EPA.                  450276014b
December 1977
     STANDARDS SUPPORT
AND ENVIRONMENTAL IMPACT
   STATEMENT - VOLUME II:
  PROMULGATED STANDARDS
      OF PERFORMANCE
    FOR KRAFT PULP MILLS

   U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air and Waste Management
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711
                          SM-X4

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                           EPA-450/2-76-014b
     STANDARDS SUPPORT
AND ENVIRONMENTAL IMPACT
   STATEMENT - VOLUME II:
  PROMULGATED STANDARDS
       OF PERFORMANCE
    FOR KRAFT PULP MILLS
        Emission Standards and Engineering Division
        U.S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Air and \kaste Management
         Office of Air Quality Planning and Standards
         Research Triangle Park, North Carolina 27711
               Decemher 1977

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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air and
Waste Management, Environmental Protection Agency, and approved for
publication.  Mention of company or product names does not constitute
endorsement by EPA. Copies are available free of charge to Federal
employees, current contractors and grantees, and non-profit organiza-
tions - as supplies permit - from the Library  Services Office  (MD-35) ,
Environmental Protection Agency, Research Triangle Park, N.C. 27711;
or may be obtained, for a fee, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
                     Publication No.  EPA-450/2-76~014b
                                    11

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                                          Final

                                  Standards Support and
                              Environmental Impact Statement

                                    Kraft Pulp Mills

                             Type of Action:  Administrative

                                       Preoared by
                                                                       (Date)
      Don R. Goodwin
      Director, Emission Standards and Engineering Division
      Environmental Protection Agency
      Research Triangle Park, North Carolina  27711

                                       Approved by


                                                               ^a/22^
                                                                       (Date)
                Administra"tor
I/    Office of Air and Waste Management
      Environmental Protection Agency
      401 M Street, S. W.
      Washington,  D.  C.  20460
       Additional  copies may be obtained at:

       Environmental  Protection Agency
       Library  (MD-35)
       Research  Triangle Park, N.  C.  27711

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                            TABLE OF CONTENTS

                                                                       Page
CHAPTER 1.  SUMMARY	1-1
        1.1  SUMMARY OF CHANGES SINCE PROPOSAL  	  1-1
        1.2  SUMMARY OF THE ENVIRONMENTAL IMPACTS 	  1-3
CHAPTER 2.  SUMMARY OF THE PUBLIC COMMENTS  	  2-1
        2.1  IMPACTS OF THE PROPOSED STANDARDS	2-1
        2.2  EMISSION CONTROL TECHNOLOGY  	  2-9
        2.3  CONTINUOUS MONITORING AND EXCESS EMISSIONS 	  2-21
        2.4  EMISSION TESTING    	  2-30
        2.5  MISCELLANEOUS	2-34
             LIST OF COMMENTERS	2-37
                                    iv

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                               1.   SUMMARY
     On September  24,  1976,  the  Environmental  Protection Agency  (EPA)
 proposed standards of  performance  for  kraft  pulp mills  (41  FR 42012)
 under the authority of section  111 of  the Clean Air Act.   Public comments
 were requested on  the  proposal  in  the  Federal  Register  publication.  Forty-
 two comment  letters were  received  from pulp  and paper industry representatives,
 State air pollution control  agencies,  other  Federal agencies, manufacturers
 and vendors  of pulping equipment,  and  individual U. S.  citizens.  The comments
 that were submitted along with  responses to  these comments  are summarized in
 this document.  This summary of  comments and responses  serves as the basis
 for the revisions which have been  made  to the  standards between proposal and
 promulgation.
 1.1  SUMMARY OF CHANGES SINCE PROPOSAL
 Limits of the Standards
     Four revisions were  made to  the  numerical limits  included in the
 proposed standards of  performance  for  kraft  pulp mills.  The major revision
 is the development of  a separate TRS numerical emission limit of 25 ppm for
 cross recovery furnaces.   The other revisions were basically concerned with
 the method of expressing the emission  limits and are, therefore, considered
minor.
     The first of these other changes  is that in determining TRS emissions
from recovery furnaces and lime kilns, correction of the TRS readings to a
specified excess oxygen concentration is now required in all cases.
     The second change concerns the units of TRS and particulate standards
for smelt dissolving tanks.   The promulgated standards have been revised to
grams per kilogram of black  liquor solids (dry weight).
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     The final  change concerns the TRS standard for lime kiln emissions.
The promulgated standard limits TRS emissions to 8 ppm.
Monitoring and Excess Emissions
     Four revisions have been made to the continuous monitoring requirements
and excess emission allowances.  Two of these revisions  are concerned with
continuous monitoring and two involve excess emission allowances.
     The first revision with regard to continuous monitoring is that
section 60.13 of the General Provisions for Subpart 60 has been amended
so that the TRS and oxygen continuous monitoring requirements will not
become effective until promulgation of performance specifications for
TRS monitors.  The second revision concerns the TRS monitoring requirement
when gases from the digesters, brown stock washers, multiple-effect
evaporators, black liquor oxidation, or condensate stripper are combusted
in a separate incinerator.  The promulgated standards require monitoring
of TRS emissions in some instances as opposed to monitoring of firebox
temperature in all cases.
     The two revisions with respect to the excess emission allowance concern
TRS emissions from recovery furnaces and lime kilns.  The excess emission
reporting requirements for recovery furnaces now include an excess emission
allowance of 1 percent.  The excess emission reproting requirements for lime
kilns, on the other hand, no longer provide an excess emission allowance.
Testing
     Two revisions have been made to Test Method 16.  The method has been
rewritten to allow greater flexibility in the selection of equipment for
use in testing, and correction of the results to account for sampling  loss
and sulfur dioxide interference is now required.
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1.2 SUMMARY OF THE ENVIRONMENTAL IMPACTS
Alternatives to the Promulgated Action
     The alternative control systems are discussed in chapter 4 of the
Standards Support and Environmental Impact Statement (SSEIS, Vol. 1).
These alternative systems are based upon combinations of the best demonstrated
technology, considering costs, for the control of TRS and particulate
emissions at kraft pulp mills.  The analysis of the alternative of
taking no action and of postponing the promulgated action is outlined in
chapter 7 (SSEIS, Vol. 1).  These alternatives remain the same.
Environmental Impact of the Promulgated Action
Primary Impact
     Two changes to the regulation since proposal affect the primary
impact on the reduction of TRS emissions from kraft pulp mills.  The
rationale for these changes is given in chapter 2.  First, a TRS standard
for recovery furnaces which burn combined liquors from neutral sulfite
semi chemical (NSSC) pulping and kraft pulping—normally termed "cross
recovery"--was established at 25 ppm.   The impact of these changes,
however, is expected to be negligible since there.are only 11 cross
recovery furnaces now in operation and very few new cross recovery
furnaces are anticipated during the next ten years.  All other new,
modified, and reconstructed recovery furnaces will be subject to the
standard of 5 ppm.
     Second, the final standard for lime kilns allows 8 ppm of TRS.  The
impact of this change is expected to be negligible since the same control
system will have to be used under the final standard as under the proposed
standard.  The change is based on a revaluation of the same data as was
used to establish the proposed emission limit.
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     Table 1-2 if chapter 1  of the SSEIS,  Vol.  1,  contains  a  summary  of
the environmental impacts associated with  implementation of the proposed
standards.  This matrix will not change as a result of these  two revisions
to the proposed standards.
Secondary Impact
     Table 7-1 of the SSEIS, Vol. 1, presents a summary of the secondary
environmental impacts attributable to the alternative control systems.  These
secondary impacts remain unchanged for the promulgated standards of performance.
Economic  Impact of the Standard
     In accordance with Executive Orders 11821 and 11949 and OMB Circular A-107,
the economic and inflationary impacts of the proposed standard and the alternative
control levels were carefully evaluated.  This economic impact analysis is
contained in chapter 8 of the SSEIS, Volume 1.  Significant comments on this
analysis  and responses to these  comments are presented  in chapter 2 of this
document.  Since the changes which were made to the proposed standard do  not
affect the level of control required, the economic impacts of  the promulgated
standard  and alternative  control  levels are essentially the same as described
for the proposed standard.
Other Considerations
Adverse Impacts
     The  potential adverse  impacts  associated  with these standards are  discussed
 in chapters  1  and  7 of the  SSEIS, Vol.  1.   These  impacts remain  unchanged
 since the regulations  were  proposed.
 Relationship Between  Local  Short-Term  Uses  of  Man's  Environment
 and the Maintenance  and  Enforcement of Long-Term  Production
           This impact  is discussed in  chapters 7  and  9  of  the  SSEIS,  Vol. 1,
 and remains  unchanged  since proposal.
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Irreversible and Irretrievable Commitments  of Resources



     This impact is discussed in chapter 7  of the SSEIS,  Vol.  1,  and



remains unchanged since proposal.
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                   2.  SUMMARY OF THE PUBLIC COMMENTS

     The  list of commenters and their affiliations is shown in Table 2-1.
Forty-two  letters  were received commenting on the proposed standards and Vol. 1
of the Standards Support and Environmental Impact Statement.  The significant
comments  have been combined into the following five major areas:
     1.   Impacts of the Proposed Standards
     2.   Emission  Control Technology
     3.  Continuous Monitoring and Excess Emissions
     4.  Emission  Testing
     5.  Miscellaneous
     The comments  and issues, along with responses to these comments are
discussed  in the following sections of this chapter.  A summary of the
changes to the regulation is included in section 2 of chapter 1.
2.1 IMPACTS OF THE PROMULGATED STANDARDS
Impact on Existing Sources
     Several comments were received from industry representatives, State
agencies and kraft pulp mill operators expressing concern over the impact
of standards of performance on existing sources.  Among the general  areas
of concern were:   (a) the stringency of EPA's guidelines for the control
of existing sources compared to the standards of performance for new sources
and (b) the impact of the standards on modified and reconstructed facilities.
     EPA's guidelines for existing sources under section lll(d) of the Act,
which are to be proposed in the near future,  are in some cases as stringent
as the standards of performance for new sources.  In other cases, however,
higher emission rates are recommended.   The proposed guidelines are  considered
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to be both technologically and economically reasonable based on an analysis



of available emission control  technology and the cost of retrofitting this



technology into existing sources.



     A 60-day comment period is provided to allow the public an opportunity



to comment on the proposed guidelines.   Since TRS emissions have been



determined to be a welfare-related pollutant, States will have considerable



flexibility in establishing regulations limiting these emissions from existing



kraft pulp mills located within their jurisdictions.  In developing their



regulations, States are free to balance the emission guidelines and the



information provided in the guideline document against other factors of



public concern in establishing requirements for specific existing kraft pulp



mills.  Hence, there may be conditions  under which the regulations adopted



by States for existing sources would be more lenient than those included in



the proposed guidelines.



     The specific areas of concern expressed in the comments which were directed



toward the impact of the standard on modified or reconstructed sources were:



(1) that the impact of the standards would curtail modernization and expansion



of existing mills, (2) the extent to which an increase in emissions would



require a modified facility to comply with the standards, and (3) whether the



addition of a batch digester or a change in the fuel fired in a lime kiln



would be considered modifications.



     As most commenters recognized, existing facilities within a kraft pulp



mill will not be subject to the standards unless they are modified or recon-



structed.  Thus, the impact of the standards on various modernization or



expansion projects depends on the extent to which existing facilities within



a kraft pulp mill are modified or reconstructed.  Alteration of an existing
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facility will only be considered a modification  if  emissions  released  to
the atmosphere from the mill taken as a whole  increase  following  the alteration.
Alteration of an existing  facility which  requires an  expenditure  equal  to
50 percent or more of the  total cost of installing  a  new  facility identical
to the altered facility, however, will be considered  a  reconstruction.
     Prior to the proposal of  the standards of performance, the potential
impact of the standards on a variety of possible modernization or expansion
projects within existing kraft  pulp mills was  assessed.   As discussed  in the
Standards Support and Environmental Impact Statement  (SSEIS)  supporting the
proposed standards, with two exceptions,  the economic impact  associated with
requiring each of the modified  or reconstructed  facilities in these projects
to comply with the standards of performance was  considered reasonable.  Con-
sequently, this impact would not affect the overall decision  to modernize
or expand an existing kraft pulp mill.  While  the various projects that were
analyzed are by no means the only ways by which existing  kraft pulp mills
can modernize or expand, they are illustrative of the types of projects that
normally occur.  Consequently,  they are viewed as broadly representative
of modernization or expansion projects in general,  and are considered a
reasonable basis from which conclusions can be drawn regarding the potential
impact of the standards on these projects.
     The two exceptions mentioned above, where the  impact of requiring modified
or reconstructed facilities to  comply with the standards was considered
unreasonable, were modification or reconstruction of the black liquor oxidation
and brown stock washer systems  at existing kraft pulp mills.   These two
exceptions were considered necessary due primarily  to the potential safety
hazard posed by combustion of the high volume-low TRS concentration waste
gases  discharged from these facilities in existing  recovery furnaces that
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were not designed to accommodate these gases.   Furthermore, since the
costs associated with the retrofit of an existing recovery furnace or
installation of a new incinerator to combust these gases could also be
prohibitive, an exemption was included in the proposed standards, and
is also included in the promulgated standards, which recognizes that
there are mills where the existing facility cannot be used to incinerate
the waste gas streams from these facilities.  Consequently, where a
brown stock washer system or black liquor oxidation system is added,
modified, or reconstructed at such a mill, the owner or operator may
request an exemption from the standard until such time as the mill
acquires the capability to successfully incinerate the gases from
these facilities.
     There were a few questions regarding the extent to which an "increase
in emissions" which would subject a modified facility to the new source
performance standards.  As pointed out above, only an increase in emissions
to the atmosphere from a kraft pulp mill taken as a whole is used to judge
the occurrence of a modification.  Therefore, when an existing facility
is altered, if emissions released to the atmosphere from the facility
following the alteration do not increase or if any emissions increase
from the altered facility are balanced off by an emission decrease
elsewhere within an existing kraft pulp mill, the altered facility will
not be considered a modified facility, even where emissions from the
altered facility exceed the standards.
     If an altered  facility is considered a modified facility due to an
increase in emissions of a specific air pollutant, such as TRS or particulate
matter, the facility would only be subject to compliance with the standard
for that specific pollutant.  Therefore,  if an existing lime kiln were
to be modified with a resulting increase  in particulate emissions,  the
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kiln would be subject only to the standard for particulate matter but
not subject to the standard for TRS emissions.  In other words, modification
with regard to one pollutant does not require that the facility meet the
standards for all pollutants.
     With regard to the question of whether the addition of a batch digester
to an existing group of digesters at a pulp mill would be considered a
modification of the digester system, the answer is no.  Since the digester
system is defined in the standards to mean each separate continuous or
batch digester, the addition of a batch digester would be considered as
the installation of a new affected facility, not modification of an
existing facility.  As a result, only the new batch digester would be
required to comply with the standards of performance.
     The situation would be different, however, in the case of black
liquor oxidation systems and multiple-effect evaporator systems.  These
systems are not defined in the standards in terms of each oxidizing
tank or evaporator, but in terms of the system as a whole. Consequently,
installation of additional stages of black liquor oxidation or multiple-
effect evaporation would be considered potential modifications or recon-
structions of these systems, not as the installation of new affected
facilities.
     One commenter suggested that due to energy considerations, a fuel switch
from natural gas to oil in a lime kiln be excluded from consideration as a
modification or reconstruction to encourage a shift from natural gas firing
within existing kraft pulp mills.  A shift from natural gas to oil  is expected
in many existing facilities.  An analysis of this situation, however,
indicates that the costs of controlling particulate emissions from a modified
or reconstructed lime kiln to the level  required by the particulate emission
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 standard is  reasonable.   Consequently,  a  shift  from natural  gas  to  oil  within
 existing lime kilns  will  be  considered  potential  modifications.
 Economic Impact
      Numerous comments were  received  on the  economic impact  of the  proposed
 standards  of performance  for kraft  pulp mills.   In  general,  these comments
 concerned  either  the overall  impact of  the proposed standards  or the  cost
 of specific  emission control  equipment.
      With  regard  to  the overall  impact  of the standards,  the commenters were
 mainly  concerned  about two points:  (a) that the  proposed standards of
 performance  would inhibit further growth  in  the  industry  by  increasing  the
 operating  costs associated with  new mills well beyond those  of well-controlled,
 presently  operating  mills; and  (b)  that the  failure to base  the  economic
 analysis on  the total costs  of all  air, water, noise and other non-revenue-
 producing  investments seriously  understated the full impact  of the  standards
 on  the  industry.
      EPA does  not agree that  the standards will inhibit growth within the
 kraft pulp industry.  The impact of the standards on the capital  and operating
 costs associated  with kraft pulp mills was considered in depth in the SSEIS.
 Because of the relatively small control  costs and a market characterized by
 price inelastic product demand, the resulting impact on return on investment
 is small.  Consequently, the  promulgated standards will  not preclude construction
of new facilities, or modification or reconstruction of existing facilities.
     Although the total  cost of pollution control affects expansion decisions,
all of these costs cannot be attributed  to the standards of performance.  The
impact associated with standards of performance is only due to the additional
emission control  required by these standards  above what is currently required
by existing State and local  air pollution control  regulations.   After all,
in the absence of standards  of performance,  new,  modified, or reconstructed
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facilities would still have to comply with existing control requirements.
Consequently, only the impact resulting from the incremental costs associated
with the additional TRS and particulate emission control required by the
standards of performance above that required by existing State or local
requirements was assessed in developing these standards.
     With regard to the costs associated with specific emission control
technologies, the main concern of the commenters was the cost associated
with maintenance of electrostatic precipitators on recovery furnaces.
As discussed in the SSEIS, however, precipitator manufacturers indicate
that better precipitators can be built at an increase in capital cost of
about 15 percent.  This will significantly reduce the maintenance requirements
to prevent deterioration.  Accordingly, the costs for electrostatic
precipitators on recovery furnaces in the SSEIS were increased to reflect
this conclusion.
Environmental Impact
     Three main areas of concern were expressed by commenters regarding the
potential environmental impacts associated with the standards:  (a) the net
environmental impact of caustic addition to the scrubber on the lime kiln,
(b) the alleged failure of EPA to prepare an Environmental Impact Statement,
and (c) the increased energy usage which would result from compliance with
the standards of performance.
     A number of commenters indicated their belief that the addition of
caustic to the lime kiln scrubber would not reduce the ambient air TRS
concentration levels over that obtained without caustic and would impose a
solid waste penalty.  Therefore, they concluded that caustic was not worth
the increased cost.
     Addition of caustic to the lime kiln scrubber will not significantly
reduce the maximum ambient air TRS concentrations.  As discussed in the SSEIS,
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however, there are two benefits associated with the addition of caustic to
the scrubber which outweigh the small  increase in cost:   a substantial
decrease in the radius of the influence of odors around  a kraft pulp
mill and a significant reduction in nationwide emissions of TRS_ over the
next five years.  With regard to the potential solid waste problem, if
solids filtration and recycle of the scrubbing liquid are used, solid
waste impacts will be negligible.
     One commenter expressed the opinion that the use of Appendix B of the
SSEIS as a cross reference to environmental impact considerations was inconsistent
with EPA's procedures for the preparation of a voluntary Environmental Impact
Statement  (39 FR 37419). This is not true.  The SSEIS is considered a
complete document identifying alternative actions and incorporating an
analysis of environmental impacts associated with these alternatives,
which is the  primary  objective  of Environmental  Impact Statements.
Accordingly,  the SSEIS  is consistent with EPA's  stated policy.
     With  respect to  the  increased  energy consumption which would  result  from
compliance with the standards  of performance,  the  industry was  concerned  that
this would conflict with  the Department  of  Energy's  goal  to reduce total
energy  consumption  in the pulp  and  paper industry  by 14  percent.
     The  standards will  increase the difficulty of  attaining  this  energy
reduction  goal.  This factor was considered in the  analysis of the energy
 impact  associated with the  standards and is discussed in the  SSEIS.   The
 4.3 percent  increase  in energy usage by  kraft pulp  mills is  reasonable,
 however,  in  comparison to the  benefits which would result from the
 corresponding reduction in TRS and particulate matter.
      As discussed in  the section of this chapter concerning emission
 control technology,  the promulgated standards include a TRS numerical  emission
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 limit of 25 ppm for cross  recovery furnaces.   The environmental  impact
 of this  revision is expected  to be minimal  since there are only  eleven cross
 recovery furnaces presently in  operation.   Very few new cross  recovery
 furnaces are projected  for construction  over  the next 10 years.
 2.2  EMISSION CONTROL TECHNOLOGY
      Most of the comments  received regarding  emission control  technology
 concerned the application  of  this  technology  to either lime kilns  or
 recovery furnaces.   A few  comments,  however,  expressed concern with the
 use of the oxygen correction  factor  included  in the proposed standards
 for both lime kilns and  recovery furnaces.  These commenters pointed  out
 that adjusting the  concentration of  particulate matter and TRS emissions to
 10 percent oxygen for lime kilns and  8 percent  oxygen for recovery furnaces
 only when the oxygen concentration exceeded these values  effectively  placed
 more stringent standards on the most  energy-efficient operators.   To  ensure
 that the standard is equitable  for all operators,  these  commenters suggested
 that the measured particulate matter  and TRS  concentrations  should always
 be adjusted  to 10 percent  oxygen for  the lime kiln  and 8  percent oxygen  for
 the  recovery furnace.
      Although  these comments are valid, within  limits, the  lower the
 oxygen concentrations of the gases from any combustion operation,  the
more  energy  efficient the  operation generally is  and  the  lower the gas
volume released.  Requiring a lime kiln or recovery furnace  with a low
oxygen concentration to meet the same emission  concentration as a lime
kiln or  recovery  furnace with a  high oxygen concentration, therefore,
would effectively place a more  stringent emission limit on the kiln or
furnace with the  low oxygen concentration.   Consequently, the promulgated
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standard requires correction of participate matter and TRS  concentrations
to 10 percent or 8 percent, as appropriate, in all cases.
Lime Kiln
     Numerous comments were received regarding the proposed TRS standard
for lime kilns.  In general, these comments questioned:  (a) the basis for
the TRS standard, (b) the numerical emission limit included in the TRS
standard, and  (c) the ability to comply with both the TRS standard and
the particulate emission standard simultaneously.
     More specifically, with regard to the basis for the TRS standard, the
commenters questioned:  (1) whether caustic scrubbing is effective in
reducing TRS emissions from lime kilns, (2) the wisdom of basing the
standard on operations observed at one lime kiln; (3) whether an over-
design  of the  mud washing  facilities at lime  kiln E was responsible for
the  lower TRS  emissions observed at this lime kiln; and (4) the ability of
existing lime  kilns  that might be  affected by the standard  to add caustic
to the  lime kiln  scrubbers  without creating a sodium  imbalance within the
chemicals recovery system.
     The effectiveness of  caustic  scrubbing is  substantiated  by comparison
of TRS  emissions  during brief  periods when caustic was not  being added  to
the  scrubber at lime kiln  E,  with  TRS emissions  during normal  operation
at  lime kiln E when  caustic was  being added to  the scrubber.   These
observations clearly indicated that TRS emissions would  be  higher  if
caustic was  not used in  the scrubber.  The ability of caustic scrubbing
 to  reduce  TRS  emissions  is also substantiated by  the experience  of
 another kraft  pulp mill  which was  able to  reduce TRS  emissions from
 its  lime kiln  from 40-50 ppm to about 20  ppm  merely  by adding caustic to
 the lime kiln  scrubber.   These factors,  coupled with  the emission  data
 showing higher TRS emissions  from those  lime  kilns which employed only
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efficient mud washing and good lime kiln process control, clearly show
that caustic scrubbing does reduce TRS emissions.
     While no other lime kiln in the United States is currently achieving
the TRS emission levels observed at lime kiln E, there is no other lime
kiln in the United States which is using the emission control system
employed at this facility, and upon which the TRS emission standard is
based (i.e. efficient mud washing, good lime kiln process operation, and
caustic scrubbing).  As discussed in the SSEIS, an analysis of the
various parameters influencing TRS emissions from lime kilns indicates
that this system of emission reduction could be applied to all new,
modified, or reconstructed lime kilns and achieve the same reduction in
emissions as observed at lime kiln E.  Section 111 of the Clean Air Act
requires that standards of performance reflect the degree of emission
reduction achievable through the application of the best system of continuous
emission reduction which (taking into consideration the cost of achieving
such emission reduction, and any nonair quality health and environmental
impact and energy requirements) the Administrator determines has been
adequately demonstrated for that category of sources.  Litigation of
standards of performance has resulted in clarification of the term "adequately
demonstrated."  In Portland Cement Association v. Ruchelshaus (486 F. 2nd
375, D.C. Circuit, 1973), standards of performance were viewed by the Court
as "technology-forcing."  While a system of emission reduction must be
available for use to be considered adequately demonstrated, it does not have
to in routine use.  Consequently, the emission control system installed at
lime kiln E is considered "adequately demonstrated" and this system is the
basis for the promulgated TRS standard for lime kilns.
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     The mud washing facilities at lime kiln E are indeed larger than
those at other kraft pulp mills of equivalent pulp capacity.   This
"overdesign" resulted from initial plans of the company to process lime
mud from wastewater treatment.  These wastewater treatment plans were
later abandoned.  Since the quality or efficiency of mud washing has
been shown to be a significant factor in reducing TRS emissions from
lime kilns, the larger mud washing facilities at lime kiln E undoubtedly
contribute to the low TRS emissions observed at this kiln.  With the
data available, however, it is not possible to separate the relative
contribution of these mud washing facilities, from the relative contribution
of good process operation of the lime kiln and caustic scrubbing to the
low TRS emissions observed.
     In those few cases where existing lime kilns will have to comply
with the TRS standard, addition of caustic to the lime kiln scrubber should
not result in a sodium imbalance within the chemicals recovery system.
Some change in  the purge and chemical make-up rates might be required,
but no major problems should arise.  Lime kiln E, for example, was an
existing lime kiln to which caustic scrubbing was a case of retrofit.
No major problems in maintaining  the sodium balance in the chemicals
recovery system were experienced.
     As shown by the continuous monitoring data obtained from  lime kiln E,
TRS emissions occasionally exceeded 5  ppm during  normal  operation.   While
these excursions in emissions  cannot be directly  related to any  specific
parameter,  they are not  the result of  improper operation or maintenance
of either  the emission control  system  or  the  kraft  pulp  mill,  but reflect
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the unavoidable day-to-day variability inherent within the kraft pulping
process.  This variability was reflected in the proposed standard by the
6 percent excess emissions allowance which was included within the
emission monitoring requirements for continuous monitoring of TRS emissions
from lime kilns.
     Although the TRS emission test data gathered from lime kiln E supported
a numerical emission limit of 5 ppm, these data consisted of only one
EPA emission test of lime kiln E and one company emission test of this
facility.  In light of this limited data base and the fact that lime kiln E
is the only facility within the domestic kraft pulp mill industry which
has installed the emission control system selected as the basis for the
standard, the TRS continuous emission monitoring data from lime kiln E
were analyzed to ensure that a numerical emission limit was selected
which was consistent with proper operation and maintenance of this emission
control system on lime kiln E.  This analysis indicated that an emission
source test of lime kiln E could have found TRS emissions above 5 ppm greater
than 5 percent of the time.  This analysis also indicated, however, that
it was very unlikely that an emission source test of lime kiln E would have
found TRS emissions above 8 ppm.  Thus, it appeared that the 5 ppm TRS
numerical emission limit included in the proposed standard for lime kilns
was too stringent.  Accordingly, the numerical emission limit included
in the promulgated TRS standard for lime kilns has been revised to 8
ppm.  As discussed later in this chapter, consistent with this change in
the numerical emission limit, the excess emissions allowance included
within the emission monitoring requirements has been eliminated.
     This does not reflect a change in the basis for the standard.  The
standard is still based on the best system of emission reduction, considering
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costs, for controlling: TRSemissions from lime kilns (i.e., efficient mud
washing, good lime kiln process operation, and caustic scrubbing).  This
system, or one equivalent to it, will still be required to comply with
the promulgated standard.
     Finally, with regard to the ability of a lime kiln to comply with
both the TRS emission standard and the particulate emission standard
simultaneously, caustic scrubbing will tend to increase particulate
emissions due to release of sodium fume from the scrubbing liquor.  Compared
to the concentration of particulate matter permitted in the gases discharged
to the atmosphere, however, the potential contribution of sodium fume
from caustic scrubbing is quite small.  Consequently, with proper operation
and maintenance, sodium fume due to caustic scrubbing would not cause
particulate emissions from a lime kiln to exceed the numerical emission
limit included in the promulgated standard.
     As a number of commenters pointed out, particulate emissions from  lime
kiln E exceeded the numerical emission limit included in the standard.  This
was not due to caustic scrubbing, however, but was due to the low oressure
drop at which the scrubber operated.  As discussed in the SSEIS,  the
standard is based on the  use of a venturi  scrubber with a pressure drop
of 0.076 kg/cm2  (30 in.).  If the scrubber at lime kiln E operated at
this pressure drop, this  kiln would meet both the TRS emission standard
and the particulate emission standard simultaneously.
Recovery Furnaces
     A  number of comments were  received  regarding both the proposed TRS
emission standard and  the proposed  particulate emission standard  for
recovery furnaces.
     With  regard to the  proposed TRS  standard, the  comments* questioned
whether it was  reasonable to expect each  of  the  different  types  of  recovery
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furnaces to meet the proposed TRS numerical  emission limit on a continuing
basis.  Most of the concern expressed in these comments focused on
direct-contact recovery furnaces, older recovery furnaces, hardwood pulp
mill recovery furnaces, and cross recovery furnaces.
     With the exception of cross recovery furnaces, there is no justification
to support separate TRS numerical emission limits for each of the different
types of recovery furnaces mentioned above.  The subject of direct-
contact versus  indirect-contact  recovery furnaces,  for example, was
explored in depth in the Standards Support and  Environmental  Impact
Statement  (SSEIS).  No additional information or data was submitted with
the  comments which  would alter this  assessment  of the ability of  these
two  types  of recovery  furnaces to reduce TRS  emissions to the level of
the  standard.
      With  regard to older  recovery  furnaces,  TRS emission source  test
data obtained  from  recovery  furnaces,  which  had been  in  operation for
some 10 years, were less  than 5  ppm indicating  that this furnace  could
achieve the standard.   As  discussed in the Draft Guideline  Document for
Control of TRS Emissions  from Existing Kraft Pulp  Mills, however, the
 "old design" recovery furnace is usually not able to reduce TRS emissions
 to less than 5 ppm at reasonable cost.  This problem stems  from the
 basic design of these furnaces which inherently leads to higher TRS
 emissions.  Since  this furnace design became outmoded about  1965 there
 should be no major problems associated with reducing TRS emissions from
 new recovery  furnaces of this type.
      Additionally, as discussed in  the previous section dealing  with lime
 kilns, existing  recovery furnaces will only  become subject  to  the TRS
 standard  of performance if  they are modified or reconstructed.   Alteration
 of  an  existing recovery furnace would  have  to  result  in increased TRS
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pulps since both TRS and particulate emissions from the smelt dissolving
tanks are proportional  to the tons of black liquor solids fed into the
tanks.  The black liquor solids produced per ton of air-dried pulp,
however, can vary substantially from mill to mill.  A standard in terms
of emissions per unit of air-dried pulp, therefore, requires greater
control of emissions at kraft pulp mills which use low-yield pulps
(higher solids-to-pulp ratio).  In addition, some commenters were concerned
that air-dried pulp production rates corresponding to particular emission
periods would be difficult to determine.
     After reviewing these comments, it is clear that the format of the
proposed standards was inequitable.  The format of the promulgated
standards, therefore, has been revised to emissions per unit of black
liquor solids fed to the smelt dissolving tanks.  Using the industry
average of 3000 pounds of black liquor solids (dry weight) per ton of
air-dried pulp, the numerical emission limits in the proposed standards
were converted to the units of the promulgated standards.  The promulgated
standards limit TRS emissions to  0.0084 gram per kilogram of black
liquor solids (dry weight) and particulate emissions to 0.10 gram  per
kilogram of black liquor solids (dry weight).  Since the percent solids
and  black liquor flow rate to the recovery furnace is routinely monitored
at kraft pulp mills, the weight of black liquor solids corresponding to
a particular emissions  period will be easy to determine.
Brown  stock washer and  black  liquor oxidation:
     Several commenters  expressed concern about combustion of the  high
volume-low TRS  concentration  discharged  from  brown stock washers and
black  liquor oxidation  facilities in recovery furnaces without facing
a serious risk  of explosions.  As discussed  in  the SSEIS, information
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 obtained from two kraft pulp mill operators indicates that this practice
 is both safe and reliable when it is accompanied by careful  engineering
 and operating practices.   Danger of flashback due to a high  volume of gas
 (low in TRS) being introduced into the recovery furnace is effectively
 eradicated by venting the gases high in the furnace.   Problems arising from
 the introduction of high  moisture content gases into the furnace are also
 eased by not venting the  gases at lower ports and use of a condenser before
 the recovery furnace.   Since some older furnaces do not have the
 capability to accept large volumes  of gases at the higher ports, however,
 the practice may not be safe for  some existing furnaces.   In addition,
 the costs  associated with  the extra  ducts,  providing  corrosion resistance
 and installing a condenser are frequently prohibitive for a  modified or
 reconstructed facility  as  is the  cost of  building  a separate incinerator.
 Consequently,  the proposed and promulgated  standards  include an  exemption
 for new, modified,  or reconstructed  brown stock washers  and  black  liquor
 oxidation  facilities within  existing  kraft  pulp mills  where  combustion
 of  the waste  gases  released  from  these  facilities  is  not  feasible  from  a
 safety or  economic  standpoint.

 2.3 CONTINUOUS  MONITORING AND  EXCESS EMISSIONS
 Continuous monitoring:
     Numerous  comments were  received  concerning  the proposed continuous
monitoring requirements.  Generally,  these  comments questioned:  (a) the
requirement to install TRS monitors in  light of  the absence of performance
specifications for these monitors, (b)  the  usefulness of opacity monitors
and scrubber pressure drop monitors in various situations, (c) the need for
oxygen monitors, and (d) the usefulness of monitoring incineration firebox
temperatures.
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     At the time of proposal of the standards, both EPA and the kraft pulp
mill industry were engaged in developing performance specifications for TRS
continuous emission monitoring systems.  It was expected that this work
would lead to performance specifications for these monitoring systems
by  the time the standards of performance were promulgated.   Unfortunately,
this is not the case.  In a joint EPA/industry effort, the compatibility
of  various TRS emission monitors with Reference Method 16,  which is the
performance test method used to determine TRS emissions, is still under study.
There is little doubt that these TRS emission monitoring systems will be
shown to be compatible with Reference Method 16, and that performance
specifications for these systems will be developed.  Consequently, the
promulgated standards include TRS continuous emission monitoring requirements.
The monitoring equipment, however, will not have to be installed until after
the performance specifications have been proposed and promulgated. To
accomodate this situation, not only for the promulgated standards for kraft
pulp mills, but also for standards of that may be developed in the future
that may also face this situation, section 60.13 of the General Provisions
for Subpart 60 is ammended to provide that continuous monitoring systems
need not be installed until performance specifications for  these systems are
promulgated under Appendix B to Subpart 60.  This will ensure that all
facilities which come under the standards of performance before the
monitoring system performance specifications are promulgated will make
the necessary provisions for and eventually install a continuous emission
monitoring system.
     With regard to the usefulness of opacity and scrubber  pressure drop
monitors, the commenters pointed out that opacity monitors  would not be
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  useful  on  recovery furnaces  equipped  with  scrubbers  to  control  particulate
  emissions,  and  that monitoring  scrubber  liquid  flow  rate  would  be  more
.  convenient  than scrubber pressure drop.
       Opacity  monitoring  is  not  appropriate where  recovery furnaces are
  equipped with scrubbers  to  control  particulate  emissions, due to the
  interference  of moisture present  in the  waste gases  discharged  to  the
  atmosphere.   Accordingly, the promulgated  standards  have  been revised to
  require monitoring of  the pressure  drop  across  the scrubber  in  these
  situations.
       It is  true that monitoring the scrubber liquid  flow  rate would be
  easier  than monitoring the  pressure drop across the  scrubber.   Pressure
  drop, however,  is  a more direct indicator  of proper  operation and
  maintenance of  the scrubber  than  liquid  flow rate.   Consequently,  the
  promulgated standards  require continuous monitoring  of  the scrubber
  pressure drop.
      The promulgated standards also require continuous  monitoring  of oxygen
  in the  waste  gases  discharged to  the  atmosphere.  Since the TRS numerical
  emission limit  is  expressed  in terms  of  concentration and significant
  variations in the  oxygen content  of the  waste gases  discharged  to  the
  atmosphere were  observed among various facilities, any  determination of
  TRS emissions must  be  referenced  to a common basis to make the  results
  meaningful.  This  also precludes  circumvention of the TRS  standards by
  dilution with air  to reduce  the measured TRS emission concentrations.
      Although oxygen monitors are necessary immediately following  the
  recovery furnace and the lime kiln  to permit good process operation
  of these facilities  in order to properly account for the  possibility
  of dilution air  the concentration of oxygen must be determined at  the
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same point as the concentration of TRS emissions.   Consequently,  the
standards may indeed require two continuous  oxygen monitors  in many
cases.
     Concerning the usefulness of monitoring the firebox temperature when
a separate incinerator is employed to control  TRS  emissions  from the
digester, multiple-effect evaporator, condensate stripper, brown stock
washer, or black liquor oxidation systems, a review of the basis for
this requirement indicates the commenters are correct.  Firebox temperature
is only one of the factors influencing TRS emissions and high firebox
temperatures do not necessarily mean low TRS emissions.  Therefore, the
standard has been revised to require continuous TRS emission monitoring
in those cases where interference from other gases is not a problem.  Tempera-
ture monitoring requirements, however, remain for those cases where it is
not feasible to monitor TRS emissions directly.
Excess emissions:
     It was apparent from the comments that were submitted on the proposed
excess emission reporting requirements that a number of commenters did not
understand the concept of excess emissions.   Consequently, a brief review
of this subject is appropriate.
     Standards of performance have two major objectives.  The first is
installation of the best system of emission reduction, considering costs;
and the second is continued proper operation and maintenance of this system
of emission reduction throughout its useful  life.  Since the numerical
emission limit included  in standards of performance is selected to
reflect the performance  of the best system of emission reduction under
conditions of proper operation and maintenance, the performance test,
under  40 CFR 60.8 represents the ability of the source to meet these
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objectives.  Performance tests, however, are often time consuming and
complex, frequently requiring three to four weeks of lead time for
planning and scheduling, a week for the actual testing itself, and two
to three weeks of lag time until the results are available and verified.
Performance tests are also sufficiently expensive, costing from $10,000
to $20,000 per test, to preclude their frequent use.  As a result, while
the performance test is an excellent mechanism for achieving these objectives,
it is rather cumbersome and inconvenient for routinely achieving these
objectives.  Therefore the Agency believes that continuous monitors must
play an important role in meeting these objectives.
     Excess emissions are defined as emissions exceeding the numerical
emission limit included in a standard of performance.  Continous emission
monitoring, therefore, can identify periods of excess emissions and when
combined with the requirement that these periods be reported to EPA, it
provides the Agency with a useful mechanism for achieving the previously
mentioned objectives.
     Continuous emission monitoring, however, will identify all periods
of excess emissions, including those which are not the result of improper
operation and maintenance.   Excess emissions due to start-ups, shutdowns,
and malfunctions, for example, are unavoidable or beyond the control of
an owner or operator and cannot be attributed to improper operation and
maintenance.   Similarly, excess emissions as a result of some inherent
variability or fluctuation within a process which influences emissions
cannot be attributed to improper operation and maintenance, unless these
fluctuations  could be controlled by more carefully attenting to those
process operating parameters during routine operation which have little
effect on operation of the process, but which may have a significant
effect on emissions.
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     To quantify the potential  for excess emissions due to inherent
variability in a process, continuous emission monitoring data are used
whenever possible to calculate an excess emission allowance.  For kraft
pulp mills, this allowance is defined as follows.  If a calendar quarter
is divided into discrete contiguous twelve-hour time periods, the excess
emission allowance is expressed as the percentage of these time periods
excess emissions may occur as the result of unavoidable variability
within the kraft pulping process.  Thus, the excess emissions allowance
represents the potential for excess emissions under conditions of proper
operation and maintenance, in the absence of start-ups, shutdowns, and
malfunctions, and is used as a guideline or screening mechanism for
interpreting the data generated by the excess emission reporting re-
quirements.
     Although the excess emission reporting requirements provide a mechanism
for achieving the objective of proper operation and maintenance of the best
system of emission reduction, this mechanism is not necessarily a direct
indicator of improper operation and maintenance.  Consequently, excess
emission reports must be reviewed and interpreted for proper decisionmaking.
     Each of the excess emission reports submitted at the end of a calendar
quarter will be reviewed.  This review may lead to no action, or it
may lead to a visit  to  the emission source to conduct a preliminary assessment
of the operation and maintenance of the  emission control system.   If
improper operation or maintenance  is suspected, this visit may be  followed
by additional investigation  to document  specific examples of improper
operation and maintenance and a performance test.  Depending on the
results obtained from these  actions, the owner  or operator of the  emission
source may be charged with a violation of the proper operation and
maintenance requirements  included  in the general provisions applicable
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to all standards of performance, and/or a violation of the numerical
emission limit included in the standard of performance.  A performance
test would in most cases be required to support sanctions for violations
of the numerical emission limit, but not necessarily required to support
a violation of the proper operation and maintenance requirements.
     The proposed standards would have required only the reporting of
excess emissions which were the result of start-ups, shutdowns, and
malfunctions, and excess emissions above the excess emission allowance.
This is not consistent with the overall concept of excess emissions, as
discussed above, and the promulgated standards have been revised to
require the reporting of all excess emissions.  In addition to providing
a more complete picture concerning the day-to-day operation of a kraft
pulp mill, this simplifies the excess emission reporting requirements
and interpretation of the data.
     In general, the comments received concerning the excess emission
reporting requirements questioned:  (1) the adequacy of the TRS excess
emission allowance for lime kilns and  (2) the lack of a TRS excess emission
allowance for recovery furnaces.
     With regard to the adequacy of the TRS excess emissions allowance
for lime kilns, an analysis of the TRS emission data from lime kiln E
has led to a revision of the TRS emission standard from 5 ppm to 8 ppm,
as discussed earlier in this chapter.  This analysis also indicates that an
excess emission allowance is not appropriate at a TRS emission level of
8 ppm.  Accordingly, the excess emission reporting requirements included
in the promulgated standard for lime kilns contains no excess emission
allowance.  This does not represent a  change in the basis of the standard.
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The stanard will still require installation of the best system of
emission reduction, considering costs (i.e., efficient mud washing, good
lime kiln process operation, and caustic scrubbing; or an alternative
system equivalent to the performance of this system).
     With regard to the lack of a TRS excess emission allowance for
recovery furnaces, at the time of proposal of the standards, no TRS
continuous emission monitoring data were available from a well controlled
and well operated recovery furnace which could be used to determine
an excess emission allowance.  Several months of TRS continuous emission
monitoring data, however, were submitted with the comments received from
the operator of recovery furnace D concerning this point.
     As discussed in  the SSEIS, recovery furnace D is a straight kraft,
direct-contact  furnace which employs good process operation of the recovery
furnace and good black liquor oxidation facilities to reduce TRS emissions
(i.e., the best system of emission reduction, considering costs).  An
inspection of the TRS continuous emission monitoring system indicated
that it was properly  operated and maintained  and produced an accurate  record
of TRS emissions.  These data,  therefore, were used  to select an appropriate
excess emission allowance.
     K review of the  data indicates  that, while some of the excursions
of TRS emissions above 5 ppm reflected either improper operation and maintenance,
or start-ups, shutdowns, or malfunctions, most of these excursions reflected
unavoidable normal variability  in the operation of a kraft pulp mill recovery
furnace.  Discounting those excursions in emissions  from the data which
were due to improper  operation  and maintenance, or start-ups, shutdowns,
or malfunctions indicates that  an excess emission allowance of 1 percent
is appropriate  at a TRS emission level of  5 ppm.

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     As  discussed  in  the  section  of  this  chapter  concerning  emission  control
 technology,  the  promulgated  TRS standard  for  recovery  furnaces  has  been
 revised  to  include a  separate  numerical emission  limit of 25 ppm for  cross
 recovery furnaces.  A review of the  data  and  information  available  on
 recovery furnaces  in  general indicates  that the excess emission allowance
 developed for  straight kraft recovery furnaces is  also appropriate  for
 cross  recovery furnaces.   Consequently, the excess  emission  reporting
 requirements included in  the promulgated  standards  for all recovery furnaces
 contains  an  excess  emission  allowance of  1 percent.
     Including an  excess  emission  allowance in the  excess  emission  reporting
 requirements associated with the  promulgated  standards for recovery furnaces,
 but not  including  such an  allowance  for lime  kilns,  represents  a  reversal
 of the proposed  requirements.  However, this  reversal  is  consistent with
 the nature of  the  different  emission control  systems which were selected
 as the bases for these standards.  The emission control system  upon
 which the TRS  standard for recovery  furnaces  is based  consists  of black
 liquor oxidation and  good  process  operation of the  recovery  furnace
 for direct recovery furnaces, and  good process operation  alone  for  indirect
 recovery  furnaces.  Neither of these emission control  systems are particularly
well suited to controlling fluctuations in TRS emissions  due to fluctuations
 in the kraft pulping  process.  Thus, fluctuations in the  process  tend to
 pass through the emission control   system and show up as fluctuations  in
TRS emissions.
     The emission control system upon which the TRS standard for  lime kilns
is based consists of efficient mud washing, good process operation  of
the lime kiln,  and caustic scrubbing of the gases discharged from the
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lime kiln.  As with the emission control system upon which the standard
for recovery furnaces is based, the first two emission control techniques
(i.e., mud washing and good process operation) are not particularly
well suited to controlling fluctuations in TRS emissions due to fluctuations
in the kraft pulping process.  The third emission control technique,
however, caustic scrubbing, is an "add-on" emission control  technique
that can be designed to accommodate fluctuations in TRS emissions and
minimize or essentially eliminate these fluctuations.
2.4  EMISSION TESTING
     Most of the comments received concerning the proposed reference
methods for determining TRS and particulate emissions questioned various
aspects of the use of Reference Method 16 and the basis for Reference
Method 17.
Reference Method 16:
     With regard to Reference Method 16 for determining TRS emissions,
the comments questioned:  (1) if equipment other than that specified
in the proposed method could be used to determine emissions; (2) the
costs associated with using Reference Method 16 to determine emissions;
(3) the validity of the results obtained by Reference Method 16, due to
sample losses and sulfur dioxide (SCL) interference; and (4) the need for
measuring the concentration of all reduced sulfur compounds rather than
just the four principle components of TRS.
     The emission measurement system included in the promulgated Reference
Method 16 is the same as that included in the proposed reference method
for determining TRS emissions.  The method has been revised, however, to
permit the use of equipment other than that specified in the EPA emission
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measurement system, provided this equipment employs the same analytical
principles to measure TRS emissions as the equipment included in the EPA
system, and that the alternative emission measurement system meets the
various performance specifications included in the promulgated reference
method.  The promulgated reference method was not revised to permit the
use of an alternate method, however, because the use of alternative methods
is already addressed in 40 CFR 60.8.
     The costs associated with the use of Reference Method 16 to determine
TRS emissions are reasonable and would not be prohibitive for State or local
air pollution control agencies or kraft pulp mills.  For example, the costs
of a performance test to determine emissions from the lime kiln, the recovery
furnace, and the smelt dissolving tanks at a kraft pulp mill using Reference
Method 16 would only be about $10,000 using a competent emission testing
contractor.  If a State or local agency or kraft pulp mill were to purchase
the necessary equipment to do the testing themselves, this would cost about
$15,000.  The cost of operating this equipment, including personnel labor
costs during the test, would probably not exceed $15,000.
     With regard to the validity of the results obtained by Reference Method 16,
as discussed in the section of this chapter concerning emission control
technology, it was not known that sample losses could occur within the
TRS emission measurement system during development of the proposed standard.
Since proposal  of the standards, however, it has been found that sample  losses
of up to 20 percent may have occurred during emission source testing.  Although
these losses were not considered in selecting the numerical  emission  limits
included in the proposed TRS emission standards, they have been  considered
in selecting the numerical  emission limit included in the  promulgated  standards.
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Also, since the amount of sample loss that occurs within the TRS emission
measurement system during source testing can be determined, procedures have
been added to Reference Method 16 requiring determination of these losses
during each source test and adjustment of the emission data obtained to
take these losses into account.  This will ensure that the TRS emission data
obtained during a performance test are accurate.
     It has also been confirmed that high concentrations of SO^ will
interfere with the determination of TRS emissions to some extent.  At
this point, however, it is not known what S02 concentration levels will
result in a significant loss of accuracy in determining TRS emissions.
The ability of a citrate scrubber to selectively remove SCL prior to
measurement of TRS emissions is currently being tested.  In addition,
various chromatographic columns might exist which would effectively resolve
this problem.  As soon as an appropriate technique is developed to
overcome this problem, Reference Method 16 will be amended.
     This problem will not present major difficulties to the use of Reference
Method 16.  Relatively high SCL concentration levels were only observed in
one EPA emission test.  Accordingly, high SCL concentration levels are
probably not a frequent occurrence within kraft pulp mills.  More importantly,
however, high SCL concentrations only interfere with the determination
of methyl mercaptan in the emission measurement system outlined in
Reference Method 16.  Since methyl mercaptan is usually only a small
contributor to total TRS emissions, neglecting methyl mercaptan where
this interference occurs should not seriously affect the determination
of TRS emissions.  Consequently, Reference Method 16 can be used to
enforce the promulgated standards without major difficulties.
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      In  response  to  the  comments questioning  the  need  to determine  the
concentration  of  all TRS emissions,  the definition of  TRS  in  the  promulgated
standards  has  been revised  to  include only hydrogen  sulfide,  methyl mercaptan,
dimethyl sulfide, and dimethyl disulfide.  There  is  no evidence to  indicate
that  kraft pulp mills emit  significant amounts of any  other reduced sulfur
compounds and  this revision will reduce the complexity of  using Reference
Method 16.
Reference Method  17:
     With regard  to  Reference Method 17 for determining particulate matter
emissions from recovery  furnaces, the comments questioned:  (1) the basis
for accepting Reference  Method 17 as equivalent to Reference  Method 5 and
(2) the  inconsistency between Reference 5 and Reference Method 17 regarding
the acceptability of non-isokinetic results.
     While Reference Method 5 was employed to obtain the emission
data supporting the  particulate emission standard for recovery furnaces,
a substantial amount of  comparative data have been collected which
provide a basis for  determining the relationship  between Reference
Method 5 and Reference Method 17.  These data are included in "Comparison
of Source Particulate Emission Measurement Methods a-t Kraft Recovery
Furnace Stacks," Atmospheric Quality Improvement Technical  Bulletin No.
67, National  Council  of  the Paper Industry for Air and Stream Improvement,
Inc., 260 Madison Avenue, New York, New York 10016,  October, 1973.
     In response to the  comments questioning the  inconsistency between
Reference Method 5 and Reference Method 17 regarding the acceptability
of results obtained from non-isokinetic sampling, Reference Method 5
has been amended to be consistent with Reference Method 17.  Guidance
for determining the acceptability of results  obtained from non-isokinetic
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sampling may be obtained by writing to Don R. Goodwin, Director, Emission
Standards and Engineering Division, Mail Drop 13, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711.

2.5  MISCELLANEOUS
     There were numerous minor questions, requests for clarification, and
suggestions submitted by the commenters.  All were given proper consideration.
The most significant of these miscellaneous comments concerned the following
issues:  (1) the U.S. Supreme Court settlement involving International Paper
Company, the State of New York, and the State of Vermont; (2) the effects of
the standards on further technological development; (3) the possibility of
separate standards for kraft pulp mills located in remote areas; and
(4) the applicability of the existing fossil  fuel-fired steam generator
standards of performance to kraft pulp mills.
     The agreement of settlement between the State of Vermont, the State of
New York, and International  Paper Company (IPCO), which was  approved by the
U.S. Supreme Court on October 29, 1974, stated that EPA could not use the
emission limitations agreed upon between the involved parties as a basis for
"emission regulations with respect to the bleached kraft pulp and paper
industry."   One commenter stated that this  agreement is being circumventing
by making reference to the IPCO mill  in the SSEIS and requested that these
references  be removed.
     The agreement has not been circumvented.  The references were
included for completeness only and no information or emission data from
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the IPCO mill was used in developing either the proposed or the promulgated
standards of performance for kraft pulp mills.
     A few commenters were concerned that the standards of performance might
stifle further technological progress within the kraft pulp industry.  These
commenters were under the mistaken impression that the standards specified
the use of certain technology.  As a result, they recommended that the
standards merely specify emission limitations.
     This is, in fact, all that standards of performance specify, a reduction
of emissions to certain levels.  In developing the numerical emission limits
included in standards of performance, each of the alternative control systems
which could be used to reduce emissions is studied.  Based on this analysis,
one or more of these systems are selected as the best system of emission
reduction, considering costs.  This system then serves as the basis for the
standard of performance.  While the capability of this system to reduce
emissions establishes the numerical emission limit included in the standard,
the standard does not require the use of this emission control system, only
the reduction of emissions to the specified emission levels.
     With regard to the possibility of separate standards of performance
for kraft pulp mills located in remote areas, section 111 does not provide
flexibility to develop standards of performance which would vary with
geographic location.  One of the primary objectives of the Congress
in section 111 is to prevent the emergence of new air pollution problems by
requiring the installation of the best systems of emission reduction in all
cases.  Separate standards for remote sources of air pollution would not be
consistent with this objective.
     Following proposal of standards of performance for kraft pulp mills, the
existing standards of performance for fossil fuel-fired steam generators were
                                     2-35

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amended to limit emissions from units firing wood residue or wood residue in
combustion with other fossil  fuels.   Consequently, new, modified, or reconstructed
fossil fuel-fired steam generators within kraft pulp mills firing greater
than 73 megawatts (250 million Btu per hour) of gas, oil, coal, wood residue,
or any combination of these fuels will be subject to compliance with these
standards.
                                     2-36

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                         TABLE 2-1           '                 ••   ..
            LIST OF COMMENTERS ON THE PROPOSED
            STANDARDS OF PERFORMANCE FOR KRAFT
       PULP MILLS - SEPTEMBER 24, 1976 (41 FR 42012)
    COMMENTER AND AFFILIATION
E. V. Fitzpatrick - EPA Region I
Harold E. Hodges - Dept. of Public Health, State of Tennessee
George H. Whiteside - Container Corp. of America
John Robinson - Kirby Lumber Co.
V. J. Tretter - Georgia-Pacific Corp.
James E. Walther - Crown Zellerbach Environmental Services
J. W. Klein - Longview Fibre Co.
Joseph R. Rippee - Potlatch Corp.
Paul M. Utterback - Babcock & Wilcox
Harry H. Hovey, Jr. - N. Y. State Dept. of Environmental
                      Conservation
W. R. Meyer - State Air Control Board, Commonwealth of Virginia
James K. Hambright - Dept. of Environmental Resources, Commonwealth
                     of Pennsylvania
C. W. Conaway - Industrial Risk Insurers
Mike Trykoski - Commonwealth Edison
Boris J. Osheroff - Public Health Service, DHEM
S. J. Kruger - The Buckeye Cellulose Corp.
C. Neal Carter, Ph.D. - P. H. Glatfelter  Co.
Jerry M. Stubberfield - Air & Water Pollution Control Commission,
                        State of Mississippi
Sidney R. Caller - U.S. Dept. of Commerce
Joseph Kolberg - Boise Cascade/Paper Group
                            2-37

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                     TABLE 2-1  (cont.)
       COMMENTER AMD AFFILIATION
Steven K. Starkey - Private Citizen
Sergio F. Galeano, Ph.D. - Owens-Illinois
Michael J. Gannam - Attorney at Law, Savannah, Georgia
H. R. Emery - St. Regis Paper Co.
James A. McColman - Division of Environmental Management,
                    N. C. Dept. of Natural & Economic Resources
C. M. Williams - Brown Co.
Paul E. Trout - Container Corp. of America
Larry Weeks - Hoerner Waldorf Corp.
C. R. Duffie - Willamette Industries
T. C. Payne - International Paper Co.
C. R. Calkins - American Paper Institute, Inc.
Russell E. Kross - The Mead Corp.
Francis J. Milotich - Scott Paper Co.
Richard C. Wigger - Champion International
Russell 0. Blosser - National Council of the Paper Industry for
                     Air & Stream Improvement, Inc.
Robert H. Collom, Jr. - Dept. of Natural Resources, State of Georgia
James W. Cooper - Alabama Air Pollution Control Commission
Leslie Carothers - EPA Region I
David Lutrick - Ekono Inc.
Peter E. Wrist - Mead
J. C. Cuthbertson - American Can Co.
                              2-38

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                                  TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
1. REPORT NO.
  RPA-^5Q/2-76-Q14b
                                                          3. RECIPIENT'S ACCESSIOI»NO.
4. TITLE AND SUBTITLE     •     -.        '
  Standard Support and Environmental  Impact btatement
  Volume ii: Promulgated Standards of Performance For
  Kraft Pulp Mills
             5. REPORT DATE
              December 1977
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                          8. PERFORMING ORGANIZATION REPORT NO.
9 PERFORMING ORGANIZATION NAME AMD ADDRESS
   Office of Air Quality Planning and Standards
   Environmental Protection Agency.
   Research Triangle Park, North Carolina 27711
                                                           10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
12 SPONSORING AGENOY-NAME AND ADD.RESS
  DAA for Air Quality .Planning and Standards
  Office of Air and .Waste Management
  U. S. Environmental Protection Agency.
  Research Triangle Park, North  Carolina 27711
                                                           13. TYPE OF REPORT AND PERIOD COVERED
             14. SPONSORING AGENCY CODE
                EPA/200/04
15. SUPPLEMENTAR-Y NOTES           -                             .      , " ,   ,--,»
  Volume 2 summarizes  the public comments on the proposed  standards, EPA responses,
  and a discussion of  differences between the Proposed  and Promulgated Standards.
16. ABSTRACT
   Standards of performance for the control of emissions  of total reduced_
   sulfur (TRS) and particulate matter from new and modified kraft pulp mills are
   being promulgated under the authority of section 111 of_the Clean Air Act. -TRS
   emissions from kraft  pulp mills are extremely odorous, and there are numerous
   instances of poorly controlled_mills creating public odor problems.  The
   promulgated standards will prevent odor problems from  most newly .constructed kraft
   pulp mills, except  in the immediate vicinity of the mills on occasions when
   meteorological conditions produce downwash of stack.plumes.  Particulate matter
   emissions from, new  mills will be reduced by more than  99 percent below.the levels
   that would result from no control and more than 50 percent below the average State
   standards.  Emissions of TRS will be reduced by more_than 95% below the uncontrolled
   levels and more  than  80 percent below the average  levels for existing sources.  An
   analysis of the  significant .changes in the environmental and economic effects
   associated with  the promulgated standards is included  in this document.
17.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                        c.  COSATI Field/Group
   Air Pollution
   Pollution Control
   Standards of performance
   Kraft pulp mills
   Total reduced .sulfur
   Particulate matter
  Air pollution control
18. DISTRIBUTION STATEMENT
   Unlimited
                                              19. SECURITY CLASS (ThisReport)

                                                Tfriol a.Q.Qi f"i prl	
                           21. NO. OF PAGES
                                 47
20. SECURITY CLASS (Thispage)
                           22. PRICE
                                                Unclassified
EPA Form 2220-1 (3-73)

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