
calculated in Step 1 is no longer used. The mill simply must comply with the
appro\ ed permit limits for each piece of equipment.
STEPS 1-5 are shown on the following pages for Mill A.
G-7
-------
STEP 1: CALCULATE THE MILL-SPECIFIC PM BUBBLE LIMIT FOR MILL A:
PM BUBBLE LIMIT EQUATION:
ELPM = [(Cref,RF*QRRot) + (Cref^*Qmot)]*Fl/BLStot+ (Elref,SDT)
(Equation 1 in final rule)
Where:
ELPM = PM bubble limit (mill-specific), Ib/ton BUS
Cref,RF = reference PM concentration for recovery furnaces = 0.044 gr/dscf
Q^ot = sum of stack gas flows from all recovery furnaces, dscfm
Cref LK = reference PM concentration for lime kilns = 0.064 gr/dscf
Quooi = sum of stack gas flows from all lime kilns, dscfm
Fl = conversion factor, 0.206 lb*min/d*gr
BLSto, = sum of black liquor solids fired in all recovery furnaces, ton/d
= reference PM emission rate for SDTs = 0.20 Ib/ton BLS
Constants in bubble equation:
CrefRf = 0.044 gr/dscf
C^LK = 0.064 gr/dscf
Fl = 0.206 lb*min/d*gr
ELref.SDT = 0.20 Ib/ton BLS
Stack test/process data from Mill A:
QRF.O, = 54.780 dscfm
QLKlol = 6.867 dscfm
BLS,n, = 450tonBLS/d
•'lot
Therefore:
ELPV - [(0.044)(54,780) + (0.064X6.867)] * (0.206/450) + 0.20
1.505 Ib/ton BLS
G-8
-------
STEP 2: SUBSTITUTE PM DATA FROM RECENT STACK TESTS INTO
APPROPRIATE EQUATIONS TO DETERMINE HOW CLOSE MILL A IS
TO THE CALCULATED PM BUBBLE LIMIT:
Total measured emissions, ERto, must be less than or equal to 1.514 Ib/ton BLS, which is the PM
•
bubble limit calculated in Step 1, ELPM.
ERtot is calculated as follows:
ERIot = ERRFlot + ERSDTtot + ERuao, (Equation 6 in final rule)
Where:
ERIO, = total measured emissions from Mill A, Ib/ton BLS
= total measured emissions from recovery furnaces, Ib/ton BLS
= total measured emissions from smelt dissolving tanks, Ib/ton BLS
= total measured emissions from lime kilns, Ib/ton BLS
I. First calculate mass emission rate from recovery furnaces,
Because there is onh one recovery furnace at Mill A. the equation for £RRFtot is:
ERRH?. = F1XCLLRF*QRF/BLS (Equation 2 in final rule)
Where:
Fl = conversion factor = 0.206 lb*min/d*gr
CELRF = measured PM emissions from RF1 at Mill A = 0.046 gr/dscf (see NOTE
bt hn\ }
QK, = measured gas flo\\ rate from RF1 at Mill A = 54,780 dscfm
BLS = firing rate of RF1 at Mill A = 450 ton BLS/d
Therefore:
ER^. = 0.206 * 0.046 * 54.780 / 450
1 . ] 54 Ib/ton BLS
Note: CELRr is defined different!) in the regulation because Equation 2 is intended to be used to determine the
preliminary recovers furnace PM emission limit that the owner/operator will propose to the permitting authority;
' however, the same equation can be used here to determine the actual emission rate from the recovery furnace
(based on the recent stack tests j
G-9
-------
II. Next, calculate mass emission rate from smelt dissolving tanks:
Because there is only one SDT at Mill A, the equation for ERSDTtot is:
(Equation 3 in final rule)
Where:
Fl
CELSDT
QSDT
BLS
Therefore:
ERsDTtot
conversion factor = 0.206 lb*min/d*gr
measured PM emissions from SDT1 at Mill A = 0.050 gr/dscf
measured gas flow rate from SDT1 at Mill A = 4,830 dscfm
firing rate of RF1 at Mill A = 450 ton BLS/d
0.206 * 0.050 * 4,830 / 450
0.111 Ib/tonBLS
III. Next, calculate mass emission rate from lime kilns:
Because there is only one lime kiln at Mill A, the equation for ER^,,,, reduces to:
;,oi = Fl*CELLK*QLK/BLStot (Equation 4 in final rule)
Where:
Fl
CEL.LK
QLK
BLS,o;
Therefore:
conversion factor = 0.206 lb*min/d*gr
measured PM emissions from LK1 at Mill A = 0.035 gr/dscf
measured gas flow rate from LK1 at Mill A = 6,867 dscfm
firing rate of RF1 at Mill A = 450 ton BLS/d
0.206 * 0.035 * 6.867 7450
O.llOlb/tonBLS
IV. Finally, determine the total emission rate for Mill A, ER,ot:
ER,,
CONCLUSION:
ER
ER
LKtol SDTtot
1.154 + 0.111+ 0.110
1.3751b/tonBLS
(Equation 6 in final rule
MILL A IS BELOW THE OVERALL CALCULATED PM BUBBLE LIMIT
OF 1.505 Ib/ton BLS, BY 0.130 Ib/ton BLS.
G-10
-------
STEP 3: PROPOSE PM EMISSION LIMITS FOR THE RECOVERY FURNACE,
SDT, AND LIME KILN, BASED ON RESULTS OF STEP 2:
In most cases, the Mill owner/operator will want to build in as much "cushion" as he/she can, so
that the proposed permit limits will be somewhat above the historical performance of the
equipment. For example, the following limits could be proposed based on the most recent stack
data (see page A-l) and the results of Step 2:
Proposed limit for recovery furnace: 0.050 gr/dscf
Proposed limit for SDT: 0.060 gr/dscf
Proposed limit for lime kiln: 0.045 gr/dscf
STEP 4: SUBSTITUTE PROPOSED PM EMISSION LIMITS (CEL) FOR EACH
RECOVERY FURNACE, SDT, AND LIME KILN INTO THE
APPROPRIATE EQUATIONS TO DETERMINE IF THE TOTAL
ESTIMATED PM EMISSIONS (ER,ot) AT THE PROPOSED EMISSION
LEVELS ARE LESS THAN OR EQUAL TO THE OVERALL PM BUBBLE
LIMIT (ELPM ) CALCULATED IN STEP 1:
I. Calculate the emission rate from RF1:
ERRV,0. = rl^Cj^R^Qiy/BLS (Equation 2 in final nile)
^ = 0.206 * 0.050 * 54,780 / 450 = 1.254 Ib/ton BLS
II. Calculate the emission rate from SDT1:
ERsDTtei = Fl'Cf^p^QsDT/BLS (Equation 3 in final ride)
0.206 x 0.060 * 4,830 / 450 = 0.133 Ib/ton BLS
III. Calculate the emission rate from LK1:
ERLkipt = Fl: CtL.LK*QLK/BLSlc, (Equation 4 in final rule)
0.205 * 0.045 * 6.867 7450 = 0.141 Ib/ton BLS '
IV. Total the calculated PM emissions from each source:
ER!ot = 1.254 + 0.133 + 0.141 = 1.528 Ib/ton BLS
V. Compare ERtot with the mill-wide emission limit, ELPM, calculated in Step 1:
ERtol (1.528) >ELPM (1.505)
G-ll
-------
VI. Because ERto, >ELPM, the owner or operator must redo Steps 3 and 4 (substituting
increasingly more stringent proposed PM limits), until ER,^ < ELPM.
For example, if the proposed PM limit for the lime kiln (LK1) is tightened from 0.045
gr/dscf to 0.035 gr/dscf (and the proposed limits for the recovery furnace and SDT are
unchanged), then ERtot = 1.497 Ib/ton BLS, which is less than ELpM (1.505 Ib/ton BLS).
Therefore, Mill A can propose these PM permit limits to the permitting authority.
Table G-1 below shows the actual emission rates and proposed emission limits for Mill A
along with the MACT emission limits for comparison.
Table G-1. Results of Example Mill A
RF1
0.046 gr/dscf
0.050 gr/dscf'
0.044 gr/dscf
SDT1
0.050 gr/dscf
(0.111 Ib/ton BLS)
0.060 gr/dscf *
(0.133 Ib/ton BLS)
0.20 Ib/ton BLS
LK1
0.035 gr/dscf
0.035 gr/dscf'
0.064 2r/dscf
ER,,
1.375 Ib/ton BLS
1.497 Ib/ton BLS
1.505 Ib/ton BLS
EL,
•PM
1.5051b/tonBLS
1.505 Ib/ton BLS
1.5051bton/BLS
* If these proposed limits are approved by the permitting authority, then these limits become part
of Mill A's permit.
As shown in Example 1 (Mill A), the PM bubble allows a mill to propose some PM permit limits
that are less stringent than the MACT limits (e.g., RF1) as long as the overall bubble limit value
(ELPM) is met. In this example, this was achieved by proposing PM permit limits for the remaining
sources (i.e., SDT1 and LK1) that were more stringent than the MACT limits.
COMMENTS ON EXAMPLE 1—MILL A:
In this example, the mill is performing sufficiently below the calculated PM bubble to allo\\ for
some "cushioning" of the proposed permit limits. However, to allow for potential emission
variations and to ensure continuous compliance with the standards, Mill A might find it more
practical to upgrade/replace the ESP on the recovery furnace so that the proposed PM emissio;,
limit for the recovery furnace can be lowered (which would significantly lower ERlr,). Fo;
example, if the ESP were upgraded such that the recovery furnace could easily meet a proposed
PM limit of 0.035 gr/dscf, ERtot would be equal to 1.121 Ib/ton BLS, which is significantly less
than ELPM (1.505 Ib/ton BLS). assuming that the proposed PM limits for the SDT and lime kiln are
unchanged. In addition, upgrading the recovery furnace ESP would allow the owner or operator to
"loosen" the proposed permit limits for the SDT and lime kiln up until the point \s heie ERun =
ELPM.
G-12
-------
EXAMPLE 2. MILL B ("TYPICAL" MILL)
•> AFFECTED SOURCES AT MILL B:
Same sources found at Mill A (Example 1), e.g.,
1 Recovery furnace (RF1)
1 Smelt dissolving tank (SDT1)
1 Lime kiln (LK1)
Plus, four additional sources:
Recoverv furnace No. 2 (RF2)
Smelt dissolving tanks, Nos. 2a and 2b (SDT2a and SDT2b)
Lime kiln No. 2 (LK2)
Assumptions:
RF2 is subject to an existing PSD permit limit of 0.033 gr/dscf
SDT2a and SDT2b are subject to the NSPS limit of 0.20 Ib/ton BLS
SDT 2a and 2b are the same size.
•> DATA FROM STACK TESTS AT MILL B:
RF1 test results (same as Mill A):
Stack gas flow rate1 54.780 dscfm @ 8 percent oxygen
Black liquor solids firing rate: 450 ton BLS/d
PM emissions. 0.046 gr/dscf @ 8 percent oxygen
RF2 test results:
Stack gas flow rate: 236.730 dscfm @ 8 percent oxygen
Black liquor solids firing rate: 1.950 ton BLS/d
PM emissions 0.028 gr/dscf @ 8 percent oxygen
SDT1 test results (same as Mill A):
Stack gas flow rate: 4,830 dscfm
PM emissions: 0.050 gr/dscf
SDT2a test results:
Stack gas flow rate: 10.400 dscfm
PM emissions: 0.057 gr/dscf
SDT2b test results:
Stack gas flow rate: 10,520 dscfm
PM emissions: 0.060 er/dscf
G-13
-------
LK1 test results (same as Mill A):
Stack gas flow rate: 6,867 dscfm @ 10 percent oxygen
Lime production rate: 72 ton CaO/d
PM emissions: 0.035 gr/dscf @ 10 percent oxygen
LK2 test results:
Stack gas flow rate: 29,760 dscfm @ 10 percent oxygen
Lime production rate: 312tonCaO/d
PM emissions: 0.055 gr/dscf @ 10 percent oxygen
Using emissions and process data from the recent stack test and equations provided in the
final rule, calculate/develop proposed PM emission limits for Mill B as follows:
STEP 1: Calculate the mill-specific (overall) PM bubble limit for Mill B.
STEP 2: Substitute PM data from recent stack tests into appropriate equations to determine
how close Mill B is to the PM bubble limit calculated in Step 1.
STEP 3: Propose PM emission limits for each recovery furnace, SDT, and lime kiln based
on the results of Step 2.
STEP 4: Substitute proposed PM emission limits for each recovery furnace, SDT. and lime
kiln into appropriate equations to determine-if the total estimated PM emissions at
the proposed emission levels are less than or equal to the overall PM bubble limit
calculated in Step 1.
STEP 5: If the total estimated PM emissions calculated in Step 4 are less than or equal to the
overall PM bubble limit calculated in Step 1, Mill B can submit the proposed PM
emission limits and supporting documentation to the permitting authority for
approval; otherwise, Mill B repeats Steps 3 and 4 until the total estimated PM
emissions calculated in Step 4 are less than or equal to the overall PM bubble hrrr
calculated in Step 1.
STEP 6: After the proposed PM emission limits are approved by the permitting authority f- ••
each recover}' furnace, SDT, and lime kiln, the overall PM bubble "hnv.: '
calculated in Step 1 is no longer used. The mill simply must comply with the
approved permit limits for each piece of equipment.
STEPS 1-5 are shown on the following pages for Mill B.
G-14
-------
STEP 1: CALCULATE THE MILL-SPECIFIC PM BUBBLE LIMIT FOR MILL 3:
PM BUBBLE LIMIT EQUATION: (Equation 1 in final rule)
= [(Cref,RF*QRRot) + (Cref4JC*QLKlot)]*Fl/BLStot+
Where:
ELpM = PM bubble limit (mill-specific), Ib/ton BLS
Cref RP = reference PM concentration for recovery furnaces, 0.044 gr/dscf
QKRO, = sum of stack gas flows from all recovery furnaces, dscfm
Cref LK = reference PM concentration for lime kilns, 0.064 gr/dscf
Quao, = sum of stack gas flows from all lime kilns, dscfm
Fl = conversion factor, 0.206 lb*min/d*gr
BLS[ot = sum of black liquor solids fired in all recovery furnaces, ton/d
ELref SDT = reference PM emission rate for SDTs, 0.20 Ib/ton BLS
Constants in bubble equation:
CrefRF = 0.044 gr/dscf
Cref.LK = 0.064 gr/dscf
Fl = 0.206 lb*min/d*gr
ELre,SDT = 0.20 Ib/ton BLS
Stack testyproce^y data from Mill B:
QRF|P, - 54.780 + 236.730 = 291,510 dscfm
QLVC = 6.S67 + 29.760 = 36,627 dscfm
BLSIC, = 450+ 1.950= 2,400 ton BLS/d
Therefore:
EL,,.,. = [(0.044)(291.510) + (0.064)(36,627)] * (0.206/2,400) + 0.20
1.502 Ib/ton BLS
STEP 2: SUBSTITUTE PM DATA FROM RECENT STACK TESTS INTO
APPROPRIATE EQUATIONS TO DETERMINE HOW CLOSE MILL B IS
TO THE CALCULATED PM BUBBLE LIMIT:
Total measured emissions. ER10I. must be less than or equal to 1.502 Ib/ton BLS, which is the PM
bubble limit calculated previously, (ELPM).
ER,ot is calculated as follows:
, + ERSDTtol + ERLK.O, (Equation 6 in final rule)
G-15
-------
Where:
ERtot
ER
RFtot
ERsDTtot
ER,
MJCtot
total measured PM emissions from Mill B, Ib/ton BLS
total measured PM emissions from recovery furnaces,
Ib/ton BLS
total measured PM emissions from SDTs, Ib/ton BLS
total measured PM emissions from lime kilns, Ib/ton BLS
Where:
Fl
RF,
I. First, calculate mass emission rate from recovery furnaces,'.
Because there are two recovery furnaces at Mill B, the equation for'.
-, *PRRF1/PRRRot) + (ERRF2*PRRF,/PRRBot) (Equation 5 in final rule)
*CELRFI*QRFI/PRRFI (Equation 2 in final rule)
conversion factor = 0.206 lb*min/d*gr
measured emissions from RF1 at Mill B = 0.046 gr/dscf
measured gas flow rate from RF1 at Mill B = 54,780 dscfm
firing rate of RF1 at Mill A = 450 ton BLS/d
(Equation 2 in final rule
Where:
Fl
QRr;RF7
and:
PRRFlc,
Therefore:
conversion factor = 0.206 lb*min/d*gr
measured emissions from RF2 at Mill B = 0.028 gr/dscf
measured gas flow rate from RF2 at Mill B = 236,730 dscfm
firing rate of RF2 at Mill A = 1,950 ton BLS/d
total black liquor solids firing rate (both recovery furnaces): 2.400 ton
BLS/d
(0.206*0.046*54,780/450)*450/2400 +
(0.206*0.028*236,730/1950)*1950/2400
0.785 Ib/ton BLS
II. Next, calculate mass emission rate from the 3 smelt dissolving tanks:
(See Table G-2 for equations and resulting calculations)
ER,
SDTio
0.1261b/tonBLS
G-16
-------
III. Next, calculate mass emission rate from lime kilns:
(See Table G-2 for equations and resulting calculations)
ER^ = 0.161 Ib/tonBLS
IV. Finally, determine the total emission rate for Mill B, ERtot:
ERtot = ERgno, + ERSDTtot +
0.785 + 0.126+ 0.161
1.0721b/tonBLS
CONCLUSION: MILL B IS OPERATING SUBSTANTIALLY BELOW THE MILL-
SPECIFIC PM BUBBLE LIMIT OF 1.502 Ib/ton BLS.
STEPS 3-5: PROPOSE PM EMISSION LIMITS FOR EACH RECOVERY FURNACE,
SDT, AND LIME KILN AT MILL B:
As mentioned in Example 1 (Mill A), the owner/operator will want to build in as much "cushion"
as he/she can, so that the proposed permit limits will be somewhat above the historical
performance of the equipment. In this example, there are some restrictions. First, recovery
furnace No. 2 must me.?t a PSD permit limit of 0.033 gr/dscf; therefore, the proposed permit limit
for that recovery furnace cannot be less stringent than 0.033 gr/dscf. Second, the SDTs associated
with recovery furnace No. 2 must meet the NSPS limit of 0.20 Ib/ton BLS; therefore, the proposed
permit limits for SDTs 2a and 2b must be less than or equal to 0.20 Ib/ton BLS.
Table G-2 sho\\ s how the equations in the final rule can be used to set the proposed permit limits.
In this example. 3 different sets of proposed PM limits are shown along with the resulting total
emission rates (ERU;). In each trial, the mill owner/operator tries to get ERlol as close to ELPM as
possible without exceeding that value. On the third trial, the owner or operator is able to build a
substantial cushion into most of the emission limits, while still meeting the total PM bubble limil.
In this example. Mill B is operating substantially under the mill-specific PM bubble limit, and
therefore, Mill B has more flexibility in setting the permit limits for each piece of equipment than
did Mill A in Example 1 . Based on the results shown on the previous page, the Mill B owner or
operator would submit the proposed emission limits from trial 3 (and the supporting
documentation) to the permitting authority for approval. Once approved, the proposed PM
emission limits would become part of the operating permit for the mill.
G-17
-------
EXAMPLE 2. (Continued)
O
oo
Table G-2. Results of Example Mill B ;
^V t '
PlP^lBwilJfR^ ;': " **"'"*'*'
"• USA »r
Recent
!p^tifuiipepp^^K'^«iH|^^H|^^^^^p^^^B^Hi
Preliminary Pr.llmin.ry Pnlifliry ' ".IPm^^BPiH^^^K I^^Bi^Bi
& : ' 'IHiJffv'; ' Stack Test PM Permit
Parameter
ERn,,
F1
^-*FI Rf t
Qnr,
BLSnn
ERW2
CEL.m?
QRFP
BLS,,r?
PRRFW
ERRF™
ERsOT,
CEL. SDT1
QSDT,
BLSRDTi
ERSDT2*
^EL SDT2n
QSOT;,
BLSSDT2,
ERsora.
GEL. SOT*
QsDia
BLSSDT2i,
PRsorw
ERgjrw
ERLK,
CEL.LK,
QLK,
CaOLK,
BLSW
ER,w
CELIK
QLK
CaOIK7
PR1K,,,, (CaOw)
ER,K.,,
F.R, ,
^Description
emission limit for RF1
conversion factor
"proposed" emission limit for RF1
measured stack flow rate from RF1
measured BLS firing rate o! RF1
emission limit for RF2
"proposed" emission limit for RF2
measured stack flow rate from RF2
measured BLS firing rate of Rr?
total BLS firing rates, all RFs
calculated emission rate, all RFs
emission limit for SDT1
"proposed" emission limit for SDT1
measured stack flow rate from SDT1
measured BLS firing rate of RF1
emission limit for SDT2a
"proposed" emission limit for SDT2a
measured stack flow rate from SDT2a
measured BLS firing rate of RF2'0.5
emission limit for SDT2b
"proposed" emission limit for SDT2b
measured stack flow rate from SDT2b
measured BLS firing rate of RF2'0 5
total BLS firing rates, all RFs
calculated emission rate, all SDTs
emission limit for LK1
"proposed" emission limit for LK1
measured stack flow rate from LK1
measured lime production from LK1
total BLS firing rates, all RFs
emission limit for LK2
"proposed" emission limit for LK2
measured stack flow rate from LK2
measured lime production firm i K2
total lime production, all LKr>
calculated emission mto. all I Ks
To' i1 ("-vision ra'o. ;iH rr'< • '"
Units
Ib/ton BLS
min'lb/d'gr
gr/dscf
dscfm
ton BLS/d
Ib/ton BLS
gr/cfict
H-.cfm
Ion Rl.S/fl
Ion RLS/d
Ib/ton RLS
Ih/ton BLS
gr/dscf
dscfm
tor BLS/d
Ib/ton BLS
gr/dscf
dscfm
ton BLS/d
Ib/ton RLS
gr/dscf
dscfm
Ion BLS/d
ton BLS/d
Ib/ton BLS
Ib/ton BLS
gr/dscf
dscfm
ton CaO/d
ton BLS/d
Ib/lon BLS
gr/dscf
dscfm
!on CaO/d
Ion CaO/d
Ih/ton BLS
'li''nn "1 T,
Value*
1 154
0206
0046
54,780
450
0700
0028
236. 730
1,950
2400
0 785
0111
005
4,830
450
0 125
0057
10.400
975
0 133
006
10,520
975
2400
0 126
0 110
0035
6,867
72
2400
0 173
0055
29,760
312
384
0 161
' '"'
Limits (1)
1 630
0206
0065
54,780
450
0825
0033
236,730
1,950
2400
0976
0 166
0.075
4,830
450
0 198
009
10,400
975
0200
009
10.520
975
2400
0193
0.189
0.06
6,867
72
2400
0236
0075
29.760
312
384
0227
1 31f-
PM Permit
Llmfts"*(2)
1 881
0206
0075
54,780
450
0825
0033
236. /30
1,950
2400
1 023
0 199
0.09
4,830
450
0 198
009
10,400
975
0200
009
10,520
975
2400
0 199
0 189
006
6,867
72
2400
0283
009
29,760
312
384
0265
1 487
PM Pipit
Limits (3)
1 956
0206
0078
54,780
450
0.825
0033
236,730
1,950
2400
1.037
0.199
0.09
4,830
450
0 198
0.09
10,400
975
0200
009
10,520
975
2400
0.199
0.189.
0.06
6,867
72
2400
0.283
'009
29.760
312
384
0265
' 501
&• ' 3» iaHBg ^"•S^Blr - - 1
ERRF, = Fr(CEL.Br,)(QRF,)/(BLSnr,)
set value
mill-specific
mill-specific
mill-specific
ERRF2 = Fr(Ca.Rre)(QHRV(BLSnFJ
mill-specific
mill-specific
mill-specific
(BLSRF,) + (BLSHF?)
ERRF,O.= (ERnF,)(PRRF,)/(PRww + (ER^XPR^WPR^™)
FRsoT, - F1'(CEL SOT,)(QSDT,)/(BLSSDT,)
mill-specific
mill-specific
mill-specific
ERsOTZ. = F1'(CEL •5DT2«)(QsDT2.V(BLSsOTai)
mill-specific
mill-specific
mill-specific
ERsor*, = F1'(CEL ,DTa)(QsDTJb)/(BLSSOTa>)
mill-specific
mill-specific
mill-specific
same as PRw«
ERSDTIO, = (ERsor.MPRsDT.XfPRsOT.J -1- (ERSOTJ,)(PRSOT2.X(PR
(ERSDT2t,)(PR30T»X(PRsOTto()
ERLK, = F1-(CBJJt,)(QlK,)(CaOw^LSM)/CaOLK,)
mill-specific
mill-specific
mill-specific
ERLK* = Fr(CEULKZ)(QLK2)/(CaO,0/BLS,0,XCaOua)
mill-specific
mill-specific
mill-specific
(CaOLK1) + (CaOua)
r~ri /PQ WPR W/DE3 j_ If^D \{DO W/DD \
ERLK,(a~ ttr'LK,M"r'LK,;'tf FlLKurt) + ( t HLK2 ^rHy^;/ (K MLKto,)
FR, . - ER,,t,,, + ER,OTM + ER,,,,,,
^^•^^•^•IJ^^^PH
(Equation 2 in final rule)
(Equation 2 in final rule)
(Equation 5 in final rule)
(Equation 3 in final rule)
(Equation 3 in final rule)
(Equation 3 in final rule)
sorw) +
(Equation S in final rule)
(Equation 4 in final rule)
(Equation 4 in final rule)
(Equation 5 in final rule)
-------
METHANOL EMISSIONS
EXAMPLE: MILL C
* AFFECTED SOURCES AT MILL C:
1 existing DCE recovery furnace (RF1) and associated BLO unit (BLO1)
1 new NDCE recovery furnace with dry ESP system (RF2)
1 new NDCE recovery furnace with wet ESP system (KF3)
1 existing smelt dissolving tank (SDT1)
2 new smelt dissolving tanks (SDT2 and SDT3)
2 existing lime kilns (LK1 and LK2)
> RELEVANT DATA FROM RECENT STACK TESTS AT MILL C:
Because the gaseous organic HAP emission limit for kraft and soda recovery furnaces only
applies to new sources, only the new NDCE recovery furnaces would be subject to the
requirements. Also, because NDCE recover)' furnaces with dry ESP systems are not
required to conduct an initial performance test, only RF3 (new NDCE recovery furnace
with wet ESP system) \\ould be required to test.
RF3 test results:
Black liquor solids fmng rate: 2.000 ton BLS/d
Methanol emissions: 0.82 Ib/hr
Using emissions and process data from the recent stack test and Equation 9 provided in the
regulation (see Appendix A), calculate methanol emission rate for RF3 at Mill C as follows:
E = (^lRn..^Rr;V(BLSRF;) (Equation 9 in final rule)
Where:
ERVDCt = methanol emission rate from NDCE recovery furnace, Ib/ton of black liquor
solids fired
MRmtJ,RF3 = average measured methanol mass emission rate from RF3, Ib/hr
BLSRF3 = a\ erage black liquor solids firing rate for RP3, ton/hr; determined using
process data measured during the performance test
Stack test/process data from Mill C:
MR^RR = 0.82 Ib/hr
BLSRF, = (2,000 ton BLS/d) * (1 d/24 hr) = 83.3 ton/hr
Therefore:
= (0.82)/(83.3)
0.0098 Ib/ton of black liquor solids fired
G-19
-------
TOTAL HYDROCARBON EMISSIONS
EXAMPLE: MILL D
•> AFFECTED SOURCES AT MILL D:
1 Semichemical combustion unit (fluidized-bed reactor) (FBR1)
- RELEVANT DATA FROM RECENT STACK TESTS AT MILL D:
Test results:
Black liquor solids firing rate: 30,000 ton BLS/d
Control device inlet THC emissions: 77.2 Ib/hr
Control device outlet THC emissions: 5.9 Ib/hr
Using emissions and process data from the recent stack test and Equations 11 or 12 provided
in the regulation (see Appendix A), calculate THC emission rate or THC percent reduction
for Mill D as follows:
SEMICHEMICAL COMBUSTION UNIT THC EMISSION RATE EQUATION:
ERSCCU = (THCmeas)/(BLS) (Equation 11 in final rule)
Where:
= THC emission rate from each semichemical combustion unit, Ib/ton of black
liquor solids fired
THCmeils = measured THC mass emission rate, Ib/hr
BLS = average black liquor solids firing rate, ton/hr: determined using process
data measured during the performance test
Stack test/process data from Mill D:
ERscci' = 5.9 Ib/hr
BLS = (30.000 ton BLS/d) * (1 d/24 hr) = 1,250 ton/hr
Therefore:
ERSCCU = (5.9)7(1,250)
= 0.0047 Ib/ton of black liquor solids fired
SEMICHEMICAL COMBUSTION UNIT PERCENT REDUCTION EQUATION
(%RTHC) = [(E, - E0)/E,] * 100 (Equation 12 m final rule >
Where:
= percentage reduction of THC emissions achieved
G-20
-------
E, = measured THC mass emission rate at the THC control device inlet, Ib/hr
E0 = measured THC mass emission rate at the THC control device oulet, Ib/hr
Stack test/process data from Mill D:
E, - = 77.2 Ib/hr
£„ = 5.9 Ib/hr
•"o
Therefore:
%RTHC = [(77.2 - 5.9)777.2] * 100
= 92.4 percent reduction
G-21
-------
Appendix H
Compliance Timelines for Existing and New Sources
-------
-------
Effective
Date
i
Initial
Notification
Compliance
Date
Notification of
Pptformance Test
Notification of
Performance
Evaluation
Performance Test
Performance
Evaluation
Notification
of
Compliance
Cfotl 10
, - ~ 1 1 " T
First
Compliance
Report
' 1
r
60 days 120 days 3 years 60 days 180 days 60 days Semiannually if no
after after after before after after ov^ooHan^oc
Promulgation
Date
Effective
Date
Effective
Date
Performance
Test
Compliance
Date
Performance
Test
quarterly if
exceedances
Figure H-1. Compliance Timeline for Existing Sources and Area Sources that Become Major Sources.
-------
Effective
Date
Compliance
Date
Initial
Notification
Notification of
Performance Test
Notification of
Performance
Evaluation
Performance Test
Performance
Evaluation
ffi
60 days
after
Promulgation
Date
Startup
Date
120 days
after
Startup
Date
• 60 days
before
Performance
Test
180 days
after
Startup
Date
Notification of
Compliance
Status
First
Compliance
Report
60 days Semiannually if no
after exceedances,
Performance quarterly if
Test exceedances
Figure H-2. Compliance Timeline for New or Reconstructed Sources with Startup after Promulgation Date.
-------
Appendix I
Flowchart Summary of the NESHAP
-------
Does this facility produce
pulp, paper, or paperboard?
NO
This facility is not subject
to this NESHAP.
YES
Does this facility recover
chemicals from its pulping
process?
NO
YES
Is this facility a major source of HAP?
(That is, does the facility emit more
than 10 tons per year of a single HAP
or more than 25 tons per year of total
HAP?)
NO
YES
Applicability and compliance schedule (see Figure I-2)
Emission limits (see Figure I-3)
Initial compliance requirements (see Figure I-4)
Continuous compliance requirements (see Figure I-5)
Reporting requirements \see Figure I-6)
Recordkeepmg requirements (see Figure I-7)
Figure 1-1. Mill Applicability
1-3
-------
Existing Affected Sources
Kraft or soda chemical recovery system
• NDCE recovery furnace/SDT
• DCE recovery furnace syslem/SDT
• Lime kiln
Sulfite combustion unit
Semichemical combustion unit
New Affected Sources
NDCE recovery furnace/SDT
DCE recovery furnace system/SDT
Lime kiln
Sulfite combustion unit
Semichemical combustion unit
Is your affected source or process unit
a new source? (That is, has your
affected source or process unit
started up since April 15, 1998?)
YES
New sources must achieve
compliance upon startup
or by March 13, 2001,
whichever is later.
NO
Has your affected source or process unit
undergone reconstruction? (That is,
have the components been replaced 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
sou"~e?)
YES
Reconstructed sources must
achieve compliance with new
source standards after
reconstruction.
NO
Existing sources must achieve
compliance by March 13, 2004.
Figure I-2. Applicability and Compliance Schedule
1-4
-------
Is your facility a kraft
or soda pulp mill?
YES
NO
Is your facility a sulfite
pulp mil'?
YES
Is your facility a stand-
alone semichemical
pulp mill? (That is, a
semichemicai pulp
mill with a chemical
recovery process that
is not integrated with a
kraft pulp mill.)
YES
Is your affected
source or process
unit a new source?
YES
NO
Choose one of the following
control options:
Recovery furnace
PM: 0.015 gr/dscf at 8% O2
Methanol: 0.025 Ib/ton BLS
SDT
PM: 0.12 Ib/ton BLS
Lime kiln
PM: 0.01 gr/dscf at 10% O2
Recovery furnace
PM: 0.044 gr/dscf at 8% O2
SDT
PM: 0.20 Ib/ton BLS
Lime kiln
PM: 0.064 gr/dscf at 10% O2
PM bubble compliance option
Comply with mill-specific
limits based on the
calculated value of the •
sum of the individual
emission limits for
recovery furnaces,
SDTs, and lime kilns.
Is your affected
source a new
source?
YES
Sulfite combustion unit
PM: 0.02 gr/dscf at 8% O2
NO
Sulfite combustion unit
PM: 0.04 gr/dscf at 8% 02
Choose one of the
following control
options:
Semichemical combustion unit
THC (as carbon): 2.97 Ib/ton BLS
Semichemical combustion unit
THC (as carbon): 90% reduction
Figure I-3. Emission Limits
1-5
-------
Are you subject to any of the PM
standards for kraft or soda recovery
furnaces or lime kilns'
Are you subject to any of the PM
standards for kraft or soda srnplt
dissolving tanks or sulfite
combustion units7
YES
Conduct an initial PM performance
test using Method 5, 29, or 17
Are you subject to the gaseous
organic HAP standard for semi-
chemical combustion units'
YES
Conduct an initial PM performance
test using Mntliod 5, ?1, or 1 7
Are you using an electrostatic
preciprtator (ESP) to comply with
the applicable standard'
NO
I
Are you using a wft scrubber
to comply with the applicable
standard9
YES
Choose one of the following:
YES
Choose one of thp following
Install, calibrate,
operate, and
maintain a COM3 to
determine and
record opacity
Install, calibrate,
operate, and maintain
a CMS to determine
and record alternative
parameters subject to
prior written approval
by Administrator
Are you subject to the gaseous
organic HAP standard for new
kraft or soda recovery furnaces'
YES
Conduct an initial performance
test using Method 25A
Are you using a renenerative
thermal oxidizer (RTO) to
comply with the standard'
Install, calibrate, operate
and maintain a CMS to
determine and record
scrubber pressure drop
and scrubbing liquid
flnw fate
Install, calibrate,
operate, and
maintain a CMS
to determine
and record
parameters for
the alternative
control technique
subject to prior
written approval
by Administrator
X YES
Choose one of the following
^
Install,
1
I
calibrate,
operate, and
maintain a CMS
to determine and
record alternative
parameters
subject to prior
written approval
by Administrator
Install,
Conduct an initial
methanol performance
test using Method 308.
i
calibrate,
operate, and
maintain a
CMS to
determine
and record
RTO operating
temperature
Install,
r
calibrate,
operate, and
maintain a CMS
to determine
and record
parameters
subject to prior
written approval
by Administrator.
.YES
Establish operating ranges for
monitoring parameters during
the initial performance test
OR
Base operating ranges on
values recorded during
previous performance tests
YES
Establish expanded or replacement
operating ranges during subsequent
performance tests
Figure 1-4. Initial Compliance Requirements
-------
Are you subject to any of the PM
standards for kraft or soda recovery
furnaces or lime kilns'
Are you sublet to any of the PM
Standards for kraft or soda smelt
dissolving tanks or sulfitr*
combustion units7
Are you subject to the gaseous
organic HAP standard for
semichrmiral combustion units9
YES
YES
Are you using an electrostatic
precipitator (ESP) to comply with
the applicable standard9
NO
Are you using a wot scrubber to
comply with HIP appln ahlr>
Mandard •'
YES
Choose one of the following
Using a COMS, determine the
opacity once every successive
10-second period and calculate
and record each successive 6-
minute average opacity.
You must implement corrective
action when the average of 10
consecutive 6-minute averages
result in a measurement > 20%
opacity.
You are in violation of the
standard when:
Existing kraft or soda
recovery furnaces:
• Opacity > 35% for 6% or more
of the operating time within any
quarterly period.
New kraft or soda recovery
furnaces or lime kilns:
• Opacity > 20% for 6% or more
of the operating time within any
quarterly period.
Choose one of Ibo following
Monitor alternative
parameters subject
to prior written
approval by
Administrator.
Using a CMS,
determine and record
scrubber pressure
drop and scrubbing
liquid flow rate once
every successive 15-
mmute period
Are you subject to the gaseous
organic HAP standard for new
kraft or soda recovery furnaces?
YES
YES
Are you using a
regenerative thermal
oxidizer (RTO) to comply
with the standard7
YES
Choose one of the following:
I
Monitor
alternative
parameters
subject to
prior written
approval by
Administrator.
Using a CMS,
determine and
record the RTO
operating
temperature once
every successive
15-mmute period.
You must implement corrective action when any 1-hour
average RTO operating temperature falls below the
temperature established during the initial test.
You must implement corrective action when any
3-hour average parameter value is outside the
range of values established during the initial test.
You are in violation of the standard when when any
3-hour average RTO operating temperature falls below
the temperature established during the initial test.
You are in violation of the standard when 6 or
more 3-hour average parameter values within
any 6-month reporting period are outside the
values established during the initial test. (No
more than one exceedance will be attributed in
any given 24-hour period.)
Figure 1-5. Continuous Compliance Requirements
-------
Are you a major source
of HAP and subject to
this NESHAP?
YES
Submit initial notification
• All relevant information in §63.9(b) of the NESHAP General Provisions (40
CFR part 63, subpart A)
Existing sources
•Submit by July 11,2001
New/reconstructed sources
• Submit 120 days after initial startup
Are you required to
conduct an initial
performance test?
YES
Submit notification of
performance test
All relevant information in
§63.9(e)
Submit notification of compliance status
• All relevant information listed in §63.9(h)
• If using PM bubble compliance alternative-
- PM limits determined in §63.865(a)(1 )(ii)
- Calculations/supporting documentation
• Submit 60 days after performance test
Have the measured values for
opacity or operating parameters
met any of the conditions
requiring corrective action or
indicating a violation during the
reporting period?
YES
NO
Submit quarterly report of excess emissions
• All relevant information listed in §63.10(c)
• Number and duration of occurrences when the source met or
exceeded the conditions requiring corrective action
• Number and duration of occurrences when the source met o'
exceeded the conditions indicating a violation
Submit semiannual report of no excess emissions
• All relevant information lirted in 63.10(e)(3)(vi)
• Statement that no excess emissions occurred during
the reporting period
Has the Administrator
approved the emission
limits you established
for your process unit
under the PM bubble
compliance alternative?
YES
Are you planning to take any of the following
actions?
• Modify or replace your air pollution control system
• Shut down any recovery furnace, SDT, or lime kiln
complying with the PM bubble compliance alternative
for more than 60 days
• Change a continuous monitoring parameter or the
value or range of values of a continuous monitoring
parameter for any process unit
• Increase the black liquor solids firing rate for any
recovery furnace more than 10 percent above the level
measured during the most recent performance test
during any 24-hour averaging period
YES
Submit
notification of
changes
Figure I-6. Reporting Requirements
1-8
-------
Are you a major source
of HAP and subject to
thisNESHAP?
YES
Keep all records for at
least 5 years, with the
most recent 2 years of
records kept onsite
YES
Keep the following records:
• All relevant information listed in §63.10(b) and (c) of the
NESHAP General Provisions (40 CFR part 63, subpart A).
• Startup, shutdown, and malfunction plan
• Parameter monitoring data
• Monitoring parameter ranges established during initial test
• Records and documentation of supporting calculations for
compliance determinations
• Occurrences when corrective action required
• Occurrences when violation noted
Is your affected source
a semichemical
combustion unit?
Is your affected source
or prbcess unit a krafi
or soda recovery
furnace9
.YES
Does your NDCE
recovery furnace have e
dry ESP system'7
YES
YES
YES
Keep records of black liquor
solids firing rates
Keep a record certifying that an NDCE recovery
furnace equipped with a dry ESP system is used
to comply with the gaseous organic HAP
emission limit for new kraft or soda recovery
furnaces
Is your affected source
or process unit a kraft
or soda lime kiln?
YES
Keep records of CaO
production rates
Figure I-7. Recordkeeping Requirements
1-9
-------
Inspection Checklist
Applicable Rule: 40 CFR Part 63, Subpart MM - National Emission Standards for Hazardous Air
Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills
General Information
Facility Name •
Facility Location
Facility TRI ID No.
Date of Inspection
Inspector(s) name Title/Affiliation Phone Number
J-3
-------
Applicability
1.
2.
3.
My facility produces pulp, paper, or paperboard.
My facility recovers chemicals from its pulping process.
My facility is a major source of hazardous air pollutants (that is,
emits at least 10 tons/yr of any HAP OR at least 25 tons/yr of
any combination of HAP).
DYes
DYes
DYes
DNo
DNo
DNo
4. My affected source or process unit started up on or before April D Yes D No
15, 1998.
If you answer NO to question 1, 2, or 3, do not continue. This rule does not apply to your facility.
If you answer YES to questions 1, 2, and 3, your facility is subject to the rule and you will need to
answer questions for each part of your plant. If you answer YES to question 4, you will need to
answer the questions that apply to existing sources. If you answer NO to question 4, you will need
to answer the questions that apply to new sources. Start with question 5 and answer each question
that applies to you.
J-4
-------
Emission Limits
This section covers requirements for all affected sources and process units to which the NESHAP
applies. For each new affected source, you are in compliance if you answer YES to each of the
following questions 5 through 10 which apply.
•frr
I am maintaining an outlet PM concentration of 0.015 gr/dscf at D Yes D No
8 percent oxygen from my kraft or soda recovery furnace.
I am maintaining an outlet methano] emission rate of 0.025
Ib/ton BLS from my kraft or soda recovery furnace system.
D Yes DNo
7. I am maintaining an outlet PM emission rate of 0.12 Ib/ton BLS D Yes DNo
from my kraft or soda smelt dissolving tank.
I am maintaining an outlet PM concentration of 0.01 gr/dscf at
10 percent o \vgen from m> kraft or soda lime kiln.
D Yes D No
9. I am maintaining an outlet PM concentration of 0.02 gr/dscf at 8 D Yes D No
percent oxygen from mv sulfite combustion unit
10 v I am maintaining a'i outlet THC emission rate of 2 97 Ib/ton CD Yes D No
BLS from m\ semichemical combustion unit OR I am reducing
THC emissions from mv semichemical combustion unit by at
least 90 percent
For each existing affected source or process unit. \ou are in compliance if you answer YES to
each of the follow in^: questions 11 through 17 \\hich apply.
Emission Limits For Existing Affected Sources Or Process Units
No. Question
Answer
Comments
11 I am complvjng with tve precisions of the PM bubble
compliance alternative for all process unit-- in mv chemical
recover} system iall existing recovery furnaces, smelt
dissolving tank-- and lime kilns at the mill) which operate at
least 6.300 hours per year OR I am complying with items 13.
14. and 15.
DYes "DNo
12. I am complying with items 13. 14, and 15 for any process units
in my chemical recovery system (any existing recovery
furnaces, smelt dissolving tanks, and lime kilns at the mill)
which operate less than 6.300 hours per year.
D Yes D No
13. I am maintaining an outlet PM concentration of 0.044 gr/dscf at
8 percent oxygen from my kraft or soda recovery furnace.
D Yes DNo
J-5
-------
14.
'"i
15.
16.
..__ , ;
•l*^^l":is£'
I am maintaining an outlet PM emission rate of 0.20 Ib/ton BLS
from my kraft or soda smelt dissolving tank.
D Yes D No
I am maintaining an outlet PM concentration of 0.064 gr/dscf at
10 percent oxygen from my kraft or soda lime kiln. •
D Yes D No
I am maintaining an outlet PM concentration of 0.04 gr/dscf at 8
percent oxygen from my sulfite combustion unit.
D Yes D No
17. I am maintaining an outlet THC emission rate of 2.97 Ib/ton
BLS from m> semichemical combustion unit OR I am reducing
THC emissions from my semichemical combustion unit by at
least 90 percent.
D Yes D No
J-6
-------
Initial Compliance Requirements
For each affected source or process unit, you have demonstrated initial compliance if you answer
YES to each of the following questions 18 through 31 which apply.
18. I have conducted all required initial PM performance tests for D Yes D No
my sulfite combustion units and my kraft or soda recovery
furnaces, smelt dissolving tanks, and lime kilns using Method 5,
29. or 17.
19. I ha\e conducted all required initial methanol performance tests D Yes D No
for my new kraft or soda DCE recovery furnace systems and
NDCE recover) furnace systems with wet ESP systems using
Method 308. (No initial methane! performance test is required
for NDCE recovery furnace systems with dry ESP systems.)
20. I have conducted all required initial THC performance tests for D Yes D No
m\ semichemical combustion units using Method 25A.
21 1 ha\e calculated the PM concentrations and emission rates D Yes D No
trorr: the initial PM performance tests and am meeting all of the
applicable PM emission limits in items 5. 7 through 9. and 11
through 16
22 1 ha\e calculated the methanol emission rates from the initial C Yes D No
methanol performance tests and am meeting the methanol
emission limit in !te;r- 6
23 I ha\e calculated trie THC emission rates from the initial THC D Yes D No
performance te^t-- and an- meeting either of the THC emission
limits in items 10 and l "
J-7
-------
24. If I am using the PM bubble compliance alternative, I have done
the following:
a. Determined the overall PM emission limit for my D Yes D No
chemical recovery system according to the equations
in Appendix G using the reference concentrations
(emission limits in items 13, 14, and 15) for the
process units in my chemical recovery system.
b. Established mill-specific PM emission limits for all D Yes D No
of the process units in my chemical recovery system.
c. Used these established emission limits to determine D Yes D No
the overall PM emission rate for my chemical recovery
system according to the equations in Appendix G.
d. Determined that the overall PM emission rate D Yes DNo
calculated in item 24c is less than or equal to the
overall PM emission limit calculated in item 24a.
e. Applied for and received approval from the D Yes DNo
Administrator to use the mill-specific PM emission
limits established in item 24c.
25. I ha\e installed and calibrated the continuous opacity monitoring D Yes D No
system for m> kraft or soda recovery furnaces and lime kilns
equipped \\ith ESP?.
26. I have installed and calibrated continuous monitoring systems D Yes D No
for scrubber pressure drop and scrubbing liquid flow rate for my
sulfite combustion units, kraft or soda recovery furnaces, kraft
or soda smelt dissoh ing tanks, and kraft or soda lime kilns
equipped with wet scrubbers.
2". 1 haNe installed aid calibrated the continuous monitoring system D Yes D No
for RTO operating temperature for my semichemical
combustion unit.x equipped with RTO;-.
28 If I decide to use Jiernatne monitoring parameters to D Yes D No
demonstrate compliance. 1 have applied for and received
approval from the Administrator to use the alternative -
monitoring parameter and I have installed and calibrated
continuous monitoring s\ stems to measure the alternative
monitoring parameters.
29. If I decide to use an alternative control device to comply. I have D Yes D No
applied for and received approval from the Administrator to use
the alternative control device and the associated monitoring
parameters, and I ha\e installed and calibrated continuous
monitoring systems TO measure the monitoring parameters for
the alternative control device.
J-8
-------
30. I have established operating values or ranges for my monitoring
parameters during the initial performance test, other previous
performance tests, and/or any additional performance tests
according the specified requirements.
D Yes D No
31. I have certified that all control techniques and processes have
not been modified subsequent to the testing upon which the data
used to establish the monitoring parameter ranges were
obtained.
D Yes D No
J-9
-------
Continuous Compliance Requirements
For each affected source or process unit, you have demonstrated continuous compliance if you
answer YES to each of the following questions 32 through 52 which apply.
32. I am maintaining and operating the continuous opacity ED Yes D No
monitoring systems for my kraft or soda recovery furnaces and
lime kilns equipped with ESPs.
33. I am maintaining and operating continuous monitoring systems D Yes D No
for scrubber pressure drop and scrubbing liquid flow rate for my
sulfite combustion units, kraft or soda recovery furnaces, kraft
or soda smelt dissolving tanks, and kraft or soda lime kilns
equipped with v\et scrubbers.
34. I am maintaining and operating the continuous monitoring D Yes D No
system for RTO operating temperature for my semichemical
combustion units equipped with RTOs.
35. If 1 decide to use alternative monitoring parameters to D Yes D No
demonstrate compliance. 1 am maintaining and operating the
continuous monitoring systems for the alternative parameters.
36 If I decide to use an alternative control device to comply. I am D Yes DNo
maintaining and operating the continuous monitoring sv stems
for the parameters for my alternative control device
37 I am determining the opacity for my kraft or soda recovery D Yes D No
furnaces or lime kilns equipped with ESPs at least once everv
successive 10-second period and calculating and recording each
successiv e 6-minu'c av erage opacitv using the specified
procedure^-
38 I am determining and recording the scrubber pressure drop and D Yes D No
scrubbing liquid flew rate for my sulfite combustion units, kraft
or soda recovers furnaces, kraft or soda smelt dissolving tanks.
and kraft or soda lime kilns equipped with wet scrubbers at least
once everv 15-minute period using the specified procedures.
39. I am determining and recording the RTO operating temperature D Yes D No
for my semichemical combustion units equipped with RTOs at
least once every 15-minute period using the specified
procedures
40. If I decide to use alternative monitoring parameters to D Yes DNo
demonstrate compliance. I am determining and recording the
alternative parameters according to the frequency approved by
the Administrator.
J-10
-------
41. If I decide to use an alternative control device to comply, I am
determining and recording the parameters for the control device
according to the frequency approved by the Administrator.
D Yes D No
42. I am implementing corrective action when the average of 10
consecutive 6-minute averages result in a measurement greater
than 20 percent opacity for my kraft or soda recovery furnaces
and lime kilns equipped with ESPs.
D Yes D No
43. I am implementing corrective action when any 3-hour average
scrubber parameter value (scrubber pressure drop or scrubbing
liquid flow rate) is outside the range of values established in my
performance test(s) for my sulfite combustion units, kraft or
soda recovery1 furnaces, kraft or soda smelt dissolving tanks, and
kraft or soda lime kilns equipped with wet scrubbers.
D Yes D No
44. I am implementing corrective action when any 1-hour average
RTO operating temperature falls below the temperature value
established in mv performance test(s) for mv semichemical
combustion units equipped with RTOs.
D Yes D No
45. If I decide to u?e alternative monitoring parameters to
demonstrate compliance. I am implementing corrective action
when am 3-hour a\eiage \alue of the alternative parameters are
outside the range of values established in mv performance
tesus)
D Yes D No
46. If I decide to use an alternative control de\ice to comph. 1 am
implementing corrective action when any 3-hour average value
for the parameters for mv alternative control device are outside
the range of v aluo e^tabhsned in mv performance te<-ti ^ i
D Yes D No
To avoid being :r violation of the standard. 1 am preventing
opacitv from being greater than 35 percent for 6 percent or
more of the operating ,ime within anv quarterly period for mv
existing kraft or soda recov ery furnaces equipped vv nh ESPs
G Ye?
No
4S To avoid being in violation of the standard. I am preventing
opacitv from being greater than 20 percent for 6 percent or
more of the operating time within any quarterly period for mv
new kraft or soda recovery furnaces and existing or new kraft or
soda lime kilns equipped with ESPs.
D Yes D No
49. To avoid being in violation of the standard. I am preventing six
or more 3-hour average scrubber parameter values (scrubber
pressure drop or scrubbing liquid flow rate) from being outside
the range of values established in my performance test(s) for
my sulfite combustion units, kraft or soda recover)- furnaces.
kraft or soda smelt dissolving tanks, and kraft or soda lime kilns
equipped with wet scrubbers.a
D Yes D No
J-ll
-------
50. To avoid being in violation of the standard, I am preventing any
3-hour average RTO operating temperature from falling below
the temperature established in my performance test(s) for my
semichemical combustion units equipped with RTOs.
D Yes D No
51. If I decide to use alternative monitoring parameters to
demonstrate compliance, to avoid being in violation of the
standard, I am preventing six cr more 3-hour average values for
the alternative parameters from being outside the range of
values established in my performance test(s)."
D Yes D No
52. If I decide to use an alternative control device to comply, to
avoid being in violation of the standard, I am preventing six or
more 3-hour average values for the parameters for my
alternative control device from being outside the range of values
established in rny performance test(s)."
D Yes D No
For the purposes of determining the number of nonopacity monitoring exceedances, no more than one
exceedance will be attributed in any given 24-hour period
J-12
-------
Recordkeeping Requirements
For each affected source or process unit, you are meeting the recordkeeping requirements if you
answer YES to each of the following questions 53 through 61 which apply.
53.
I have developed and implemented a startup, shutdown, and
malfunction plan that includes the information described in
Table 11.
D Yes D No
54 I am maintaining records of the relevant information listed in
§63.10(b) and (C) of the NESHAP General Provisions (40 CFR
part 63. subpart A).
D Yes D No
55. I am maintaining records, of th" parameter monitoring data
described in Table 11
DYes
D Yes
DYes
DNo
DNo
DNo
56 I am maintaining records of occurrences when corrective action
is required as described in Table 11.
I am maintaining record*, of occurrences when violation is noted
a*- described in Table 11.
58 I am maintaining records of black liquor solids firing rates for
rr.\ kraft or soda reco\er\ furnaces and semichemical
combustion units
D Yes D No
59 1 am maintaining records of CaO production rates for my kraft
or soda lime kilr.s
D Yes D No
60 I am maintaining records of monitoring parameter ranges
established in m> pc-;orrnLnce test(s).
j Yes
INo
6] If I ha\e an NDCE reco\er\ furnace equipped with a dr\ ESP
SNSiem. I am maintaining a certification that this equipment is
used to comph v. ith the gjseous organic HAP emission limit
for new recover\ furnaces
LJ Yes D No
J-13
-------
Reporting Requirements
For each affected source or process unit, you are meeting the reporting requirements if you answer
YES to each of the following questions 62 through 70 which apply.
62. I have submitted an initial notification containing the relevant D Yes D No
information listed in §63.9(b) of the NESHAP General
Provisions."
63. If I need an extension of compliance. I have submitted an D Yes D No
extension request containing the relevant information listed in
§63.9(c) of the NESHAP General Provisions."
64. If my source is subject to special compliance requirements, I D Yes D No
have submitted a notification of this containing the relevant
information listed in §63 9(d) of the NESHAP General
ProvisionsJ
65. I ha\e submitted a notification of performance test containing D Yes D No
the relevant information listed in §63.9(e) of the NESHAP
General Provisions"
66 I have submitted additional notifications related to CMS D Yes D No
containing the relevant information listed in §63.9(g) of the
NESHAP General Pro\ isions/
67. I have submitted a notification of compliance status containing D Yes D No
the information described in Table 12.
68 If I decide to u-e trie PM bubble compliance alternative. I have D Yes D No
submitted a notification if I make any of the changes described
in Table 12
69. If m> measureJ p^.; ameters meet any of the conditions requiring D Yes D No
corrective action ot indicating a violation. I have submitted a
quarterly repon of excess emissions containing the information
described in Table 12
70. If no exceedances of parameters have occurred. I have submitted D Yes D No
a semiannual report of no excess emissions containing the
information described in Table 12.
' The NESHAP General Provisions can be found in 40 CFR part 63. subpart A.
J-14
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Appendix K
Example Notifications and Compliance Reports
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Initial Notification
Applicable Rule: 40 CFR Part 63, Subpart MM - National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and
Stand-Alone Semichemical Pulp Mills
1. Print or type the following general information for each pulp mill in which chemical recovery
operations are performed:
Owner/Operator/Title:
Street Address:
City: State: Zip Code:.
Plant Name: _
Plant Contact/Title:
Plant Contact Phone Number (optional):
Plant Address (if different than owner/operator's)
Street Address:
City: State: Zip Code:
2. Provide the following information as appropriate:
• Jhe affected source's compliance date:
A brief description of the nature, size, design, and method of operation of the affected source,
including its opeiatmg design capacity:
An identification of each point of emission for each hazardous air pollutant:
A statement of \\hether the affected source is a major source or an area source:
K-3
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Application for Approval of Construction or Reconstruction
Applicable Rule: 40 CFR Part 63, Subpart MM - National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and
Stand-Alone Semichemical Pulp Mills
1. Print or type the following general information for each pulp mill in which chemical recovery
operations are performed:
Owner/Operator/Title:
Street Address:
City: State: Zip Code:.
Plant Name:
Plant Contact/Title:
Plant Contact Phone Number (optional):
Plant Address (if different than owner/operator's)
Street Address:
City: State: Zip Code:
2. When do you plan to commence construction or reconstruction of the new major affected
source?:
3. In addition to the information requested above, please include the following information in
each application for approval of construction or reconstruction:
• Notification that you intend to construct a new major affected source or make any physical
change or operational change to a major affected source that may meet or has been determined
to meet the criteria for a "reconstruction." as defined in §63.2 of the NESHAP General
'Provisions (40 CFR p-irt 63. subpart A)
• The expected completion date of the construction or reconstruction:
• The anticipated date of initial start-up of the source:
• The type and quantm of HAP emitted by the source, reported in units and averaging times, or.
if actual emissions data are net yet available, an estimate of the type and quantity of HAP
expected to be emitted oy your source (in units and averaging times):
4. In addition to the information requested above, please include.the following information in
each application for approval of construction:
• Technical information describing the proposed nature, size, design, operating design capacity.
and method of operation of the source:
K-4
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An identification of each point of emission for each hazardous air pollutant that is emitted (or
could be emitted):
A description of the planned air pollution control equipment for each emission point, including
each control device for each hazardous air pollutant and the estimated control efficiency
(percent) for each control device:
A description of the planned air pollution control method for each emission point, including an
estimated control efficiency:
Calculations of emission estimates:
5. In addition to the information requested above, please include the following information in
each application for appro\al of reconstruction:
• A brief description of the affected source and the components that are to be replaced:
A description of present and proposed emission control systems, including each control
de\ice. its estimated control efficiency, and calculations of emission estimates in sufficient
detail for the EPA to evaluate the control efficiencv determination:
An estimate of the fixed capital cost of the replacements:.
An estimate of the cost of constructing a comparable entirely new source:.
The estimated life of the affected source after the replacements:
Discuss any economic or technical problems that you may have in complying with these
requirements after the proposed replacements:
K-5
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Notification of Compliance Status
This is a sample form for Notification of Compliance Status that can be used by facilities at their
discretion to meet the requirements in the Chemical Recovery Combustion Sources NESHAP.
Applicable Rule: 40 CFR Part 63, Subpart MM - National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and
Stand-Alone Semichemical Pulp Mills
1. Print or type the following general information for your pulp and paper mill:
Owner/Operator/Title:
Street Address:
City: State: Zip Code:.
Plant Name:
Plant Contact/Title:
Plant Contact Phone Number (optional):
Plant Address (if different than owner/operator's)
Street Address:
City: State: Zip Code:
2. Provide the following information, as appropriate:
• The methods that were used to determine compliance
• The results of all performance tests
• The results of all continuous monitoring system performance evaluations
• The methods that will be used for determining continuing compliance, including a description
of monitoring and reporting requirements and test methods
• The type and quantity of hazardous air pollutants emitted by the source (or surrogate pollutant-
specified in subpart MM), reported in units and averaging times and in accordance with the
test methods specified in subpart MM
• An analysis demonstrating whether the affected source is a major source or an area source
(using the emissions data generated for this notification)
• A description of the air pollution control equipment (or method) for each emission point,
including each control device (or method) for each hazardous air pollutant and the control
efficienc> (percent) for each control device (or method)
• A statement by the owner or operator of the affected existing, new, or reconstructed source a\
to whether the source has complied with the relevant standard or other requirements
• The PM emission limits determined in §63.865(a)(l)(ii) of subpart MM
• The calculations and supporting documentation for the PM emission limits determined in
§63.865(a)(l)(n) of subpart MM
K-6
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Excess Emissions Report
This is a sample form for Excess Emissions Report that can be used by facilities at their
discretion to meet the requirements in the Chemical Recovery Combustion Sources NESHAP.
Applicable Rute: 40 CFR Part 63, Subpart MM - National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and
Stand-Alone Semichemical Pulp Mills
1. Print or type the following general information for your pulp and paper mill:
Owner/Operator/Title:
Street Address:
City: State: Zip Code:.
Plant Name:
Plant Contact/Title:
Plant Contact Phone Number (optional):
Plant Address (if different than owner/operator's)
Street Address-
Cit>. State: Zip Code:
2. Pro\ idc the lollov, ing information, as appropriate:
• Identification ot each hazardous air pollutant monitored at the affected source
• The beginning and ending dates of the reporting period
• A bnef description of the process units
• The emission and operating parameter limitations specified in subpart MM
• The monitoring equipment manufacturer(s) and model number(s)
• The date of thu lateit continuous monitoring system certification or audit
• The total proce^ operating time of the affected source during the reporting period
• An emission da;.-, o- control system parameter summary, including the following: (1) Specific
identification of each period of excess emissions and parameter monitoring exceedances that
occurs during sunups, shutdowns, and malfunctions of affected source. (2) specific
identification o; each period of excess emissions and parameter monitoring exceedances that
occurs during periods other than startups, shutdowns, and malfunctions of affected source, (3;
number and duration of occurrences when the source met or exceeded the conditions in
§63.864(c)(l) of subpart MM requiring corrective action, (4) number and duration of
occurrences when the source met or exceeded the conditions in §63.864(c)(2) in subpart MM
indicating a violation, (5) total duration of excess emissions during the reporting period, (6)
total duration of excess emissions expressed as a percent of the total source operating time
during that reporting period, and (7) a breakdown of the total duration of excess emissions
during the reporting period into those that are due to startup/shutdown, control equipment
problems, process problems, other known causes, and other unknown causes.
• A continuous monitoring system summary', including the following: (1) date and time
identifying each period during which the continuous monitoring system was inoperative except
for zero (low-level) and high-level checks, (2) date and time identifying each period during
K-7
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which the continuous monitoring system was out of control, (3) nature and cause of any
malfunction, (4) corrective actions taken or preventive measures adopted, (5) nature of the
repairs or adjustments to continuous monitoring system that was inoperative or out of control,
(6) total continuous monitoring system downtime during the reporting period, (7) total duration
of continuous monitoring system downtime expressed as a percent of the total source operating
time during that reporting period, and (8) a breakdown of the total continuous monitoring
system downtime during the reporting period into those that are due to monitoring equipment
malfunctions, nonmonitoring equipment malfunctions, quality assurance/quality control
calibrations, other known causes, and other unknown causes.
All information necessary to demonstrate conformance with the startup, shutdown, and
malfunction plan when all actions taken during periods of startup, shutdown, and malfunction
are consistent with the procedures specified in the startup, shutdown, and malfunction plan
A description of any changes in continuous monitoring systems, processes, or controls since
the last reporting period
The name, title, and signature of the responsible official who is certifying the accuracy of the
report
The date of the report
K-8
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Summary Report
This is a sample form for Summary Report that can be used by facilities at their
discretion to meet the requirements in the Chemical Recovery Combustion Sources NESHAP.
Applicable Rule: 40 CFR Part 63, Subpart MM - National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda; Sulfite, and
Stand-Alone Semichemical Pulp Mills
1. Print or type the following general information for your pulp and paper mill:
Owner/Operator/Title:
Street Address:
City: State: Zip Code:.
Plant Name:
Plant Contact/Title:
Plant Contact Phone Number (optional):
Plant Address (if different than owner/operator's)
Street Address:
Cn\: State: Zip Code:
2. provide the following information, as appropriate:
• Identification of each hazardous air pollutant monitored at the affected source
• The beginning and ending dates of the reporting period
• A brief description of the process units
• The emission and operating parameter limitations specified in subpart MM
• The monitoring equipment manufacturer(s) and model number(s)
• The date of the latest continuous monitoring system certification or audit
• The total process operating time of the affected source during the reporting period
• Statement that no excess emissions occurred during the reporting period
• A description of an\ changes in continuous monitoring systems, processes, or controls since
the last reporting period
• The name, title, and signature of the responsible official who is certifying the accuracy of the
report
• The date of the report
K-9
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Appendix L
Technical Report Data Sheet
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1
1. REPORT NO
EPA-456/R-0 1-003
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
2
4. TITLE AND SUBTITLE
• Pulp and Paper Combustion Sources NESHAP: A Plain English
Description
7 AUTHORi S.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
•5520 Dillard Road. Suite 100
Gary, NC 27511
_12 SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agencv
Research Triangle Park, NC 27711
3. RECIPIENTS ACCESSION NO
5. REPORT DATE
September 2001
6. PERFORMING ORGANIZATION CODE
8 PERFORMING ORGANIZATION REPORT NO
10 PROGRAM ELEMENT NO
10203 A
11. CONTRACT/GRANT NO
68-D6-0012
13 TYPE OF REPORT AND PERIOD COVERED
Final (199 1-2001)
14 SPONSORING AGENCY CODE
15 SUPPLEMENTARY NOILS
16 ABSTRACT
National emission standards for hazardous air pollutants (NESHAP) were promulgated on January 12, 2001
for chemical reco\ er\ combustion sources in the pulp and paper industry under authonty of Section 1 12(d) of
the Clean Air Act as amended in 1990. This implementation document contains an overview of the NESHAP
and its requirements, other Federal regulations affecting pulp and paper mills, and other information.
Appendices to this document contain a list of affected pulp and paper mills, the final NESHAP and technical
corrections, a flowchart summar\ of the NESHAP, compliance timelines, a list of EPA Regional Office
contacts, equipment diagrams, inspection checklists, responses to commonly asked questions, a glossary of
commonly used terms, example notifications and compliance reports, and example calculations.
r
KE^i WORDS AND DOC! MT.NT ANALYSIS
!>:• - • 'I''"-- b IDENTIFIERS/OPEN ENDED TERMS
black liquor reco\er\ furnace air pollution control
black liquor gasification red liquor hazardous air pollutants
black liquor oxidation rotary liquor kiln • MACT
chemical recovery smelt dissolving tank NESHAP
combustion source smelter pulp and paper mills
fluidi-zed-bed reactor soda pulp mill
kraft pulp mill stand-alone semichemical pulp
lime kiln mill
paniculate matter sulfite pulp mill
18 DISTRIBUTION STATEMENT
Release Unlimited
19 SECURITY CLASS (Repon)
Unclassified
20 SECURITY CLASS (Page)
Unclassified
c COSATIField'Grcur
21. NO OF PAGES
220
22 PRICE
EPA Form 2220-1 (Re\. 4-77i PREVIOUS EDITION IS OBSdLETE • '"
L-3
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