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
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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
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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.
-------
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
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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.
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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
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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.
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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
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21. NO. OF PAGES
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EPA Form 2220-1 (3-73)
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ENVIRONMENTAL PROTECTION AGENCY
General Services Division (MD-28)
Office of Administration
Research Triangle Park, North Carolina 27711
POSTAGE AND FEES PAID
ENVIRONMENTAL PROTECTION AGENCY
EPA-335
OFFICIAL BUSINESS
AN EQUAL OPPORTUNITY EMPLOYER
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PUBLICATION NO. EPA-150/2-76-014b
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