United States
Environmental Protection
Agency
Office of Air Quality EPA-4567R-01 -002
Planning and Standards September 2001
Research Triangle Park, NC 27711 www.epa.gov/ttn/atw/pulp/pulppg.html
Pulping and Bleaching System NESHAP
for the Pulp and Paper Industry:
A Plain English Description
-------
Disclaimer
The Office of Air Quality Planning and Standards of the U.S. Environmental Protection Agency
has approved this document for publication.
•
When using this document, remember that it is not legally binding and does not replace the
National Emission Standard for Hazardous Air Pollutants (NESHAP)for Source Category:
Pulp and Paper Production (April 15,1998, 63 FR 18504) for purposes of application of the rule
to any specific mill.
This document is not intended, nor can it be relied upon, to create any rights enforceable by any
party in litigation with the United States. The EPA may change this document at any time
without public notice.
Amendments to the Cluster Rule have been promulgated and are posted on the Technology
Transfer Network (TTN) at \vww.epa.gov/ttn/atw/pulp/pulppg.html. You should periodically
check this website for amendments and/or other relevant information.
11
-------
Contents
Page
Chapter 1 -
Introduction
Chapter 2 -
Description of
the Pulping and
Bleaching
Processes
1.1 What does this document do? 1
1.2 Why do I need this document? 2
1.3 How should I use this document? 3
1.4 What are the Pulp and Paper "Cluster Rules"? 4
Figure 1. Types of Mills Covered Under the Cluster
Rules 4
Figure 2. Comparison of the Re\ ised Final
Subcategories with Previous Subcategories ... 7
1.5 What is the purpose of the Pulp and Paper NESHAP0 8
Figure 3. Highest Emitted Hazardous Air Pollutants
from Pulp and Paper Mills 8
1.6 Hem many sources does the NESHAP affect0 10
Figure 4. Location of Pulp and Paper Mills • 10
1." \Vha; if 1 have questions0 : . . . 11
1.8 Ho\\ do I get addinonal copies of this document0 11
1.9 Where can I find additional information about this NESHAP? 12
1.10 Where can I find additional information on the pulp and paper industry? 14
2.1 What distinguishes the types of mills that manufacture pulp and paper? . 15
Figure 5. Chemical Pulping Process Differences 16
2.2 What is the kraft pulping process? 17
Kraft digesting process 17
Figure 6. Example Overview of a Kraft Pulping Mill with
a Papermaking System 18
iii
-------
Contents (Continued)
Page
Kraft pulp processing steps 19
Figure 7. Brown Stock Washing System (Rotary Vacuum) 20
Evaporator system 21
Oxygen delignification system 21
Gas collection systems 22
Figure 8. Typical Oxygen Delignification System
(Medium Consistency) 23
Condensate stripping 24
2.3 What is bleaching? 25
Figure 9. Example Bleaching Line 26
Bleaching chemicals ' 2~
Bleaching mixers 28
Bleaching retention towers 28
Bleached pulp washers 28
What is pulp preparation and papermaking? 29
2.4 Soda mills :•(''
2.5 Sulfite mills '•'•.
Figure 10. Example Sulfite Pulping System 32
2.6 Semi-chemical mills -•
Figure 11. Example Semi-chemical Pulping Svsterr, .. 3-
2.7 Mechanical, secondary fiber, and non-wood fiber pulp mills 35
Mechanical pulping : 35
Secondary fiber pulping 35
Non-wood fiber pulping 36
2.8 References for Chapter 2 37
IV
-------
Contents (Continued)
Chapter 3 -
Overview of the
Pulp and Paper
NESHAP
Chapter 4 -
NESHAP
Requirements
for Kraft Mills
Page
3.1 Which mills are subject to the NESHAP? 38
3.2 What processes and equipment systems must be controlled? 39
Figure 12. Equipment Systems Covered by the
Pulping Vent Standards 40
3.3 What are the emission control requirements? 41
Figure 13. Alternative Emission Limits 42
3.4 What control systems will mills typically use to meet the emission
limits? 43
3.5 How do mills demonstrate initial and continuous compliance? 44
Figure 14. What Pollutants or Surrogates Must
Be Measured0 46
3.6 When must mills comph0 47
3." What additional requirements apply to new sources0 48
5.S What is a new source? 49
4.; Standards for kraft pulping system vents 52
What kraft pulping system vents must be controlled0 52
What are the emission limits for kraft pulping system vents? 53
What does the NESHAP require for enclosures and closed-vent systems? 54
When must mills comply with the kraft pulping vent standards? 55
How does a mill demonstrate initial compliance with the kraft
pulping system vent standards? 56
Figure 15. How Does a Mill Demonstrate Initial
Compliance with the Kraft Pulping
System Vent Emission Limits? 56
How does a mill demonstrate continuous compliance with the
kraft pulping system vent standards? 57
-------
Contents (Continued)
Page
Figure 16, How Does a Mill Demonstrate Initial and
Continuous Compliance with the
Closed-Vent Systems Standard? 57
Figure 17. How Does a Mill Demonstrate Continuous
Compliance with the Kraft Pulping
System Vent Emission Limits? 58
Must a mill comply at all times? 59
4.2 Standards for kraft pulping process condensates 60
What is a condensate and why control it? 60
What kraft pulping condensates must be controlled? 60
Does the mill have to collect all those streams? 61
What are the control requirements? 6!
What does the NESHAP require for condensate closed
collection systems? 62
When must a mill be in compliance0 63
Ho\v does a mill demonstrate initial compliance for kraft pulping process
condensate standards? 64
Figure 18. How Does a Mill Demonstrate Initial
Compliance with Kraft Pulping Condensate
Emission Limits? 65
Hovv does a mill demonstrate continuous compliance \\ith
pulping process condensate standards? . 6:-
Figure 19. How Does a Mill Demonstrate Continuou
Compliance with Kraft Pulping Process
Condensate Emission Limits? <>
Must a mill comply at all times? 6
4.3 Standards for the kraft bleaching system vents 68
What bleaching emission points must be controlled? 68
Are there any exemptions to the bleaching requirements? 68
What are the control requirements for chlorinated HAPs? 69
What are the control requirements for chloroform? 69
When must bleaching systems comply? 70
How does a mill demonstrate initial compliance with the
bleaching standards? 71
VI
-------
Contents (Continued)
Page
Chapter 5 -
NESHAP
Requirements
for Semi-
Chemical and
Soda Mills
How does a kraft mill demonstrate continuous compliance with
the bleaching standards? 72
Figure 20. How Does a Kraft Mill Demonstrate
Continuous Compliance with Emission
Limits for Chlorinated HAPs? 73
4.4 Clean condensate alternative for HVLC vents 75
Which equipment systems can be used to generate the emission reductions7^
What emission reductions are creditable? 76
Can a mill use the CCA for only part of the emission reduction requirement
for the HVLC system? 76
Hovv does a mill use the CCA? 77
How does a mill demonstrate initial compliance? 78
How does a mill demonstrate continuous compliance0 78
What approvals are required to use the CCA? 78
4.5 Hou do the requirements for the NSPS and the NESHAP compare0 79
Figure 21. Comparison of NESHAP and NSPS Alternative
Emission Limit(s) Requirements 80
5.: Standards for semi-chemical and soda pulping system vent standards ... 82
What pulping system vents must be controlled0 82
V ;...: are the emission limits for semi-chemical and soda pulping system
\ents° 83
What does the NESHAP require for enclosures and closed-vent systems at
semi-chemical and soda mills? 84
When must mills comply with the semi-chemical and soda pulping process
standards0 ' 85
How does a mill demonstrate initial and continuous compliance with the
pulping system vent standards? 85
Must a mill comply at all times? 85
5.2 Standards for bleaching system vents at semi-chemical and soda mills . . 86
Semi-chemical mills . 86
Soda mills 86
vn
-------
Contents (Continued)
Page
NESHAP " 6>1 Standards for sulflte PulPin8 system vents 88
NtfcHAK ^^ sulfite puipjng system vents must be controlled? 88
What are the emission limits for sulfite pulping system vents? 89
Sulflte Mills what does the NESHAP require for enclosures and closed-vent systems? 90
When must mills comply with the sulfite pulping process requirements? 91
How does a mill demonstrate initial compliance with the sulfite pulping
system vent standards? 91
How does a mill demonstrate continuous compliance with the
sulfite pulping system vent standards? 92
Figure 23. How Does a Mill Demonstrate Initial and
Continuous Compliance with
the Closed-Vent Systems Standard0 92
Figure 24. How Does a Mill Demonstrate Continuou
Compliance with the Sulfite Pulping S\ stem
Vent Standards? . 9?
6.2 Standards for sulfite bleaching system vents *W
When must sulfite bleaching systems comply? 94
Chapter 7- ... „ , , . ,. , .
KIPQUAP Standards tor bleaching system vents
_ . What mechanical, secondary fiber, and non-wood fiber bleachim: >\
Requirements . - ..
. emission points must be controlled/ . . v:
' Are there any exemptions to the bleaching requirements?
C-K Ji M What are the control requirements for chlorinated HAPs? . . 9'
,' ^-L n T V, hen must mechanical, secondarv1 fiber, and non-wood fiber hi, ;, ,nn.
wood Fiber Pulp systems comply-
How does a mill demonstrate initial compliance with the
bleaching standards? Q~
How does a mill demonstrate continuous compliance with the bicacn;.,.
standards? 98
Figure 25. How Does a Kraft Mill Demonstrate
Continuous Compliance with Emis>
Limits for Chlorinated HAPs? . . .
99
via
-------
Contents (Continued)
Chapter 8 -
Other Federal
Regulations
Affecting Pulp
and Paper Mills
Appendices
Page
8.1 What other Federal air regulations affect the pulp and paper industry? . 101
8.2 What other Federal water regulations affect the pulp and paper industry?! 03
Figure 26. A Guide to the Acronyms for
Technology-Based Water Standards '105
Figure 27. Applicability of Technology-Based
Standards 106
8.3 What Federal hazardous wastes regulations affect the pulp and paper
industry ? 107
8.4 What upcoming regulations will affect pulp and paper mills? 109
A:
B:
C:
D:
E
F:
G:
H:
I:
J:
List of U.S. Pulp and Paper Mills
NESHAP for Source Category: Pulp and Paper Production
Flowchart Summary of the NESFIAP
L IST of EPA Region Office Contacts
Equipment Diagrams for Pulp and Paper Mills
Li^t of Equipment Affected by the NESHAP
Pulp and Paper NESFIAP Control Requirements
Compliance Milestones Timeline for Existing Sources
Summary of Effluent Limitations Guidelines for Bleached
Papergrade Kraft Mills
Inspection Checklists
IX
-------
Chapter 1 - Introduction
Subpart MM
establishes emission
limits for gaseous
organic and metal
HAP for chemical
recovery processes
that involve the
combustion of spent
pulping liquor at
kraft, soda, sulfite,
and semi-chemical
pulp mills.
This document does
NOT replace the
NESHAP for purposes
of making legal
interpretations'.
The U.S. Environmental Protection Agency (EPA) has published two
National Emission Standards for Hazardous Air Pollutants (NESHAP) for
the Pulp and Paper Industry:
40 CFR 63, Subpart S was published on April 15, 1998, and
applies to the pulping and bleaching systems at all chemical
pulping mills and bleaching systems at mechanical pulping,
non-wood fiber, and secondary fiber mills.
40 CFR 63, Subpart MM was published on January 12, 2001
and applies to chemical recovery processes that involve the
combustion of spent pulping liquor.
These NESHAP require affected sources to control hazardous air pollutant
(HAP) emissions using the maximum achievable control technology
(MACT).
Subpart S was published as part of the Pulp and Paper Cluster Rules and
affects the pulping and bleaching systems at major sources that chemically
and nonchemically pulp wood and non-wood fibers for pulp and paper
production. The Cluster Rules also revised the effluent limitations
guidelines and standards under the Clean V/ater Act for pulp mills that
make bleached papergrade products.
1.1 What does this document do?
Thi> document focuses on the pulping and bleaching system NESHAP
i Subpart S) and describes:
• the pulping and bleaching processes
• the requirements of the NESHAP
• the scope of effluent limitations guidelines and standards
revisions
• additional references and sources of information about pulp
and paper mills
-------
1.2 Why do I need this document?
You need this document because it will help you understand the NESHAP.
Implementation of the pulp and paper NESHAP is complex for both
affected mills and regulators because:
• There is a tremendous amount of variability in the pulp and.
paper industry with respect to processes, equipment, and
products. For example, the task of turning wood into pulp is
performed by different processes using different equipment
and different chemicals at kraft mills, sulfite mills, and
mechanical pulping mills. As a result, different emission
points must be controlled at each type of mill.
• The NESHAP allows for a significant amount of flexibility
in the control strategies used to reach compliance.
• The timelines for compliance vary for different parts of the
mill.
• More stringent control requirements apply to some new
sources.
• Technical requirements for some of the^available control
strategies will be specified on a mill-by-mill basis by the
implementing agency.
Chapter 1 - Introduction
-------
1.3 How should I use this document?
If you are familiar with the pulping and bleaching processes, there is no
need to read Chapter 2. You should skip ahead to Chapter 3. Everyone
should read Chapter 3 as it provides the overview of the NESHAP. After
reading Chapter 3, you should decide what other sections of the document
you need.
If YOB N«ed the Foilowiag Information.,.
TbeaReadL.
A description of the Cluster Rules
A description of pulping and bleachirig processes
An overview of the NESHAP
A description of how new source requirements
apply
NESHAP requirements for kraft mills
NESHAP requirements for soda and semi-
chemical mills
NESHAP requirements for sulfite mills
NESHAP requirements for mechanical, secondary
fiber, and non-wood fiber pulp mills
A description of other existing and upcoming
FcJi-rJ regulations affecting pulp and paper mills
A list of pulp and paper mills
A cop;, ,: :he NESHAP
Flowchart summary of the NESHAP
A list of EPA Regional Office contacts
Equipment diagrams
A list of equipment affected by the NESHAP
A summary of the NESHAP control requirements
A timeline of compliance milestones
Summary of effluent limitations guidelines and
standards for bleached papergrade kraft mills
Chapter 1
Chapter 2
Chapter 3
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Chapter 8
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Chapter 1 - Introduction
-------
Stay informed about
new or revised
requirements by
visiting "What's New"
pages of the OECA
and Air Toxics
Websites:
http://es. epa.gov/
oeca/wn2.html
and
http://www. epa.gov/
ttn/atw/atwnew.html
1.4 What are the Pulp and Paper "Cluster Rules"?
The Cluster Rules are a simultaneous publication of Federal air and water
pollution control regulations. They are an example of the EPA's efforts to
simplify compliance by coordinating the regulation of multimedia industrial
pollution and will reduce both air and water pollutant discharges. You can
get an electronic copy of the Cluster Rules from the Federal Register
website at http://www.access.gpo.gov/su_docs/aces/acesl40.html or the
EPA Air Toxics website at http://www.epa.gov/ttn/atw on the Rules and
Implementation Page.
The goals of this coordinated regulatory approach are to:
• provide greater protection of human health and the
environment
• reduce the overall cost of complying with wastevvater
regulations and air emissions controls
• promote and facilitate coordinated compliance planning by
the industry
• promote and facilitate pollution prevention
• emphasize the multimedia nature of pollution control
Figure 1 identifies the mill types covered under the Cluster Rule-.
Appendix A lists the mills potentially affected by the Cluster Rule.- K;
facility name and location.
Figure 1.
Types of Mills Covered Under the Cluster Rules
Then it is Subject to Th«* Parts of the Cluster Rules,,.
If tfeeMJHb^fe Type...
Kraft
Soda
Sulfite
Semi-Chemical
Mechanical
Non-Wood Fiber
Secondary Fiber
NESHAP
X
X
X
X
X
X
X
Revised Effluent Urr'iaii.nv
Gflideiines and Standard*
Bleached Papergrade only
Bleached Papergruie onK
Papergrade onK
Chapter 1 - Introduction
-------
The features of the
NESHAP are:
•Alternative emission
limits
• Varying compliance
periods (3-8 years)
• New and existing
source controls
• Flexibility for
evolving
technologies
• Compliance dates
coordinated with
effluent limitations
guidelines and
standards
The Cluster Rules consist of the following two components:
(1) National Emission Standards for Hazardous Air Pollutants
(NESHAP) from the Pulp and Paper Industry
(40 CFR 63, Subpart S). The pulp and paper NESHAP specifies
emission standards for pulping and bleaching systems at all chemical
pulping mills and bleaching systems at mechanical pulping, non-
wood fiber, and secondary fiber mills.
The air emissions control standards require mills to reduce
hazardous air pollutant emissions through the use of thermal
oxidizers, boilers, lime kilns, recovery furnaces, caustic scrubbers,
or other control devices, or process modifications. In general, the
NESHAP requires mills to:
• collect and incinerate pulping process vent emissions
• collect and control bleaching process vent emissions
with a caustic scrubber
• eliminate the use of certain bleaching chemicals
• collect and treat process condensate streams to
remove HAPs (kraft mills only)
The XESHAP is written to encourage pollution prevention
techniques. See Appendix B for a copy of the NESHAP and .
Appendix C for a flowchart summary of the NESHAP.
This NESHAP does NOT address emissions from chemical recover.
process combustion sources. Emissions from these sources are
covered by 40 CFR 63, Subpart MM. which was promulgated on
January 12. 2001 (66 FR 3180).
Chapter 1 - Introduction
-------
Stay informed
about new or
revised
requirements by-
visiting the EPA
Office of Water's
Pulp and Paper
Website:
http://www.epa.
gov/ost/pulppaper/
(2) Effluent Limitations Guidelines and Standards, Pretreatment
Standards, and New Source Performance Standards for the Pulp,
Paper, and Paperboard Category (40 CFR 430, Subparts A-L).
These regulations control discharge of pollutants in waste waters
generated at pulp and paper mills. The pretreatment standards apply
to mills that discharge waste.water to a municipal wastewater
treatment facility (i.e., Publicly Owned Treatment Works or POTW).
The effluent limitations guidelines and standards are applied to the
mills that directly discharge into receiving water via the National
Pollution Discharge Elimination System (NPDES) permit program.
In addition, the effluent limitations guidelines and standards portion
of the Cluster Rules:
• Includes best management practices (BMP)
regulations for a portion of the pulp, paper, and
paperboard industry. The BMP rules are designed to
prevent or contain leaks and spills of pulping liquor.
soap, and turpentine, and to control any intentional
diversions of these substances.
• Specifies new analytical methods for twelve
chlorinated phenolic pollutants and for adsorbable
organic halides (AOX).
• Revises the subcategorization scheme for existing
effluent limitations guidelines and standards for thi
pulp and paper industry (shown in Figure 2 . and
revises the effluent limitations guidelines an j
standards for Bleached Papergrade Kraft and Sodi.-
subcategory (Subpart B) and the Papergrade Sulfiu:
subcategory (Subpart E). The EPA revised the
subcategorization scheme to better define the
processes typically found in U.S. mills.
• Includes the Voluntary Advanced Technology
Incentives Program which is designed to encourage
direct discharging bleached papergrade kraft mills to
install more pollution prevention technology than
required by the regulations.
Chapter 1 - Introduction
-------
Figure 2.
Comparison of the Revised Final
Subcategories with Previous Subcategories
Fiwtf Fi»«lk ,
Subpttt Scheme
A Dissolving Kraft
Ba Bleached Papergrade Kraft and Soda
C Unbleached Kraft
D Dissolving Sulfite
E Papergrade Sulfite
F Semi-Chemical
G Mechanical Pulr
H Non-Wood Chemical Pulp
I Secondary Fiber Demk
J Secondary FIDS: Non-Demk
K Fine and Lightweight Papers from Purchased Puip
L Tissue. Filter. Non-Woven, and Paperboard from
Purchased Pulp
TKVHIUD SnhcatevorizafioH
4i Cftfc&S&ibpar&Ndfed: « PartHtliettS
Dissolving Kraft (F)
Market Bleached Kraft (G)
BCT Bleached Kraft (H)
Fine Bleached Kraft (I)
Soda(P)
Unbleached Kraft (A)
Linerboard
Bag and Other Products
Unbleached Kraft and Semi-Chemical (D, V)
Dissolving Sulfite (K)
Nitration
Viscose
Cellophane
Acetate
Papergrade Sulfite (J.U)
Blow Pit Wash
Drum Wash
Semi-Chemical (B )
Ammonia
Sodium
G\V-Thermo-Mechanical (M)
GW-Coarse. Molded. News (N:)
GW-Fine Papers (O)
GW-Chemical-Mechanical (L)
Miscellaneous mills not covered by a specific subpart
Deink Secondary- Fiber (Q)
Fine Papers
Tissue Papers
Newsprint
Tissue from Wastepaper (T't
Paperboard from Wastepaper (E'i
Corrugating Medium
Non-Corrugating Medium
Wastepaper-Molded Products (Wj
Builders' Paper and Roofing Felt
(40 CFR Part 43 1 Subpart A)
Non-Integrated Fine -Papers (R)
Wood Fiber Furnish
Cotton Fiber Furnish
Lightweight Papers (X)
Lightweight Papers
Lightweight Electrical Papers
Non-Integrated
Tissue Paper (S)
Filter and Non-Woven (Y)
Paperboard (Z)
8 Revised under the Cluster Rules.
Chapter 1 - Introduction
-------
A major source is a
stationary source that
has the potential to
emit 10 tons per year
of any one HAP or
25 tons per year of
total K4Ps.
1.5 What is the purpose of the Pulp and Paper
NESHAP?
The purpose of this NESHAP is to reduce HAP emissions from the pulp and
paper industry, thus reducing public health hazards. The EPA regulated this
industry because pulp and paper mills are major sources of HAP emissions
listed in Section 112 of the Clean Air Act (CAA). Section 112(d) of the
CAA directs EPA to set maximum achievable control technology (MACT)
standards for major stationary sources. MACT standards are technology-
based emission limitations that require the maximum degree of emission
limitations that is achievable considering cost, human health,
environmental, and energy impacts.
Pulp and paper mills emit 240,000 tons of HAPs annually that impact both
air quality and public health. The pulp and paper NESHAP will reduce
1996 emissions of HAPs from pulp and paper facilities by 153,000 tons per
year (a 64 percent reduction). Figure 3 lists the HAPs emitted in the largest
quantities from pulp and paper mills.
Figure 3.
Highest Emitted Hazardous Air Pollutants
from Pulp and Paper Mills
Hazardous Air Pollutants
Acrolein
Acetaldehyde
o-Cresol
Carbon tetrachloride
Chloroform
Cumene
Formaldehyde
. Methanol
Methylene chloride
Methyl ethyl ket^n-j
Phenol
Propionaldehydc
,2,4-TrichloroberL>ene
o-Xylene
Chapter 1 - Introduction
-------
The control techniques used to reduce HAP emissions will also reduce
emissions of other pollutants. For example, the NESHAP will reduce
volatile organic compound (VOC) emissions by 450,000 tons per year.
Volatile organic compounds cause a variety of adverse health effects and are
precursors to the formation of tropospheric (ground level) ozone.
Emissions of total reduced sulfur (TRS) compounds cause the odors
commonly associated with pulp and paper production. Exposure to TRS
emissions has been linked to symptoms including headaches, watery eyes,
nasal problems, and breathing difficulties. Total reduced sulfur emissions
are regulated by new source performance standards (NSPS) under
Section 111 of the CAA. Although not specifically regulated by the
NESHAP, the NESHAP will result in a reduction of TRS emissions by
87,000 tons per year.
Chapter 1 - Introduction
-------
The list of mills in
Appendix A is
provided for
information only.
The list is not
necessarily
complete, nor does
it represent an
EPA determination
that any specific
mill is subject to
the rules.
1.6 How many sources does the NESHAP affect?
Figure 4 shows the location of the pulp and paper facilities in the United
States that are potentially affected by the pulp and paper NESHAP.
Appendix A lists the pulp and paper mills (including facility name, and
location by city and state) that were identified as potentially affected sources
at the time the NESHAP was published.
Figure 4.
Location of Pulp and Paper Mills
Source: Lockwood-Post Directory, 1996.
State
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Iowa
Idaho
Illinois
Indiana
Mais
19
8
2
34
r
10
1
11
24
2
1
10
12
State
Kansas
Kentucky
Louisiana
Massachusetts
Maryland •
Maine
Michigan
Minnesota
Missouri
Mississippi
Montana
North
Carolina
New
Hampshire
New Jersey
Mills
2
5
13
38
3
18
33
9
3
10
1
17
12
14
State Mills
New Mexico 1
New York 49
Ohio 30
Oklahoma 6
Oregon 1 2
Pennsylvania ^ '
South 9
Carolina
Tennessee • .'- ;
Texas ' j
Virginia !
Vermont
Washing;. T 2.
j
Wisconsin 4(
West Virginia 2
Total 564
10
Chapter 1 - Introduction
-------
Identify your Slate
and local contacts
using the Membership
Directory at the
STAPPA/ALAPCO
website at
http://www.4cleanair.
org
STAPPA/ALAPCO =
State and Territorial
Air Pollution
Program
Administrators''
Association of Local
Air Pollution Control
Officials
Copies arc
available free of
charge frnm the
EPA librar\:
1.7 What if I have questions?
If you are the owner or operator of a pulp and paper mill, you can get
additional information from:
• your State or local air pollution control agency
• trade associations, such as Technical Association of the Pulp
& Paper Industry' (TAPPI) at http://www.tappi.org or
American Forest and Paper Association (AF&PA) at
http://wwwjifandpa.org
If you work for a State or local regulatory agency and have questions
regarding the implementation of this NESHAP, you should contact your
EPA Regional Office. A list of EPA Regional Office contacts is included in
Appendix D.
1.8 How do I get additional copies of this document?
You can get copies of this document from:
• EPA's Technology Transfer Network (TTN) on the world
wide web at http://wvwv.epa.gov/ttn/atw7pulp/pulppg.html
• Library Services Office (MD-35)
U.S. Environmental Protection Agency
Research Triangle Park. North Carolina 27711
Telephone: (919) 541-2777
• National Technical Information Services (NTIS)
Technology Administrations
5285 Port Royal Road
Springfield. Virginia 22161
Telephone: (703) 605-6000
Fax: (703)321-8547
Note: NTIS will charge a fee for each document
requested.
Chapter 1 - Introduction
11
-------
' An overview of this
NESHAP is
available on a
40 minute video
tape. You can view
this tape at your
State or local air
pollution control
office.
Check the AJWfor
correction notices
and amendments.
1.9 Where can I find additional information about this
NESHAP?
You can find information about the basis and purpose of this NESHAP in
the Federal Register notices and background information documents. The
background information documents are:
• Pulp, Paper, Paperboard Industry - Background Information
for Proposed Air Emissions Standards for Manufacturing
Processes at Kraft, Sulfite, Soda, and Semi-chemical Mills.
Publication No. EPA-453/R-93-050a. October 1993
• Pulp, Paper, Paperboard Industry - Background Information
for Promulgated Air Emissions Standards for Manufacturing
Processes at Kraft, Sulfite, Soda, and Semi-Chemical.
Mechanical, and Secondary and Non-wood Fiber Mills.
Publication No. EPA-453/R-93-050b. October 1997
Federal Register notices pertaining to the NESHAP are:
Proposed NESHAP: published December 17, 1993
(58 FR 66078)
• Correction notice to the proposed NESHAP: published
March 17. 1994(59FR 12567)
• Notice of Da.ta Availability (NODA): published
February 22. 1 995 (60 FR9813)
• Supplemental Notice: published March 8, 1996
(61 FR 9383)
Promulgated NESHAP: published Aprill 5, 199 S
(63 FR 18504)
• Correction of minor errors on the April 15,1998 Notice:
published August 7,1998 (63 FR 42238)
• Interpretation and Technical Amendment published
September 16, 1998 (63 FR 49455)
Chapter 1 - Introduction
-------
• Proposed amendments regarding the interim MACT standard
(63 FR 71408) and direct final rule, December 28, 1998
(63 FR 71385)
• Direct Final Amendment: Addresses nine technical issues
raised by the industry. April 12,1999 (64 FR 17555)
• Proposed amendments to add testing and monitoring
alternatives (65 FR 3907), published January- 25,2000
• Final Rule Amendments: Adds alternatives to the testing and
monitoring of boilers and open biological treatment units
December 22, 2000 (65 FR 80755)
• Final Rule Amendments: Includes amendments to
Appendix C. January 22. 2001 (66 FR 6922)
You can get these documents and other relevant documents from:
• EPA's Air Toxics website (ATW) at
http://www.epa.gov/tth/arvv or
http://www.epa.gov/ttn/arvv/pulp/pulppg.html. These
sites contain background documents, preambles, regulations.
guidance documents, and policy memos
• "What's New" page of the ATW at
http://wwvv.epa.gov/ttn/atvv/arvvnew for the most current
information
The Air Dockets (A-92-40 and A-95-31) which are available
for public inspection between 8 a.m. and 4 p.m.. Monday
through Friday, except for Federal holidays. The address for
the dockets can be found at
http://www.epa.gov/ttnyatw/pulp/pulppg.html.
Chapter 1 - Introduction
13
-------
The Kraft Pulp
Mill Compliance
Assessment Guide
covers the'Cluster
Rules as well as
XSPS and other
rules affecting
kraft mills.
1.10 Where can I find additional information on the
pulp and paper industry?
You can get additional information from:
• Biermann, C.J. 1993. Essentials of Pulping and
Papermaking. San Diego, CA: Academic Press, Inc.
• Burgess, T. 1995. The Basics of Foul Condensate Stripping.
1995 Kraft Recovery Short Course. Atlanta, GA:
TAPPI PRESS.
• EPA. 1998. Permit Guidance Document for Pulp. Paper and
Paperboard Manufacturing Point Source Category. 40 CFR
Part 430, draft. Office of Water, Washington, DC.
• EPA. 1995. Office of Compliance Sector Notebook Project
Profile of the Pulp and Paper Industry.
• Publication No. EPA/310-R-95-015.'
http://es.epa.goV/oeca/.sector/index.htmltfpulp Office of
Enforcement and Compliance Assurance, Washington. DC
• EPA. 1999. Kraft Pulp Mill Compliance Assessment Guide-
Publication No. EPA/310-B-99-001. Office of Enforcement
and Compliance Assurance. Washington. DC.
• How Paper is Made: An Overview of Pulping ar^i
Papermaking from Woodyard to Finished Produ:: !u"".
Available on CD-ROM, Atlanta. GA: TAPPI PRIZES
Kocurek, M.J. and Stevens, C.F.B., eds. 1983. Pulp and
Paper Manufacture. Third Edition. Joint Textbook
Committee of the Paper Industry.
• Mimms, A., Kocurek, M., Pyatte, J. and Wright. E. eds.
1993. Kraft Pulping. Atlanta, GA: TAPPI PRESS.
Smook, G.A. 1992. Handbook for Pulp and Paper
Technologists. Second Edition. Bellingham, WA: Angus
Wilde Publications. .
Chapter 1 - Introduction
14
-------
If you ore already
familiar with
pulping and
bleaching
processes, you can
move ahead to
Chapter 3.
The types of pulp
mills are: :-
• kr:;f:
• soda
• sulfite
• semi-chemical
• mechanical
• se~or>dar\ _/?/v
• non-wood fibers
Chapter 2 - Description of the Pulping and
Bleaching Processes
Three major types of fibers are used to make pulp and paper products:
wood; secondary fibers (recycled fibers); and non-wood fibers (e.g., cotton,
flax, hemp). However, the majority of pulp and paper products are made
from wood, and most wood mills use the kraft pulping process.
Because kraft mills represent the majority of the industry, this chapter
describes the processes at kraft mills using wood. A general process
overview for each of the other types'of mills is also provided. This chapter
does not explain each individual process, but rather focuses on the main
activities affected by the NESHAP. For further information about the pulp
and paper industry and process operations, please refer to the list of
materials provided in Chapter 1.
2.1 What distinguishes the types of mills that
manufacture pulp and paper?
Kraft, soda, and sulfite mills all use chemicals in their pulping processes.
These processes differ primarily in the chemicals used for digesting wood
chips. Mechanical pulping involves shredding or grinding wood chips
without the use of chemicals and semi-chemical pulping combines chemical
and mechanical methods. Secondary fiber mills mechanically separate pulp
iron. \\aste paper products. Non-wood fiber mills can use mechanical and
chemical pulping processes. Figure 5 summarizes the characteristics of the
differeni types of chemical pulping processes.
15
-------
Figure 5.
Chemical Pulping Process Differences
Kraft
Kraft
NaOH,NajS 40-50
Softwood and
hardwood
Writing paper;
paper bags;
cardboard;
specialty
products such
as rayon,
acetate, and
cellophane
Soda
Soda
NaOH
45-55
Hardwood
Writing paper;
specialty
products such
as rayon,
acetate, and
cellophane
Sulfite
Acidsulfite
H:SO3.
M(HSO3)
(M=Ca,Mg,
Na, NH4)
45-55
Softwood and
hardwood
Writing paper;
specialty
products such
as rayon.
acetate, and
cellophane
Semi-chemical Neutral
Sulfite
Semi-
chemical
Na,SO:,
Na-CO,
65-80
Hardwood
Corrugated
containers
Source: Smook. 1992.
16
Chapter 2 • Pulping and
Bleaching Processes
-------
The NESHAP has
the same emission
limits for
papergrade and
dissolving grade
pulp production.
2.2 What is the kraft pulping process?
The pulping process converts raw materials into a fibrous mass that can be
formed into paper or cardboard. Wood contains both cellulose fibers and
lignin; the objective of the kraft pulping process is to dissolve the lignin and
leave most of the cellulose fibers intact.
The main operations performed in the kraft pulping process are:
• digestion of wood to form pulp
• pulp processing to recover spent cooking chemicals and to
remove impurities and uncooked wood chips (deknotting,
pulp washing, pulp screening)
• concentration of used pulping liquor for chemical recovery
Figure 6 depicts a typical overview of a kraft pulp and paper mill. More
detailed diagrams for each equipment system in the pulping process are
provided in Appendix E.
Kraft digesting process
Kraft pulping entails cooking, or digesting, wood chips at elevated
temperature and pressure in an alkaline pulping liquor that contains sodium
sulfide (Na-S) and sodium hydroxide (NaOH). Cooking may be performed
in eiiher batch digester or continuous digester systems. For mills that use
softwood feedstock (e.g.. pine"), the digester system generally will include a
turpentine recover, system. The turpentine is recovered from digester relief
vent gases.
The pulping liquor and elevated temperature and pressure promote
breakdown of the bonds in the lignin compounds. Depending on pulping
conditions, as much as 90-95 percent of the lignin can be removed from
wood in kraft pulping.
Two types of pulp are produced:
• papergrade (for making paper, paperboard, tissue)
• dissolving grade (for making rayon, cellophane, acetate, food
additives) •
Chapter 2 - Pulping and
Bleaching Processes
17
-------
e
S
2
II
e
Illl
0
S1
•o
V
e ^»
5'«
U ""
.£ «
.
l
s u
*- V)
«_-
£ 5 c 2 = t- =.
(A
O)
C3
l_
O
a
n
a.
TO
3 3 «: > "v .
CL ZL C- ^— ^
t*~ GO C". O
§ C
01 J3-
11 £
it
re
>*-
c
I
a>
O
"a
E
re
x
UJ
-, ^.
18
o w^!= = j<
u y. > — — c
*- N m if in -i
-------
Weak black liquor
consists of
dissolved wood
compounds and
spent cooking
chemicals.
Kraft pulp processing steps
Kraft mills remove impurities from the raw pulp prior to bleaching or
papermaking. The primary pulp cleaning operations include deknotting (in
the knorter), brown stock washing (in the pulp washing system), and pulp
screening (in the screening system).
Deknotting removes
knots and other
portions of uncooked
wood from the pulp
slurry. Kraft mills,
burn the knots and
uncooked wood for
energy recover)",
dispose of them as
waste, or recycle them
for repulping. The diagram to the right shows a typical knotter.
Brown stock washing recovers spent cooking liquor (weak black liquor) for
reuse in the pulping process. Efficient washing is critical to maximize the
return of cooking liquor to chemical recovery and to minimize carryover of
cooking liquor (known as brown stock washing loss) into the bleach plant.
A variety of brown stock washing technologies are used; the most common
technology is a series of two to four rotary vacuum washers. In each
washer, wash water is applied to displace cooking liquor in the pulp:
counter-current washing is generally used to reduce fresh water
requirements. Other common washer types are diffusion washers, rotary.
pressure washers, horizontal belt filters, wash presses, and
dilution, extraction washers. Figure 7 shows a typical rotary vacuum washer
svstem.
Chapter 2 - Pulping and
Bleaching Processes
19
-------
•o
§
=
E
3
O
re
5.
3 CO
.2» os
u. c
IE
(0
o
o
•
c
o
(T
20
-------
A screen system
removes oversized
particles from the
pulp slurry prior to
the bleaching or
papermaking
system.
A decker is used to
thicken the pulp for
storage after
screening or
subsequent
delignification
steps.
Pulp screening removes the remaining oversized particles (fiber bundles
and contaminants) from washed pulp. The pulp is diluted to low percent
solids, then passed through a perforated screen, and rejects are continuously
removed from the screen. Methods for removing rejects are shaking and
vibration, hydraulic sweeping action, back-flushing, or pulsing the flow
through the openings with various moving foils, paddles, and bumps. Mills
may operate open, partially closed, or closed screen rooms. In open screen
rooms, wastewater from the screening process is discharged to wastewater
treatment. In closed screen rooms, wastewater is reused in brown stock
washing or other pulping operations and ultimately enters the chemical
recovery system.
A decker system is all of the equipment used to thicken the pulp slurry after
the pulp washing system. It includes decker vents, filtrate tanks, and
vacuum pumps.
Evaporator system
Weak black liquor collected from the pulp washers goes into a weak black
liquor storage tank. The weak black liquor is sent to the multiple effect
evaporator (MEE) to evaporate water and concentrate the weak black liquor
in order to increase solids content. Typically, weak black liquor recovered
from the brown stock washers contains between 13 and 17 percent solids.
The weak black liquor is then concentrated to 60-80 percent solids, which is
required for efficient combustion in the recovery boiler. An MEE will
include four to seven effects, or bodies, arranged in series. At pulp mills
using soft wood, a tall oil recover}- system is generally incorporated into the
evaporator system to recover tall oil from the black liquor. Tall oil is sold
for use ir. manufacturing cosmetics.
Oxygen delignification system
Some mills that produce bleached pulp may also have an oxygen
delignification stage either in the pulping area or as a prebleaching stage.
The oxygen delignification process reduces the lignin content without
reducing pulp strength or yield. High efficiency oxygen delignification
minimizes the amount of bleaching chemicals needed to achieve adequate
pulp brightness.
Chapter 2 • Pulping and
Bleaching Processes
21
-------
There are currently two types of oxygen delignification systems available:
high consistency and medium consistency. Medium consistency systems
are more popular due to safer operation and lower capital costs. Design and
placement of these systems vary from mill to mill. Oxygen delignification
systems of the two-stage design are most often employed in the U.S. for
new installations. Figure 8 shows a typical oxygen delignification.system.
Gas collection systems
Gas collection systems, or noncondensible gas (NCG) systems, are used to
collect gases from the various pulping processes and transport them to an
appropriate air pollution control device. There are two basic categories of
NCGs: low volume, high concentration (LVHC); and high volume, low
concentration (HVLC).
Low volume, high concentration (LVHC) systems typically collect gases
from the following systems:
• digester system
• turpentine recovery system
• evaporator system
° steam stripper system
• any other system serving one of these functions
High volume, low concentration (HVLC) systems typically collect eases
from the following systems:
• knotter system
• pulp washing system
• screen system
• oxygen delignification system
• weak liquor storage tanks
• any other equipment serving one of these functions
Chapter 2 - Pulping and
Bleaching Processes
22
-------
.2
'35
c
o
O
E
'•$
o
23
00
0)
-------
Historically, most
L VHC gases have
been controlled,
while a smaller
portion of the
HVLC gases have
been controlled.
Steam stripper
systems were
historically
installed to control
TRS odor.
A number of mills use a dedicated incinerator to control NCG emissions,
but most mills use process combustion sources such as the lime kiln, power
boilers, or a recovery boiler.
Condensate stripping
The pulping process equipment may include a steam stripper system to
remove organics and total reduced sulfur (TRS) compounds from various
liquid process condensate streams. Steam stripping is a multistage
distillation separation process that uses direct steam as the heat source. The
pulping process condensate streams most often stripped are the turpentine
decanter underflow, blow steam condensates, and certain evaporator
condensates. The stripped condensates may then be used as hot process
water.
Kraft pulping process condensates originate from the following systems:
• ' digester system
• turpentine recovery system
• evaporator system
Chapter 2 - Pulping and
Bleaching Processes
24
-------
Each bleaching
stage performs
three Junctions:
• mixing of pulp
and bleaching
chemicals
• reaction of
bleaching
chemicals with
the pulp
• washing the
chemicals out of
the pulp
2.3 What is bleaching?
Bleaching brightens the pulp in a series of chemical operations that are
together called a bleaching line. A bleaching line typically consists of a
sequence of three to six bleaching stages. The number of stages varies
depending on the brightness requirements of the pulp and the specific
design of the mill. Typically, the stages are sequenced as an alternating.
series of bleaching and extraction stages. In a bleaching stage, the pulp is
treated with chemical bleaching agents. In an extraction stage, chemicals
(usually sodium hydroxide) are added to neutralize the chemical reactions
and the acidity of the pulp prior to the next bleaching stage. An extraction
stage is not required in all cases.
Each bleaching stage consists of three steps: mixing of pulp and bleaching
chemical (and in some cases steam); reaction of the chemical with the pulp
in a retention tower; and washing the chemical out of the pulp. Thus, the
equipment considered part of a stage includes chemical and steam mixers.
retention (bleaching or extraction) towers, and the washers and their
associated seal (filtrate) tanks and'or vacuum pumps.
Figure 9 depicts the major equipment found in a typical three-stage
bleaching plant. The function of these equipment systems and a brief
description follow.
Chapter 2 - Pulping and
Bleaching Processes
25
-------
II
i!
3 -
i
o
0)
c
o>
IE
o
5
O CD
il _o>
Q.
re
x
LLJ
26
CQ o
-------
Bleaching stage
means all process
equipment
associated with a
discrete step of a
chemical
application and
removal in the
bleaching process.
Bleaching fine
means a group of
bleaching stages
arranged in series
such that bleaching
of the pulp
progresses as the
pulp moves from
one stage to the
next.
Bleaching chemicals
Almost any oxidant could be used as a bleaching agent. However, for
bleaching pulp, the chemical must be both powerful and inexpensive to
produce or purchase. There are a variety of chemicals that meet these
criteria. Both chlorinated and non-chlorinated chemicals are used for
bleaching. The chemicals and their common bleaching stage abbreviations
are shown below. These bleaching chemicals are grouped into two
categories: chlorinated and non-chlorinated.
Chemicals Abbreviation
Chlorinated Bleach Chemicals
Elemental chlorine
Hypochlorite
Chlorine dioxide
Chlorine with chlorine dioxide • .
substitution
C
H
D
(CD), (C+D)
Non-chlorinated Bleach Chemicals
Oxygen
Peroxide
Ozone
O
P
Z
Chlorinated bleaching chemicals There are three chlorinated chemicals
commonly used for bleaching pulp: elemental chlorine (C). chlorine
dioxide (D), and hypochlorite (H). Since elemental chlorine is a good
delignifying agent, it performs best when used in the first bleaching stage.
Non-chlorinated bleach chemicals Common examples of non-chlorinated
bleaching chemicals include: oxygen (O); peroxide (P); and ozone (Z).
Bleach stages that use various combinations of alkali, oxygen, and peroxide
are common in many bleach plants.
Chapter 2 - Pulping and
Bleaching Processes
-------
TheNESHAP
requires- collection
and control of HAP
emissions from the
chlorinated
bleaching stages
only!
Bleaching mixers
Bleaching chemicals must be thoroughly mixed with the pulp to ensure pulp
quality, to ininimize chemical waste, and to minimize the generation of
bleaching contaminants such as chlorinated dioxins and furans. Enclosed
rotary high-shear mixers or static in-the-pipe mixers are used to mix the
pulp and bleaching chemicals.
Bleaching retention towers
Retention towers are used to maintain bleaching conditions for the pulp as it
passes through each bleaching stage. For complete bleaching chemical
reaction, it is necessary to maintain a certain temperature, time, consistency,
pressure, and pH for each bleach stage. Conditions vary with the bleaching
chemical used (e.g., chlorine, chlorine dioxide, hydrogen peroxide). In
many bleaching systems, the retention towers are named by the bleach
chemical used or the function of that particular bleaching stage
(e.g., chlorination tower).
There are two primary types of retention towers: the upflow tower: and the
downflow tower. The choice of tower design depends on the particular
conditions desired for the bleach stage. As a general rule, chlorinated
bleaching stages use an upflow tower design or a similar design. See
diagram number 29 in Appendix E.
Bleached pulp washers
To minimize chemical usage and equipment corrosion, it is important u
remove as much bleaching chemical as possible from the pulp before it
enters the next bleaching stage. Bleached pulp washing is performed in t:;,
same type of equipment that washes the brown stock-. See discussion on
brown stock washers on page 19.
More detailed diagrams on the air and water discharges of each s> stem OK
provided in Appendix E.
Chapter 2 • Pulping and
Bleaching Processes
28
-------
What is pulp preparation and papermaking?
The final stages at a pulp and paper mill include the preparation of pulp for
papermaking and the actual papermaking process. In the pulp preparation
area, the pulp fibers are cleaned to remove unwanted particles (such as dirt
and sand) from the pulp stock. The cleaned fibers will then undergo some
level of refining. In the refining process, the pulp fibers are subjected to
mechanical action to develop their optimal papermaking properties with
respect to the product being made.
In the papermaking process, the pulp stock is converted into paper. This
process begins when the pulp stock is distributed across the forming table.
On the forming table, the paper sheet formation starts as the excess water
contained in the pulp stock drains from the pulp fibers. The newly formed
paper sheet is removed from the forming table and is conveyed through a
series of presses to remove additional water and to continue the sheet
forming process. The remaining water contained in the paper sheet is
removed as the sheet travels around a series of steam-heated cylinders.
After the paper sheet leaves the dryers, it may undergo several other
proc -sses. depending on the final paper product. These additional processes
include: calendering (where the sheet is pressed to reduce thickness and
smooth the surface), winding (where the sheet is wound onto a reel), and
coating (where various chemical or dyes are applied to the paper sheet).
Chapter 2 - Pulping and
Bleaching Processes
29
-------
The soda pulping
process was the first
chemical pulping
method and was the
precursor to the krqft
pulping process.
2.4 Soda mills
The soda pulping process utilizes an alkaline liquor with sodium hydroxide
as the only active chemical. Except for the difference in chemicals used,
this process is the same as that described for the kraft mill.
Chapter 2 - Pulping and
Bleaching Processes
30
-------
The sulfite pulping
process uses acid
solutions ofsulfurous
acid (HzSOJ and
bisulfite ions (HSO}~).
2.5 Sulfite mills
The sulfite pulping process uses an acid solution of sulfurous acid (H2SO3)
and bisulfite ion (HSO3") to break the lignin bonds between wood fibers,
while kraft mills use an alkaline solution. Because the sulfite cooking
process is an oxidizing reaction, sulfur dioxide is generated instead of the
reduced sulfur compounds generated by the kraft process (a reducing .
reaction). Thus, the chemical recovery processes at sulfite mills are
different than at kraft mills. Otherwise, the process is similar to the kraft
process.
Sulfite pulp has less color than kraft pulp and can be more easily bleached,
although the sulfite pulp is not as strong as kraft pulp. Figure 10 depicts an
overview of a typical sulfite pulping system.
Chapter 2 - Pulping and
Bleaching Processes
31
-------
Acid
Making
System
Chemical
Recovery
System
Digester System
Strong Liquor
Storage Tank*
Acid Condensate
Storage Tank*
Knotter
System
Pulp Washing System
Evaporator System
Weak Liquor
Storage Tank
Screen >>•.- . •
and Deckei Svsi
Pulp to Bleaching Sysu :ni F j
Dryers, or Papermakiiiij Svste:
pulp How
liquid streams
gas streams
HVLC* high volume,
low concentration
LVHC* low volume,
high concentration
'Affected source only at new sources
Figure 10.
Example Sulfite Pulping System
32
-------
Semi-chemical pulp is
generally not
bleached.
2.6 Semi-chemical mills
Semi-chemical pulping involves partial digestion of wood chips in a weak
chemical solution such as sodium sulfite (NajSOj) and sodium carbonate
(NajCOj) followed by mechanical refining for fiber separation. Semi-
chemical pulp is very stiff, making this process common in corrugated
container manufacture. Figure 11 shows an overview of a typical semi-
chemical pulping system.
Chapter 2 - Pulping and
Bleaching Processes
33
-------
—^—»- liquid streams
HVLC= high volume
low cotKHllralion
LVHC- low volume.
high concentiation
Digester System
I
Refiners
Pulp Washing System*
Collection System
• H\IC
T
Refiners
T
Pulp to Pulp Dryers
or Papermaking System.
'AHecled source only at new sources.
Figure 11.
Example Semi-chemical Pulping System
34
-------
Bleaching systems
that use chlorine or
chlorine dioxide are
the only emission
sources at
mechanical,
secondary fiber, and
non-wood fiber mills
affected by the pulp
and paper NESHAP.
Secondary fiber
mills make pulp
from recycled
paper and other
products
2.7 Mechanical, secondary fiber, and non-wood fiber
pulp mills
Mechanical pulping
Mechanical pulping uses physical pressure instead of chemicals to separate
wood fibers. Mechanical pulping processes have the advantage of
converting up to 95 percent of the dry weight of the fiber source into pulp,
but require an enormous amount of energy relative to chemical pulping.
Mechanically produced pulp is of lower strength than chemically produced
pulp and is used principally for newsprint and other non-permanent paper
goods.
Mechanical pulps are brightened with hydrogen peroxide (H2O2) and/or
sodium sulfite (Na2SO3). The brightening chemicals are applied during the
pulp processing stage (e.g., in-line brightening), or in chemical application
towers. These chemicals only brighten the pulp and do not permanently
bleach the pulp. Typically, bleaching of mechanical pulps using chlorine or
chlorine dioxide is not practiced because of the high cost of bleaching
chemicals and negative impact on pulp yield.
Secondary fiber pulping
Secondary fibers include any fibrous material that has undergone a
manufacturing process and is being recycled as the raw material for another
manufactured product. Secondary fibers have less strength and bonding
potential than virgin fibers. The fibrous material is dropped into a large
tank, or puiper. and mixed by a rotor. The pulper may contain either hot
water or pulping chemicals to promote dissolution of the paper matrix.
Debris and impurities are removed by "raggers"(wires that are circulated in
the secondary fiber slum so that debris accumulates on the wire) and
"junkers" (bucket elevators that collect hea\y debris pulled to the side of the
pulper by centrifugal force).
Chapter 2 - Pulping and
Bleaching Processes
35
-------
The NESHAP does
not apply, to mills
that rewater
purchased pulp
(e.g., dried bales or
sheets of pulp
being made into a
slurry).
Non-wood fiber pulping
Non-wood pulping is the production of pulp from fiber sources other than
trees. Non-wood fibers used for papermaking include straws and grasses
(e.g., flax, rice), bagasse (sugarcane), hemp, linen, ramie, kenaf, cotton, and
leaf fibers. Pulping of these fibers may be performed by mechanical means
at high temperatures or using a modified kraft or soda process. Non-wood
fiber pulp production is not common in the U.S.
Chapter 2 - Pulping and
Bleaching Processes
36
-------
2.8 References for Chapter 2
Biermann, C.J. 1993. Essentials of Pulping and Papermaking. San Diego,
CA: Academic Press, Inc.
Burgess,!. 1995. The Basics of Foul Condensate Stripping. 1995 Kraft
Recovery Short Course. Atlanta, GA: TAPPI PRESS.
EPA. 1995. Office of Compliance Sector Notebook Project: Profile of the
Pulp and Paper Industry. EPA/310-R-95-015. Office of Enforcement and
Compliance Assurance, Washington, DC.
EPA. 1993. Pulp, Paper, Paperboard Industry - Background Information
for Proposed Air Emissions Standards for Manufacturing Processes at Kraft.
Sulfite, Soda, and Semi-chemical Mills. EPA-453/R-93-050a. Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
Mimms. A., Kocurek, M., Pyatte, J-., and Wright, E., eds. 1993. Kraft
Pulping. Atlanta, GA: TAPPI PRESS.
Smook. G.A. 1992. Handbook for Pulp and Paper Technologists. Second
Edition. Bellinsham. WA: Anaus Wilde Publications.
Chapter 2 - Pulping and
Bleaching Processes
37
-------
-------
A copy of the
April 15, 1998
NESHAP is in
Appendix B. Refer
to the A 7W for
correction notices
and amendments.
The NESK4P does
NOT apply to
paper mills unless
thev also produce
pulp.
Find a Us, O/H.4P.S
a! http://wwH-.epa.
gov/ttn/atw/
pollsour.htm!
Chapter 3 - Overview of the Pulp and Paper
NESHAP
3.1 Which mills are subject to the NESHAP?
The pulp and paper NESHAP applies to existing and new major sources that
produce pulp, paper, or paperboard, and use any of these pulping processes:
• kraft using wood
• soda using wood
• sulfite using wood
• semi-chemical using wood
• mechanical using wood
processes using secondary fibers or non-wood fibers
A major source is any mill that emits or has the potential to emit
(considering Federally enforceable controls^ 10 tons per year (tpy) or more
of any HAP or 25 tpy or more of any combination of HAPs.
38
-------
General
Requirements of the
NESHAP:
• vent control on
pulping systems
• treatment of
condensates from
kraft pulping
systems only
• vent control on
bleaching systems
• elimination of
certain bleaching
chemicals
• no control of
papermaking
svstems
3.2 What processes and equipment systems must be
controlled?
The NESHAP has separate emission limits for pulping system vents,
pulping process condensate streams, and bleaching systems. The
applicability of these standards varies depending on the type of mill.
If the Mill is
TfcfeTvpe...
Kraft
Sulfite
Semi-chemical
Soda
Mechanical
Secondary Fiber
Non-Wood Fiber
flrea tfce NESHAP Covers These Processes...
Bteaeyng Systems
That Use the
Pulping Pulping Following
System Veate Ctmdeit&iles Ceaspoands
X X Chlorine or any
chlorinated compound
X Chlorine or any
chlorinated compound
X Chlorine or an\
chlorinated compound
X Chlorine or an>
chlorinated compound
Chlorine or chlorine
dioxide
Chlorine or chlorine
dioxide
Chlorine or ch'rrirv.
dioxide
Chapter 3 • Overview of
NESHAP
39
-------
For purposes of
this NESHAP,
LVHC systems are:
• digester
system
• turpentine
recovery
system
• evaporator
system
• steam stripper
system
• any other,
system serving
one of these
functions
Systems that are
not regulated:
• wood yards
•pulping systems
at mechanical
non-wood, and
secondary fiber
pulp mills
• tall oil recovery-
systems
• caustici:ing
systems
•papermaking
systems
In addition, the specific pulping process vents covered by the standards vary
depending on the type of mill and the classification of the pulping system as
a new or existing source. See Figure 12. The applicability and control
requirements of each type of mill are explained in detail in Chapters 4
through 7.
Figure 12.
Equipment Systems Covered by the
Pulping Vent Standards
If the
MM is
This
Type-.
Kraft
Soda
Siilfr.e
Semi-
chemical
TheaTbfise EguipmeBt Systems* are
Covered *$ f&isti&g Se&rc«s.-
• LVHC systems
• Pulp washing system
• Oxygen delignification system
• Decker systems that use any process water
other than fresh water or paper machine
white water or any process water with
total HAPs concentration > 400 ppmw
• Knotter systems with HAP emissions
greater than 0.05 kg/Mg 'oven-dried pulp
• Screen svstems with HAP emissions
greater than 0.1 kg/Mg oven-dried pulp
• Combined knotter and screen svstems
with
HAP emissions greater than 0.15 kg'Tvlg
oven-dried pulp
LVHC systems
• Disaster svstem
• Evaporator system
• Pulp washing systems
LVHC systems
And These Equipment
Systein* are Covered at
New Sources „,
Same as existing sources
plus all...
• Decker systems
• Screen systems
• Knotter systems
• Weak liquor storage
tanks
Same as existing sources
plus all...
• Pulp washing systems
Same as existina sources
plus all...
• Weak liquor storage
tanks
• Strong liquor storage
tanks
• Acid condensate storage
tanks
Same as existing sources
plus all...
• Pulp washing systems
, See Appendix F for a list of specific equipment within each system.
See page 49 for the definition of a new source.
Chapter 3
Overview of
NESHAP
40
-------
The NESHAP has
one alternative
emission limit for
pulping system
yents, pulping
condensates, and
bleaching systems
that does not
require testing and
monitoring.
3.3 What are the emission control requirements?
The NESHAP provides several alternative emission limits for the pulping
vent standard, pulping condensates standard, and bleaching system standard.
For each regulated emission point, a mill can choose the emission limit with
which to comply and can use any emission control technology to achieve
compliance.
The format (e.g., percent reduction or outlet concentration) of the alternative
emission limits varies depending on the type of mill (Figure 13). For ease
of explanation, Figure 13 provides only the formats of the alternative limits,
since the actual emission limits vary depending on the type of mill. The
emission limits for each type of mill are presented in Chapters 4 through 7
and are summarized in Appendix G.
Where two or more pulping processes share a piece of equipment, that piece
of equipment is considered a part of the pulping process type with the more
stringent NESHAP requirements for that piece of equipment.
Chapter 3 • Overview of
NESHAP
41
-------
Figure 13.
Alternative Emission Limits
And * MmCaB Choose One of tbe
Pulping system vents
•Kraft
• Soda
• Semi-chemical
Total HAPs
Percent reduction
Outlet concentration (parts per million by
volume) for thermal oxidizer
Design specification for thermal oxidizer
Duct vents to a boiler, recovery furnace,
or lime kiln
Pulping system vents
• Sulfite
Total HAPs
Percent reduction
Mass emission limit (Ib/ton oven-dried
pulp)C
Pulping system
condensates
•Kraft
Total HAPs
Recycling to equipment subject to pulping
standards
Percent reduction (HAP mass in the
condensates)
Mass removal (Ib/ton oven-dried pulp)
Outlet concentration (parts per million by
weight) (option not available for
biological treatment systems)
Bleaching system
• Kraft"
• Soda
• Sulfite
Chlorinated HAPs (other
than chloroform)
Percent reduction
Outlet concentration (ppmv) from the
treatment device
Mass emission limit (Ib/ton oven-dried
pulp)
Eliminate use of chlorinated compounds
Chloroform
Eliminate use of hypochlorite and
chlorine
Effluent (water) limitations
Emission limits van.1 for different types of pulping systems and control devices. A mill will likely use several
closed-vent systems and each one can comply with any of these alternative emission limits.
The vent stream must be introduced with the primary fuel or into the flame zone. For boilers and recovery
furnaces with heat input capacities of 150 MMBtu/hr of more, the vent stream can be introduced with the
combustion air.
Percent reduction and mass emission limits apply to sulflte pulping system vents, and any emissions from vents,
wastewater, and condensate streams from the control device.
Mass emission limit applies to total emission from all regulated bleaching stages in the bleaching system.
Chapter 3 - Overview of
NESHAP
42
-------
3.4 What control systems will mills typically use to
meet the emission limits?
The control systems that most mills are likely to use to meet the emission
limits shown in Figure 13 are listed below:
• Pulping system vents
thermal oxidizers
power boilers, lime kilns, recovery furnaces
• Pulping process condensates
steam strippers
biological treatment
recycling to pulping equipment that is controlled by
theNESHAP
• Bleaching system vents
caustic scrubbers (for chlorinated HAPs. other than
chloroform)
process modifications to eliminate the use of chlorine
and hypochlorite
Chapter 3 - Overview of
NESHAP
43
-------
Figure 14 explains
in general how
mills must
demonstrate
compliance with
the NESK4P.
Administrator
means ar.
authorized
representative of
th(. Ei'A ie.g.. a
State that has been
delegated the
author ir\- to
imr'ement and
enforce this
NESR4PJ.
3.5 How do mills demonstrate initial and continuous
compliance?
In general, mills must conduct an initial performance test and then
continuously monitor a set of control device or process operating
parameters. Exceeding a monitoring parameter will constitute a violation of
the standard.
Initial performance test. A performance test is required for most sources
regulated by this NESHAP. The performance test serves two purposes:
(1) To demonstrate that the control device complies with the
emission limit (Figure 14 explains the pollutants that must be
measured and the allowable surrogates that a mill may
choose to measure as an alternative)
(2) To establish the process operating parameter values (e.g., fire
box temperature for 'thermal oxidizers) that must be
monitored to demonstrate continuous compliance with the
standard
The NESHAP specifies the required monitoring parameters for most control
devices. If a mill uses a control device for which the monitoring parameters
are not specified, then the mill must propose and demonstrate, to the
satisfaction of the Administrator, a set of monitoring parameters that can
prove continuous compliance with the XESHAP. During the performance
test, mills must test simultaneously for emissions and monitor the
appropriate operating parameters to establish the parameter values (e.g.. the
specific fire box temperature) that constitute continuous compliance.
Chapter 3 • Overview of
NESHAP
44
-------
TheNESHAP
generally requires
continuous
monitoring of
operating
parameters (not
emissions) to
demonstrate
compliance.
Continuous monitoring. Continuous monitoring is used to demonstrate
that a mill is in compliance with the NESHAP at all times. Mills must
continuously monitor operating parameters and report all instances where
the values deviate from the maximum or minimum values established
during the initial performance test. As an alternative, mills may install a
continuous emissions monitor.
Recordkeeping and reporting requirements. Mills must comply with the
recordkeeping and reporting requirements of the NESHAP General
Provisions (40 CFR 63) and those of the pulp and paper NESHAP. These
requirements include initial notifications, retaining records of performance
tests and monitoring data, and periodic reporting of periods of excess
emissions. Table 1 of Appendix B identifies which sections of the General
Provision requirements apply and which are overridden by this NESHAP.
In addition, the pulp and paper NESHAP requires some mills to submit a
control strategy report. The control strategy report must be submitted with
the initial notification (by April 15. 1999) and updated every 2 years until
compliance is achieved. The report must include the following:
• description of emission controls or process modifications
selected for compliance
• compliance schedule
• a report on the progress of installing the emission controls or
process modifications during the past 2-year period.
The control strategy report is required only if a mill uses one of the
following strategies that provide either additional compliance time or
compliance flexibility-:
• Bleaching systems that comply with the Voluntary
Technology Advanced Incentives Program (see page 70)
• HVLC system vents that comply after April 16, 2001
• HVLC system vents that comply with the Clean Condensate
Alternative (see page 75) .
Chapter 3 - Overview of
NESHAP
45
-------
Figure 14.
What Pollutants or Surrogates Must Be Measured?
lif^Xlwse'.SysteBwt-ai
Cftvered by the
Pulping
Bleaching
Condensates
Biological
treatment
Steam stripping
*,&,s^i8*»a» "- -- And a M» May
"" f f f nut D
j^bi'ionittffltGB" •T^fjHHtyM^ $fr ^Evft*
*& S 'i,jB€ll t)l& _, ^ *|>^fi^|^i<%^:.x *' ^ ^1ffy fflwjtf *"
K*>gdbM«d - Itf^^^pldtll' Sorrogate
PollBtastSs... frequency*,.. P^EIutaat..
Total HAPs Initially Methanol
Chlorinated Initially Chlorine
HAPs (excluding
chloroform)
Chloroform None
Total HAPs Quarterly Methanol
(ir condensates)
Total HAPs Initially Methanol
(in condensates)
And These :
Parameters
CoBtiauoDSiv
MonitiHMii
Operating
parameters or
methanol outlet
concentration
Operating
parameters or
chlorine outlet
concentration
None
Operating
parameters
(daily)
Operating
parameters or
methanol outlet
concentration
Compliance tests are conducte
The U.S. EPA or the delegated authority may require an owner or operator to conduct performance tests at the
affected facility at any other time when the action is authorized under Section 114 of the CAA (40 CFR
subsection 63.7(a)(3)i.
using the following methods:
Compound(s)
Total HAPs; methanol
rhlorinated HAPs
Chlorine
Total HAPs; methanol in
condensates
Methanol in condensates
Test method
M308
Any method approved by the Administrator
M26A
M305
NCASI GC/FID6
A mill can comply by eliminating the use of chlorine and hypochlorite or by complying with the numerical limits
of the effluent limitations guidelines and standards for water in 40 CFR 430.
The initial performance test and annual 1st quarter tests must be performed for acetaldehyde, methanol, methyl
ethyl ketone, and propionaldehyde. However, if the ratio between the four HAPs and methanol is established in
the 1st quarter, methanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and 4th quarter tests instead
of performing the tests for the four HAPs.
e The National Council of the Paper Industry for Air and Stream Improvement (NCASI) direct injection gas
chromatography/flame ionization (GC FID) method may be used as an alternative to EPA Method 305.
Chapter 3 - Overview of
NESHAP
46
-------
For purposes of
this NESHAP,
HVLC systems are:
• knotter system
•pulp washing
system
• screen system
• oxygen
delignification
system
• weak liquor
storage tanks
3.6 When must mills comply?
The major compliance milestones for affected sources are shown below.
This information presents only a portion of the requirements faced by
owners and operators of pulp and paper mills. Appendix H provides the
detailed milestone compliance timeline for existing sources.
" Affected S«are« Must CemplybyHril 16,2001...
J&keept for the FoJfowiag.,.
New sources
o
HVLC system vents at kraft mills
Dissolving grade bleaching systems
at kraft or sulfite pulping mills
Bleaching system at any mill
choosing to implement the
Voluntary Advanced Technology
Incentives Program for effluent
limitations guidelines and
standards
mkh Mast Csmpty...
At startup or by June 15, 1998,
whichever is later
Within 8 years (April 17, 2006)
Within 3 years of publication of the
revised effluent limitations
guidelines and standards
Within 6 years (April 15, 2004)
LVHC systems must still meet the April 16, 2001 compliance date (see page 55).
L Dissolving grade bleaching systems are similar to bleaching systems at bleached kraft
or sulfite mills but usually contain six to eight bleach stages for maximum delignificatn.
and pulp cleanliness. The April 15, 1998 Cluster Rules did not publish effluent
limitations guidelines and standards for these subcategories. Development of these
^revised rules is underway.
" Refer to page 70.
Also, by April 15, 1999, the following is due:
• Initial notification
• Initial control strategy report
Chapter 3 - Overview of
NESHAP
47
-------
For new sources,
the emission limits
are the same as
existing sources.
See page 49 for the
definition of a new
source.
3.7 What additional requirements apply to new
sources?
New sources at pulp and paper mills have more stringent compliance
requirements than existing sources. These include:
• More emission points must be controlled. For pulping
systems, the emission limits (see Figure 12) for new and
existing processes are the same, but more emission points
must be controlled at new sources. For bleaching systems
and pulping condensates, the emission limits and emission
points that must be controlled for new and existing sources
are identical.
• Earlier compliance dates. New sources must comply at the
date of startup or on June 15,1998, whichever is later.
• Preconstruction approval. The owner or operator of mills
subject to the pulp and paper NESHAP must submit an
application to EPA for approval to construct any new source
that is subject to this rule. The preconstruction approval
process applies only if two conditions are met:
if the construction or reconstruction is a "new source"
as defined in Section 3.8
the new or reconstructed source in and of itself is a
major source
Construction must not commence until the EPA Administrator
approves the application. The EPA Administrator will approve the
application after determining that the source, if properly constructed,
will not cause a violation of the NESHAP. The requirements for the
submission and approval of construction applications are contained
in40CFR63.5(e)and(f).
Chapter 3 - Overview of
NESHAP
48
-------
The definition of a
new source is
different under the
Clean Water Act.
See 40 CFR 122.2
and
40 CFR 430.01 (j)
for the definition of
a new source for
effluent limitations
guidelines and
standards, and
pretreatment
standards.
Upon
reconstruction, an
existing source
immediately
becomes subject to
the new source
requirements!
3.8 What is a new source?
What constitutes a new or reconstructed source for each mill type that is
subject to this NESHAP is defined below.
-••:-, -, f
A^*W
Source at « ...
Kraft mill,
Soda mill,
Semi-
chemical mill,
or
Sulfite mill.
Mechanical
pulping mill
Other mills
- - * '&:/,-,;
.. ''.•"' * *~ * *.
,< RQHiVOBsfcrwtwPBf Any
Using.- Ow of tta JfiOliowing.-.
Wood • A new mill
• New pulping system
• New bleaching system
• Additional pulping line
• Additional bleaching line
Wood • Bleaching system
• Bleaching line
Secondary1 • Bleaching system
or non- • Bleaching line
wood fibers
Qrife *'
AoyOoeof^ti: Commences
Stowing... After...
• Pulping system 1 21 1 7/93
• Bleaching system
Bleaching system 03 '08 %
Bleaching system 03/08/96
Reconstruction means replacement of components fo the extent that the fixed capital cost of the nev-
components exceeds 50 percent of the fixed capital cost that would be required to construe; a
comparable nen source. (40 CFR 63.2 Subpart A).
What is an "Additional Line?" An additional line means a line that adds
capacity to an existing pulping or bleaching system. For example, considei a
mill with two existing pulping lines. The construction of a third line vsouid
constitute an additional line and would be subject to new source controls On
the other hand, a like-kind replacement of one of the lines would not ho
considered an additional line. However, the replacement of one of the line--
with a new line that increases the capacity of the pulping system would be
considered an additional line that is subject to the new source requirements
What Does "Reconstruction" Mean? Reconstruction means the replacement
of components to the extent that the fixed capital cost of the new components
exceeds 50 percent of the fixed capital cost that would be required to construct
a comparable new source. If this condition is met, upon construction, an
existing source immediately becomes subject to the MACT standards for new
sources irrespective of any change hi emissions of HAPs. See 40 CFR 63.2
and 63.5.
Chapter 3 - Overview of
NESHAP
49
-------
The pulp and paper NESHAP defines either the entire pulping system or
bleaching system as the equipment to which the 50 percent criterion is applied.
For example, consider a mill that is refurbishing one of its two pulping lines by
replacing worn out equipment or components. To determine if reconstruction
occurs, the replacement costs would be compared to the construction costs for
replacing the entire pulping system (e.g., both lines). If the replacement cost is
less than 50 percent, the line is treated as an existing source. However, if the
cost exceeds 50 percent, then the replacement/construction project would be
deemed as a reconstruction of the pulping system, and both lines would
become subject to the new source provisions, even if emissions after the
reconstruction are the same or decrease.
Chapter 3 - Overview of
NESHAP
50
-------
Chapter 4 • NESHAP Requirements for Kraft Mills
Systems that are
not regulated:
• wood yards
• tall oil recovery
systems
• causticizing
systems
•papermaking
systems
The CCA focuses
on reducing HAP
emissions
throughout the mill
bv reducing the
H.iP mass in
process waier
streams thai arc
recycled to various
process areas in
the mill
For kraft mills, the NESHAP contains emission standards for pulping system
vents, pulping process condensates, and bleaching system vents.
There are several alternative emission limits for each process covered.
Compliance times will vary based on the process and emission limit selected,
even within the same mill. This designed flexibility promotes and encourages
new technologies, particularly joint air/water controls and pollution prevention
technologies.
The NESHAP also includes an option called the Clean Condensate Alternative
(CCA). The CCA applies only to kraft pulping system vent standards for the
HVLC system and features both pollution prevention and emission averaging.
The CCA is described on page 75.
If You Need the FoUowinglBformation...
Then Read..
Standards for kraft pulping system vents
Standards for kraft pulping process condensates
Standard? for kraft bleaching system vents
Description of the clean condensate alternative
Comparison of requirements for the XESHAP
and thi NSPS
Section 4.1
Section 4.2
Section 4.3
Section 4.4
Section 4.5
51
-------
For purposes of this
NESHAP, the LVHC
system includes all
vents from:
• digester system
• turpentine recovery
system
• evaporator system
• steam stripper
system
and
The HVLC system
includes all vents
from:
•pulp -washing
system
• knotter system
• screen system
• decker system
• oxygen
delignification
system
• weak liquor
storage
tanks
The combined
knotter and screen
system limit applies
only if the mill is
unable to
differentiate
emissions between
the two systems.
4.1 Standards for kraft pulping system vents
The NESHAP requires the pulping system emission points to be enclosed,
collected in a closed-vent system, and then vented to a control device. This
section describes the emission points that must be controlled, the five
alternative emission limits, and the compliance requirements.
What kraft pulping system vents must be controlled?
The NESHAP specifies that vents from the mill systems must be controlled.
All the vents from the LVHC system must be controlled. The HVLC vents
requiring control vary based on the quantity of emissions and whether the
source is new or existing.
The Following Pulping Systems Must be Controlled -.
Existing Sources
LVHC system
• Pulp washing system
• Oxygen delignification system
• Decker systems that use any process water other than fresh water or paper machine
white water, or process water with a concentration of HAPs greater than 400 part;
per million by weight (ppmw)
• Knotter systems with HAP emissions equal to or greater than O.I pounds per tor.
oven-dried pulp
Screen systems with HAP emissions equal to or greater than 0.2 pounds per;. T,
oxen-dried pulp
• Combined knotter and screen systems with HAP emissions equa! to or '.irea;,-: :'...•
0.3 pounds per ton oven-dried pulp
New Sources
• Same as existing sources plus... .
• All decker systems
• All screen systems
• All knotter systems
• All weak liquor storage tank vents
Each equipment system has multiple emission points. For example, the e\ aporator system
comprises pre-evaporators, multi-effect evaporators, concentrators, vacuum systems.
associated condensers, hot wells, and condensate streams. A complete list of the emission
points in each equipment system is provided in Appendix F.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
52
-------
These emission
limits apply to
each control
device.
A sixth alternative
is crcailablefor
kraf: //I 'L C system
vents only. See
Section 4.4 for an
explanation of the
Clean Condensate
Alternative.
What are the emission limits for kraft pulping system vents?
The emissions from kraft pulping system vents must meet one of five
alternative emission limits, as shown below. These emission limits apply to
each control device used to control HAP emissions. A mill will likely use
several closed-vent systems and control devices (including both add-on control
devices and existing combustion devices) and each can comply with any of
these five alternative emission limits. These emission limits apply to both new
and existing sources.
Pulping System Ye«t Gases Must be Collected in a Closed-vent System
and Routed to One of These Five Control Devices..,
A boiler, lime kiln, or recover.7 furnace in which the HAP gas stream
is introduced with the primary fuel or into the flame zone
A boiler, lime kiln, or recover.' furnace with a heat input capacity of
at least 150 MMBtu hr in which the HAP gas stream is introduced
with the combustion air.
A thermal oxidizer operated at a minimum temperature of 1.600CF
and a minimum residence time of 0.75 seconds
A thermal oxidizer that reduces the total HAP concentration at the
outlet to < 20 ppmv corrected to 10% O; on a dry basis, measured as
total HAPs or methane 1
Any control device that reduces total HAP emissions by >98% by
weight, measured as total HAPs or methanol
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
53
-------
A closed-vent
system means a
system that is not
open to the
atmosphere and
comprises piping,
ductwork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems?
All regulated equipment system vents must be enclosed and routed through a
closed-vent system to the control device that is selected for compliance. The
requirements for enclosures and closed-vent systems are presented below. The
requirements are intended to prevent leaks and ensure that process openings
(e.g., sampling ports on a brown stock washer enclosure) are closed while the
mill is in operation.
This Etptipment....
Mas* Meet These Requirements....
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance.
or repairs
Components operated at positive
pressure
Operate with no detectable leaks
(500 parts per million by volume
[ppmv] VOC above background»
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so that
the valve or closure mechanism
cannot be opened withou; break;:...:
the seal
or
If computer controlled, monitor fur-
presence of gas stream flov. at K-as.
once even' 15 minutes
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
54
-------
Compliance Dates:
LVHC system:
April 16, 2001
HVLC system:
April 17, 2006
HVLC systems that
comply before
April 16, 2001 are
not required to
submit a
compliance
strategy- report.
When must mills comply with the kraft pulping vent standards?
The LVHC system sources at kraft mills must comply with the NESHAP by
April 16,2001, while the HVLC system sources must comply by
April 17, 2006.
For HVLC system vents complying after April 16,2001, a non-binding
compliance strategy report must be submitted initially and updated every
2 years until compliance is achieved. The compliance strategy report must
contain, among other information, a description of the emission controls or
process modifications selected for compliance and a compliance schedule
indicating when each step toward compliance will be reached.
For safety purposes, kraft mills typically separate pulping vent streams into two
groups: low volume, high concentration (LVHC) vent streams and high
volume, low concentration (HVLC) vent streams. The NESHAP does not
specify- which vents must be routed to the LVHC and HVLC collection
systems. Each mill makes this decision. However, compliance dates are based
on EPA's definition of LVHC and HVLC system equipment, and these
compliance dates do not change based on how a mill chooses to collect their
system vents. For example, a mill could control an evaporator vent (LVHC
source) along with a group of HVLC vents. In such cases, the emissions from
this closed-vent system would have to comply by April 2'001, because 2001 is
the compliance date specified for the LVHC system source.
Chapter 4 • NESHAP Requirements
Kraft Mills
Pulping System Vents
55
-------
The test method
specified is used to
determine pollutant
concentration.
Additional
calculations or
formulas are
svecified in the
NESHAP to
convert the
concentration
values into the
appropriate format
to demonstrate
compliance with a
particular emission
limit.
How does a mill demonstrate initial compliance with the kraft
pulping system vent standards?
A mill must demonstrate compliance through an initial performance test for
each closed-vent system and control device. However, the rule contains three
alternative emissions limits for which an initial performance test of the control
device is not required. If a mill complies with the pulping system vent
standards by venting the gases to a boiler, lime kiln, or recovery furnace, the
mill must demonstrate only that the gases are being introduced with the
primary fuel or into the flame zone (or with the combustion air if the heat input
rate of the boiler, lime kiln, or recovery furnace is at least 150 MMBtu/hr).
Also, if a mill complies with the pulping system vents standards by venting the
gases to a thermal oxidizer operating at the minimum design specifications, the
mill must demonstrate only that the gases are being properly introduced into
the thermal oxidizer.
The initial performance test has three objectives:
(1) To demonstrate that each control device complies with the emission
limit. Refer to Figure 15.
(2) To demonstrate that the closed-vent system captures and contains
all HAP emissions. Refer to Figure 16.
(3) To establish the process operating parameter values that must be
monitored to demonstrate continuous compliance. For example, the
test would establish the minimum fire box temperature of the thermal
oxidizer that indicates 98 percent by weight reduction of total liAPs.
Figure 15.
How Does a Mill Demonstrate Initial Compliance with
the Kraft Pulping System Vent Emission Limits?
To Demonstrate Initial
Com pfiaoce With This
Emission Limit...
Introduce HAP emission
stream with the primary fuel.
into the flame zone, or with
the combustion air
Operate at a minimum
temperature of 1,600CF and a
minimum residence time of
0.75 seconds
Reduce the total HAP
concentration at the outlet to
s 2C ppmv corrected to 1 0%
O2 on a dry basis
Reduce total HAP emissions
by ;> 98% by weight
Conduct an Initial
Performance Test Following
This Methad_
None required. Demonstrate
that gases are properly
introduced.
None required
Method 308 ,
Method 308
ToMeasurt Thcst. \
Farameiers... \
None required
None required
Total HAP or methane!
concentration at the outlet of
the thermal oxidizer
Total HAP or methane i r-i.:
at the control device inlet ana
outlet
Chapter 4 • NESHAP Requirements
Kraft Mills
Pulping System Vents
56
-------
Continuous
monitors are
required except for
vent streams that
are combusted in a
lime kiln, recovery
furnace, or boiler.
These same tests
are require J as
part of the initial
performance test.
How does a mill demonstrate continuous compliance with the
kraft pulping system vent standards?
Mills must install a continuous monitoring system to measure either HAP
concentration or control device operating parameters. Figure 17 presents
the monitoring, reporting, and recordkeeping requirements for each
alternative emission limit.
In addition, a mill must periodically inspect and maintain all enclosures and
closed-vent systems. These requirements are explained in Figure 16. The
mill must maintain a site-specific inspection plan for the enclosures and
closed-vent system. Records of all inspection results and repairs must also
be kept according to the specifications of 40 CFR 63.454.
Figure 16.
How Does a Mill Demonstrate Initial and Continuous Compliance with
the Closed-Vent Systems Standard?
If tta System has.-
Enclosure opening
Ciosed-^eni system
Positiie p'esiure
closed-1, sr.; system
Bypass !:'-.-• \a!\e
Then Inspect...
Visually inspect every 30
days to ensure closed and
sealed
Annually demonstrate
negative pressure
Visuall) inspect e\erv 30
da\ 5 for visible defects
Annually demonstrate no
detectable leaks (less than
500 ppmv)
Inspect every 30 da\ s to
ensure valve is in a closed
position and vent stream is
not diverted through
bypass line
And Report...
Any exceedences of the
closed-vent standard in
quarterly reports. If no
exceedences occur, submit
semi-annual reports
Same as above
Same as above
Same as above
Same as above
And Keep
Records ot..
All visual checks and
any repairs
All pressure tests
All visual checks and
repairs
All leak tests
All visual checks and
repairs
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
57
-------
O)
JO.
CL
2
Q)
fl
8 |I
3> iS
11 c S
O ^
re
*^
(A
C
O
o
o
re
(A
Q>
O
Q
O
en
>s
-
f. $j
>>•%
tn c
S £
c 2
53 «
.S a.
?
e
U
u
.s
O ^^ "*^
S|I
2! C
S **
ca S
1
3
£~
_p
^
t>
"Z.
-o
^
' ^
S"
c
2
HAP emission
ith the primary
the flame zone,
e combustion
8 *s«
•§ E-S«
O 03 - >
- £ T3 ? i-
£ S «S S -a
£
3
'3
8.
E
X
^
£
to.
•£ cu en /-s
o •- 2 >•* •— •
CL *^ c "fc-
£ Jo 'S t ~
| •- S g_ =.«
u E "c £ C M
« u en 0 •£ O
C " C C „ T
P C 0 CO I- ^-"
Certify in the perfor
the minimum reside
Semi-annual emissii
monitoring perform
If exceedences occu
reports are required
• • •
u
3
7s
^
u
E
0
X
o
£
tZ
_ U.
P o >r>
3 o r-
•i8- £
1• -— '
c ™ 2
•— £
C i _-' " ^*^
s a§-^
•o o e u.
en 0 •£ 0
C C - T
rt C3 ^ "^^ '
Semi-annual emissii
monitoring perform
If exceedences occu
reports are required
* •
a
3
CC
C.
£1
'-> U
X °
£
tz
CO
|
**
O
o
u
o.
X
o
1
n*
= •£ E ~
2 « &i
o c o —
« -S N 2 „,
Hill
lli it
Oc u o u co
£
1
8.
E
u
X
^d
_£
""
u
CO
tn
C3
1
re
V*
1_"
O
S O
• — 1—
11
S E
E «
0) *"
CO -C
ao tu
.E c
.= 0
'£ E
2
1
.OT
c
•o
tu
.c
>>
"S
1
1
e
u
1
1
CL
£
re
C/5
CO
0>
re
^
re ^
is' ^'
"^ ' ~ "*^ ,
fj l^, r- — '"•
•? .E •£ :•= s i
| 'i § 1 1
C |«j ^ -j- "*
g .N p .E tn^
^3 R ™ ^y k—
CD 2 ^ _^ o "^
"« "rt ^ ^ 2 ~
gl'fl 1 1
,e j= 3 « t £
>. •" C. « tu Ji
l> CO O tu O- <
x>
ca ^
I Al
O en
— C
u .2 *-
« 'en -C
•i .22 .SP
tu C -.
•£
«
58
-------
Must a mill comply at all times?
The \ESK4P does
no! specify- rigid
averaging times.
but rather allows
Slate permitting
authorities
flexibility- in
establishing mill-
specific times.
Check the AJT1'
periodically for
additional
information
concerning
averaging times.
For pulping system vents, the NESHAP establishes an allowable percent of
operating time during which HAP emission levels in excess of the
established limit shall not be considered to be a violation of the standard.
Periods of excess emissions include when the control device is inoperable
and when the operating parameter values established during the initial
performance test cannot be maintained at the appropriate level. The
allowance is hi addition to excused periods under the startup, shutdown or
malfunction provisions, and is calculated by dividing the time of excess
emissions by the total process operating time in a semi-annual reporting.
period.
The excess emissions allowances are:
• 1 percent of operating time for control devices used for
LVHC system vents
• 4 percent of operating time for control devices used for
HVLC system vents
4 percent of operating time for control devices used for
combined LVHC and HVLC system vents (i.e.. controlled by
the same device)
Even though periods of excess HAP emissions may be exempt under the
M.-\CT requirements, these periods of excess emissions must still comply
with NSPS total reduced sulfur (TRS) requirements, and any applicable
Slate requirements.
11' calculate the percent of periods of excess emissions in a semi-annua!
per;, ,:. divide the number of hours in the reporting period during which the
control device was not operating or parameter deviations occurred by the
total number of process operating hours and multiply by 100 percent. For
example, to calculate the semi-annual excess emissions for an LVHC
system control device where the device down time was 25 hours and the
total process operating time was 4.250 hours:
Control device down time
Total process operating time
100%
25 hours
4,250 hours
100% = 0.59%
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping System Vents
59
-------
The condensate
streams subject to
control and the
alternative emission
limits are the same
for new and existing
sources.
Liquid streams
intended for
byproduct recovery,
such as the combined
turpentine,'v>.ater
streams prior to the
turpentine decanter
or concentrated black
liquor, are not
considered process
condensate streams
subject to the control
requirements of this
regulation.
4.2 Standards for kraft pulping process condensates
The NESHAP requires condensate streams from the pulping system to be
collected in a closed collection system and treated. The NESHAP provides
five alternative emission limits (shown on page 61). This section describes
the condensates that must be controlled and the alternative emission limits.
What is a condensate and why control it?
Kraft pulping condensates are HAP-containing liquids that are condensed
from pulping system vent streams. These HAP-containing liquids result
from the contact of water with organic compounds in the pulping process.
In absence of this rule, most condensates would be discharged into open
collection systems and transported to either the wastewater treatment plant
or a publicly owned wastewater treatment plant. The emissions of concern
are the HAPs that volatilize as the condensates travel through these open
systems.
What kraft pulping condensates must be controlled?
The NESHAP requires control of condensates from all of the equipment in
the following systems:
• digester system
• turpentine recover}' system
• evaporator system (condensates from weak liquor feed stage
vapors and vacuum systems only).
• LVHC collection system
• HVLC collection system
The LVHC and HVLC collection system condensates means those
condensates generated by the condensation of moisture in the closed-vent
collection systems that convey the LVHC and HVLC system vent gases to a
control device.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
60
-------
Does the mill have to collect all those streams?
By segregating
condensate streams
containing the
greatest amount of
HAP and treating
only these streams, an
equivalent emission
reduction can be
achieved at a lower
cost. t
Most mills are
expected to use
steam stripping for
alternative
emission limits 4
and 5.
No. A mill may choose to collect and control all the condensate streams
from the equipment systems listed on page 60. Alternatively, the NESHAP
contains two options for minimizing the volume of condensate that must be
treated (referred to as volume reduction options). These options are
summarized below.
A MB! Mwrt Collect and Control On* of lire Following
CombiBatiojis of Streams...
All condensate streams
Volume reduction option 1: Treat all LVHC and HVLC collection system
streams plus streams that contain 65% of the total HAP mass from the digester
system, turpentine recovery system, and evaporator system (only condensates
from weak liquor feed stage vapors and vacuum systems)
Volume reduction option 2: Treat any subset of the regulated streams that
contain in total 7.2 Ibs HAP per ton of oven-dried pulp at mills that do not
perform bleaching or 11.1 Ibs HAP per ton of oven-dried pulp at mills that
perform bleaching
What are the control requirements?
The NESHAP provides five alternative emission limits for condensate
streams as shown below. The three strategies expected to be used by most
mills are: recycling, biological treatment, and steam stripping.
Kraft Palping Process Condensates Must be Collected in a Closed-collection
Svstem and Treated to Meet Oneof These Five Alternative Emission Limits...
Recycle the condensate to a piece of equipment that meets the control
standards for pulping system vents (see page 53 i
Use a biological treatment system to reduce or destroy the total HAPs" to meet
the emission limits in alternatives 3 or 4
Treat the condensates to reduce or destroy the total HAPs by >92°o by weight
Treat the condensates to remove 10.2 pounds HAPs per ton of oven-dried
pulp at mills performing bleaching or 6.6 pounds HAPs per ton of oven-dried
pulp at mills that do not perform bleaching
Treat the condensates to achieve a total HAP concentration of s330 ppmw at
the outlet of the control device at mills that perform bleaching or <210 ppmw
at the outlet of the control device at mills that do not perform bleaching
Measured acetaldehyde, methanol, methy 1 ethyl ketone, propionaldehyde
Measured as either the sum of acetaldehyde, methanol, methyl ethyl ketone, and
propionaldehyde, or as methanol.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
61
-------
The compensate
tank requirement
applies only to
tanks used to store
or handle the
regulated
condensates, not
tanks used Jo store
weak liquor.
What does the NESHAP require for condensate closed
collection systems?
Regardless of the emission limit selected, the condensates subject to control
must be transported in a closed collection system such that no emissions
occur. The NESHAP requirements for closed collection systems are
presented below.
Tfcis Eqaipisent....
Must Meet ALL of These
Requirements....
Closed collection systems used to
transport pulping process condensates
containing HAPs
All of the individual drain system
requirements specified in §63.960,
63.961, and 63.962 of Subpart RRa
and any air vents in the collection
system must meet standards of
§63.443 (c) and (d) for the closed-vent
systems and HAP reductions for kraft
pulping system vent emissions
Condensate tanks used in the closed
collection svstem
.Operate with no detectable leaks
(500 ppmv VOC above background)
and
Vent emissions to a closed-vent
system (see page 54) and route to a
control device (see page 53)
and
When the tank contains pulping
process condensates or any RAP
removed from the pulping condensate
stream, all openings must be kept in a
closed, sealed position - except
during sampling, inspection.
maintenance, or repair operations
Subpart RR of 40 CFR 63 (National Emission Standards for Individual Drain Systems
establishes design, operating, inspection, and monitoring requirement standards for
controlling air emissions from individual drain system.s. The standards control
emissions from individual drain systems using covers or seals, or hard-piping
Subpart RR also requires inspections of water seals and closure devices for defects or
damage initially and establishes repair requirements for individual drain systems. The
NESHAP requires inspection every 30 days.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
62
-------
The mill can meet the closed collection system requirements in two ways:
• Hardpiping
• Use existing drains, but cover all openings and route all open
vents through a closed-vent collection system to a control
device meeting the NESHAP requirements for pulping
system vents.
If there are air vents off the closed collection system, these vents must be
routed to a closed-vent system. These air vents must comply with the kraft
pulping system standards for closed-vent systems and HAP emissions (see
pages 53 and 54).
When must a mill be in compliance?
Mills must achieve compliance with the pulping process condensate
requirements by April 16. 2001.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
63
-------
For demonstrating
initial compliance for
the krafi pulping
process condensate
standards, total HAPs
are measured as
acetaldehyde.
methanol. methyl
ethvl ketone. and
propionaldehyde
How does a mill demonstrate initial compliance for /craft pulping
process condensate standards?
Mills must conduct a performance test to demonstrate initial compliance. A
performance test is required for each closed collection system and treatment
option.
With respect to pulping condensates, the performance test serves four
purposes:
(1) To demonstrate that the appropriate condensate streams are
being collected and treated. The options for determining the
streams to be collected and controlled are presented on page 61. If a
mill uses one of the volume reduction options, the NESHAP
requires documentation to support the choice. For example, if a mill
opts to control condensate streams based on mass of total HAPs. the
mill must present test results to support that a complying mass of the
total HAPs is collected. Even in the case where a mill chooses to
collect and treat all pulping condensate streams, the mill must
demonstrate that all of the condensate streams have been identified
and collected.
n\
(3)
To demonstrate that the closed collection system does not allow
any emissions to occur. Refer to page 62.
To demonstrate that the control device complies with the
emission limit. For all alternative emission limits excep: bioiogica1
treatment, the mill can measure either total HAPs or methane:
concentration to document compliance with the emission lirnr.s Fo:
biological treatment, total HAP concentrations must be measure^.
See Figure 18. .
(4) To establish the process operating parameter values that must
be continuously monitored. During the performance test, th*. rni'l
must measure the parameter values that the mill will monitor to
indicate continuous compliance. For example, the values of steam
feed rate, condensate feed rate, and temperature are specified as the
monitoring parameters for steam strippers.
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
64
-------
For the recycle
treatment option,
the performance
test would consist
only of verifying
that no leaks were
present in the
closed collection
system and
confirming closed-
vent system and
control device
requirements.
The test method
specified is used to
determine liquid
stream polhitan:
concentration.
Additional
calculations or
formulas are
specified in the
NESHAP lu
convert the
concentration
values into the
format appropriate
to demonstrate
compliance with a
particular emission
limit. '
Figure 18.
How Does a Mill Demonstrate Initial
Compliance with Kraft Pulping Condensate Emission Limits?
To Demonstrate Inttiai
Complice With This
Eipisstaft&fcniL.*
Recycle the condensate to
controlled equipment
Use a biological treatment
system to meet 92%
reduction or to meet mass
limits
Treat condensates to meet
s92°/o reduction
Treat the condensates to
meet ma;s limits
Treat the condensates to
meet concentration limits
CoBdactaa initial
PerfefrasBf* Test
Following This Method.,.
None required
Method 305"
and
Part 63, Appendix C
Method 305'
Method 305a
Method 3052
To Measure These
Paraneters-.
None required
Total HAPs"
and
Fraction of total HAPs"
removed (4J
Total HAP11 or methanol
mass at the control device
inlet and outlet
Total HAP" or methanol
mass at the control device
inlet and outlet
Total HAP6 or methanol
concentration at the control
device outlet
1 The National Council of the Paper Industry for Air Stream Improvement (NCASI) direct
injection gas chromotography/flame ionization detection (GC/FID), may be used as an
aitemati\e to EPA Method 305 for measuring methanol.
* Measured as aceta!deh\de. methano!. methyl ethyl ke'one. and propionaldehyde.
How does a mill demonstrate continuous compliance with
pulping process condensate standards?
Mills must install continuous monitors to measure control device operating
parameters, except when recycling condensates to controlled process
equipment. In addition, quarterly testing is required if a mill chooses to
comply using biological treatment. The monitoring requirements depend on
the alternative emission limit selected. Figure 19 summarizes the
monitoring, reporting, and recordkeeping requirements for each alternative
emission limit.
The closed collection system must be visually inspected every 30 days
according to the following requirements':
• National Emission Standards for Individual Drain Systems
(63.964 subpart RR) requires inspection and monitoring
Chapter 4 - NESHAP Requirements
Kraft Mills
Pulping Process Condensates
65
-------
c-
£
E
o
•'5
J2
u
(0
(0
o
T3
C
O
o
(A
(0
0)
U
O
O)
C
3
0-
£
2
oi ^
11
O) Q)
il g
.2
"5.
o
o
v>
3
O
3
C
O
O
S
(A
O
0>
Q
re
(0
o
o
Q
o
X
, 1
w
^t
in
£
N> fe
W
1
a.
|
*
_o
'eo
£
h»
4^v
e
ca
^C
tl
O
[^
^
c
^
c-
t:
•o
tu
3
CT
e
o .
~^J
=r
•j
£
^
Z
•^ • i
"•* ^ i
? ^
^•i ^
S ^
^- *
— ' ^
-O ^
%^
fi::-:''.-;;-;;:.Thcsc;
... (S
-2 Jjs
1/J- i-! ,-fTt
1Sf~ ^S jfSc £M *
Ilfra/Murciiil
|||:;|;£0inpiyr$!
|A,lteruatlve Em
!il|Limite:tJsirig:?
illl!!STechnicj«e>
•p
o
Z
o
re
z^i
sj
Recycle the cond
to controlled
equipment
4>
2
TJ
Process wastewater fee
u 2^
c <5
c C
E —
-o <£ ^
ra *^ qj
u. ^
c 2f
o .= b
"as S "B ^
Tl £'!§
"re "~ y w o-i
— i£ 3 ^ *O
= " "O re «x
c s to re Oi
.2 .£ c 8 r b
~ — o x o
1 1 §•£ at.
* *
o
'M
^
5J
^>
k.
S
Process wastew;
2
•o
E
re
55
^>
>
0
re
to
re
5>
E
re
00
a
T3
re
u
55
•o
u
c
E
3
Process wastewater col
temperature
^
>
0
JS
^)
E
re
00
•73
°^
^
^
«—
^
c
o
o
Process wastew;
temperature
^,
S g
U* C
O. J-
^-^^ O
» c
& ' ~
'S =" 2
1 1 | I
« -o £ c
^s u o E
co c o —
c
o
1
§
g
Steam stripper outlet ci
o
re
«
re
i>
^
^
00
~
^~
^
u
c
o
'S
•r;
Steam stripper c
Steam stripper
(concentration)
re
0
E
£
en
CO
u.
0
HAP percent reduction
u
• >
c.
re
re
o
E
•^
00
™
•^ ~
^ "^
'-* i-
— o
a. £•
< 5
— tn
1. CO
Quarterly test ol
reduction or ma:
Outlet soluble BOD,
u
o
re
CO
re
u
E
re
on
1
r^
0
Outlet soluble 13
T>
"o
in
U
•o
1
«
3
Mixed liquor volatile si
o
C5
C3
W
£
[•j
oo
1
£
o
c.
to
P
«i
r^
*3
O
o
.5-
'i 1
a
C
Horsepower of aerator
i>
>
re
re
o
P
re
00
-
-M
'"
JJ
—"
o
u.
Horsepower of i
o
'5
u
>
o
re
V)
re
u
E
re
C/0
3
1
•o
3-
i
Liquid temperature
0
re
re
cr
ff
O
E
^
c
1 i
~ 'w
C u
C- • ™
~ ^"
"C '^f
CO r-
S v:
"C V
Operating paran
the Administrall
">
T3
.C
6
u
i
en
03
U
E
5J
>
c
"re
o
P
re
00
0)
^.
Volume reductioi
options
-a
j: TJ
11
e O
II
11
2 £>"
"(3 -j;
"QJ re
u ~
re cr
•O «>
CJ r-
^ C
r-i
u ;=
-0 -
O
C
re
<
CO
Lu
Z
S •£ '->
*•* • ^ **~
.± i<
'u S
ll
u < £ "5
c. i- — S
0> '-
c "re - 'C
re E i_ o
E 5 3 .=
C ',-> I— —
"£ £ =. =
" c- ^ 3
f= U i •-
t— ^ <-> oo
66
-------
Although there are
no explicit back-up
control
requirements as
part of the
NESHAP, back-up
controls may be
necessary for mills
that are concerned
that the excess
emission allowance
is inconsistent with
expected control
device operating
experience.
• Subpart S requires reporting and recordkeeping of all visual
inspection results. Semi-annual reports must be submitted.
If exceedences occur, then quarterly reports are required.
Must a mill comply at all times?
The NESHAP provides a 10 percent excess emissions allowance for all
control devices other than biological treatment systems (63 FR 49455). For
example, the allowance would include steam stripper tray damage or
plugging, efficiency losses in the stripper due to contamination of
condensate with fiber or black liquor, steam supply downtime, and
combustion control device downtime.
Unlike the pulping standard, the 10 percent allowance for condensates
includes excused periods of excess emissions associated with the startup.
shutdown, and malfunction.
Chapter 4 • NESHAP Requirements
Kraft Mills
Pulping Process Condensates
67
-------
Bleaching is the
brightening of pulp by
the addition of
oxidizing or reducing
chemicals.
A bleaching line is
a group of
bleaching stages
arranged in a
series such that
bleaching of the
pulp progresses as
the pulp moves
from one stage to
the next. Typically
a bleaching line
contains
3-5 stages.
4.3 Standards for the kraft bleaching system vents
At kraft mills, the emission limits apply to bleaching systems that use
chlorine or chlorinated compounds. The rules have emission limits for both
chloroform and chlorinated HAP (excluding chloroform). Kraft mills must
comply with both of these requirements. This section describes the
emission points that must be controlled, the alternative emission limits, and
compliance requirements.
What bleaching emission points must be controlled?
The NESHAP applies only to bleaching lines that use chlorinated
compounds and only to the bleaching stages where chlorine or chlorinated
compounds are introduced. Extraction stages are not covered. All vents in
a regulated stage must be controlled. A stage consists of the following
equipment:
• retention towers
• washers
• seal tanks
• chemical and steam mixers (if vented to the atmosphere i
• vacuum pumps (if present)
Are there any exemptions to the bleaching requirements?
Yes. .Any bleaching system that does not use chlorine or any chlorinate"
HAP is exempt from all NESHAP requirements for bleaching
Chapter 4- NESHAP Requirements
Kraft Mills
Bleaching Systems
68
-------
What are the control requirements for chlorinated HAPs?
The requirements for
enclosures and
closed-vent systems
are the same as for
the pulping system
vent standards
(page 54).
The equipment at each bleaching stage where chlorinated compounds are
introduced must be enclosed and routed via a closed-vent collection system
to a control device. The rules provide three alternative emission limits for
demonstrating compliance, as shown below. Most mills are expected to use
caustic scrubbers to comply.
Bleaching System Cases Most be Collected in a Closed-veal System and Meet One
-------
Bleaching Systems
Compliance Dates:
' Most mills:
April 16, 2001
Mills enrolled in
VATIP: April 15,
2004
VATIP is available
only to papergrade
kraft and papergrade
soda mills that
discharge directly to
receiving waters.
The application rate
limitation and the
dioxin and
adsorbable organic
halide limits are
provided to prevent a
bleaching system
from "backsliding"
(i.e.. increasing
chlorinated bleaching
chemical use during
the extended
compliance period).
When must bleaching systems comply?
Bleaching systems must comply by April 16, 2001 with two exceptions.
• Mills enrolled in the Voluntary Advanced Technology
Incentives Program (VATIP)
• Dissolving grade kraft mills
Voluntary Advanced Technology Incentives Program (VATIP). Under the
Effluent Limitations Guidelines and Standards (40 CFR Part 430.24), a mill
may choose to enroll one or more of its bleach lines in the Voluntary
Advanced Technology Incentives Program. The program provides extended
compliance with the water pollution control requirements for bleached
papergrade kraft and soda mills in exchange for achieving greater water
pollutant reductions than the regulatory baseline. Mills electing this
program receive a 3-year extension for complying with the NESHAP
bleaching standards (i.e., must comply by April 15, 2004). Three conditions
must be met to qualify for the extension.
(1) Comply with the interim MACT standard for chloroform
emissions by either:
No increase the application rates of either chlorine or hypochlorite
(in kg per Mg oven-dried pulp) in the bleaching system beyond the
average daily rates used over the three months prior to June 15.
1998,
or
Comply with the enforceable effluent limitations guidelines
for 2,3,7.8 - tetrachloro-dibenzo-p-dioxin and adsorbable
organic halides at least as stringent as the BAT levels set out
in 40 CFR 430.24(a)(l) asexpeditiously as possible, but no
later than by April 16, 2001.
(2) Submit a control strategy report by April 1999 (see 63.445(b)).
(3) Submit an updated control strategy report every two years
under 63.455(b) until compliance is achieved. The report
must contain milestones and status reports for achieving
compliance.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
70
-------
The compliance
date for dissolving
grade kraft mills is
not specified in the
NESHAP. but is
anticipated
between
2003-2005.
Dissolving grade kraft mills must comply within 3 years after publication
of revised effluent limitations guidelines and standards under 40 CFR
430.14 through 430.17 and 40 CFR 430.44 through 430.47. These rules are
scheduled to be revised sometime between 2.000 and_2002.
How does a mill demonstrate initial compliance with the
bleaching standards?
Chlorinated HAPs. Mills must demonstrate initial compliance with
chlorinated HAP standards by conducting an initial performance test for
each bleaching stage where chlorine or chlorinated compounds are
introduced.
The initial performance test has two objectives:
(1) To demonstrate that the control device complies with the
emission limit.
(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 16.
(3) To establish the process operating parameter values that
must be monitored to demonstrate continuous
compliance.
At the option of the mill, compliance may be demonstrated by measuring
either total chlorinated HAPs (including chloroform) or chlorine
concentration. The follovvins methods must be used:
Chlorinated HAPs
Chlorine
Any method that has been
demonstrated to the Administrator's
satisfaction.
Method 26A, as modified by
63.457(b)(5)oftherules.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
71
-------
Continuous
monitoring is
required unless a
mill complies by
eliminating all use
of chlorine or
chlorinated
compounds as
bleaching agents.
These same
demonstrations are
required as part of
the initial
performance test.
Chloroform. No initial performance test is required if the mill chooses to
eliminate use of chlorine and chlorinated HAPs. The mill must demonstrate
in the initial notification that is hot using these chemicals. Alternatively, if a
mill chooses to comply with the Effluent Limitations Guidelines and
Standards, then all compliance demonstration requirements of 40 CFR 430
apply. „
How does a kraft mill demonstrate continuous compliance with
the bleaching standards?
For chlorinated HAPs, mills must install a continuous monitoring system
to measure either emissions, or control device or process operating
parameters. The monitoring, reporting, and recordkeeping requirements are
summarized in Figure 20.
In addition, the mill must conduct periodic inspection and maintenance of
all enclosures and closed-vent systems. These requirements are explained
below. The mill must maintain a site-specific inspection plan for the
enclosures and closed-vent system. Records of repairs based on the
inspections must also be kept.
If tbe System has—
Enclosure opining
Closed-vent system
Positive pressure
closed-vent system
Bypass line valve
Then Inspect..
Visually inspect every 30
days to ensure closed and
sealed
Annually demonstrate
negative- pressure
Visually inspect ever. 30
days for visible defects
Annually demonstrate no
detectable leaks (less than
500 ppmv)
Inspect every 30 days to
ensure valve is in a closed
position and vent stream is
not diverted through
bypass line
And Report™
Any exceedences of the
closed-vent standard in
quarterly reports. If no
exceedences pccur. submit
semi-annual reports
Same as above
Same as above
Same as above
Same as above
Am) Keep
Record* of _
All visual checks and
any repairs
All pressure test? |
All visual ;heck; .ir. i
repair^ \
All leak test* I
All visual checks and
repairs
Note: This is the same table as the one presented on page 57.
For chloroform, if the mill chooses to eliminate the use of hypochlorite and
chlorine, then no parametric monitoring is required to show continuous
compliance. If the mill chooses not to eliminate the use of hypochlorite and
chlorine, then the mill must comply with the effluent limitations guidelines
and standards.
Chapter 4 - NESHAP Requirements
Kraft Mills
' Bleaching Systems
72
-------
e Records for S
:-,•, J
.::.;:.i:-;^> :H.
' :. -.-. "•" " o.
>•.?.:•:-• $
^
'•::•.:• :- e
.•-•• .<
:
e
^o
E
£
a
"**
s
;.;
^
*
o
£.
-
"~
_
t^m
o
~S
5
o
a.
|
t3
13
U
k.
"c
o
re
-3
)<
= e
o J
"a."y
y >*
y ~
5 r
§L_
2
-a '-£ ~
= 5 "S-
•i '£ S "? —
•n Z o JJ —
Z •— o •— y
s 2 S |£ -
— = <-> d •
= = J y 5
= £ S " atf
~ ^ „ y ;2 —
• — - — ^- "^ kt ^J
1 I §-,* 1 =
ly. ,-* -J -*— D ^^
• •
-I
i/- 1 —
•V 1 ~
M
c :
C !«•
c «
? «*
Continuously 1
Pa rani
If « Mill Chooses This
Technique to Comply
With This Alternative
Emission Limit...
^
—
2
'-*
~
u
^.
X
i- 3
O 3
"c. "o
1
S
0
X:
re
c/5
re
y
cr
re
C/5
U
re
u.
0
y
,c
V)
re
00
y
>
£
2
|
c
u
3
gj
^
o-
Scrubber
y
>
^~
r;
^:
re
y
«
ir.
v
w
^
C
—
^J
™
^
^
• '5
_o~
£
-O
k.
u
yj
U ^ CO fc.
^ ^^ i^ 8. ex
iillillf
£ ~= -° 2 120^-3
^i£SSo«7
225f£dgg
M.I §^ r§ °
oilllsll
u
rj
*©
"3
3
o
«
k>
U
u
c
o
• Chlorine i
following
y
>
£
• re
«
y
re
y:
L.
y ..
— st
s 'i
y -
~ ^
re ~
~- _c
• — .
Chlorine concentral
measure all three o
parameters
^M
O
"<5
eduction potent!
IS
•a
'x
0 c
Jr u
O 3
IE
a. u
u
>
0
x>
re
-jn
re
0
re
^;
"re
'^
5
c
c_
5
u
2
pM or oxidation/red
effluent
»
o
c
s
_c
V)
re
30
C
u
u
>
o
x>
re
01
re
u
£;
re
Cfl
u
CO
u.
1
J?
^c
(/)
eo
00
C
u
u
s
1
c:
c
u
3
C
C
_•«
'5
g-
1
X)
1
y
• >
O
X)
re
VJ
re
u
re
c«
—
're
u.
J
0
„
u
Scrubber liquid int]
y
> c
.SJ 2 a,
111
25 =
fell
lS.il
g£ S |
« 3 2; °-
« O o o
*v r- *- — •
0 g^ V,
o
1
(A
\S
•V
U
1
1
1
D.
§•
V)
Parametei
y
>
xl
re
•*n
re
y
p
^
c^
i£ ^
_c .2
c .§ '
5 "
1 M
u c
.3 i;
Determine appropri
parameter values di
performance test
Any control device
other than a gas
scrubber or process
modincations
c
f>
v-i
•V
r*i
vo
I
a:
u.
O
73
-------
Mills in the voluntary advanced technology incentives program must
monitor compliance in the interim!
If a mill chooses the "no backsliding" alternative to comply with the interim
MACT standard for chloroform emissions, the NESHAP specifies
monitoring, reporting, and recordkeeping requirements. These
requirements, which are summarized in the figure below, apply from June
1998 up to the time that the mill demonstrates compliance with all the
applicable bleaching system-emission limits. The NESHAP does not
specify monitoring, reporting, and recordkeeping requirements for mills that
choose to comply with the BAT levels for 2,3,7,8, - tetrachloro-dibenzo-p-
dioxin and adsorbable organic halides instead of the "no backsliding"
alternative.
If a Mill Chooses
This Interim
Emission Limit*.
No increase in the
use of
hypochiorite and
cnlorine
Comply with the
BAT levels for
2.3.7,8-
tetrachloro-
dibenzo-p-dioxin
and adsorbable
organic halides
Then Continuously
Monitor These
Parameters...
Chlorine and
hypochiorite
application rates in .
Jb/ton oven-dried pulp
(daily average)
NoneJ
And Report This
Information...
An initial control
strategy report by
April 1999 that
meets the
requirements of
63.455. Updated
control strategy
report every 2 years.
and
Dajly application
rates ot" chlorine and
hypochiorite must
be reported every
six months .
NoneJ
And Keep These
Records for
5 Years...
Daily application
rates
I
I
NoneJ
*Comply with any monitoring, reporting, and recordkeeping requirements of
the BAT permit.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
74
-------
The CCA applies
only to the krqft
HVLC system:
• washers
• knotters and
screens
• deckers
• oxygen
delignification
4.4 Clean condensate alternative for HVLC vents
The clean condensate alternative (CCA) is a pollution prevention alternative
emission limit for pulping vents that is available only to kraft HVLC
systems. The CCA allows mills to meet the HVLC emission limits by
reducing the HAP concentration in the process waters that are recycled to
other pieces of process equipment. This approach allows mills to control
HAP emissions by reducing the amount of HAPs that are volatilized from
selected process equipment instead of using combustion devices to control
HVLC system vent streams. By reducing the HAP concentration in process
water, the amounts of volatilized HAPs are also reduced.
To achieve compliance, the facility must demonstrate that the HAP
emissioii reductions using the CCA technology are equal to or greater than
those emission reductions that would have been achieved through
compliance with the HVLC system requirements.
For example, a mill could use a stand-alone biological treatment device to
reduce the total HAP concentration in pulping process condensates. The
effluent from the stand-alone biological treatment device could be used as
process water in the pulping washing system and causticizing system. In
this scenario, initial compliance using the CCA would be demonstrated by
showing that the reduction of emissions from both the pulping washing
system and causticizing system is equal to or greater than the reductions that
would have been achieved by applying the pulping vent standards to the
puip washing system vent emissions.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
75
-------
The CCA is similar
to emission
averaging.
The concept of the
CCA is the reduction
of HAP emissions
through reduction of
HAP concentration in
process water.
The CCA can be
used by both new
and existing
sources.
Which equipment systems can be used to generate the
emission reductions?
Process condensates are recycled throughout the mill. The CCA allows
mills to take credit for emission reductions achieved in several systems
through the use of CCA technologies.
Sources frrom Wbkfc Eaiuies Reductions Caa be Credited^
Pulping systems (HVLC)
Bleaching systems
Causticizing systems
Papermaking systems
What emission reductions are creditable?
A CCA technology must achieve the emission reductions by removing
HAPs from condensate streams. The CCA emission reductions are
generated by either of two methods:
• control of condensates that are not regulated under the kraft
pulping condensate standard
• control beyond the levels required by the condensate
standard
Emission reductions from add-on controls on vent streams do not count.
Can a mill use the CCA for only part of the emission reduction
requirement for the HVLC system?
Yes. The HAP emission reductions resulting from the CCA can be used as
partial or complete fulfilment of the emission reductions required for the
HVLC pulping standard. For example, a mill may elect to use the CCA in
lieu of vent controls for the washer system, but comply by using vent
controls for the rest of the HVLC system.
Chapter 4 • NESHAP Requirements
Kraft Mills
Bleaching Systems
76
-------
All CCA emission
reductions must be
'based on actual
test data.
How does a mill use the CCA?
A mill must follow these steps to implement the CCA:
(1)
(3)
(4)
Determine baseline emissions. Baseline emissions are to be
measured after compliance has been achieved with all of the
following:
• Kraft pulping process condensate standards
• All effluent limitations guidelines and standards in
40 CFR subpart B
• Emission reductions attributable to control
technology required by local, State, or Federal
agencies
Furthermore, baseline emissions must include any control
equipment installed and operated before December 17, 1993.
Calculate emission reductions that would have been achieved
through compliance with the kraft pulping HVLC system
standards.
Measure emissions reductions achieved bv the CCA.
Emission reductions _ Baseline
achieved bv the CCA emissions
Emission levels after
the CCA has been
implemented
Demonstrate compliance through the CCA by documenting
that emission reductions achieved through the CCA are
greater than or equal to emission reductions that would have
been achieved through compliance with the kraft pulping
HVLC system standards.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
77
-------
Since the CCA
applies only to the
HVLC system, the
compliance date
for existing sources
is April H, 2006.
How does a mill demonstrate initial compliance?
A mill must conduct a performance test before and after CCA
implementation. Baseline emission levels and all CCA emission reductions
must be based on actual test data.
How does a mill demonstrate continuous compliance?
The control strategy using the CCA will vary among mills, depending on
mill configuration and emission points selected. Thus, the monitoring and
reporting requirements for the CCA are not specified in the rules. Each mill
must propose monitoring, reporting, and recordkeeping requirements for the
Administrator's approval.
What approvals are required to use the CCA?
Mills that opt to use the CCA must submit a CCA control strategy report
along with the initial notification. Updates are required every 2 years. The
requirements of the control strategy report are specified at
40 CFR 63.455(b) and 40 CFR 63.44.7(g).
The mill must report to the Administrator by the final compliance date the
rationale, calculations, test procedures, and data used to demonstrate
compliance. The Administrator will make the final compliance
determination.
Chapter 4 - NESHAP Requirements
Kraft Mills
Bleaching Systems
78
-------
In addition to TRS,
the NSPS limits
paniculate matter
from recovery
furnaces, smelt
dissolving tanks,
and lime kilns
4.5 How do the requirements for the NSPS and the
NESHAP compare?
The kraft NSPS (40 CFR 60, subpart B) contains TRS emission limits for
the following sources: the digester system, brown stock washer system,
evaporator system, recovery furnace, smelt dissolving tank, lime kiln, and
condensate stripper system. The kraft NSPS applies to equipment that was
constructed, modified, or reconstructed after September 24, 1976. Because
the pulp and paper NESHAP (subpart S) does not cover recovery furnaces,
smelt dissolving tanks, or lime kilns, the only equipment systems that have
overiapping NSPS and the NESHAP requirements are the digester, brown
stock washer, evaporator, and condensate stripper systems.
To demonstrate compliance with the NSPS and NESHAP (subpart S), it is
possible that the same device could be used to control emissions from these
equipment systems. Figure 21 compares the NSPS and NESHAP emissions
limits for the control devices that are likely to be used to comply with both
of these regulations. Note that only one control option (the thermal oxidizer
design requirement of 1600°F for 0.75 seconds) automatically satisfies both
the NESHAP and NSPS requirements. For all of the other potential control
devices mills must demonstrate compliance with both the NSPS and the
NESHAP.
Chapter 4 - NESHAP Requirements -
Kraft Mills • NSPS vs. NESHAP
79
-------
The MACT control
technologies can
be used to comply
•with the NSPS
limits for TRS, but
mills still must
demonstrate that
the NSPS emission
limits for TRS are
being met.
A thermal oxidizer
is the only option
where meeting the
NESHAP
automatically
meets the NSPS for
TRS.
Figure 21.
Comparison of NESHAP (Subpart S) and NSPS (TRS) Emission
Limit Requirements
, •. %
,x\ <&<;*
K«M&Um
TbtsCwrtral
Option.,.
Lime KJln
Recovery Furnace
Power
Boiler
Thermal Oxidizer
or other
combustion
device
Other
noncombustion
devices
' *" f
The NSPS
Re^mrOU.
A maximum TRS
outlet concentration
of 8 ppmv corrected
to 10% oxygen
Straight recovery: A
maximum TRS outlet
concentration of
5 ppmv corrected at
8% oxygen
Cross recovery: A
maximum TRS outlet
concentration of 25
ppmv corrected to 8%
oxygen
1200=F for
0.5 second
1200"F for
0.5 second
5 ppmv TRS at actual
oxygen content of
untreated stream
* DwsfJESHAP
OtoRpRme*
Ej»ar*?«S£S
And
-------
The NESHAP
requirements for
semi-chemical and
soda mills are similar
to the requirements
for kraft mills except
that pulping process
condensates are not
regulated at semi-
chemical and soda
mills.
Chapter 5 - NESHAP Requirements for
Semi-Chemical and Soda Mills
For semi-chemical and soda mills, the NESHAP contains emission
standards for pulping system vents and bleaching system vents. There are
several alternative emission limits for both processes, and mills can choose
the emission limits with which to comply.
The requirements in the NESHAP for semi-chemical and soda mills are
described in this chapter.
If YOQ Need the Following Information.
Then Read...
Standards for semi-chemical and soda pulping
system vents
Standards for semi-chemical and soda
bleaching svstem vents
Section 5.1
Section 5.2
81
-------
For purposes of
this NESHAP, the
LVHC system
includes all vents
from:
• digester system
• turpentine
recovery
system
• evaporator
system
For semi-chemical
and soda mills, the
NESHAP does not
apply to existing
HVLC systems.
5.1 Standards for semi-chemical and soda pulping
system vent standards
What pulping system vents must be controlled?
The NESHAP requires certain equipment in the pulping systems at semi-
chemical and soda mills to be enclosed, collected in a closed-vent system.
and then vented to a control device.
The Following Puipi&g System Vests Mast be Controlled.
Existing Sources
LVHC system
New Sources
LVHC system
• Pulp washing system
Each equipment system has multiple emission points. For example, the
pulp washing system can include vacuum drum washers, diffusion washers.
rotary pressure washers, horizontal belt filters, intermediate stock chests
associated vacuum pumps, filtrate tanks, an,d foam breakers. A complete
list of the emission points in each equipment system is provided in
Appendix F.
Chapter 5 - NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
82
-------
The NESHAP does
not provide the
Clean Condensate
Alternative to
semi-chemical and
soda pulping
systems because
the Clean
Condensate
Alternative was
provided to krqfi
mills as an option
for meeting the
HVLC system
emission limits.
HVLC systems at
existing semi-
chemical and soda
mills are not
regulated by the
NESHAP.
What are the emission limits for semi-chemical and soda
pulping system vents?
The emissions from semi-chemical and soda pulping system vents must
meet one of five alternative emission limits, as shown below. These
emission limits apply to each control device used to control HAP emissions.
A mill will likely use several closed-vent systems and control devices
(including both add-on control devices and existing combustion devices)
and each can comply with any of these five alternative emission limits.
These emission limits apply to both new and existing sources.
Pulping System Vent Gases Must be Collected in a Closed-vent
System and Routed to One of These Five Control Devices...
Any control device that reduces total HAP emissions by >98% by
weight, measured as total HAPs or methanol
A boiler, lime kiln, or recovery furnace with a heat input capacity
of at least 150 MMBtu/hr in which the HAP gas stream is
introduced with the combustion air
A boiler, lime kiln, or recovery furnace in which the HAP gas
stream is introduced with the primary fuel or into the flame zone
A thermal oxidizer operated at a minimum temperature of L600°F
and a minimum residence time of 0.75 seconds
A thermal oxidizer that reduces the total HAP concentration at the
outlet to < 20 ppmv corrected to 10% 0: on a dry basis, measured
as total HAPs or methanol
Note: These emission limits are the same as for kraft mills (see page 53).
Chapter 5 - NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
83
-------
A closed-vent
system means a
system that is not
open to ihe
atmosphere and
comprises piping,
ductwork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems at semi-chemical and soda mills?
All regulated equipment system vents must be enclosed and routed through
a closed-vent system to the control device that is selected for compliance.
The requirements for enclosures and closed-vent systems are presented
below. The requirements are intended to prevent leaks and ensure that
process openings (e.g., sampling ports on a brown stock washer enclosure)
are closed while the mill is in operation.
Mast Meet These
Requirements-..
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance.
or repairs
Components operated at positive
pressure
Operate with no detectable leaks
(500 ppmv VOC above
background)
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so that
the valve or closure mechanism
cannot be opened withou' breaking
the seal
or
If computer controlled, monitor for
presence of gas stream flow at iear
once every 15 minutes
Note: These requirements are the same as for kraft mills (presented on
page 54).
Chapter 5 • NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
84
-------
Because semi-
chemical and soda
mills are not
affected by the
Effluent
Limitations
Guidelines and
Standards, the
NESHAP does not
allow these mills
any extended
compliance times.
The excess
emission
allowances are
the same for
kraft, semi-
chemical, and
soda mills. Refer
to page 59 for
additional
details.
When must mills comply with the semi-chemical and soda
pulping process standards?
Pulping systems at semi-chemical and soda mills must comply with the
MACT standards by April 16, 2001.
How does a mill demonstrate initial and continuous compliance
with the pulping system vent standards?
A mill must demonstrate compliance through an initial performance test and
then continuously monitor a set of control device operating parameters for
each closed-vent system and control device. When complying by venting
gases to a boiler, lime kiln, or recovery furnace, the initial performance test
must demonstrate that the gases are being introduced with the primary fuel
or into the flame zone. If the boiler, lime kiln, or recovery furnace has a
heat input capacity of at least 150 MMBtu/hr. the initial performance test
must demonstrate that the HAP gases are introduced with the combustion
air.
The initial and continuous compliance requirements for semi-chemical and
soda mills are identical to those for kraft mills. Please read pages 56
through 59 of this document.
Must a mill comply st all times?
For pulping system vents, the NESHAP establishes an allowable percent of
operating time during which HAP emission levels in excess of the
established limit shall not be considered to be a violation of the standard.
For soda and semi-chemical mills, the excess emission allowances are:
• 1 percent of operating time for control devices used for
LVHC system vents
• 4 percent of operating time for control devices used for pulp
washing systems (HVLC)
• 4 percent of operating time for control devices used for
combined LVHC and pulp washing system vents
(i.e., controlled by the same device)
Chapter 5 • NESHAP Requirements
Semi-Chemical and Soda Mills
Pulping System Vents
85
-------
Currently, there is
only one soda mill
operating in the
U.S.
5.2 Standards for bleaching system vents at
semi-chemical and soda mills
Semi-chemical mills
Generally, semi-chemical mills in the United States do not have bleaching
systems and therefore are not subject to bleaching standards. Technically,
the rule would apply if a semi-chemical mill installed a bleaching system
using chlorine. While this is not expected to occur, such a mill would have
to comply with the emission standards for chlorinated HAPs (excluding
chloroform) from bleaching vents. The rule would not apply to bleaching
systems using chlorinated compounds other than chlorine. Refer to
Section 4.3 for information about bleaching standards, excluding the
chloroform standard.
Soda m/7/s
At soda mills, emission limits apply to bleaching systems that use chlorine
or chlorinated compounds. The emission standards and compliance
demonstration requirements for soda mills are the same as for kraft mills
(presented in Section 4.3) and are not repeated in this chapter. Refer to the
following pages for specific information.
• Emission points to be controlled—page 68
• Control requirements for chlorinated HAPs and
chloroform—page 69
• How to demonstrate initial compliance—page 71
• How to demonstrate continuous compliance—page 72.
Chapter 5 • NESHAP Requirements
Semi-Chemical and Soda Mills
Bleaching System Vents
86
-------
Chapter 6 - NESHAP Requirements for
Sulfite Mills
For sulfite mills, the NESHAP contains emission standards for pulping
system vents and bleaching system vents.
The NESHAP contains two alternative emission limits for pulping system
vents. A mill can choose to comply with either limit. Different numerical
emission limits are specified for calcium- and sodium-based pulping
systems than for magnesium- and ammonium-based pulping systems.
The NESHAP also contains several alternative emission limits for bleaching
process system vents. The NESHAP does not regulate pulping process
condensates at sulfite mills.
If You Need the Following Information
Standards for sulfite pulping system vents Section 6.1
Standards for sulfite bleaching system vents Section 6.2
87
-------
The emission limits
are the same for
existing and new
sources.
Appendix C
contains a
flowchart summary
'of the NESHAP.
6.1 Standards for sulfite pulping system vents
The NESHAP requires the pulping systems to be enclosed, coHected in a
closed-vent system, and then vented to a control device. This section
describes the emission points that must be controlled, the two alternative
emission limits, and the compliance requirements.
What sulfite pulping system vents must be controlled?
The NESHAP specifies that all the vents from the digester system,
evaporator system, and pulp washing systems must be controlled.
Additional equipment must be controlled at new sources. These pulping
system vents are identified below.
The Following Pulping System Vents Must be Controlled^.
Existing Sources
• Digester system
• Evaporator system
• Pulp washing system
New Sources
• Same as existing sources plus...
• All weak liquor storage tanks
• All strong liquor storage tanks
• All acid condensate storaee tanks
Each equipment system has multiple emission points. For example, the
evaporator system comprises pre-evaporators, multi-effect evaporators,
concentrators, vacuum systems, associated condensers, hot wells, and
condensate streams. A complete list of the emission points in each
equipment system is provided in Appendix F.
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
88
-------
These emission
limits apply to the
entire source, not
to individual pieces
of equipment as do
the emission limits
for pulping system
vents at other
mills.
Outlet emission
level and percent
reduction
requirements must
account for HAP
releases from
vents, condensates,
and waste-water
from control
devices used to
reduce ri-iP
emissions.
What are the emission limits for sulfite pulping system vents?
The sulfite pulping system vents must meet either a percent reduction or
mass emission limit identified for the specific type of sulfite pulping process
(i.e., calcium- and sodium-based or magnesium- and ammonium-based
pulping processes). The emission limits apply to the combined emissions
from both the regulated equipment and any vents, wastewater, and
condensate streams generated from any control device used to reduce the
HAP emissions. Therefore, a mill must choose either the percent reduction
or the mass emission format and demonstrate compliance with the emission
limit using the combined emissions from the entire pool of regulated
equipment. Compliance may not be demonstrated at individual pieces of
equipment or individual closed-vent systems.
If the Sulfhe Pulping System
fa This Type-,
Then Choose One of the
Following Emission Limits.,,
Calcium-based and
Sodium-based
Reduce total HAP concentration to
$0.89 Ib/ton oven-dried pulp,
measured as total HAPs or
methanol
or
Reduce total HAP emissions by
292% by weight, measured as total
HAPs or methanol
Ammonium-based and
Magnesium-based
Reduce total HAP concentration to
-<,2.2 Ib/ton oven-dried pulp,
measured as total HAPs or
methanol
or
Reduce total HAP emissions by
£ 87% by weight, measured as total
HAPs or methanol
Chapter 6 • NESHAP Requirements
Sulfite Mills
Pulping System Vents
89
-------
A closed-vent
system means a
system that is not
open to the
atmosphere and
comprises piping,
ducfrvork,
connections, and if
necessary, flow-
inducing devices
that transport gas
or vapor from an
emission point to a
control device.
What does the NESHAP require for enclosures and closed-vent
systems?
All regulated equipment systems must be enclosed and routed through a
closed-vent system to the control device that is selected for compliance.
The requirements for enclosures and closed-vent systems are presented
below. The requirements are intended to prevent leaks and ensure that
process openings (e.g., sampling ports on a brown stock washer enclosure)
are closed while the mill is in operation.
This Equipment^..
Most Meet These
Requirements....
Enclosures, openings, and hoods
Maintain negative pressure
and
If closed during the initial
performance test, must be closed
during operation except for
sampling, inspection, maintenance.
or repairs
Components operated at positive
pressure
Operate with no detectable Itaks
(500 ppmv VOC above
background) ,
Bypass lines that could divert vent
stream containing HAPs to the
atmosphere
Seal and secure the opening so iha;
the valve or closure mechanism
cannot be opened with oat breaking
the seal
or
If computer controlled, monitor for
presence of gas stream flow at le;..'
once every 15 minutes
Note: These requirements are the same as for kraft mills (presented on
page 54).
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
90
-------
When must mills comply with the sulfite pulping process
requirements?
Affected sources at sulfite mills must comply with the NESHAP by
April 16,2001.
How does a mill demonstrate initial compliance with the sulfite
pulping system vent standards?
A mill must demonstrate compliance through an initial performance test.
Total HAP may be measured as methanol using Method 308.
The initial performance test has three objectives:
(1) To demonstrate that the control device complies with the
emission limit.
(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 23.
(3) To establish the process operating parameter values that must
be monitored to demonstrate continuous compliance. For
example, at a calcium-based and sodium-based sulfite mill, the vent
gas flow rate, scrubbing media flow rate, and pH of the scrubber
effluent that indicate 92 percent reduction by weight of total HAPs
or methanol usine Method 308.
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
91
-------
The excess
emissions
allowance (for
krafi, semi-
chemical, and soda
mills) does NOT
apply to sulfite
mills.
These same tests
are required as
part of the initial
performance test.
How does a mill demonstrate continuous compliance with the
sulfite pulping system vent standards?
Mills must install a continuous monitoring system to measure either control
device or process operating parameters. Control device (other than gas
scrubbers) or process parameters to be monitored are determined by the
facility (i.e., site-specific). Continuous monitors for the selected parameters
are required to demonstrate continuous compliance. Figure 24 presents the
continuous compliance monitoring requirements.
In addition, the mill must comply with the requirements for periodic
inspection and maintenance of all enclosures and closed-vent systems.
These requirements are explained in Figure 23. The mill must maintain a
site-specific inspection plan for the enclosures and closed-vent system.
Records of repairs based on the inspections must also be kept.
Figure 23.
How Does a Mill Demonstrate initial and Continuous Compliance with
the Closed-Vent Systems Standard?
If the System has...
Enclosure opening
Closed-1. ent system
Positive pressure
closed-vent system
Bypass line valve
Then Inspect—
Visually inspect every 30
days to ensure closed and
sealed .
Annuallv demonstrate
negative pressure
Visually inspect every 30
days for visible detects
Annually demonstrate no
detectable leaks (less than
500 ppmv)
Inspect every 30 days to
ensure valve is in a closed
position and vent stream is
not diverted through
bypass line
AatfKetp
And Report... Records of...
Any exceedences of the All visual checks anu
closed-vent standard in a.n> repair
quarterly reports. If rv
exceedences occur, si^rr..:
semi-annual repon;
Same as above •'• ~^> ;• - ••>•,-
Same as above Ai; •. i^uu. .':•*••->. ;mJ
•r"p:>'"" _,
Same, as above -\i; ici.-, :ssu:
Same as above Vi visuji ,:'-.;xh.-i and
repair;.
Note: These are the same requirements as for kraft mills (presented on
page 57).
Chapter 6 - NESHAP Requirements
Sulfite Mills
Pulping System Vents
92
-------
CM
0)
u
= c-
.2 w
a"S
c re
O?
O g
"55
0 c
ll.
= E
2? ° w
^ o -S
3 c/)
.S> 5 >
u. re «
•fc o
« c
il-
i*
D o
re
tf>
Q)
O
O
O
I
:?:$n '"•:
SJ »-
^i -
^rf«
*s>
1*«
:;::'<
•: • ' " . E
f 2
§<2
' 1«
— !»
•w 4>
c •»
aH
W
o
•^ *
O *;
5.1-
~ ^
? a
i-
«* r-
£ ^
i*
vi
I
C
a
ao
11
monitoring
performance
report
If exceedences
•
i) ^~
re 3
L. 3
> =
O • —
D 5.
2 s 2
a •= s
— Jw
1 gl
> y; c:
-.C
< ^
_,r \
— >^
•=•»
•^T '•/}
— 3
H S-5)
m
Scrubber liquid
u
^
1^
3
U
8
w
s
1
c
u
3
.C
en
c
h
^'So:^
1 o-Se
c suo
? « ° ^c
3 L. ^- rn
o- re 3.^0
Parameters approved
by the Administrator
?
S
CO
(A
re
u
re
on
u re
_ t- • —
a u • —
'S «* •-
**• s .—
c E "^ —
C CQ j= in
&!.«?
2gi-g|
c.E 3 5
~ c ^ -
— S w n
4> '£ 3 l2
5 2"« «
C = > o.
c/5
L»
H
0
H
re
0.
u
C
'u
c.
f,
o
i/5
i>
1
re
en
re
u
a
c/3
me as above
re
c/l
u
O
re
to
re
u
re
y:
u
>
.£
re
t/i
re
o
c/:
« 2 S.
-> -C Or
< ii
~~ C (N
2-2^
0 re ^
•"•^ t. ^
j» ti *^
u =
1 3J
C re
,
J3
S?
•3 cr>
2- r-
< °°
5 H
^™
>%
•3-0
c 5!
« c
o
o •- -S
3 ft To
"S S'i
y. v f
o
,o
re f^
OO'O
O •»
93
-------
The compliance
date for dissolving
grade sulfite mills
is not specified in
the NESHAP, but is
anticipated
between
2003-2005.
6.2 Standards for sulfite bleaching system vents
At sulfite mills the emission limits apply to bleaching systems that use
chlorine or chlorinated compounds. The NESHAP has emission limits for
both chloroform and chlorinated HAP. Sulfite mills must comply with both
of these requirements. The emission standards and compliance
demonstration requirements for sulfite mills are the same as for kraft mills
(presented in Section 4.3) and are not repeated in this chapter. Refer to the
following pages for specific information.
• Emission points to be controlled—page 68
• Control requirements for chlorinated HAPs and
chloroform—page 69
• How to demonstrate initial compliance—page 71
• How to demonstrate continuous compliance—page 72.
When must sulfite bleaching systems comply?
Bleaching systems must comply by April 16,2001 with one exception.
• Dissolving grade sulfite mills must comply within 3 years after
publication of revised effluent limitations guidelines and standards
under 40 CFR 430.14 through 430.17 and 40 CFR 430.44 through
430.47. These rules are scheduled to be revised sometime between
2001 and 2002.
Chapter 6 - NESHAP Requirements
Sulfite Mills
Bleaching System Vents
94
-------
Secondary fiber
means recycled fiber.
The chloroform
control requirements
of the NESHAP do not
apply to bleaching
systems at these types
of mills.
Typically, a bleaching
line contains
3-5 stages.
Chapter 7 - NESHAP Requirements for
Mechanical, Secondary Fiber,
and Non-wood Fiber Pulp Mills
The NESHAP regulates bleaching system vents for mechanical pulping,
secondary fiber, and non-wood fiber pulp mills. The NESHAP applies to
bleaching systems that use chlorine or chlorine dioxide, and has identical
requirements for mechanical, secondary fiber, and non-wood fiber
processes.
The pulping process system vents and condensates are not regulated at these
mills.
7.1 Standards for bleaching system vents
At mechanical, secondary fiber, and non-wood fiber pulp mills the
NESHAP regulates chlorinated HAPs (excluding chloroform). The
emission limits apply to bleaching systems that use chlorine or chlorine
dioxide. However, if a bleaching system for one of these processes also
accepts pulp from a kraft, semi-chemical, soda, or sulfite process, then more
stringent bleaching system requirements will apply (i.e., the bleaching
system also must meet the chloroform control requirements).
What mechanical, secondary fiber, and non-wood fiber
bleaching system emission points must be controlled?
The NESHAP applies only to bleaching stages that use chlorine or chlorine
dioxide. Extraction stages are not covered. All vents in a regulated stage
must be controlled. A stage consists of the following equipment:
• retention towers
• washers
• seal tanks
• chemical and steam mixers (if vented to the atmosphere)
• vacuum pumps (if present)
95
-------
There are no control
requirements for
chloroform at these
other types of mills.
The requirements for
enclosures and
closed-vent systems
are the same as for
the pulping system
vent standards
(page 54).
Are there any exemptions to the bleaching requirements?
Yes. Any bleaching system that does not use chlorine or chlorine dioxide is
exempt from all NESHAP requirements for bleaching.
What are the control requirements for chlorinated HAPs?
The equipment at each bleaching stage where chlorinated compounds are
introduced must be enclosed and routed via a closed-vent collection system
to a control device. The rule provides three alternative emission limits for
demonstrating compliance, as shown below. Most mills are expected to use
caustic scrubbers to comply.
Bleaching System Gases Must be Collected in a Closed-vent System
and Meet One of These Three Alternative Emission Limits ...
b
1 . Reduce chlorinated HAP emissions by 99% by weight
2. Achieve a total outlet mass emission rate < 0.002 pounds
chlorinated HAPs per ton oven-dried pulp for all subject
3. Achieve an outlet concentration of chlorinated HAPs < 1
stages
0 pprrn
Some mills may be able to meet the outlet concentration or mass limits through use o:
process modifications (i.e., -100 percent chlorine dioxide substitution), iri Lhese case;.
enclosures and closed-vent systems are not required.
Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HA!' •>•
as chlorine.
Note: These emission limits are the same for krart mills (presented on
page 69).
When must mechanical, secondary fiber, and non-wood fiber
bleaching systems comply?
All mechanical, secondary fiber, and non-wood fiber processes must comply
witn the chlorinated HAP control requirements by April 16. 2001
Chapter 7 • NESHAP Requirements
Mechanical Pulping, Secondary
Fiber, and Non~wof>d Fiber Mills
Pulping System Vents
96
-------
How does a mill demonstrate initial compliance with the
bleaching standards?
Chlorinated HAPs. The mill must demonstrate initial compliance with
chlorinated HAP standards by conducting an initial performance test for
each bleaching stage where chlorine or chlorinated compounds are
introduced.
The initial performance test has three objectives:
(1) To demonstrate that the control device complies with the
emission limit.
(2) To demonstrate that the closed-vent system captures and
contains all HAP emissions. Refer to Figure 16.
' (3) To establish the process operating parameters that must
be monitored to demonstrate continuous compliance.
At the option of the mill, compliance may be demonstrated by measuring
either total chlorinated HAPs or chlorine concentration. The following
methods must be used:
Chlorinated HAPs
Any method that has been
demonstrated to the Administrator's
satisfaction.
Chloric
Method 26A. as modified by
63.457(b)(5)oftherule.
Chapter 7 - NESHAP Requirements
Mechanical Pulping, Secondary
Fiber, and Non-wood Fiber Mills
Pulping System Vents
97
-------
Continuous
monitoring is
required unless a
mill complies by
eliminating all use
of chlorine or
chlorinated
compounds as
bleaching agents.
These same tests
are required as
part of the initial
performance lest.
How does a mill demonstrate continuous compliance with the
bleaching standards?
For chlorinated HAPs, a continuous monitoring system must measure
either emissions, or control device or process operating parameters. The
monitoring, reporting, and recordkeeping requirements are summarized in
Figure 25.
In addition, the mill must conduct periodic inspection and maintenance of
all enclosures and closed-vent systems. These requirements are explained
below. The mill must maintain a site-specific inspection plan for the
enclosures and closed-vent system. Records of repairs based on the
inspections must also be kept.
If the System has.-
Enclosure opening
Closed-vent system
Positive pressure
closed-vent system
Bypass line val\c
Then J aspect...
Visually inspect every 30
days to ensure closed and
sealed
Annually demonstrate
negative pressure
Visually inspect every 30
days for visible detects
Annually demonstrate no
detectable leaks (less than
500 ppnrv )
Inspect every 30 days to
ensure valve is in a closed
position and vent stream is
not diverted through
bypass line
Aad Report-.
Any exceedences of the
closed- vent standard in
quarterly reports. If no
exceedences occur, submit
semi-annual reports.
Same as above
Same as above
Same as above
Same as above
And Keep
Records of...
All usual checks and
any repair;
All pressure !e.~iy
All 'i '.sua! checki or...
repair
All leak tests
Aii \isiia! c:;c.>..- ;• .: '
Note: These are the same requirements as for kraft mills (presented on
page 57).
Chapter 7 - NESHAP Requirements
Mechanical Pulping, Secondary
Fiber, and Non-wood Fiber Mills
Pulping System Vents
98
-------
2
c.
O
99
-------
The Cluster Rules do
NOT represent all of
the air and water
pollution regulation
of the pulp ana paper
industr\.
Chapter 8 - Other Federal Regulations Affecting
Pulp and Paper Mills
The Cluster Rules do not represent all of the air and water pollution
regulation of the pulp and paper industry. Pulp and paper mills are subject
to additional air requirements under the CAA; additional water requirements
under the Clean Water Act; and other Federal, State and local laws not
associated in any way with the Cluster Rules.
Federal regulations affecting the pulp and paper industry include:
• National Ambient Air Quality Standards (NAAQS)
• Kraft Mill New Source Performance Standards (NSPS)
(40 CFR 60, Subparts B and BB)
Industrial Boilers NSPS (40 CFR 60. Subparts D. Db, and
DC)
Gas-Fired Turbines NSPS (40 CFR 60, Subpart GG)
NESHAP (40 CFR 63. Subpart MM)
• Prevention of Significant Deterioration (PSD)/Ne\v Source
Review (NSR)
• National Pollutant Discharge Elimination System (NPDES)
Related Statutes and Regulations
• Spill Prevention Control and Countermeasure (SPCC) Plans
(40 CFR 112)
• Notice of Discharge of Reportable Quantities of Hazardous
Substances (40 CFR 116 and 117)
• Resource Conservation and Recovery Act (RCRA)
• Emergency Planning and Community Right-to-;Know Act
(EPCRA)/Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)
100
-------
BACT = best
available control
technology
LAER = lowest
achievable emissions
rate
8.1 What other Federal air regulations affect the pulp
and paper industry?
Federal air regulations affecting the pulp and paper industry are shown
below.
The Following Air
Affects...
By.
NAAOS
Energy generation at
pulp and paper mills
Controlling NOX, PM,
VOC,a and SO, as part
of the state
implementation plans
NSPS
40 CFR 60, Subpart B Kraft pulp mills
40 CFR 60, Subpart BB Kraft pulp mills
40 CFR 60, Subpart D, Industrial boilers
Db. and DC
40 CFR 60, Subpart GG Gas-fired turbines
Controlling PM and
TRS at existing sources
under state regulations.
State regulations are
based on EPA
guidelines.
Controlling PM and
TRS
Controlling PM. NO,.
SO;
Controlling PM. SL
NO,
NESHAP
Chemical recovery
processes at kraft,
soda, sulfite, and
standalone semi-
chemical pulp mills
Controlling gase^u.
organic and metal HAP
PSD/NSR
Pulp and paper mills
installing new or
modified equipment
Requiring a
pre-construction permit
that imposes emission
limitations based on
BACT or LAER for
criteria pollutants for
which there is a
significant emission
increase.
Chapter 8 • Other
Regulations
101
-------
National Ambient Air Quality Standards (NAAQS) have been established
for six criteria pollutants. Pulp and paper mills are potential sources of
paniculate matter (PM), ozone precursors (volatile organic compounds
[VOCs] and nitrogen oxides [NOJ), and sulfur dioxide (SO,). Each State
must develop a State Implementation Plan (SIP) to identify sources of air
pollution and to determine what actions are necessary to achieve attainment
with the NAAQS for all criteria pollutants. The SIP contains emission
regulations that may affect the pulp and paper industry, including emission
limitations and standards and pre-construction permitting requirements
(e.g.. New Source Review [NSR], Prevention of Significant Deterioration
[PSD]).
Kraft Mill New Source Performance Standards (NSPS) (40 CFR 60,
Subpart BB). The majority of kraft mills in operation are currently
regulated under the kraft mill NSPS (40 CFR Subpart BB) or State
regulations for existing sources promulgated under Section 11 l(d) of the
Act (40 CFR 60, Subpart B). The kraft mill NSPS sets emission limits for
paniculate matter and TRS for recovery furnaces, smelt dissolving tanks.
lime kilns, digester systems, brown stock washer systems, multiple effect
evaporators, black liquor oxidation systems, and condensate stripper
systems. See page 79 for a more detailed discussion of the kraft mill NSPS,
as this regulation applies to kraft mills only.
Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and DC) and Gas-
Fired Turbines NSPS (40 CFR 60, Subpart GG). Almost all pulp and
paper facilities have boilers and turbines for generating electricity and
steam. Newer combustion units may be subject to regulation under one of
these rales which set emissions limits for paniculate matter, nitrogen
oxides, and sulfur dioxide.
National Emission Standards for Hazardous Air Pollutants (NESHAP)
(40 CFR 63, Subpart MM). The NESHAP for chemical recovery-
combustion sources at kraft. soda, sulfite, and semi-chemical pulp mills (40
CFR 63, Subpart MM) establishes emission limits for gaseous organic and
metal HAP. Subpart MM applies to all existing and new kraft, soda, sulfite,
and stand-alone semi-chemical pulp mills with chemical recovery processes
that involve the combustion of spent pulping liquor.
Chapter 8 - Other
Regulations
102
-------
NPDES = National
Pollutant Discharge
Elimination System
8.2 What other Federal water regulations affect the
pulp and paper industry?
Federal water regulations affecting the pulp and paper industry are shown
below:
The Following Water
Regulation^.
NPDES: Technology and
water quality-based
limitations
Pretreatment program
—
Storm water permit
application
Section HOofCWA
(40CFR 110)
Spill Prevention Control
and Countermeasure
(SPCC)(40CFR 112)
Notice of Discharge of
Reportable Quantities of
Hazardous Substances
(40 CFR 116 and 117)
Affects-.
Direct-discharging of
pollutants into
navigable waters
Indirect-discharging
of pollutants to
publicly-owned
treatment works
(POTWs)
Any facility
Any facility
Oil storing/
consuming facilities
Any facility
By_
Setting effluent
limitations on pollutants
based on available
technology and intended
use of receiving
waterbody; also sets
monitoring and
reporting requirements
Setting pollutant
discharge limits to
POTWs
Establishing pollution
prevention plans and
best management
practices (BMP'
Prohibiting oil
discharges ;
Requiring a spill
prevention and control
•plan, reporting, plan
updates, and training
obligations
Requiring reporting of
designated hazardous
substance discharges to
U.S. government
following the
Department of
Transportation
regulations
Chapter 8 - Other
Regulations
103
-------
The acronyms are
defined on the next
page in Figure 26.
The applicability of
these standards is
explained'on
page 106 in
Figure 27.
National Pollutant Discharge Elimination System (NPDES) Program
(Clean Water Act, Section 402). The NPDES program controls direct
discharges into navigable waters. The scope of this program is quite broad,
and most point source discharges associated with a pulp and paper mill will
be subject to NPDES permitting requirements. The effluent limitations
guidelines and standards and requirements for direct discharging mills are
presented in the table below. The applicability of these standards is more
fully explained in Figure 27.
These Clean Water Act Standards
Apply...
BAT,
For These Mill Types or PSES, and
Production Operations... PSNS
Dissolving Kraft X
Bleached Papergrade Kraft X
and Soda
Unbleached Kraft • X
Dissolving Sulfite X
Papergrade Sulfite X
St.mi-cnernical X
Mechanical
Non-uood Chemical
Secondary Fiber Deink
Fine and Lightweight Papers
from Purchased Pulp
Tissue. Filter. Non-Woven,
and Paperboard from
Purchased Pulp
BPT,
BCT,
NSPS
X
X
X
X
X
X
X
X
. x
X
X
BMP
X
X
X
X
X
X
X
The effluent limitations guidelines and standards tor these subcategories were revised in
the Cluster Rules.
Chapter 8 - Other
Regulations
104
-------
Figure 26.
A Guide to the Acronyms for Technology-Based Water Standards
A ____.„,..
UUIijriii
PSESa
PSNSa
BPT
BCT
V
BAT
BMP
NSPS
t Definition
Pretreatment Standards for Existing
Sources
Pretreatment Standards for New
Sources
Best Practical Control Technology
Currently Available
Best Conventional Pollutant Control
Technology
Best Available Technology
Economically Achievable
Bes; Management Practices
New Source Performance Standards
Description of Standard
Industry-by-industry pretreatment
standards for existing sources that
discharge their wastewater indirectly
(i.e., to a POTW).
Industry-by-industry pretreatment
standards for new sources that
discharge their wastewater indirectly
(i.e., to a POTW).
A baseline standard, applicable in all
circumstances
More stringent than BPT. Only
applies if certain cost tests are met.
Must be "cost-reasonable." See
.51 FR 24.974-24,976 (July 9. 1986).
for EPA's BCT methodology.
A standard similar to BPT/BCT. but
with cost concerns playing a lesser
role. A "best of the best" standard.
Designed to prevent or contain leaks
and spills of pulping liquor, soap.
and turpentine, and to control any
intentional diversions of these
substances.
Applicable to new direct discharge
sources, as defined in 40 CFR 122.2.
Although the categorical standards in 40 CFR Pan 430 cover kraft pulp mills, most krat't pulp mills are direct
dischargers subject to NPDES permit requirements and not the pretreatment standards.
Chapter 8 - Other
Regulations
105
-------
Figure 27.
Applicability of Technology-Based Standards
If a Mill
Discharges These
Pollutants...
Conventional
pollutants
Toxic and
conventional
pollutants
, Any pollutants
Any pollutants
An\ pollutants
To These Direct
Receivers
Surface waters
Surface waters
Surface waters
POTWs
POTWs •
And the Mill is
Classified as an...
Existing source
Existing source
New source
Existing source
New Source
Then the
Required
Standards
That
Apply
are...
BPTor
BCT
BAT
NSPS
PSES
PSNS
Source: 40 CFR 125.3
Spill Prevention Control and Countermeasure (SPCC) Plans
<-4fl CFR 1121 This regulation applies to all facilities that store or use oil or
oil products, and which because of their location, could reasonably be
expected to discharge oil into navigable waters of the United States. Such
facilities are required to prepare a SPCC plan.
Notice of Discharge of Reportable Quantities of Hazardous Substances
(40 CFR 116 and 117). This regulation defines the discharges into
navigable waters of the United States that must be reported to appropriate
agencies of the U.S. Government. This requirement does NOT apply to
discharges covered by a facility's NPDES permit.
Chapter 8 - Other
Regulations
106
-------
TRI = Toxic
Release Inventory
BIF = Boilers and
Industrial
Furnaces (40 CFR
266, Subpart H)
8.3 What Federal hazardous wastes regulations
affect the pulp and paper industry?
Federal hazardous wastes and emergency planning regulations affecting the
pulp and paper industry are shown below:
'"- Waste ,
Regulation*.
Affects^
By-.
RCRA
Black liquor at
pulp mills
Requiring reclamation and reuse
of black liquor
Steam stripper
systems
Exempting on-site combustion
of concentrated methanol
condensates derived from steam
stripper overhead gases from the
BIF regulation
EPCRA/CERCLA Pulp mills
Requiring annual reporting
of discharges (TRI Form R
reports) for certain pollutants
Requiring mills to provide
information on chemicals
used in the bleach plan:
Requiring mills to report
emergency spills or off-siu
releases (air, water, or solid
wastes)
Resource Conservation and Recovery Act (RCRA). Most RCRA
requirements are not industry specific but apply to any facility ma
transports, treats, stores, or disposes of hazardous wastes. The pulping
process generally does not generate significant RCRA-related hazardous
waste streams. However, handling of black liquor can create RCRA-relateu
concerns. Black liquor is exempt from regulation as a solid waste under
40 CFR 261.2(e) and Table 1,261.4(a)(6), but only if the black liquor is
reclaimed in a recovery furnace and reused in the pulping process.
Therefore, potential liquor spills that are not reused in the process, such as
leaks from surface impoundments used to store black liquor prior to
recovery will be an issue for RCRA compliance assessment.
Chapter 8 - Other
Regulations
107
-------
Concentrated steam
stripper
condensates consist
primarily of
methanol which can
be burned as a fuel.
RCRA/Boilers and Industrial Furnaces (BIF) regulation (40 CFR 266,
Subpart H). One of the options for controlling emissions from kraft
pulping process condensates is to steam strip HAPs from the condensate
streams. The vent gas from the steam stripper is required to be sent to a
combustion device for destruction. If the methanol in the steam stripper
vent gas were concentrated, using a rectification column, the concentrated
condensate could be burned as a fuel. However, the concentrated methanol
condensate could be identified as hazardous waste under RCRA because it
exhibits the ignitability characteristic. Boilers burning such a hazardous
waste fuel would ordinarily be required to comply with the emission
standards for boilers and industrial furnaces burning hazardous waste.
Because the rectification practice would save energy, not increase
environmental risk, and would provide a cost savings, combustion sources
at kraft mills that burn condensates derived from steam stripper overhead
vent gases are excluded from RCRA. The exclusion applies only to the
condensates generated from the steam stripper methanol rectification
process and only to combustion units located at the facility generating the
condensate stream.
Emergency Planning and Community Right-to-Know Act (EPCRA)/
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA). Section 313 of EPCRA requires pulp mills to submit a
Toxic Release Inventory (TRI) report to EPA each year. These reports.
referred to as Form R. include the amounts of toxic chemicals that the
facility releases into the environment (i.e.. air. water, and land) both
roiir.neK and as a result of accidents. In general reported releases would
include releases of toxic chemicals from pulp mill process vent air
emissions and from mill wastewater discharges. Data must be provided for
any of the more than 600 listed toxic chemicals that are manufactured,
processed, or otherwise used above the reporting threshold.
Chapter 8 - Other
Regulations
108
-------
More regulations
are coming!
Five NESHAPfor
combustion
sources are
scheduledfor
2001.
Effluent limitations
guidelines and
standards
scheduledfor
2001-2002.
8.4 What upcoming regulations will affect pulp and
paper mills?
Pending regulations that will affect the pulp and paper industry include:
• NESHAPfor Combustion Sources. EPA plans to publisn
several NESHAP that will affect power boilers, process
heaters, gas turbines, reciprocating internal combustion
engines, and incinerators.
• Effluent Limitations Guidelines and Standards. EPA plans
to publish revised effluent limitations guidelines and
standards for additional subcategories in the near future
These include: dissolving kraft; dissolving sulfite:
unbleached kraft; semi-chemical; mechanical pulp; non-
wood chemical pulp; secondary fiber deink; secondary fiber
non-deink; fine and lightweight fibers from purchased pulp:
and tissue, filter, non-woven, and paperboard from purchased
pulp.
Pending water regulations consist of EPA proposing effluent limitations
guidelines and standards for the pulp and paper industry subpans that were
not included in the Cluster Rules. And finally, EPA is considering whether
pulp mill wastewater treatment system sludges are to be considered a
hazardous waste and subject to RCRA Subtitle C. Since the effluer'
guidelines address concerns about chlorine containing compoun, :: i:-
expected that diere will be no change in the exemption of pulp miil sludge-
from being classified as a hazardous waste.
Chapter 8 - Other
Regulations
109
-------
Appendix A
List of U.S. Pulp and Paper Mills
Source: Lockwood-Post Directory, 1996
-------
Name
KETCHIKAN PULP CO.
ALASKA PULP CORP.
MACMILLAN BLOEDEL CORP.
KIMBERLY-CLARK CORP.
BOISE CASCADE CORP.
HAMMERMILL PAPERS GROUP
SCOTT PAPER CO.
ALABAMA PINE RIVER
INTERNATIONAL PAPER CO.
JAMES RIVER CORP.
ALABAMA RIVER PULP CO.
CHAMPION INTERNATIONAL
CONTAINER CORP. OF AMERICA
GULF STATES PAPER CORP.
MEAD COATED BOARD INC.
UNION CAMP CORP.
MEAD CORF.
NATIONAL GYPSUM CO.
GAF BUILDING MATERIALS CORP.
MOBILE PAPERBOARD CORP.
KEYES FIBER CO.
POTLATCH CORF
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
GEORGIA-PACIFIC CORP.
GREEN BAY PACKAGING INC.
INTERNATIONAL PAPER CO.
GAYLORD CONTAINER CORP.
CELOTEX CORP.
STONE CONTAINER CORP.
PONDEROSA PAPER PRODUCTS INC.
LOUISIANA-PACIFIC CORP.
SIMPSON PAPER CO.
B.J. FIBRES
CONTAINER CORP. OF AMERICA
Cfty -
KETCHIKAN
SITKA
PINE HILL
COOSA PINES
JACKSON
SELMA
MOBILE
CLAIBORNE
MOBILE
PENNINGTON
PERDUE HILL
COURTLAND
BREWTON
DEMOPOLIS
MAHRT
PRATTVILLE
STEVENSON
ANNISTON
MOBILE
MOBILE
ALBERTVILLE
MCGEHEE
PINE BLUFF
ASHDOV.-N
CROSSETT
MORRILTON
CAMDEN
PINE BLUFF
CAMDEN
SNOWFLAKE
FLAGSTAFF
SAMOA
ANDERSON
SANTA ANA
SANTA CLARA
Sttfe
AK
AK
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
AR
AR
AR
AZ
AZ
CA
CA
CA
CA
t>1MHH
sulfite
co-semi
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
semichem
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
Steadied?
bleached
unbleached
bleached
bleached
bleached
bleached
bleached.
bleached
bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached
bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached
bleached
bleached
bleached
A-1
-------
* ' "' -' Ntone v _-%-?•, -^-
CELLULO CO. INC.
LOS ANGELES PAPER BOX & BOARD
LUNDAY-THAGARD ROOFING CO.
USG INDUSTRIES PAPERBOARD CO.
INLAND CONTAINER CORP.
LEATHERBACK INDUSTRIES
P & G PAPER PRODUCTS CO.
NEWARK PACIFIC PAPERBOARD
CORP.
NATIONAL GYPSUM CO.
SPECIALTY PAPER MILLS INC.
PABCO PAPER
SIMPSON PAPER CO.
SIMPSON PAPER CO.
KJMBERLY-CLARK
KEYES FIBRE CO.
WILLAMETTE INDUSTRIES INC.
DOMTAR GYPSUM
SIERRA TISSUE INC.
FONT ANA PAPER MILLS INC.
SIMPSON PAPER CO.
-*;**- **, -f'Qgg
FRESNO
LOS ANGELES
SOUTH GATE
SOUTH GATE
NEWARK
HOLLISTER
OXNARD
LOS ANGELES
STOCKTON
SANTA FE SPRINGS
VERNON
POMONA
FAIRHAVEN
FULLERTON
SACRAMENTO
OXNARD
VERNON
PONOMA
FONTANA
RIPON
State MBtType Bleached?
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
DOMTAR GYPSUM
CONTAINER CORP. OF AMERJCA
GOLDEN STATE NEWSPRINT CO. INC
CALIFORNIA PAPERBOARD CORP.
INLAND CONTAINER CORP.
SAN LEANDRO
VERNON
POMONA
SANTA CLARA
ONTARIO
CA
CA
CA
CA
CA
SONOCO PRODUCTS CO.
PACKAGING CO. OF CALIFORNIA
REPROCELL
PACKAGING CO. OF CALIFORNIA
P^PER-PAK PRODUCTS INC.
CITY OF INDUSTRY . CA
CITY OF INDUSTRY CA
SUN VALLEY CA
RED BLUFF CA
LA VERNE CA
REPUBLIC PAPERBOARD CO.
KIMBERLY-CLARK CORP.
STONE CONTAINER CORP.
THE DEXTER CORP.
CELLU TISUE CORP.
DENVER CO
NEWMILFORD CT
UNCASVILLE CT
WINDSOR LOCKS CT
EAST HARTFORD CT
A-2
-------
- s i fftone
WINDSOR-STEVENS INC.
RAND WHITNEY PAPERBOARD
CORP.
FEDERAL PAPER BOARD CO.
ROGERS CORP. '
SIMKINS INDUSTRIES INC.
LYDALL INC.
JAMES RIVER CORP.
NVF CORP.
CHAMPION INTERNATIONAL
STONE CONTAINER CORP.
ST. JOE FOREST PRODUCTS CO.
GEORGIA-PACIFIC CORP.
BUCKEYE FL LIMITED PARTNERSHIP
CONTAINER CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
ITT RAYONIER INC.
ATLAS TISSUE MILLS
STONE CONTAINER CORP.
U.S. GYPSUM CORP.
FEDERAL PAPER BOARD CO.
GEORGIA-PACIFIC COFJ
WEYERHAUSER PAPER CO
GEORGIA-PACIFIC CORP.
GILMAN PAPER
STONE CONTAINER CORP.
INTERSTATE PAPER CORP.
PACKAGING CORP. OF AMERICA
RIVER WOOD INTERNATIONAL GA
INC.
UNION CAMP CORP.
INLAND ROME INC.
ITT RAYONIER INC.
AUSTELL BOX BOARD CORP.
P & G PAPER PRODUCTS CO.
HOLLINGSWORTH & VOSE CO.
SONOCO PRODUCTS CO.
; a* --
WINDSOR
MONTVILLE
VERSAILLES
MANCHESTER
NEW HAVEN
MANCHESTER
NEWARK
YORKLYN
CANTONMENT
PANAMA CITY •
PORT ST. JOE
PALATKA
PERRY
FERNANDINA BEACH
JACKSONVILLE'
FERNANDINA BEACH
HIALEAH
JACKSONVILLE
JACKSONVILLE
AUGUSTA
CEDAR SPRINGS
OGLETHORPE
BRUNSWICK
ST. MARY'S
PORT WENTWORTH
RICEBORO
CLYATTSVILLE
MACON
SAVANNAH
ROME
JESUP
AUSTELL
ALBANY
HAWKINSVILLE
ATLANTA
Stale
CT
CT
CT
CT
CT
CT
DE
DE
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MBIType
kraft
kraft
kraft
kraft
kraft
kraft
kraft
sulfite
co-semi
co-semi
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
Bleached?
bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
bleached
bleached
unbleached
bleached
bleached
bleached
bleached
unbleached
unbleached
unbleached
unbleached
unbleached
bleached
A-3
-------
Nttae
JEFFERSON SMURFIT CORP.
FORT HOWARD CORP.
PACKAGING CORP. OF AMERICA
AUGUSTA NEWSPRINT CO.
DEERFIELD SPECIALTY PAPERS INC.
SOUTHEAST PAPER MFG. CO.
PONDEROSA GEORGIA
SWEETWATER PAPER BOARD CO.
CONSOLIDATED PACKAGING CORP.
PACKAGING CORP. OF AMERJCA
POTLATCH CORP.
JEFFERSON SMURFIT CORP.
IVEX CORP
CHICAGO PAPERBOARD CORP.
QUAKER OATS CO.
SONOCO PRODUCTS CO.
IVEX CORP.
CELOTEX CORP
DAVEY CO.
FSC PAPER CO.
GEORGIA-PACIFIC CORP
WESTON PAPER AND MFG. CO.
KEYES FIBRE CO.
PACKAGING CORP OF AMERJCA
INLAND CONTAINER CORP
KIEFFER PAPER MILLS INC.
FIBRE FORM CORP.
JEFFERSON SMURFIT CORP.
ROCK-TENN CO.
BRIDGEWATER PAPER CO. INC.
GEORGIA-PACIFIC CORP.
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
TAMKO ASPHAULT PRODUCTS
REPUBLIC PAPERBOARD CO.
™€»* vr*
CEDARTOWN
RINCON
MACON
AUGUSTA
NIXON
DUBLIN
AUGUSTA
AUSTELL
FORT MADISON
TAMA
LEWISTON
ALTON
JOL1ET
CHICAGO
PEKJN
ROCKTON
PEORJA
QUINCY
AURORA
ALDIP
TAYLORVILLE
TERRE HAUTE
HAMMOND
GRIFFITH
NEWPORT
BROWNSTOWN
COLUMBIA CITY
LAFAYETTE
EATON
INDIANAPOLIS
GARY
CARTHAGE
WABASH
PHILLIPSBURG
HUTCHINSON
:,,,,- 't^te siiiHType Stead**?
GA
GA .
GA
GA
GA
GA
GA
GA
IA semichem unbleached
IA
ID kraft bleached
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IN semichem unbleached
IN
IN '
IN
IN
IN
IN
IN
IN
IN
IN
IN-
KS
KS
A-4
-------
Name
WESTVACO CORP.
WILLAMETTE INDUSTRIES INC. (25A)
WILLAMETTE INDUSTRIES (25B)
AHLSTROM FILTRATION INC.
W.R. GRACE & CO.
STONE CONTAINER CORP.
RIVERWOOD INTERNATIONAL CORP.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
INTERNATIONAL PAPER CO.
JAMES RIVER CORP.
BOISE CASCADE CORP.
WILLAMETTE INDUSTRIES INC.
GAYLORD CONTAINER CORP.
INTERNATIONAL PAPER CO.
M.D. VALENTINE PAPER CO INC
CELOTEXCORP.
G. S. ROOFING PRODUCTS
WESTFIELD RIVER PAPER CO. INC.
STRATHMORE PAPER CO.
ESLEECK MANUFACTl RING CO INC.
CROCKER TECHNICAL PAPERS INC.
WESTFIELD RIVER PAPER C'"' INC.
MERRJMAC PAPER CO IN"
ERVING PAPER MILLS
JAMES RIVER CORP
MEAD CORP.
HOLLINGSWORTH i VOSE CO.
JAMES RIVER CORP.
MEAD CORP.
Cily
WICKLIFFE
HAWESVILLE
HAWESVILLE
MADISONVILLE
OWENSBORO
HODGE
WEST MONROE
MANSFIELD
PORT HUDSON
BASTROP
ST. FRANCISVILLE
DERIDDER
CAMPTI
BOGALUSA
PINEVILLE
LOCKPORT
MARRERO
SHREVEPORT
RUSSELL
TURNERS FALLS
TURNERS FALLS
FITCHBURG
LEE
LAV.HENCE
ERVING
FITCHBURG
SOUTH LEE
EAST WALPOLE
DALTON
WEST SPRINGFIELD
SOUTH LEE
DALTON
State
KY
KY
KY
KY
KY
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MKTyp* Bleadirf?
kraft bleached
kraft bleached
semichem bleached
co-semi unbleached
co-semi unbleached
co-semi unbleached
kraft bleached
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft unbleached
kraft unbleached
A-5
-------
Name ^f -- . "^:*^<*m® ^-* ' Stele ?^|*Brrfpe Bleached?
NEWARK ATLANTIC PAPERBOARD
JAMES RIVER CORP.
BYRON WESTON CO.
STRATMORE PAPER CO.
NVFCO.
TEXTON USA
STRATHMORE PAPER CO.
SEAMAN PAPER CO. OF MASS. INC.
KIMBERLY-CLARK CORP.
NATICK PAPERBOARD CORP
RISING PAPER DIV.
CASCADES DIAMOND FNC.
ROLAND-FITCHBURG PAPER INC.
STRATHMORE PAPER CO.
HAVERHILL PAPERBOARD CORP.
V
PERKIT FOLDING BOX CORP.
JAMES RIVER CORP.
SOUTHWORTH CO
HOLLINGSWORTH & VOSE CO
BALDWIN VILLE PRODUCTS INC.
NEPONSET RIVER PAPER INC.
SONOCO PRODUCTS CO.
WESTVACO CORP.
SIMKINS FNDUSTRIES INC.
CHESAPEAKE PAPERBOARD CO. '
S D WARREN CO.
S.D. WARREN CO.
GEORGIA-PACIFIC CORP.
BOISE CASCADE CORP.
INTERNATIONAL PAPER CO.
LAWRENCE
PEPPERELL
DALTON
DALTON
RUSSELL
HOLYOKE
RUSSELL
WESTFIELD
DALTON
OTTER RIVER
LEE
NATICK
HOUSATONIC
THORNDIKE
FITCHBURG
MILLERS FALLS
HAVERHILL
BOSTON
ADAMS
WEST SPRINGFIELD
WEST GROTON
ERVING
HYDE PARK
HOLYOKE
LUKE
CATONSVILLE
BALTIMORE
WESTBROOK
HINCKLEY
WOODLAND
RUMFORD
JAY
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA !
MA
MA
MD kraft bleached
MD
MD
ME kraft bleachec
ME kraft bleached
ME kraft bleached
ME kraft bleached
ME kraft bleached
A-6
-------
Name
LINCOLN PULP & PAPER CO. INC.
JAMES RIVER CORP.
GREAT NORTHERN PAPER INC.
CHAMPION INTERNATIONAL
JAMES RIVER CORP.
EASTERN FINE PAPER INC.
STATLER TISSUE CO.
YORKTOWNE PAPER MILLS CO.
SCOTT PAPER CO.
FRASER PAPER LTD.
KEYES FIBRE CO.
GREAT NORTHERN PAPER CO.
MADISON PAPER INDUSTRIES
MEAD CORP.
CHAMPION INTERNATIONAL
S D WARREN CO.
MENASHA CORP.
PACKAGING CORP. OF AMERICA
STONE CONTAINER CORP.
JEFFERSON SMURFIT CORP.
PLAINWELL PAPER CO INC
JAMES RIVER CORP.
MONROE PAPER CO
JAMES RIVER CORP.
KIMBERLY-CLARK CORP.
WHITE PIGEON PAPER CO.
ROCK-TENN CO.
JAMES RIVER CORP.
FLETCHER PAPER CO.
SIMPSON PAPER CO.
SIMPLEX PRODUCTS GROUP
P & G PAPER PRODUCTS CO.
E. B. EDDY PAPER INC.
BIG M PAPERBOARD
JAMES RIVER CORP.
City
LINCOLN
OLD TOWN
MILLINOCKET
BUCKSPORT
LIVERMORE
BREWER
AUGUSTA
GARDINER
WINSLOW
MADAWASKA
WATERVILLE
EAST MILLINOCKET
MADISON
ESCANABA
QUINNESEC
ML'SKEGON
OTSEGO
FILER CITY
ONTONAGON
MONROE
PLAINWELL
PARCHMENT
MONROE
ROCHESTER
MUNIS ING
WHITE PIGEON
OTSEGO
YPSILANTI
ALPENA
VICKSBURG
CONSTATINE
CHEBOYGAN .
PORT HURON
PALMYRA
KALAMAZOO
Stale
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
MI
MI
MI
MI
Ml
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI.
MI
MI
MI
MI
MI
MI
MBfType Bleached?
kraft bleached
kraft bleached
sulfite unbleached
kraft bleached
kraft bleached
kraft bleached
semichem unbleached
semichem unbleached
semichem unbleached
-
A-7
-------
Name
MANISTIQUE PAPERS INC.
GEORGIA-PACIFIC CORP.
AMERICAN FIBRIT CO.
WALDORF CORP.
DETROIT RIVER PAPER CO.
SIMPLICITY PATTERN CO. INC.
MENOMINEE PAPER CO. INC.
FRENCH PAPER CO.
JAMES RIVER CORP.
CONVERTERS PAPERBOARD CO.
MICHIGAN PAPERBOARD
BOISE CASCADE CORP.
POTLATCH CORP.
BLANDIN PAPER CO.
CHAMPION INTERNATIONAL
CERTAINTEED CORP.
POTLATCH CORP
LAKE SUPERIOR PAPER INDUSTRIES
HENNEPIN PAPER CO.
WALDORF CORP.
City
MANISTIQUE
KALAMAZOO
BATTLE CREEK
BATTLE CREEK
DETROIT
NILES
MENOMINEE
NILES
PORT HURON
ROCKFORD
BATTLE CREEK
INTERNATIONAL FALLS
CLOQUET
GRAND RAPIDS
SARTELL
SHAKOPEE
BRAINERD
DULUTH
LITTLE FALLS
ST. PAUL
State 8«»Tj>p« Steadied?
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MN kraft bleached
MN kraft bleached
MN
MN
MN
MN
MN
MN
MN
TAMKO ASPHAULT PRODUCTS INC.
U.S. GYPSUM CORP.
TALLMAN CONDUIT CO.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
WEYERHAEUSER PAPER CO.
INTERNATIONAL PAPER CO.
GEORGIA-PACIFIC CORP.
INTERNATIONAL PAPER CO.
BURROWS PAPER CORP.
JAMES RIVER CORP.
NEWSPRINT SOUTH INC.
ATLAS ROOFING CO.
STONE CONTAINER CORP.
FEDERAL PAPER BOARD CO.
JOPLIN
N. KANSAS CITY
LOUISIANA
MOSS POINT
NEW AUGUSTA
COLUMBUS
NATCHEZ
MONTICELLO
REDWOOD
PICKENS
WIGGINS
GRENADA
MARIDIAN
MISSOULA
RIEGELWOOD
MO
MO
MO
MS
MS
MS
MS
MS
MS
MS
MS
MS
MS
MT
NC
kraft
kraft
kraft
kraft
kraft
kraft
kraft
kraft
bleajr,'.:..:
bleached
bleached
bleached
unbleached
unbleached
bleached
bleached
A-8
-------
Name
CHAMPION INTERNATIONAL
WEYERHAEUSER PAPER CO.
WEYERHAEUSER PAPER CO.
CHAMPION INTERNATIONAL
u.s. PACKAGING'INC.
ALPHA CELLULOSE CORP.
CAROLINA PAPER BOARD CORP.
SEALED AIR
JACKSON PAPER MFG. CO.
CASCADES INDUSTRIES INC.
LAUREL HILL PAPER CO.
LYDALL INC.
CELLU PRODUCTS
CELOTEX CORP.
P. H. GLATFELTER CO.
HALIFAX PAPERBOARD CO. INC.
JAMES RIVER CORP.
GROVETON PAPER BOARD INC.
CPM INC.
QUIN-TCORP. -NH
LYDALL INC.
PAPER SERVICES LYL-
PENACOOK FIBRE GJ.
PAPERTECH CORP
ASHUELOT PAPER CO.
COY PAPER CO.
MONADNOCK PAPER MILLS INC.
G.E. ROBERTSON & CO.
CAMDEN PAPERBOARD
GEORGIA-PACIFIC CORP
HOMASOTECO.
U.S. GYPSUM CORP.
MILLEN INDUSTRIES
KIMBERLY-CLARK CORP.
JAMES RIVER CO.
City
CANTON
NEW BERN
PLYMOUTH
ROANOKE RAPIDS
MAXTON
LUMBERTON
CHARLOTTE
ROCKINGHAM
SYLVA
ROCKINGHAM
CORDOVA
TROY
PATTERSON
GOLDSBORO
PISGAH FOREST
ROANOKE RAPIDS
BERLIN
GROVETON
CLAREMONT
T1LTON
ROCHESTER
HINDALE
PENACOOK
WEST HOPKFNTON
HINSDALE
CLAREMONT
BENNINIGTON
HINSDALE
CAMDEN
DELAIR
W. TRENTON
CLARK
GARWOOD
SPOTSWOOD
WARREN GLEN
Stale
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
ND
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NH
NJ
NJ
NJ
NJ
NJ
NJ
NJ
SUKType Bleached?
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft bleached
semichem unbleached
A-9
-------
Name
JAMES RIVER CO.
DAVEY CO.
JAMES RIVER CORP.
NEWARK BOXBOARD CO.
MARCAL PAPER MILLS INC.
GARDEN STATE PAPER CO.
LOWE PAPER CO.
LEATHERBACK INDUSTRIES
INTERNATIONAL PAPER CO.
FINCH PRUYN & CO. INC.
JAMES RIVER CORP.
U.S. GYPSUM CORP.
MCINTYRE PAPER CO. INC.
EASTMAN KODAK
NORTH END PAPER CO.
HOLLINGSWORTH & VOSE CO.
CLIMAX MFG. CO.
SCHOELLER TECHNICAL PAPERS FNC
COLUMBIA CORF.
SPAULDING COMPOSITES CO
MOHAWK PAPER MILLS INC
COLUMBIA CORP.
BURROWS PAPER CORP.
TAGSONS PAPERS FNC
FORT ORANGE PAPER CO. INC.
RED HOOK PAPER CO.
LEWIS MILL
C & A WALLCOVERINGS INC.
HAMMERMILL PAPERS BUSINESS
City
MILFORD
JERSEY CITY
MILFORD
NEWARK
ELMWOOD PARK
GARFIELD
RIDGEFIELD
ALBUQERQUE
TICONDEROGA
GLENS FALLS
GOUVERNEUR
OAKFIELD
FAYETTEVILLE
ROCHESTER
FULTON
GREENWICH
CARTHAGE :
PULASKI
WALLOOMSAC
TON A WAND A
WATERFORD
CHATHAM
LITTLE FALLS
MECHAMCVILLE
CASTLETON-ON-
HUDSON
RED HOOK
BEAVER FALLS
PLATTSBURGH
OSWEGO
- Stale MOIType Bleached?
NJ
NJ . .
NJ
NJ
NJ
NJ
NJ
MM
NY kraft bleached
NY sulfite bleached
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
A-10
-------
Name
POTSDAM PAPER MILLS
BURROWS PAPER CORP.
LYDALL INC.
EASTMAN KODAK CO.
INTERNATIONAL PAPER CO.
CORNWALL PAPER MILLS
COTTRELL PAPER CO. INC.
KIMBERLY-CLARK CORP.
HOLLINGSWORTH & VOSE CO.
STEVENS & THOMPSON PAPER
CO.INC.
LYONS FALLS PULP & PAPER INC.
CHAMPION INTERNATIONAL .
KNOWLTON SPECIALTY PAPERS INC.
JAMES RIVER CORP.
JAMES RIVER CORP
MOHAWK PAPER MILLS INC
PAPYRUS NEWTON FALLS INC.
SPECIALTY PAPER BOARD INC.'
JAMES RIVER CORP.
SCOTT PAPER CO.
SONOCO PRODUCTS : O
FLOWER CITY TISSUE Nli.LS CO
NORFOLK PAPER CO.
CASCADES NIAGARA FALLS INC.
PACKAGING CORP. OF AVF'MCA
DOMTAR GYPSUM
MARTISCO PAPER CO. INC
LYONS FALLS PULP & PAPER INC.
MEAD PAPER
STONE CONTAINER CORP.
CONTAINER CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
FRANKLIN BOXBOARD CO.
PACKAGING CORP. OF AMERICA
JEFFERSON SMURFIT CORP.
City
POTSDAM
LITTLE FALLS
HOOSICK FALLS
ROCHESTER
CORINTH
CORNWALL
ROCK CITY FALLS
ANCRAM
GREENWICH
MIDDLE FALLS
LYONS FALLS
DEFERJET
WATERTOWN
SOUTH GLENS FALLS
BROWN VILLE
COHOES
NEWTON FALLS
BEAVER FALLS
CARTHAGE
FORT EDWARD
AMSTERDAM
ROCHESTER
NORFOLK
NIAGARA FALLS
PLATTSBURGH
LOCKPORT
MARCELLUS
LYONS FALLS
CHILL1COTHE
COSHOCTON
CIRCLEVILLE
MIDDLETON
FRANKLIN
RITTMAN
LOCKLAND
Stale JfcJBIType
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
OH kraft
OH semichem
OH semichem
OH
OH
OH
OH
Bleached?
bleached
unbleached
unbleached
A-ll
-------
%"x'"' * (feme
CLEANERS HANGER CO.
CHASE PACKAGING CORP.
OHIO PULP MILLS INC.
MIAMI PAPER
U.S: GYPSUM CORP.
SORG PAPER CO.
DUPONT SPECIALTY IMAGING
MEDIA
CRYSTAL TISSUE CO.
SONOCO PRODUCTS CO.
CHENEY PULP & PAPER CO.
BECKETT PAPER CO.
GAYLORD CONTAINER CORP.
GEORGIA-PACIFIC CORP.
CHAMPION INTERNATIONAL
CINCINNATI PAPERBOARD CORP.
ROCK-fTENN CO.
GREIF 'BOARD CORP.
APPLETON PAPERS INC.
SONOCO PRODUCTS CO.
HOWARD PAPER MILLS INC.
CERTAINTEEDCORP.
HOWARD PAPER MILLS INC.
MIDDLETOWN PAPERBOARD INC.
WEYERHAEUSER PAPER CO.
NATIONAL GYPSUM CO.
PORT HOWARD CORP.
ROBEL TISSUE MILLS INC.
GEORGIA-PACIFIC CORP.
GEORGIA-PACIFIC CORP.
GEORGIA-PACIFIC CORP.
BOISE CASCADE CORP.
POPE &. TALBOT INC.
JAMES RIVER CORP.
INTERNATIONAL PAPER CO.
WEYERHAEUSER PAPER CO.
C«y
MASSILLON
CHAGRIN FALLS
CINCINNATI
WEST CARROLLTON
GYPSUM
MIDDLETON
COLUMBUS
MIDDLETON
MUNROE FALLS
FRANKLIN
HAMILTON
BALTIMORE
FRANKLIN
HAMILTON
CINCINNATI
CINCINNATI
MASSILLON
WEST CARROLLTON
LANCASTER
DAYTON
MILAN
URBANA
MIDDLETOWN
VALLIANT
PRYOR
MUSKOGEE
PRYOR
PRYOR
ARDMORE
TOLEDO
ST HELENS
HALSEY
CLATSKANIE
GARDINER
SPRINGFIELD
'**' Slate
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OK
OK
OK
OK
OR
OR
OR
OR
OR
OR
MBl Type Bleached?
kraft unbleached
co-semi unbleached
kraft bleached
kraft bleached
kraft bleached
kraft unbleached
kraft unbleached
A-12
-------
N«ne
WILLAMETTE INDUSTRIES INC.
WEYERHAEUSER PAPER CO.
JAMES RIVER CORP.
JAMES RIVER CORP.
SMURFIT NEWSPRINT CORP.
SMURFIT NEWSPRINT CORP.
WILLAMETTER INDUSTRIES INC.
P. H. GLATFELTER CO.
APPLETON PAPERS INC.
INTERNATIONAL PAPER CO.
P & G PAPER PRODUCTS CO.
WESTVACO CORP.
AHLSTROM FILTRATION INC.
BRANDYWINE PAPER CORP.
YORKTOWNE PAPER MILLS INC.
NEWMAN AND COMPANY' INC.
SHRYOCK BROTHERS
INTERSTATE CONTAINER CORP
HAMMERMILL PAPERS BUSINESS
AMERICAN PAPER PRODUCTS CO
CONTAINER COR- Of AMERICA
EXTON PAPER
SCOTT PAPER CO
NATIONAL GYPSUM CO
WOODSTREAM CORP.
STONE CONTAINER CORP
ROCK-TENN CO.
READING PAPERBOARD CORP.
SONOCO PRODUCTS CO
QUIN-T CORP. - PA
HENRY MOLDED PRODUCTS INC.
SEALED AIR
POPE & TALBOT INC.
CORNELLY CONTAINERS
DAVEY CO.
Ciiy
ALBANY
NORTH BEND
HALSEY
WEST LINN
OREGON CITY
NEWBURG
JOHNSONBURG
SPRING GROVE
ROARING SPRING
ERIE
MEHOBANY
TYRONE
MT HOLLY SPRINGS
DOWNFNGTOWN
YORK
PHILIDELPHIA '
DO.WNTNGTO\\"N
READING
LOCK HAVEN
EDEN
PHILADELPHIA
MODENA
CHESTER
MILTON
LITITZ
YORK
DELAWARE WATER GAP
READING
DOWNINGTOWN
ERIE
LEBANON
MODENA
RANSOM
PHILIDELPHIA
DOWNINGTOWN
StiHt
OR
OR
OR
OR
OR
OR
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
MQITyp* Bleached?
kraft bleached
semichem unbleached
kraft bleached
kraft bleached
kraft bleached
soda bleached
sulfite bleached
A-13
-------
N«ne
City
State NffiType Bleached?
SIMPSON PAPER CO.
M.H. DIELECTRICS INC.
UNION CAMP CORP.
WILAMETTE IND.
BOWATER SOUTHERN PAPER CO.
MIQUON PA
MOUNT HOLLY SPRINGS PA
EASTOVER SC kraft bleached
BENNETTSVILLE SC kraft bleached
CATAWBA SC kraft bleached
INTERNATIONAL PAPER CO.
STONE CONTAINER CORP.
WESTVACO CORP.
SONOCO PRODUCTS CO.
KIMBERLY-CLARK. CORP.
GEORGETOWN SC
FLORENCE SC
NORTH CHARLESTON SC
HARTSVILLE SC
BEECH ISLAND SC
kraft bleached
kraft unbleached
kraft unbleached
semichem unbleached
CAROTELL PAPER BOARD CORP.
BOWATER SOUTHERN PAPER CO.
PACKAGING CORP. OF AMERICA
INLAND CONTAINER CORP.
MEAD CORP. '
TAYLORS SC
CALHOUN TN
COUNCE TN
NEWJOHNSONVILLE TN
KINGSPORT TN
kraft bleached
kraft unbleached
semichem unbleached
soda bleached
TAMKO ASPHAULT PRODUCTS FNC.
PONDEROSA OF TENNESSEE
ROCK-TEN^ CO
LYDALL INC.
P&G CELLULOSE
KNOXV1LLE
MEMPHIS
CHATTANOOGA
COVINGTON
MEMPHIS
TN
TN
TN
TN
TN
KIMBERLY-CLARK CORP
SONOCO PRODUCTS CO.
AHLSTROM FILTRATION INC.
CHATTANOOGA PAPERBOARD
CORP.
TEMPLE-INLAND FOREST PROD. INC
MEMPHIS
NEWPORT
CHATTANOOGA
CHATTANOOGA
SILSBEE
TN
TN
TN
TN:
TX
kraft
bleached
SIMPSON PAPER CO.
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
INTERNATIONAL PAPER CO.
INLAND-ORANGE INC.
PASADENA
LUFKIN
HOUSTON
TEXARKANA
ORANGE
TX
TX
TX
TX
TX
kraft
kraft
kraft
kraft
kraft
bleached
bleached
bleached
bleached
unbleached
CELOTEX CORP.
ROCK-TENN CO.
CORRUGATED SERVICES
U.S. GYPSUM CORP.
EQUITABLE BAG CO. INC.
SAN ANTONIO
DALLAS
FORNEY
GALENA PARK
ORANGE
TX
TX
TX
TX
TX
A-14
-------
Hcne
WESTVACO CORP.
CHESAPEAKE CORP.
UNION CAMP CORP
STONE CONTAINER CORP.
GEORGIA-PACIFIC CORP.
VIRGINIA FIBRE CORP.
JAMES RIVER CORP.
GEORGIA BONDED FIBERS
BEAR ISLAND PAPER CO.
SONOCO PRODUCTS CO.
ROCK-TENN CO.
MANCHESTER BOARD & PAPER CO.
EHV-WEIDMAXN INDUSTRIES INC.
SPECIALTY PAPERBOARD
SIMPSON PAPER CO.
CPM INC
PUTNEY PAPER CO INC
SPECIALTY PAPER BOARD
BOISE CASCADE CORP.
WEYERHAEUSER PAPER CO.
LONGVIEW FIBRE CO
JAMES RIVER CORP
SIMPSON TACOVA KRAFT CO
WEYERHAEUSER PULP MILL
PORT TOWNSEND PAPER CORP.
ITT RAYONIER INC.
GEORGIA-PACIFIC CORP.
SCOTT PAPER CO.
WEYERHAEUSER PAPER CO
SONOCO PRODUCTS CO.
PONDERAY NEWSPRINT CO.
CONTAINER CORP. OF AMERICA
BOISE CASCADE CORP.
KEYES FIBRE CO.
NORTH PACIFIC PAPER CO.
City
COVINGTON
WEST POINT
FRANKLIN
HOPEWELL
BIG ISLAND
AMHERST
RICHMOND
BUENA VISTA
ASHLAND
RICHMOND
LYNCHBURG
RICHMOND
ST. JOHNSBURY
SHELDON SPRINGS
OILMAN
E. RYEGATE
PUTNEY
SHELDON SPRINGS
WALLULA
LONGVIEW
LONG VIEW
CAMAS
TACOMA '
EVERETT
PORT TOWNSEND
PORT ANGELES
BELLINGHAM
EVERETT
COSMOPOLIS
SUMNER
USK
TACOMA
VANCOUVER
WENATCHEE
LONGVIEW
State
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VT
VT
VT
VT
VT
VT
WA
,WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
MQITyp*
kraft
kraft
kraft
kraft
semichem
semichem
co-semi
Co-semi
co-semi
co-sulfite
kraft
kraft
kraft
sulfite
sulflte
sulfite
sulfite
Bte&<$ed?
bleached
bleached
bleached
unbleached
unbleached
unbleached
bleached
bleached
bleached
bleached
bleached
unbleached
unbleached
bleached
bleached
bleached
bleached
A-15
-------
Nttoe
BOISE CASCADE CORP.
DAISHOWA AMERICA CO. LTD.
GRAYS HARBOR PAPER CO.
ITT-RAYON1ER, INC.
INLAND EMPIRE PAPER CO.
GEORGIA-PACIFIC CORP.
CONSOLIDATED PAPERS INC.
MOSINEE PAPER CO.
THILMANY PULP & PAPER CO.
PACKAGING CORP. OF AMERICA
CROSS POINTE PAPER CORP.
BADGER PAPER MILLS INC.
WEYERHAUSER
WAUSAU PAPER MILLS CO.
GEORGIA-PACIFIC CORP.
NICOLET PAPER CO.
GLOBE BUILDING MATERIALS INC.
BELOIT BOX BOARD CO.
SCOTT PAPER CO.
POPE & TALBOT INC.
WARD PAPER CO TNTN'L. PAPER
MEAD CORP.
U.S. PAPER MILLS INC.
CONSOLIDATED PAPERS INC.
JAMES RIVER CORP
SHAWANO PAPER MILS
STEVENS POINT DIV.
FORT HOWARD CORP.
RHINELANDER PAPER CORP. INC.
SCOTT PAPER CO.
NIAGARA OF WISCONSIN PAPER
CORP.
FOX RIVER PAPER CO. INC.
POPE & TALBOT INC.
NEENAH PAPER
KERW1N PAPER CO.
City
STEILACOOM
PORT ANGELES
HOQUIAM
HOQUIAM
MILLWOOD
NEKOOSA
WISCONSIN RAPIDS
MOSINEE
KAUKAUNA
TOMAHAWK
PARK FALLS
PESHITIGO
ROTHSCHILD
BROKAW
PORT EDWARDS
DE PERE
CORNELL
BELOIT
MARINETTE
EAU CLAIRE
MERRILL
MENASHA
DEPERE
WISCONSIN RAPIDS
GREEN BAY
SHAWANO
STEVENS POINT
GREEN BAY
RHINELANDER
OCONTOFALLS
NIAGARA
APPLETON
EAST LADYSMITH
STEVENS POINT
APPLETON
State MB! Type Steadied?
WA
WA
WA
WA
WA
WI kraft bleached
WI kraft bleached
WI kraft unbleached
WI kraft unbleached
WI semichem unbleached
WI sulfite bleached
WI sulfite bleached
WI sulfite bleached
WI sulfite bleached
WI sulfite bleached
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI '
WI
WI
WI
A-16
-------
Name
GEO A. WHITING PAPER CO.
WISCONSIN TISSUE MILLS INC.
P&G
WISCONSIN PAPERBOARD
JAMES RIVER CORP.
PONDEROSA PULP PRODUCTS
P. H. GLATFELTER CO.
MIDTEC PAPER CORP.
APPLETON PAPERS INC.
CONSOLIDATED PAPERS INC.
U.S. PAPER MILLS CORP.
CONSOLIDATED PAPERS INC.
FILTER MATERIALS INC.
KIMBERLY-CLARK
KIMBERLY-CLARK CORP.
BADGER PAPER MILLS FNC
HALLTOWN PAPERBOARD Cu.
BANNER FIBREBO.ARD CO
City
MENASHA
MENASHA
GREEN BAY
MILWAUKEE
ASHLAND
OSHKOSH
NEEHAH
KIMBERLY
COMBINED LOCKS
STEVENS POINT
MENASHA
WISCONSIN RAPIDS
WAUPACA
NEENAH
NEENAH
NEENAH
HALLTOXVN
WELLSBL'RG
State MBIType Bleached?
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
WI
wv
wv
A-17
-------
-------
Appendix B
NESHAP for Source Category: Pulp and Paper Production
(40 CFR 63 Subpart S)
-------
PART 63-NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
POLLUTANTS FOR SOURCE CATEGORIES
1. The authority citation for part 63 continues to read as follows:
Authority: 42 U.S.C. 7401, et seq.
2. Part 63 is amended by adding subpart S to read as follows:
Subpart S—National Emission Standards for Hazardous Air Pollutants from the Pulp and
Paper Industry
Sec.
63.440 Applicability.
63.441 Definitions.
63.442 [Reserved]
63.443 Standards for the pulping system at kraft. soda, .and semi-chemical processes.
63.444 Standards for the pulping system at suifite processes.
63.445 Standards for the bleaching system.
63.446 Standards for kraft pulping process condensates.
63.447 Clean condensate alternative.
63.448-63.449 [Reserved]
63.450 Standards for enclosures and closed-vent systems.
63.451-63.452 [Reserved]
63.453 Monitoring requirements.
63.454 Recordkeeping requirements.
63.455 Reporting requirements.
63.456 [Reserved
63.457 Test methods ar.j procedures.
63.458 Delegate:- ,-
-------
(1) For the processes specified in paragraph (a)(l) of this section, the affected source is the
total of all HAP emission points in the pulping and bleaching systems; or
(2) For the processes specified in paragraphs (a)(2) or (a)(3) of this section, the affected source
is the total of all HAP emission points in the bleaching system.
(c) The new source provisions of this subpart apply to the total of all HAP emission points at
new or existing sources as follows:
(1) Each affected source defined in paragraph (b)(l) of this section that commences
construction or reconstruction after December 17,1993;
(2) Each pulping system or bleaching system for the processes specified in paragraph (a)(l) of
this section that commences construction or reconstruction after December 17, 1993;
(3) Each additional pulping or bleaching line at the processes specified in paragraph (a)(l) of
this section, that commences construction after December 17. 1993;
(4) Each affected source defined in paragraph (b)(2) of this section that commences
construction or reconstruction after March 8, 1996; or
(5) Each additional bleaching line at the processes specified in paragraphs (a)(2) or (a)(3) of
this section, that commences construction after March 8. 1996.
(d) Each existing source shall achieve compliance no later than April 16, 2001. except as
provided in paragraphs (d)(l) through (d)(3) of this section.
(1) Each kraft pulping system shall achieve compliance with the pulping system provisions of
Sec. 63.443 for the equipment listed in Sec. 63.443(a)(l)(ii) through (a)(l)(v) as expeditiously as
practicable, but in no event later than April 17. 2006 and the owners and operators shall establish
dates, update dates, and report the dates for the milestones specified in Sec. 63.455(bi.
(2) Each dissolving-grade bleaching system at either kraft or sulfite pulping mills shall achieve
compliance with the bleach plant provisions of Sec. 63.445 of this subpart as expeditiously as
practicable, but in no event later than 3 years after the promulgation of the revised effluent
limitation guidelines and standards under 40 CFR 430.14 through 430.17 and 40 CFR 430.44
through 430.47.
(3) Each bleaching system complying with the Voluntary Advanced Technology Incentives
Program for Effluent Limitation Guidelines in 40 CFR 430.24. shall comply with the
requirements specified in either paragraph (d)(3)(i) or (d)(3)(if) of this section for the effluent
limitation guidelines and standards in 40 CFR 430.24.
(i) Comply with the bleach plant provisions of Sec. 63.445 of this subpart as expeditioush as
practicable, but in no event later than April 16, 2001.
(ii) Comply with all of the following:
(A) The owner or operator of a bleaching system shall comply with the bleach plant provisions
of Sec. 63.445 of this subpart as expeditiously as practicable, but in no event later than April 15
2004.
(B) The owner or operator of a bleaching system shall not increase the application rate of
chlorine or hypochlorite in kg of bleaching agent per megagram of ODP, in the bleaching system
above the average daily rates used over the three months prior to June 15, 1998 until the
requirements of paragraph (d)(3)(ii)(A) of this section are met and record application rates as
specified in Sec. 63.454(c). . •
(C) Owners and operators shall establish dates, update dates, and report the dates for the
milestones specified in Sec. 63.455(b).
B-2
-------
(e) Each new source, specified as the total of all HAP emission points for the sources
specified in paragraph (c) of this section, shall achieve compliance upon start-up or June 15,
1998, whichever is later, as provided in Sec. 63.6(b) of subpart A of this part.
(f) Each owner or operator of an affected source with affected process equipment shared by
more than one type of pulping process, shall comply with the applicable requirement in this
subpart that achieves the maximum degree of reduction in HAP emissions.
(g) Each owner or operator of an affected source specified in paragraphs (a) through (c) of this
section must comply with the requirements of subpart A~General Provisions of this part, as
indicated in table 1 to this subpart.
Sec. 63.441 Definitions.
All terms used in this subpart shall have the meaning given them in the CAA, in subpart A of
this pan, and in this section as follows:
Acid condensaie storage tank means any storage tank containing cooking acid following the
sulfur dioxide gas fortification process.
Black liquor means spent cooking liquor that has been separated from the pulp produced by
the kraft. soda, or semi-chemical pulping process.
Bleaching means brightening of pulp by the addition of oxidizing chemicals or reducing
chemicals.
Bleaching line means a group of bleaching stages arranged in series such that bleaching of the
pulp progresses as the pulp moves from one stage to the next.
Bleaching stage means a!! process equipment associated with a discrete step of chemical
application and remo\ai in the bleaching process including chemical and steam mixers, bleaching
towers, washers, sea! (filtrate < tanks, vacuum pumps, and any other equipment serving the same
function as those pre-. iou;-:y listed.
Bleaching system means ail process equipment after high-density pulp storage prior to the first
application of oxidizing chemicals or reducing chemicals following the pulping system, up to and
including the final bleaching stage.
Boiler means any enclosed combustion device that extracts useful energy in the form of steam.
A boiler is not considered a thermal oxidizer.
Chip steamer means a vessel used for the purpose of preheating or pretreating wood chips
prior to the digester, using flash steam from the digester or live steam.
Closed-vent system means a system that is not open to the atmosphere and is composed of
piping, ductwork, connections, and, if necessary, flow-inducing devices that transport gas or
vapor from an emission point to a control device.
B-3
-------
Combustion device means an individual unit of equipment, including but not limited to, a
thermal oxidizer, lime kiln, recovery furnace, process neater, or boiler, used for the thermal
oxidation of organic hazardous air pollutant vapors.
Decker system means all equipment used to thicken the pulp slurry or reduce its liquid content
after the pulp washing system and prior to high-density pulp storage. The decker system includes
decker vents, filtrate tanks, associated vacuum pumps, and any other equipment
serving the same function as those previously listed.
Digester system means each continuous digester or each batch digester used for the chemical
treatment of wood or non-wood fibers. The digester system equipment includes associated flash
tank(s), blow tank(s). chip steamer(s) not using fresh steam, blow heat recovery
accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding the pulp washing system,
and any other equipment serving the same function as those previously listed. The digester
system includes any of the liquid streams or condensates associated with batch or
continuous digester relief, blow, or flash steam processes.
Emission point means any part of a stationary source that emits hazardous air pollutants
regulated under this subpart. including emissions from, individual process vents, stacks, open
pieces of process equipment, equipment leaks, wastewater and condensate collection and
treatment system units, and those emissions that could reasonably be conveyed through a stack.
chimnev, or duct where such emissions first reach the environment.
t• '
Evaporator system means all equipment associated with increasing the solids content and'or
concentrating spent cooking liquor from the pulp washing system including pre-evaporators.
multi-effect evaporators, concentrators, and vacuum systems, as well as associated
condensers, horvvells. and condensate streams, and any other equipment serving the same
function as those previously listed.
Flow indicator means any device that indicates gas or liquid flow in an enclosed system.
HAP means a hazardous air pollutant as defined in Sec. 63.2 of subpart A of this part.
High volume, low concentration or HVLC collection system means the gas collection and
transport system used to convey gases from the HVLC system to a control device.
High volume, low concentration or HVLC system means the collection of equipment including
the pulp washing, knotter. screen, decker, and oxygen delignification systems, weak liquor
storage tanks, and any other equipment serving the same function as those previously listed.
Knctter system means equipment where knots, oversized material,.or pieces of uncooked wood
are removed from the pulp slurry after the digester system and prior to the pulp washing system. \
The knotter system equipment includes the knotter, knot drainer tanks, ancillary tanks, and any |
other equipment serving the same function as those previously listed.
B-4
-------
Kraft pulping means a chemical pulping process that uses a mixture of sodium hydroxide and
sodium sulfide as the cooking liquor.
*r
Lime kiln means an enclosed combustion device used to calcine lime mud, which consists
primarily of calcium carbonate, into calcium oxide.
Low volume, high concentration or L VHC collection system means the gas collection and
transport system used to convey gases from the L VHC system to a control device.
Low volume, high concentration or L VHC system means the collection of equipment including
the digester, turpentine recovery, evaporator, steam stripper systems, and any other equipment
serving the same function as those previously listed.
Mechanical pulping means a pulping process that only uses mechanical and
thermo-mechanical processes to reduce wood to a fibrous mass. The mechanical pulping
processes include, but are noi limited to. stone groundwood, pressurized groundwood. refiner'
mechanical, thermal refiner mechanical, thermo-mechanical, and tandem thermo-mechanical.
Non-wood pulping means the production of pulp from fiber sources other than trees. The
non-wood fiber sources include, but are not limited to. bagasse, cereal straw, cotton, flax straw.
hemp. jute, kenaf. and leaf fibers.
Oven-dried pulp or OOP means a pulp sample at zero percent moisture content by weight.
Pulp samples for applicability or compliance determinations for both the pulping and bleaching
systems shall be unbleached pulp. For purposes of complying with mass emission limits in
this subpart. megagram of OOP shall be measured to represent the amount of pulp entering and
processed by the equipment system under the specified mass limit. For equipment that does not
process pulp, megagrarr; of OOP shall be measured to represent the amount of pulp that was
processed to produce the gas and liquid streams.
Ox\'gen deligni'i^dtion system means the equipment that uses oxygen to remove lignin from
pulp after high-density stock storage and prior to the bleaching system. The oxygen
delignification system equipment includes the blow tank, washers, filtrate tanks, any interstage
pulp storage tanks, and any other equipment serving the same function as those previously listed.
Primary fuel means the fuel that provides the principal heat input to the combustion device. To
be considered primary, the fuel must be able to sustain operation of .the combustion device
without the addition of other fuels.
Process wastewater treatment system means a collection of equipment, a process, or specific
technique that removes or destroys the HAP's in a process wastewater stream. Examples include,
but are not limited to. a steam stripping unit, wastewater thermal oxidizer, or ;
biological treatment unit.
Pulp washing system means all equipment used to wash pulp and separate spent cooking
chemicals following the digester system and prior to the bleaching system, oxygen delignification
B-5
-------
system, or paper machine system (at unbleached mills). The pulp washing system equipment
includes vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt
filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, foam
breakers or tanks, and any other equipment serving the same function as those previously listed.
The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp
storage tanks following the last stage of pulp washing.
Pulping line means a group of equipment arranged in series such that the wood chips are
digested and the resulting pulp progresses through a sequence of steps that may include knotting,
refining, washing, thickening, blending, storing, oxygen delignification, and any other equipment
serving the same function as those previously listed.
Pulping process condensates means any HAP-containing liquid that results from contact of
water with organic compounds in the pulping process. Examples of process condensates include
digester system condensates. turpentine recovery system condensates, evaporator system
condensates. LVHC system condensates. HVLC system condensates. and any other condensates
from equipment serving the same function as those previously listed. Liquid streams that are
intended for byproduct recovery are not considered process condensate streams.
Pulping system means all process equipment, beginning with the digester system, and up to
and including the last piece of pulp conditioning equipment prior to the bleaching system.
including treatment with ozone, oxygen, or peroxide before the first application of a chemical
bleaching agent intended to brighten pulp. The pulping system includes pulping process
condensates and can include multiple pulping lines.
Recovery furnace means an enclosed combustion device where concentrated spent liquor is
burned to recover sodium and sulfur, produce steam, and dispose of unwanted dissolved wood
components in the liquor.
Screen system means equipment in which oversized particles are removed from the pulp slum
prior to the bleaching or paper-making system washed stock storage.
Secondary fiber pulping means a pulping process that converts a fibrous material, that has
previously undergone a manufacturing process, into pulp stock through the addition of water and
mechanical energy. The mill then uses that pulp as the raw material in another manufactured
product. These mills may also utilize chemical, heat, and mechanical processes to remove ink
particles from the fiber stock.
Semi-chemical pulping means a pulping process that combines both chemical and mechanical
pulping processes. The semi-chemical pulping process produces intermediate yields ranging from
55 to 90 percent.
Soda pulping means a chemical pulping process that uses sodium hydroxide as the active
chemical in the cooking liquor.
B-6
-------
Spent liquor means process liquid generated from the separation of cooking liquor from pulp
by the pulp washing system containing dissolved organic wood materials and residual cooking
compounds. *
Sieam stripper system means a column (including associated stripper feed tanks, condensers,
or heat exchangers) used to remove compounds from wastewater or condensates using steam.
The steam stripper system also contains all equipment associated with a methanol rectification
process including rectifiers, condensers, decanters, storage tanks, and any other equipment
serving the same function as those previously listed.
Strong liquor storage tanks means all storage tanks containing liquor that has been
concentrated in preparation for combustion or oxidation in the recovery process.
Sulfite pulping means a chemical pulping process that uses a mixture of sulfurous acid and
bisulfite ion as the cooking liquor.
Temperature monitoring device means a piece of equipment used to monitor temperature and
having an accuracy of 1.0 percent of the temperature being monitored expressed in degrees
Celsius or 0.5 degrees Celsius ( deg.C), whichever is greater.
Thermal oxidizer means an enclosed device that destroys organic compounds by thermal
oxidation.
Turpentine recover, system means all equipment associated with recovering turpentine from
digester system gases including condensers, decanters, storage tanks, and any other equipment
sen-ing the same function as those previously listed. The turpentine recovery system includes any
liquid streams associated with the turpentine recovery process such as turpentine decanter
underflow. Liquid streams that are intended for byproduct recovery are not considered turpentine
recovery system condensaic streams.
Weak liquor storage lank means any storage tank except washer filtrate tanks containing spent
liquor recovered from the pulping process and prior to the evaporator system.
Sec. 63.442 [Reserved]
Sec. 63.443 Standards for the pulping system at kraft, soda, and semi-chemical processes.
(a) The owner or operator of each pulping system using the kraft process subject to the
requirements of this subpart shall control the total HAP emissions from the following equipment
systems, as specified in paragraphs (c) and (d) of this section.
(1) At existing affected sources, the total HAP emissions from the following equipment
systems shall be controlled:
(i) Each LVHC system;
(ii) Each knotter or screen system with total HAP mass emission rates greater than or equal to
the rates specified in paragraphs (a)(l )(ii)(A) or (a)(l)(ii)(B) of this section or the combined rate
specified in paragraph (a)(l)(ii)(C) of this section.
B-7
-------
(A) Each knotter system with emissions of 0.05 kilograms or more of total HAP per megagram
of ODP (0.1 pounds per ton).
(B) Each screen system with emissions of 0.10 kilograms or more of total HAP per megagram
of ODP (0.2 pounds per ton).
(C) Each knotter and screen system with emissions of 0.15 kilograms or more of total HAP per
megagram of ODP (0.3 pounds per ton).
(iii) Each pulp washing system;
(iv) Each decker system that:
(A) Uses any process water other than fresh water or paper machine white water; or
(B) Uses any process water with a total HAP concentration greater than 400 parts per million
by weight; and
(v) Each oxygen delignification system.
(2) At new affected sources, the total HAP emissions .from the equipment systems listed in
paragraphs (a)( 1 )(i), (a)( 1 )(iii), and
(a)(l)(v) of this section and the following equipment systems shall be controlled:
(i) Each knotter system;
(ii) Each screen system;
(iii) Each decker system; and
(iv) Each weak liquor storage tank.
(b) The owner or operator of each pulping system using a semi-chemical or soda process
subject to the requirements of this subpart shall control the total HAP emissions from the
following equipment systems as specified in paragraphs (c) and (d) of this section.
(1) At each existing affected sources, the total HAP emissions from each LVHC system shall
be controlled.
(2) At each new affected source, the total HAP emissions from each LVHC system and each
pulp washing system shall be controlled.
(c) Equipment systems listed in paragraphs (a) and (b) of this section shall be enclosed and
vented into a closed-vent system and routed to a control device that meets the requirements
specified in paragraph (d) of this section. The enclosures and closed-vent system shall meet the
requirements specified in Sec. 63.450.
(d) The control device used to reduce total HAP emissions from each equipment system listed
in paragraphs (a) and (b) of this section shall:
(1) Reduce total HAP emissions by 98 percent or more by weight; or
(2).Reduce the total HAP concentration at the outlet of the thermal oxidizer to 20 parts per
million or less by volume, corrected to 10 percent oxygen on a dry basis; or
(3) Reduce total HAP emissions using a thermal oxidizer designed and operated at a minimum
temperature of 871 deg.C (1600 deg.F) and a minimum residence time of 0.75 seconds: or
(4) Reduce total HAP emissions using a boiler, lime kiln, or recovery furnace by introducing
the HAP emission stream with the primary fuel or into the flame zone.
(e) Periods of excess emissions reported under Sec. 63.455 shall not be a violation of Sec.
63.443 (c) and (d) provided that the time of excess emissions (excluding periods of startup.
shutdown, or malfunction) divided by the total process operating time in a semi-annual reporting
period does not exceed the following levels:
(1) One percent for control devices used to reduce the total HAP emissions from the LVHC
system; and
B-8
-------
(2) Four percent for control devices used to reduce the total HAP emissions from the HVLC
system; and
(3) Four percent for control devices used to reduce the total HAP emissions from both the
LVHC and HVLC systems.
Sec. 63.444 Standards for the pulping system at sulfite processes.
•S
(a) The owner or operator of each sulfite process subject to the requirements of this subpart
shall control the total HAP emissions from the following equipment systems as specified in
paragraphs (b) and (c) of this section.
(1) At existing sulfite affected sources, the total HAP emissions from the following equipment
systems shall be controlled:
(i) Each digester system veni;
(ii) Each evaporator system vent: and
(iii) Each pulp washing system.
(2) At new affected sources, the total HAP emissions from the equipment systems listed in
paragraph (a)(l) of this section and the following equipment shall be controlled:
(i) Each weak liquor storage tank:
(ii) Each strong liquor storage tank: and
(iii) Each acid condensate storage tank.
(bi Equipment listed in paragraph (a) of this section shall be enclosed and vented into a
closed-vent system and routed to a control device that meets the requirements specified in
paragraph (c ) of this section. The enclosures and closed-vent system shall meet the requirements
specified in Sec. 63.450. Emissions from equipment listed in paragraph (a) of this section that is
not necessary to be reduced to meet paragraph (c) of this section is not required to be routed to a
control device.
(c) The total HAP emissions from both the equipment systems listed in paragraph (a) of this
section and the vents, \\astewater. and condensate streams from the control device used to reduce
HAP emissions, shall be controlled as follows.
(1 i Each calcium-base j; ^: sodium-based sulfite pulping process shall:
(i) Emit no more than 0.-14 kilograms of total HAP or methanol per megagram (0.89 pounds
per ton) of OOP: or
(ii) Remove 92 percent or more by weight of the total.HAP or methanol.
(2.) Each magnesium-based or ammonium-based sulfite pulping process shall:
(i) Emit no more than 1.1 kilograms of total HAP or methanol per megagram (2.2 pounds per
ton)ofODP;or
(ii) Remove 87 percent or more by weight of the total HAP or methanol.
Sec. 63.445 Standards for the bleaching system.
(a) Each bleaching system that does not use any chlorine or chlorinated compounds for
bleaching is exempt from the requirements of this section. Owners or operators of the following
bleaching systems shall meet all the provisions of this section:
(1) Bleaching systems that use chlorine;
(2) Bleaching systems bleaching pulp from kraft, sulfite, or soda pulping processes that uses
any chlorinated compounds; or
B-9
-------
(3) Bleaching systems bleaching pulp from mechanical pulping processes using wood or from
any process using secondary or non-wood fibers, that use chlorine dioxide.
(b) The equipment at each bleaching stage, of the bleaching systems listed in paragraph (a) of
this section, where chlorinated compounds are introduced shall be enclosed and vented into a
closed-vent system and routed to a control device that meets the requirements specified in
paragraph (c) of this section. The enclosures and closed-vent system shall meet the requirements
specified in Sec. 63.450.
(c) The control device used to reduce chlorinated HAP emissions (not including chloroform)
from the equipment specified in paragraph (b) of this section shall:
(1) Reduce the total chlorinated HAP mass in the vent stream entering the control device by 99
percent or more by weight;
(2) Achieve a treatment device outlet concentration of 10 parts per million or less by volume
of total chlorinated HAP; or
(3) Achieve a treatment device outlet mass emission rate of 0.001 kg of total chlorinated HAP
mass per megagram (0.002 pounds per ton) of OOP.
(d) The owner or operator of each bleaching system subject to paragraph (a)(2) of this section
shall comply with paragraph (d)(l) Qr (d)(2) of this section to reduce chloroform air emissions to
the atmosphere, except the owner or operator of each bleaching system complying with extended
compliance under Sec. 63.440(d)(3)(ii) shall comply with paragraph (d)(l) of this section.
(1) Comply with the following applicable effluent limitation guidelines and standards specified
in 4Q CFR part 430:
(i); Dissolving-grade kraft bleaching systems and lines. 40 CFR 430.14 through 430.17:
(ii) Paper-grade kraft and soda bleaching systems and lines, 40 CFR 430.24(a)(l) and (e), and
40 CFR 430.26 (a) and (c);
(iii) Dissolving-grade sulfite bleaching systems and lines. 40 CFR 430.44 through 430.47; or
(iv) Paper-grade sulfite bleaching systems and lines. 40 CFR 430.54(a) and (c). and 430.56(a)
and (c).
(2) Use no hypochlorite or chlorine for bleaching in the bleaching system or line.
Sec. 63.446 Standards for kraft pulping process condensates.
(a) The requirements of this section apply to owners or operators of kraft processes subject to
the requirements of this subpart.
(b) The pulping process condensates from the following equipment systems shall be treated to
meet the requirements specified in paragraphs (c). (d). and (e) of this section:
(1) Each digester system;
(2) Each turpentine recovery system:
(3) Each evaporator stage where weak liquor is introduced (feed stages) in the evaporator
system;
(4) Each HVLC collection system; and
(5) Each LVHC collection system.
(c) One of the following combinations of HAP-containing pulping process condensates
generated, produced, or associated with the equipment systems listed in paragraph (b) of this
section shall be subject to the requirements of paragraphs (d) and (e) of this section:
(1) All pulping process condensates from the equipment systems specified in paragraphs (b)(l)
through (b)(5) of this section.
B-10
-------
(2) The combined pulping process condensates from the equipment systems specified in
paragraphs (b)(4) and (b)(5) of this section, plus pulping process condensate stream(s) that in
total contain at least 65 percent of the total HAP mass from the pulping process condensates from
equipment systems listed in paragraphs (b)(l) through (b)(3) of this section.
(3) The pulping process condensates from equipment systems listed in paragraphs (b)(l)
through (b)(5) of this section that in total contain a total HAP mass of 3.6 kilograms or more of
total HAP per megagram (7.2 pounds per ton) of ODP for mills that do not perform bleaching or
5.5 kilograms or more of total HAP per megagram (11'.l pounds per ton) of ODP for mills that
perform bleaching. •
(d) The pulping process condensates from the equipment systems listed in paragraph (b) of this
section shall be conveyed in a closed collection system that is designed and operated to meet the
requirements specified in paragraphs (d)( 1) and (d)(2) of this section.
(1) Each closed collection system shall meet the individual drain system requirements
specified in Sec. 63.960. 63.961, and 63.962 of subpart RR of this part, except for closed vent
systems and control devices shall be designed and operated in accordance with Sees. 63.443(d)
and 63.450. instead of in accordance with Sec. 63.693 as specified in Sec. 63.962 (a)(3)(ii),
(b)(3)(ii)(A), and (b)(3)(ii)(B)(5)(iii); and
(2) If a condensate tank is used in the closed collection system, the tank shall meet the
following requirements:
(i) The fixed roof and all openings (e.g.. access hatches, sampling ports, gauge wells) shall be
designed and operated with no detectable leaks as indicated by an instrument reading of less than
500 pans per million above background, and vented into a'closed-vent system that meets the
requirements in Se<_. 65.450 and routed to a control device that meets the requirements in Sec.
63.443(d): and
(ii'i Each opening shali be maintained in a closed, sealed position (e.g., covered by a lid that is
gasketed and latched) at aii times that the tank contains pulping process condensates or any HAP
removed from a pulping process condensate stream except when it is necessary to use the
open i .it: for sampnn.:. remove, or for equipment inspection, maintenance, or repair.
(ei Each pulping process condensate from the equipment systems listed in paragraph (b) of this
section shall be treated according to one of the following options:
(1) Recycle the pulping process condensate to an equipment system specified in Sec. 63.443(a)
meeting the requirements specified in Sec. 63.443(c) and (d); or
(2) Discharge the pulping process condensate below the liquid surface of a biological
treatment system meeting the requirement specified in paragraph (e)(3) of this section: or
(3) Treat the pulping process condensates to reduce or destroy the total HAP's by at least 92
percent or more by weight; or
(4) At mills that do not perform bleaching, treat the pulping process condensates to remove 3.3
kilograms or more of total HAP per megagram (6.6 pounds per ton) of ODP. or achieve a total
HAP concentration of 210 parts per million or less by weight at the outlet of the control device;
or
(5) At mills that perform bleaching, treat the pulping process condensates to remove 5.1
kilograms or more of total HAP per megagram (10.2 pounds per ton) of ODP. or achieve a. total
HAP concentration of 330 parts per million or less by weight at the outlet of the control device.
(f) Each HAP removed from a pulping process condensate stream during treatment and
handling under paragraphs (d) or (e) of this section, except for those treated according to
paragraph (e)(2) of this section, shall be controlled as specified in Sec. 63.443(c) and (d).
B-ll
-------
(g) For each steam stripper system used to comply with the requirements specified in
paragraph (e)(3) of this section, periods of excess emissions reported under Sec. 63.455 shall not
be a violation of paragraphs (d), (e), and (f) of this section provided that the time of excess
emissions (including periods of startup, shutdown, or malfunction) divided by the total process
operating time in a semi-annual reporting period does not exceed 10 percent.
(h) Each owner or operator of a new or existing affected source subject to the requirements of
this section shall evaluate all new or modified pulping process condensates or changes in the
annual bleached or non-bleached OOP used to comply with paragraph (i) of this section, to
determine if they meet the applicable requirements of this section.
(i) For the purposes of meeting the requirements in paragraphs (c)(2), (e)(4), or (e)(5) of this
section at mills producing both bleached and unbleached pulp products, owners and operators
may meet a prorated mass standard that is calculated by prorating the applicable mass standards
(kilograms of total HAP per megagram of ODP) for bleached and unbleached specified in
paragraphs (c)(2), (e)(4), or (e)(5) of this section by the ratio of annual megagrams of bleached
and unbleached ODP.
Sec. 63.447 Clean condensate alternative.
As an alternative to the requirements specified in Sec. 63.443(a)(l)(ii) through (a)(l)(v) for the
control of HAP emissions from pulping systems using the kraft process, an owner or operator
must demonstrate to the satisfaction of the Administrator, by meeting all the requirements belou.
that the total HAP emissions reductions achieved by this clean condensate alternative technology
are equal to or greater than the total HAP emission reductions that would have been achieved by
compliance with Sec. 63.443(a)(l)(ii) through (a)(l)(v).
(a) For the purposes of this section only the following additional definitions apply.
(1) Clean condensate alternative affected source means the total of all HAP emission points in
the pulping, bleaching, causticizing. and papermaking systems (exclusive of HAP emissions
attributable to additives to paper machines and HAP emission points in the LVHC
system).
(2) Causticizing system means all equipment associated with converting sodium carbonate into
active sodium hydroxide. The equipment includes smelt dissolving tanks, lime muu washers and
storage tanks, white and mud liquor clarifiers and storage tanks, slakers, slaker grit washers, lime
kilns, green liquor clarifiers and storage tanks, and dreg washers ending with the white liquor
storage tanks prior to the digester system, and any other equipment serving the same function as
those previously listed.
(3) Papermaking system means all equipment used to convert pulp into paper, paperboard, or
market pulp, including the stock storage and preparation systems, the paper or paperboard
machines, and the paper machine white water system, broke recovery systems, and the systems
involved in calendering, drying, on-machine coating, slitting, winding, and cutting
(b) Each owner or operator shall install and operate a clean condensate alternative technology
with a continuous monitoring system to reduce total HAP emissions by treating and reducing
HAP concentrations in the pulping process water used within the clean condensate alternative
affected source.
(c) Each owner or operator shall calculate HAP emissions on a kilogram per megagram of
ODP basis and measure HAP emissions according to the appropriate procedures contained in
Sec. 63.457.
B-12
-------
(d) Each owner or operator shall determine the baseline HAP emissions for each equipment
system and the total of all equipment systems in the clean condensate alternative affected source
based on the following: ,*
(1) Process and air pollution control equipment installed and operating on or after December
17,4993, and
(2) Compliance with the following requirements that affect the level of HAP emissions from
the clean condensate alternative affected source:
(i) The pulping process condensates requirements in Sec. 63.446;
(ii) The applicable effluent limitation guidelines and standards in 40 CFR part 430, subparts A,
B. D. and E; and
(iii) All other applicable requirements of local, State, or Federal agencies or statutes.
(e) Each owner or operator shall determine the following HAP emission reductions from the
baseline HAP emissions determined in paragraph (d) of this section for each equipment system
and the total of all equipment systems in the clean condensate alternative affected source:
(1) The HAP emission reduction occurring by complying with the
requirements of Sec. 63.443(a)(l)(ii) through (a)(l)(v): and
(2) The HAP emissions reduction that occurring by complying with the clean condensate
alternative technology.
(ft For the purposes of all requirements in this section, each owner or operator may use as an
alternative, individual equipment systems (instead of total of all equipment systems) within the
clean condensate alternative affected source to determine emissions and reductions to
demonstrate equal or greater than the reductions that would have been achieved by compliance
with Sec. 63.443(a)(l)(ii) through (a)(l)(v).
(g) The initial and updates to the control strategy report specified in Sec. 63.455(b) shall
include to the extent possible the following information:
(1) A detailed description of:
(i) The equipment systems and emission points that comprise the clean condensate alternative
affected source:
(ill The air pollution control technologies that would be used to meet the requirements of Sec.
63.443(a)( 1 )(ii) through (ait 1 ji.vj;
(iii) The clean condensate alternative technology to be used.
(2) Estimates and basis for the estimates of total HAP emissions and emissions reductions to
fulfill the requirements paragraphs (d), (e). and (f) of this section.
(h) Each owner or operator shall report to the Administrator by the applicable compliance date
specified in Sec. 63.440(d) or (e) the rationale, calculations, test procedures, and data
documentation used to demonstrate compliance with all the requirements of this section.
Sees. 63.448-63.449 [Reserved]
Sec. 63.450 Standards for enclosures and closed-vent systems.
(a) Each enclosure and closed-vent system specified in Sees. 63.443(c), 63.444(b). and
63.445(b) for capturing and transporting vent streams that contain HAP shall meet the
requirements specified in paragraphs (b) through (d) of this section.
(b) Each enclosure shall maintain negative pressure at each enclosure or hood opening as
demonstrated by the procedures specified Sec. 63.457(e). Each enclosure or hood opening closed
B-13
-------
during the initial performance test specified in Sec. 63.457(a) shall be maintained in the same
closed and sealed position as during the performance test at all times except when necessary to
use the opening for sampling, inspection, maintenance, or repairs.
(c) Each component of the closed-vent system used to comply with Sees. 63.443(c), 63.444(b),
and 63.445(b) that is operated at positive pressure and located prior to a control device shall be
designed for and operated with no detectable leaks as indicated by an instrument reading of less
than 500 parts per million by volume above background, as measured by the procedures specified
in Sec. 63.457(d).
(d) Each bypass line in the closed-vent system that could divert vent streams containing HAP
to the atmosphere without meeting the emission limitations in Sees. 63.443, 63.444, or 63.445
shall comply with either of the following requirements:
(1) On each bypass line, the owner or operator shall install, calibrate, maintain, and operate
according to manufacturer's specifications a flow indicator that provides a record of the presence
of gas stream flow in the bypass line at least orice every 15 minutes. The flow indicator shall be
installed in the bypass line in such a way as to indicate flow in the bypass line; or
(2) For bypass line valves that are not computer controlled, the owner or operator shall
maintain the bypass line valve in the closed position with a car seal or a seal placed on the valve
or closure mechanism in such a way that valve or closure mechanism cannot be opened without
breaking the seal.
Sees. 63.451-63.452 [Reserved]
Sec. 63.453 Monitoring requirements.
(a) Each owner or operator subject to the standards specified In Sees. 63.443(c) and (d),
63.444(b) and (c), 63.445(b) and (c), 63.446(c), (d). and (e), 63.447(b) or Sec. 63.450(d), shall
install, calibrate, certify, operate, and maintain according to the manufacturer's specifications, a
continuous monitoring system (CMS. as defined in Sec. 63.2 of this part) as specified in
paragraphs (b) through (mi of this section, except as allowed in paragraph (m) of this section.
The CMS shall include a continuous recorder.
(b) A CMS shall be operated to measure the temperature in the firebox or in the ductwork
immediately downstream of the firebox and before any substantial heat exchange occurs for each
thermal oxidizer used to comply with the requirements of Sec. 63.443(d)(l) through (d)(3).
Owners and operators complying with the requirements in Sec. 63.443(d)(2) or (d)(3) shall
monitor the parameter specified and for the temperature and concentration limits specified.
(c) A CMS shall be operated to measure the following parameters for each gas scrubber used
to comply with the bleaching system requirements of Sec. 63.445(c) or the sulfite pulping system
requirements of Sec. 63.444(c).
(1) The pH or the oxidation/reduction potential of the gas scrubber effluent;
(2) The gas scrubber vent gas inlet flow rate; and
(3) The gas scrubber liquid influent flow rate.
(d) As an option to the requirements specified in paragraph (c) of this section, a CMS shall be
operated to measure the chlorine outlet concentration of each gas scrubber used to comply with
the bleaching system outlet concentration requirement specified in Sec. 63.445(c)(2).
B-14
-------
(e) The owner or operator of a bleaching system complying with 40 CFR 430.24, shall monitor
the chlorine and hypochlorite application rates, in kg of bleaching agent per megagram of OOP,
of the bleaching system during the extended«ompliance period specified in Sec. 63.440.(d)(3).
(f) A CMS shall be operated to measure the gas scrubber parameters specified in paragraphs
(c)(l) through (c)(3) of this section or those site specific parameters determined according to the
procedures specified in paragraph (n) of this section to comply with the sulfite pulping system
requirements specified in Sec. 63.444(c).
(g) A CMS shall be operated to measure the following parameters for each steam stripper used
to comply with the treatment requirements in Sec. 63.446(e) (3), (4), or (5):
(1) The process wastewater feed rate;
(2) The steam feed rate; and
(3) The process wastewater column feed temperature.
(h) As an option to the requirements specified in paragraph (g) of this section, a CMS shall be
operated to measure the methanol outlet concentration to comply with the steam stripper outlet
concentration requirement specified in Sec. 63.446 (e)(4) or (e)(5).
(i) A CMS shall be operated to measure the appropriate parameters determined according to
the procedures specified in paragraph (n) of this section to comply with the condensate
applicability requirements specified in Sec. 63.446(c).
(j) Each owner or operator using a biological treatment system to comply with Sec.
63.446(e)(2> shall perform the following monitoring procedures.
(1) On a daily basis, monitor the following parameters for each biological treatment unit:
(ii Composite daily sample of outlet soluble BOD5 concentration to monitor for maximum
daily and maximum monthly average:
(ii: Mixed liquor volatile suspended solids:
(iiij Horsepower of aerator unit(s);
(iv) Inlet liquid flow: and
(v~> Liquid temperature.
(2; Obtain daily inle: anc outlet liquid grab samples from each biological treatment unit to
have HAP data avail-r!;: to perform quarterly percent reduction tests specified in paragraph
(j i(2)(ii) of this section and the compliance percent reduction tests specified in paragraph
(p ••{ 1 Hi) of this section. Perform the following procedures with the liquid samples:
(i) Store the samples for 5 days as specified in Sec. 63.457(n). The 5 d.ay storage requirement
is required since the soluble BODS test requires 5 days to obtain results. If the results of the
soluble BODS test are outside of the range established during the initial performance test, then
the archive sample shall be used to perform the percent reduction test specified in Sec. 63.457(1).
(ii) Perform the percent reduction test procedures specified in Sec. 63.457(1) within 45 days
. after the beginning of.each quarter as follows.
(A) The percent reduction test performed in the first quarter (annually) shall be performed for
total HAP and the percent reduction obtained from the test shall be at least as great as the total
HAP reduction specified in Sec. 63.446(e)(2).
(B) The remaining quarterly percent reduction tests shall be performed for methanol and the
percent reduction obtained from the test shall be at least as great as the methanol reduction
determined in the previous first-quarter test specified in paragraph (j)(2)(ii)(A) of this section.
(C) The parameter values used to calculate the percent reductions required in paragraphs
(j)(2)(ii)(A) and (j)(2)(ii)(B) of this section shall be parameter values measured and samples
taken in paragraph (j)( 1) of this section.
B-15
-------
(k) Each enclosure and closed-vent system used to comply with Sec. 63.450(a) shall comply
with the requirements specified in paragraphs (k)(l) through (k)(6) of this section.
(1) For each enclosure opening, a visual inspection of the closure mechanism specified in Sec.
63.450(b) shall be performed at least once every 30 days to ensure the opening is maintained in
the closed position and sealed.
(2) Each closed-vent system required by Sec. 63.450(a) shall be visually inspected every 30
days and at other times as requested by the Administrator. The visual inspection shall include
inspection of ductwork, piping, enclosures, and connections to covers for visible evidence of
defects.
(3) For positive pressure closed-vent systems or portions of closed-vent systems, demonstrate
no detectable leaks as specified in Sec. 63.450(c) measured initially and annually by the
procedures in Sec. 63.457(d).
(4) Demonstrate initially and annually that each enclosure opening is maintained at negative
pressure as specified in Sec. 63.457(e).
(5) The valve or closure mechanism specified in Sec. 63.450(d)(2) shall be inspected at least
once every 30 days to ensure that the valve is maintained in the closed position and the emission
point gas stream is not diverted through the bypass line.
(6) If an inspection required by paragraphs (k)(l) through (k)(5) of this section identifies
visible defects in ductwork, piping, enclosures or connections to covers required by Sec. 63.450.
or if an instrument reading of 500 parts per million by volume or greater above background is
measured, or if enclosure openings are not maintained at negative pressure, then the following
corrective actions shall be taken as soon as practicable.
(i) A first effort to repair or correct the closed-vent system shall be made as soon as practicable
but no later than 5 calendar days after the problem is identified.
(ii) The repair or corrective action shall be completed no later than 15 calendar days after the
problem is identified.
(1) Each pulping process condensate closed collection system used to comply with Sec.
63.446(d) shall be visually inspected even' 30 days and shall comply with the inspection and
monitoring requirements specified in Sec. 63.964 of subpart RR of this part, except for the
closed-vent system and control device inspection and monitonng requirements specified in Sec.
63.964(a)(2) of subpart RR of this part, the closed-vent system and the control device shall meet
the requirements specified in paragraphs (a) and (k) of this section.
(m) Each owner or operator using a control device, technique or an alternative parameter other
than those specified in paragraphs (b) through (1) of this section shall install a CMS and establish
appropriate operating parameters to be monitored that demonstrate, to the Administrator's
satisfaction, continuous compliance with the applicable control requirements.
(n) To establish or reestablish, the value for each operating parameter required to be monitored
under paragraphs (b) through (j). (1). and (m) of this section or to establish appropriate
parameters for paragraphs (f). (i). and (m) of this section, each owner or operator shall use the
following procedures:
(1) During the initial performance test required in Sec. 63.457(a) or any subsequent
performance test, continuously record the operating parameter;
(2) Determinations shall be based on the control performance and parameter data monitored
during the performance test, supplemented if necessary by engineering assessments and the
manufacturer's recommendations;
B-16
-------
(3) The owner or operator shall provide for the Administrator's approval the rationale for
selecting the monitoring parameters necessary to comply with paragraphs (f), (0, and (m) of this
section; and
(4) Provide for the Administrator's approval the rationale for the selected operating parameter
value, and monitoring frequency, and averaging time. Include all data and calculations used to
develop the value and a description of why the value, monitoring frequency, and averaging time
demonstrate continuous compliance with the applicable emission standard.
(o) Each owner or operator of a control device subject to the monitoring provisions of this
section shall operate the control device in a manner consistent with the minimum or maximum
(as appropriate) operating parameter value or procedure required to be monitored under
paragraphs (a) through (n) of this section and established under this subpart. Except as provided
in paragraph (p) of this section. Sec. 63.443(e). or Sec. 63.446(g). operation of the control device
below minimum operating parameter values or above maximum operating parameter values
established under this subpart or failure to perform procedures required by this subpart shall
constitute a violation of the applicable emission standard of this subpart and be reported as a
period of excess emissions.
(pj Each owner or operator of a biological treatment system complying with paragraph (j) of
this section shall perform all the following requirements when the monitoring parameters
specified in paragraphs (j)(l)(ij through (j)(l)(iii) of this section aVe below minimum operating
parameter values or above maximum operating parameter values established in paragraph (n) of
this section.-
(1) The following shall occur and be recorded as soon as practical:
(i'l Determine compliance with Sec. 63.446(e)(2) using the percent reduction test procedures
specified in Sec. 63.457(1) and the monitoring data specified in paragraph (j)U) of this section
that coincide with the time period of the parameter excursion;
(ii) Steps shall be taken to repair or adjust the operation of the process to end the parameter
excursion period; and
(iii) Steps shall be taken to minimize total HAP emissions to the atmosphere during the
parameter excursion period.
(2) A parameter excursion is not a violation of the applicable emission standard if the percent
reduction test specified in paragraph (pi( 1 )(i) of this section demonstrates compliance with Sec.
63.446('e)(2), and no maintenance or changes have been made to the process or control device
after the beginning of a parameter excursion that would influence the results of the
determination.
Sec. 63.454 Recordkeeping requirements.
(a) The owner or operator of each affected source subject to the requirements of this subpart
shall comply with the recordkeeping requirements of Sec. 63.10 of subpart A of this part, as
shown in table 1. and the requirements specified in paragraphs (b) through (d) of this section for
the monitoring parameters specified in Sec. 63.453.
(b) For each applicable enclosure opening, closed-vent system, and closed collection system.
the owner or operator shall prepare and maintain a site-specific inspection plan including a
drawing or schematic of the components of applicable affected equipment and shall record the
following information for each inspection:
(1) Date of inspection;
B-17
-------
(2) The equipment type and identification;
(3) Results of negative pressure tests for enclosures;
(4) Results of leak detection tests;
(5) The nature of the defect or leak and the method of detection (i.e., visual inspection or
instrument detection);
(6) The date the defect or leak was detected and the date of each attempt to repair the defect or
leak;
(7) Repair methods applied in each attempt to repair the defect or leak;
(8) The reason for the delay if the defect or leak is not repaired within 15 days after discovery;
(9) The expected date of successful repair of the defect or leak if the repair is not completed
within 15 days;
(10) The date of successful repair of the defect or leak;
(11) The position and duration of opening of bypass line valves and the condition of any valve
seals; and
(12) The duration of the use of bypass valves on computer controlled valves.
(c) The owner or operator of a bleaching system complying with Sec. 63.440(d)(3)(ii)(B) shall
record the daily average chlorine and hypochlorite application rates, in kg of bleaching agent per
megagram of ODP. of the bleaching system until the requirements specified in Sec.
63.440(d)(3)(ii)(A) are met.
(d) The owner or operator shall record the CMS parameters specified in Sec. 63.453 and meet
the requirements specified in paragraph (a) of this section for any new affected process
equipment or pulping process condensate stream that becomes subject to the standards in this
subpart due to a process change or modification.
Sec. 63.455 Reporting requirements.
(a) Each owner or operator of a source subject to this subpart shall comply with the reporting
requirements of subpart A of this part as specified in table 1 and all the-following requirements in
this section. The initial notification report specified under Sec. 63.9(b)(2) of subpart A of this
part shall be submitted by April 15. 1999.
(b) Each owner or operator of a kraft pulping system specified in Sec. 63.440(d)(l) or a
bleaching system specified in Sec. 63.440(d)(3)(ii) shall submit, with the initial notification
report specified under Sec. 63.9(b)(2) of subpart A of this part and paragraph (a) of this section
and update even two years thereafter, a non-binding control strategy report containing, at a
minimum, the information specified in paragraphs (b)( 1) through (b)(3) of this section in addition
to the information required in Sec. 63.9(b)(2) of subpart A of this part.
(1) A description of the emission controls or process modifications selected for compliance
with the control requirements in this standard.
(2) A compliance schedule, including the dates by which each step toward compliance will be
reached for each emission point or sets of emission points. At a minimum, the list of dates shall
include:
(i) The date by which the major study(s) for determining the compliance strategy will be
completed;
(ii) The date by which contracts for emission controls or process modifications will be
awarded, or the date by which orders will be issued for the purchase of major components to
accomplish emission controls or process changes;
B-18
-------
(iii) The date by which on-site construction, installation of emission control equipment, or a
process change is to be initiated;
(iv) The date by which on-site construction, installation of emissions control equipment, or a
process change is to be completed;
(v) The date by which final compliance is to be achieved;
(vi) For compliance with paragraph Sec. 63.440(d)(3)(ii), the tentative dates by which
compliance with effluent limitation guidelines and standards intermediate pollutant load effluent
reductions and as available, all the dates for the best available technology's milestones reported in
the National Pollutant Discharge Elimination System authorized under section 402 of the Clean
Water Act and for the best professional milestones in the Voluntary Advanced Technology
Incentives Program under 40 CFR 430.24 (b)(2); and
(vii) The date by which the final compliance tests will be performed.
(3) Until compliance is achieved, revisions or updates shall be made to the control strategy
report required by paragraph (b) of this section indicating the progress made towards completing
the installation of the emission controls or process modifications during the 2-year period.
(c) The owner or operator of each bleaching system complying with Sec. 63.440(d)(3)(ii)(B)
shall certify in the report specified under Sec. 63.10(e)(3) of subpart A of this part that the daily
application rates of chlorine and hypochlorite for that bleaching system have not increased as
specified in Sec. 63.440(d)(3)(ii)(B) until the requirements of Sec. 63.440(d)(3)(ii)(A) are met.
(d) The owner or operator shall meet the requirements specified in paragraph (a) of this section
upon startup of any new affected process equipment or pulping process condensate stream that
becomes subject to the standards of this subpart due to a process change or modification.
Sec. 63.456 [Reserved]
Sec. 63.45" Test methods and procedures.
(ai Initial performance lest. An initial performance test is required for all emission sources
subject to the limitations in Sees. 63.443. 63.444. 63.445, 63.446. and 63.447. except those
controlled by a corr/custion device that is designed and operated as specified in Sec. 63.443(d)(3)
or(d)(4i.
(b) Vent sampling port locations and gas stream properties. For purposes of selecting vent
sampling port locations and determining vent gas stream properties, required in Sees. 63.443,
63.444, 63.445. and 63.447. each owner or operator shall comply with the applicable procedures
in paragraphs (b)( 1) through (b)(6) of this section.
(1) Method 1 or 1A of part 60, appendix A, as appropriate, shall be used for selection of the
sampling site as follows:
(i) To sample for vent gas concentrations and volumetric flow rates, the sampling site shall be
located prior to dilution of the vent gas stream and prior to release to the atmosphere;
(ii) For determining compliance with percent reduction requirements, sampling sites shall be
located prior to the inlet of the control device and at the outlet of the control device;
measurements shall be performed simultaneously at the two sampling sites; and
(iii) For determining compliance with concentration limits or mass emission rate limits, the
sampling site shall be located at the outlet of the control device.
(2) No traverse site selection method is needed for vents smaller than 0.10 meter (4.0 inches)
in diameter.
B-19
-------
(3) The vent gas volumetric flow rate shall be determined using Method 2,2A, 2C, or 2D of
part 60, appendix A, as appropriate.
(4) The moisture content of the vent gas shall be measured using Method 4 of part 60,
appendix A.
(5) To determine vent gas concentrations, the owner or operator shall collect a minimum of
three samples that are representative of normal conditions and average the resulting pollutant
concentrations using the following procedures.
(i) Method 308 in Appendix A of this part shall be used to determine the methanol
concentration.
(ii) Except for the modifications specified in paragraphs (b)(5)(ii)(A) through (b)(5)(ii)(K) of
this section, Method 26A of part 60, appendix A shall be used to determine chlorine
concentration in the vent stream.
(A) Probe/Sampling Line. A separate probe is not required. The sampling line shall be an
appropriate length of 0.64 cm (0 25 in) OD Teflon" tubing. The sample inlet end of the sampling
line shall be inserted into the stack in such a way as to not entrain liquid condensation from the
vent gases. The other end shall be connected to the impingers. The length of the tubing may vary
from one sampling site to another, but shall be as short as possible in each situation. If sampling
is conducted in sunlight, opaque tubing shall be used. Alternatively, if transparent tubing is used.
it shall be covered with opaque tape.
(B) Impinger Train. Three 30 milliliter (ml) capacity midget impingers shall be connected in
series to the sampling line. The impingers shall have regular tapered stems. Silica gel shall be
placed in the third impinger as a desiccant. All impinger train connectors shall be glass and/or
Teflon*.
(C) Critical Orifice. The critical orifice shall have a flow rate of 200 to 250 ml/min and shall
be followed by a vacuum pump capable of providing a vacuum of 640 millimeters of mercury
(mm Hg). A 45 millimeter diameter in-line Teflon8 0.8 micrometer filter shall follow the •
impingers to project the critical orifice and vacuum pump.
(D) The following are necessary for the analysis apparatus:
(1) Wash bottle filled with deionized water:
(2) 25 or 50 ml graduated burette and stand:
(3) Magnetic stirring apparatus and stir bar;
(4) Calibrated pH Meter:
(5) 150-250 ml beaker or flask; and
(6) A 5 ml pipette.
(E) The procedures listed in paragraphs (b)(5)(ii)(E)(l) through (b)(5)(ii)(EX7) of this section
shall be used to prepare the reagents.
(1) To prepare the 1 molarity (M) potassium dihydrogen phosphate solution, dissolve 13.61
grams (g) of potassium dihydrogen phosphate in water and dilute to 100 ml.
(2) To prepare the 1 M sodium hydroxide solution (NaOH), dissolve 4.0 g of sodium
hydroxide in water and dilute to 100 ml.
(3) To prepare the buffered 2 percent potassium iodide solution, dissolve 20 g of potassium
iodide in 900 ml water. Add 50 ml of the 1 M potassium dihydrogen phosphate solution and 30
ml of the 1 M sodium hydroxide solution. While stirring solution, measure the pH of solution
electrometrically and add the 1 M sodium hydroxide solution to bring pH to between 6.95 and
7.05.
B-20
-------
(4) To prepare the 0.1 normality (N) sodium thiosulfate solution, dissolve 25 g of sodium
thiosulfate, pentahydrate, in 800 ml of freshly boiled and cooled distilled water in a 1-liter
volumetric flask. Dilute to volume. To prepaje the 0.01 N sodium thiosulfate solution, add 10.0
ml standardized 0.1 N sodium thiosulfate solution to a 100 ml volumetric flask, and dilute to
volume with water.
(5) To standardize the 0.1 N sodium thiosulfate solution, dissolve 3.249 g of anhydrous
potassium bi-iodate, primary standard quality, or 3.567 g potassium iodate dried at 103 +/-2
degrees Centigrade for 1 hour, in distilled water and dilute to 1000 ml to yield a 0.1000 N
solution. Store in a glass-stoppered bottle. To 80 ml distilled water, add, with constant stirring, 1
ml concentrated sulfuric acid, 10.00 ml 0.1000 N anhydrous potassium bi-iodate, and 1 g
potassium iodide. Titrate immediately with 0.1 n sodium thiosulfate titrant until the yellow color
of the liberated iodine is almost discharged. Add 1 ml starch indicator solution and continue
titrating until the blue color disappears. The normality of the sodium thiosulfate solution is
inversely proportional to the ml of sodium thiosuifate solution consumed:
Normality of 1
Sodium Thiosulfate " m\ Sodium Thiosulfate -Consumed
(6) To prepare the starch indicator solution, add a small amount of cold water to 5 g starch and
grind'in a mortar to obtain u :nin paste. Pour paste into 1 L of boiling distilled water, stir, and let
settle overnight. Use clear supernate for starch indicator solution.
(7) To prepare the 10 percent, sulfuric acid solution, add 10 ml of concentrated sulfuric acid to
80 ml water in an 100 ml volumetric flask. Dilute to volume.
(F) The procedures specified in paragraphs (b)(5)(ii)(F)(l) through (b)(5)(ii)(F)(5) of this
section shall be used to perform the sampling.
(1) Preparation ofCoikc'.'.on Tram. Measure 20 ml buffered potassium iodide solution into
each of the first two impingers'and connect probe, impingers. filter, critical orifice, and pump.
The sampling line ar.J the impingers shall be shielded from sunlight.
(2) Leak and Fh>->\ Check Procedure. Flag sampling line inlet tip and turn on pump. If a flow
of bubbles is visible in either of the liquid impingers. tighten fittings and adjust connections and
impingers. A leakage rate nu in excess of 2 percent of the sampling rate is acceptable. Carefully
remove the plug from the end of the probe. Check the flow rate at the probe inlet with a bubble
tube flow meter. The flow should be comparable or slightly less than the flow rate of the critical
orifice with the impingers off-line. Record the flow and turn off the pump.
(3) Sample Collection. Insert the sampling line into the stack and secure it with the tip slightly
lower than the port height. Stan the pump, recording the time. End the sampling after 60 minutes.
or after yellow color is observed in the second in-line impinger. Record time and remove the
tubing from the vent. Recheck flow rate at sampling line inlet and turn off pump. If the flow rate
has changed significantly, redo sampling with fresh capture solution. A slight variation (less than
5 percent) in flow may be averaged. With the inlet end of the line elevated above the impingers,
add about 5 ml water into the inlet tip to rinse the line into the first impinger.
(4) Sample Analysis. Fill the burette with 0.01 N sodium thiosulfate solution to the zero mark.
Combine the contents of the impingers in the beaker or flask. Stir the solution and titrate with
thiosulfate until the solution is colorless. Record the volume of the first endpoint (TN, ml). Add
B-21
-------
5 ml of ihe 10 percenl sulfuric acid solution, and continue the titration until the contents of the
flask are again colorless. Record the total volume of titrant required to go through the first and lo
the second endpoint (TA, ml). If the volume of neutral tiler is less lhan 0.5 ml, repeat Ihe testing
for a longer period of time. It is important that sufficient lighting be present to clearly see the
endpoints, which are determined when Ihe solution turns from pale yellow to colorless. A lighted
stirring plate and a white background are useful for this purpose.
(5) Interferences. Known interfering agents of this method are sulfur dioxide and hydrogen
peroxide. Sulfur dioxide, which is used to reduce oxidani residuals in some bleaching systems,
reduces formed iodine to iodide in ihe capture solution. Il is therefore a negative interference for
chlorine, and in some cases could result in erroneous negative chlorine concentrations. Any agent
capable of reducing iodine to iodide could interfere in this manner. A chromium trioxide
impregnated filler will capture sulfur dioxide and pass chlorine and chlorine dioxide. Hydrogen
peroxide, which is commonly used as a bleaching agent in modem bleaching systems, reacts with
iodide to form iodine and thus can cause a positive interference in ihe chlorine measurement.
Due to the chemistry involved, the precision of the chlorine analysis will decrease as the ratio of
chlorine dioxide to chlorine increases. Slightly negative calculated concentrations of chlorine
may occur when sampling a vent gas wilh high concentrations of chlorine dioxide and very low
concentrations of chlorine.
(G) The following calculation shall be performed to determine the corrected sampling flow
rate:
' BP - PW U 293
760 M273*t
Where:
Sc=Corrected (dry standard) sampling flow rate, liters per minute;
SL<=Uncorrected sampling flow rate. L/min:
BP=Barometric pressure at time of sampling:
PW=Saturated partial pressure of water vapor, mm Hg at temperature; and
t= Ambient temperature. deg.C.
(H) The following calculation shall be performed to determine the moles of chlorine in the
sample:
CUMoies = 1/8000 (5 TN - T^xN^
Where:
TN=Volume neutral liter, ml:
TA=Volume acid tiler (total ), ml; and
ium ihiosulfate titrant.
(i) The following calculation shall be performed to determine ihe concenlraiion of chlorine in
ihe sample:
B-22
-------
3005(5
5
Where:
Sc=Corrected (dry standard"* sampling flow rate, liters per minute;
t5=Time sampled, minutes;
TN=Volume neutral liter, ml:
TA=Volume acid titer (total), ml; and
N-n«o=Normaliry of sodium thiosulfate titrant.
(J) The following calculation shall be performed to determine the moles of chlorine dioxide in
the sample:
ClO,Moles = 1/4000 (TA - TN)xNThio
Where:
TA=Volume acid titer (totalX ml:
TN=Volume neutral liter, ml: and
NT,.i0=Normalir\' of sodium thiosulfate titrant.
(K) The following calculation shall be performed to determine the concentration of chlorine
dioxide in the sample:
6010(T - T)xN
ClO,ppmv =
Where:
Sc=Corrected (dry standard) sampling flow rate, liters per minute;
ts=Time sampled, minutes:
TA=Volume acid titer (total), ml:
TN=Volume neutral titer, ml; and
NThio=Normality of sodium thiosulfate titrant.
(iii) Any other method that measures the total HAP or methanol concentration that has been
demonstrated to the Administrator's satisfaction.
(6) The minimum sampling time for each of the three runs per method shall be 1 hour in which
either an integrated sample or four grab samples shall be taken. If grab sampling is used, then the
samples shall be taken at approximately equal intervals in time, such as 15 minute intervals
during the run.
(c) Liquid sampling locations andproperties. For purposes of selecting liquid sampling
locations and for determining properties of liquid streams such as wastewaters, process waters.
and condensates required in Sees. 63.444, 63.446, and 63.447, the owner or operator shall
comply with the following procedures:
B-23
-------
(1) Samples shall be collected using the sampling procedures specified in Method 305 of part
60, appendix A;
(i) Where feasible, samples shall be taken from an enclosed pipe prior to the liquid stream
being exposed to the atmosphere; and
(ii) When sampling from an enclosed pipe is not feasible, samples shall be collected in a
manner to minimize exposure of the sample to the atmosphere and loss of HAP compounds prior
to sampling.
(2) The volumetric flow rate of the entering and exiting liquid streams shall be determined
using the inlet and outlet flow meters or other methods demonstrated to the Administrator's
satisfaction. The volumetric flow rate measurements to determine actual mass removal shall be
taken at the same time as the concentration measurements;
(3) To determine liquid stream total HAP or methanol concentrations, the owner or operator
shall collect a minimum of three samples that are representative of normal conditions and
average the resulting pollutant concentrations using one of the following:
(i) Method 305 in Appendix A of this part, adjusted using the following equation:
Where:
C=Pollutant concentration for the liquid stream, parts per million by weight.
C=Measured concentration of pollutant I in the liquid stream sample determined using Method
305, pans per million by weight.
fm,=Pollutant-specific constant that adjusts concentration measured by Method 305 to actual
liquid concentration: the frn for methanol is 0.85. Additional pollutant fin values can be
found in table 34, subpart G of this pan.
n=Number of individual pollutants. I, summed to calculate total HAP.
(ii) Any other method that measures total HAP concentration that has been demonstrated to the
Administrator's satisfaction.
(4) To determine soluble BODS in the effluent stream from a biological treatment unit used to
comply with Sees. 63.446(e)(2) and 63.453(j). the owner or operator shall use Method 405.1, of
part 136, with the following modifications:
(i) Filter the sample through the filter paper, into Erlenmeyer flask by applying a vacuum to
the flask sidearm. Minimize the time for which vacuum is applied to prevent stripping of volatile
organics from the sample. Replace filter paper as often as needed in order to maintain filter times
of less than approximately 30 seconds per filter paper. No rinsing of sample container or filter
bowl into the Erlenmeyer flask is allowed.
(ii) Perform Method 405.1 on the filtrate obtained in paragraph
(c)(4) of this section. Dilution water shall be seeded with 1
milliliter of final effluent per liter of dilution water. Dilution
ratios may require adjustment to reflect the lower oxygen demand of the
filtered sample in comparison to the total BODS. Three BOD
bottles and different dilutions shall be used for each sample.
B-24
-------
(d) Detectable leak procedures. To measure detectable leaks for closed-vent systems as.
specified in Sec. 63.450 or for pulping process wastewater collection systems as specified in Sec.
63.446(d)(2)(i), the owner or operator shall cemply with the following:
(1) Method 21, of part 60, appendix A; and
(2) The instrument specified in Method 21 shall be calibrated before use according to the
procedures specified in Method 21 on each day that leak checks are performed. The following
calibration gases shall be used:
(i) Zero air (less than 10 parts per million by volume of hydrocarbon in air); and
(ii) A mixture of methane or n-hexane and air at a concentration of approximately, but less
than, 10,000 parts per million by volume methane or n-hexane.
(e) Negative pressure procedures. To demonstrate negative pressure at process equipment
enclosure openings as specified in Sec. 63.450(b), the owner or operator shall use one of the
following procedures:
(1) An anemometer to demonstrate flow into the enclosure opening:
(2) Measure the static pressure across the opening;
(3) Smoke tubes to demonstrate flow into the enclosure opening; or
(4) Any other industrial ventilation test method demonstrated to the Administrator's
satisfaction.
ff) HAP concentration measurements. For purposes of complying with the requirements in
Sees. 63.443. 63.444. and 63.447. the owner or operator shall measure the total HAP
concentration as one of the following:
(1} As the sum of all individual HAP's: or
(2) As methanol.
(g) Condensait HAP concentration measurement. For purposes of complying with the kraft
pulping condensate requirements in Sec. 63.446. the owner or operator shall measure the total
HAP concentration as. methanol except for the purposes of complying with the initial
performance test specified in Sec. 63.457(a) for Sec. 63.446(e)(2) and as specified in Sec.
63.453g')(2)(iii.
(h) Bleaching HAP concentration measurement. For purposes of complying with the bleaching
system requirements in Sec. 63.445. the owner or operator shall measure the total HAP
concentration as the sum of all individual chlorinated HAP's or as chlorine.
(i) Vent gas stream calculations. To demonstrate compliance with the mass emission rate.
mass emission rate per megagram of ODP, and percent reduction requirements for vent gas
streams specified in Sees. 63.443,63.444, 63.445. and 63.447, the owner or operator shall use the
following:
' (1) The total HAP mass emission rate shall be calculated using the following equation:
E =
Where:
E=Mass emission rate of total HAP from the sampled vent, kilograms per hour.
K:=Constant. 2.494 x 10-6 (parts per million by volume)-! (gram-mole per standard cubic meter)
(kilogram/grarn) (minutes/hour), where standard temperature for (gram-mole per standard
cubic meter) is 20 deg.C.
B-25
-------
(^Concentration on a dry basis of pollutant j in parts per million by volume as measured by the
test methods specified in paragraph (b) of this section.
Mj=Molecular weight of pollutant j, gram/gram-mole.
Qs=Vent gas stream flow rate (dry standard cubic meter per minute) at a temperature of 20 deg.C
as indicated in paragraph (b) of this section.
n=Number of individual pollutants, I, summed to calculate total HAP.
(2) The total HAP mass emission rate per megagram of OOP shall be calculated using the
following equation:
Where:
F=Mass emission rate of total HAP from the sampled vent, in kilograms per megagram of OOP.
E=Mass emission rate of total HAP from the sampled vent, in kilograms per hour determined as
specified in paragraph (i)( 1 ) of this section.
P=The production rate of pulp during the sampling period, in megagrams of ODP per hour.
(3) The total HAP percent reduction shall be calculated using the following equation:
E - E
R =
R=Efficiency of control device, percent.
E,=Inlet mass emission rate of total HAP from the sampled vent, in kilograms of pollutant per
hour, determined as specified in paragraph (i)(l) of this section.
E0=Outlet mass emission rate of total HAP from the sampled vent, in kilograms of pollutant per
hour, determined as specified in paragraph (i)( 1) of this section.
(j) Liquid stream calculations. To demonstrate compliance with the mass flow rate, mass per
megagram of ODP. and percent reduction requirements for liquid streams specified in Sec.
63.446, the owner or operator shall use the following:
(1) The mass flow rates of total HAP or methanol entering and exiting the treatment process
shall be calculated using the following equations:
Where:
B-26
-------
Eb=Mass flow rate of total HAP or methanol in the liquid stream entering the treatment process,
kilograms per hour.
Ea=Mass flow rate of total HAP or methanol in the liquid exiting the treatment process,
kilograms per hour.
K^Density of the liquid stream, kilograms per cubic meter.
V^Volumetric flow rate of liquid stream entering the treatment process during each run I, cubic
meters per hour, determined as specified in paragraph (c) of this section.
Vai=Volumetric flow rate of liquid stream exiting the treatment process during each run I, cubic
meters per hour, determined as specified in paragraph (c) of this section.
Cbl=Concentration of total HAP or methanol in the stream entering the treatment process during
each run I, parts per million by weight, determined as specified in paragraph (c) of this
section.
Ca,=Concentration of total HAP or methanol in the stream exiting the treatment process during
each run I, parts per million by weight, determined as specified in paragraph (c) of this
section.
n=N umber of runs.
(2) The mass of total HAP or methanol per megagram ODP shall be calculated using the
following equation:
Where:
F=Mass loading of total HAP or methanol in the sample, in kilograms per megagram of ODP.
Ea=Mass flow rate of total HAP or methanol in the wastewater stream in kilograms per hour as
determined using the procedures in paragraph (j)(l) of this section.
P=The production rate of pulp during the sampling period in megagrams of ODP per hour.
(3) The percent reduction of total HAP across the applicable treatment process shall be
calculated using the following equation:
E. - E
R = — -*100
Where:
R=Control efficiency of the treatment process, percent.
Eb=Mass flow rate of total HAP in the stream entering the treatment process, kilograms per hour,
as determined in paragraph (j)( 1) of this section.
Ea=Mass flow rate of total HAP in the stream exiting the treatment process, kilograms per hour,
as determined in paragraph (j)(l) of this section.
(4) Compounds that meet the requirements specified in paragraphs G)(4)(i) or (4)(ii) of this
section are not required to be included in the mass flow rate, mass per megagram of ODP, or the
mass percent reduction determinations.
B-27
-------
(i) Compounds with concentrations at the point of determination that are below 1 part per
million by weight; or
(ii) Compounds with concentrations at the point of determination that are below the lower
detection limit where the lower detection limit is greater than 1 part per million by weight.
(k) Oxygen concentration correction procedures. To demonstrate compliance with the total
HAP concentration limit of 20 ppmv in Sec. 63.443(d)(2), the Concentration measured using the
methods specified in paragraph (b)(5) of this section shall be corrected to 10 percent oxygen
using the following procedures:
( 1 ) The emission rate correction factor and excess air integrated sampling and analysis
procedures of Methods 3 A or 3B of part 60, appendix A shall be used to determine the oxygen
concentration. The samples shall be taken at the same time that the HAP samples are taken.
(2) The concentration corrected to 10 percent oxygen shall be computed using the following
equation:
c-c
20.9 -%0:d
Where:
Cc=Concentration of total HAP corrected to 10 percent oxygen, dry basis, parts per million by
volume.
C^Cpncentration of total HAP dry basis, parts per million by volume, as specified in paragraph
; (b) of this section.
°/oO:d=Concentration of oxygen, dry basis, percent by volume.
( 1 ) Biological treatmem system percent reduction calculation. To determine compliance with
an open biological treatment system option specified in Sec. 63.446(e)(2) and the monitoring
requirements specified in Sec. 63.453(j)(2). the percent reduction due to destruction in the
biological treatment system shall be calculated using the following equation:
R=fbloxlOO
Where:
R=Destruction of total KAP or methanol in the biological treatment process, percent.
fblo=The fraction of total HAP or methanol removed in the biological treatment system. The
site-specific biorate constants shall be determined using the procedures specified and as
limited in appendix C of part 63.
(m) Condensate segregation procedures. The following procedures shall be used to
demonstrate compliance with the condensate segregation requirements specified in Sec.
63.446(c).
( 1 ) To demonstrate compliance with the percent mass requirements specified in Sec.
63.446(c)(l), the procedures specified in paragraphs (m)(l)(i) through (m)(l)(iii) of this section
shall be performed.
(i) Determine the total HAP mass of all condensates from each equipment system listed in Sec.
63.446 (b)( 1 ) through (b)(3) using the procedures specified in paragraphs (c) and (j) of this
section.
B-28
-------
(ii) Multiply the total HAP mass determine in paragraph (m)(l)(i) of this section by 0.65 to
determine the target HAP mass for the high-HAP fraction condensate stream or streams.
(iii) Compliance with the segregation requirements specified in Sec. 63.446(c)(l) is
demonstrated if the condensate stream or streams from each equipment system listed in Sec.
63.446 (b)(l) through (b)(3) being treated as specified in Sec. 63.446(e) contain at least as much
total HAP mass as the target total HAP mass determined in paragraph (mXl)(ii) of this section.
, (2) To demonstrate compliance with the percent mass requirements specified in Sec.
63.446(c)(2), the procedures specified in paragraphs (m)(2)(i) through (m)(2)(ii) of this section
shall be performed.
(i) Determine the total HAP mass contained in the high-HAP fraction condensates from each
equipment system listed in Sec. 63.446(b)(l) through (b)(3) and the total condensates streams
from the equipment systems listed in Sec. 63.446(b)(4) and (b)(5), using the procedures specified
in paragraphs (c) and (j) of ihis section.
(ii) Compliance with the segregation requirements specified in Sec. 63.446(c)(2) is
demonstrated if the total HAP mass determined in paragraph (m)(2)(i) of this section is equal to
or greater than the appropriate mass requirements specified in Sec. 63.446(c)(2).
(n) Biological treatment system monitoring sampling storage. The inlet and outlet grab
samples required to be collected in Sec. 63.4530(2) shall be stored at 4 deg. C (40 deg. F) to
minimize the biodegradation of the organic compounds in the samples.
Sec. 63.458 -Delegation of authority.
(a) In delegating implementation and enforcement authority to a State under section 112(d) of
the CAA. the authorities contained in paragraph (b) of this section shall be retained by the
Administrator and not transferred to a State.
(b) Authorities which will not be delegated to States:
(1) Section 63.6(g)—Use of an alternative nonopacity emission standard;
(2) Section 63.453(m i—Use of an alternative monitoring parameter:
(3 > Section 63.457(b >• 5 :
-------
TABLE 1 TO SUBPART S—GENERAL PROVISIONS APPLICABILITY TO SUBPART S*~Continued
Reference
63.1(aXHM14)
63.1(bXD . . .
63.1(bX2M3) - -
63.1(cXlH2) .-
63.1(c)(3)
63.1(0(4X5) -.
63.1(d) . ..
63.1(e)
632 .
63.3
63.4(a)(l) ...
63.4(a)(3).
63.4(a)(4)
63.4(a)(5)
63.4(b)
63.4(c)
63.5(ai
63 5(b)(l )
63.5(b)(2)
63 5(b)(3)
63.5(b)(4)-(6) . .
63 >(c)
63 5(d)
63.5(e»
63.5(f)
63.6fa)
63.6(b)
636(c)
63.6(d^
63.6(e) . .
63.6(0
63. 6(2)
63.6(h)
63.6(i)
63.6(j) . . .
63.7
63.8(a)(l) . .
63.8(a)(2) . .
63.8(aM3)
Applies
to
Subpart S
Yes.
No
Yes.
Yes.
No
Yes.
No
Yes.
Yes
Yes.
Yes
No
Yes.
Yes.
Yes.
Yes.
Yes
No
Yes
Yes.
No
Yes
Yes.
Yes.
Yes.
No
No
No
Yes.
Yes.
Yes.
No ...
Yes.
Yes
Yes
Yes
Yes
No
Comment
Subpart S specifies its own applicability.
Section reserved.
Section reserved.
Section reserved. ,
Section reserved.
Section reserved
i
:
Subpart S specifies compliance dates'for sources subject to subpart S.
Subpart S specifies compliance dates for sources subject to subpart S
Section reserved
Pertains to continuous opacity monitors that are not part of this standard.
Section reserved.
B-30
-------
TABLE 1 TO SUBPART S—GENERAL PROVISIONS APPLICABILITY TO SUBPART S*~Continued
Reference
63.8(a)(4) . . .
63.8(bXD
63.8(b)(2)
63.8(bX3)
63.8(c)(l)
63.8(cX2')
63.8(c)(3)
63.8(c)(4)
63 8(c)(^)
63 8(0(6)
63.8(c)i~i
63.8(c)(8)
63.8(d)
63. Sic,
63.8(f)(l i-(5) . .
63.Sifi(6.<
63.8(g)
63.9(ai
63.9(bi
63.9(ci
63.Q(d>
63.9ic!
63. 9!f;
63.9(g)( 1)
63.9(g)(2)
63.9(g)(3)
63.9(h)
63 9(i)
63 9(i)
63 10(a)
63 10(b) . .
63 10(c)
63.10(dXD ...
63.10(d)(2) ....
63.10(d)(3) ....
63.10(d)(4)
63.IO(d)(5) ....
Applies
to
Subpart S
Yes,
Yes.
No
Yes
Yes
Yes
Yes.
No . .
No
Yes
Yes.
Yes.
Yes.
Yes.
Yes.
No
Yes.
Yes.
Yes ....
Yes
N:
^ies.
N, . . .
Ye-.
No
No . . . .
Yes.
Yes.
Yes.
Yes
Yes.
Yes.
Yes
Yes.
No
Yes.
Yes.
Comment
Subpart S specifies locations to conduct monitoring.
Subpart S allows site specific determination of monitoring frequency in §63.453(n)(4).
Pertains to continuous opacity monitors that are not part of this standard
*
(
Subpan S does not specify relative accuracy test for CEM's.
Initial notifications must be submitted within one year after the source becomes subject to the
relevant standard.
Special compliance requirements are only applicable to kraft mills.
Pertains to continuous opaci'ty monitors that are not pan of this standard.
Pertains to continuous opacity monitors that are not part of this standard.
Subpart S does not specify relative accuracy tests, therefore no notification is required for an
alternative.
Pertains to continuous opacity monitors that are not pan of this standard.
B-31
-------
TABLE 1 TO SUBPART S—GENERAL PROVISIONS APPLICABILITY TO SUBPART S*~Continued
Reference
63.10(eXl)....
63.10(6X2X0 -•
63.10(eX2Xii)
63.10(eX3)....
63.10(eX4) ....
63 10(0
63.11-63.15 ...
Applies
to
SubpaitS
Yes.
Yes.
No
Yes.
No
Yes
Yes.
Comment
Pertains to continuous opacity monitors that are not part of this standard.
Pertains to continuous opacity monitors that are not part of this standard.
a Wherever subpart A specifies "postmark" dates, submittals may be sent by methods other than the U.S. Mail (e.g., by fax or
courier). Submittals shall be sent by the specified dates, but a postmark is not required.
B-32
-------
3. Appendix A of part 63 is amended by adding Method 308 in numerical order to read as
follows:
Appendix A to Part 63-Test Methods
Method 308— Procedure for Determination of Methanol Emission From Stationary Sources
1. 0 Scope and Application
1.1 Analyte. Methanol. Chemical Abstract Service (CAS) No. 67-56-1.
1.2 Applicability. This method applies to the measurement of methanol emissions from
specified stationary sources.
2. 0 Summary ofMelhod
A gas sample is extracted from the sampling point in the stack. The methanol is collected in
deionized distilled water and adsorbed on silica gel. The sample is returned to the laboratory
where the methanol in the water fraction is separated from other organic compounds with a gas
chromatograph (GO and is then measured by a flame ionization detector (FID). The fraction
adsorbed on silica gel is extracted with an aqueous solution of n-propanol and is then separated
and measured by GC/TID.
3.0 Definitions [Reser\-ed]
4.0 Interferences [Reserve.:'
5.0 Safer,
5.1 Disclaimer. This method may involve hazardous materials, operations, and equipment.
This test method does not purport to address all of the safety problems associated with its use. It
is the responsibility of the u^er of this test method to establish appropriate safety and health
practices and to determine the applicability of regulatory limitations before performing this test
method.
5.2 Methanol Characteristics. Methanol is flammable and a dangerous fire and explosion risk.
It is moderately toxic by ingestion and inhalation.
6. 0 Equipment and Supplies
6.1 Sample Collection. The following items are required for sample collection:
6. 1 . 1 Sampling Train. The sampling train is shown in Figure 308- 1 and component parts are
discussed below.
6.1.1.1 Probe. Teflon®, approximately 6-millimeter (mm) (0.24 inch) outside diameter.
6.1.1.2 Impinger. A 30-milliliter (ml) midget impinger. The impinger must be connected with
leak-free glass connectors. Silicone grease may not be used to lubricate the connectors.
B*» ^
OJ
-------
6.1.1.3 Adsorbent Tube. Glass tubes packed with the required amount of the specified
adsorbent.
6.1.1.4 Valve. Needle valve, to regulate sample gas flow rate.
6.1.1.5 Pump. Leak-free diaphragm pump, or equivalent, to pull gas through the sampling
train. Install a small surge tank between the pump and rate meter to eliminate the pulsation effect
of the diaphragm pump
on the rotameter.
6.1.1.6 Rate Meter. Rotameter, or equivalent, capable of measuring flow rate to within 2
percent of the selected flow rate of up to 1000 milliliter per minute (ml/min). Alternatively, the
tester may use a critical orifice to set the flow rate.
6.1.1.7 Volume Meter. Dry gas meter (DGM), sufficiently accurate to measure the sample
volume to within 2 percent, calibrated at the selected flow rate and conditions actually
encountered during sampling, and equipped with a temperature sensor (dial thermometer, or
equivalent) capable of measuring temperature accurately to within 3 deg.C (5.4 deg.F).
6.1.1.8 Barometer. Mercury (Hg), aneroid, or other barometer capable of measuring
atmospheric pressure to within 2.5 mm (0.1 inch) Hg. See the NOTE in Method 5 (40 CFR part
60, appendix A), section 6.1.2.
6.1.1.9 Vacuum Gauge and Rotameter. At least 760-mm (30-inch) Hg gauge and 0- to
40-ml/min rotameter, to be used for leak-check of the sampling train.
6.2 Sample Recovery. The following items are required for sample recovery:
6.2.sl Wash Bottles. Polyethylene or glass. 500-ml. two.
6.2.2 Sample Vials. Glass. 40-ml. with TeflonMined septa, to store impinger samples (one
per sample).
6.2.3 Graduated Cylinder. 100-mlsize.
6.3 .Analysis. The following are required for analysis:
6.3.1 Gas Chromatograph. GC with an FID, programmable temperature control, and heated
liquid injection port.
6.3,2 Pump. Capable of pumping 100 ml/min. For flushing sample loop.
6.3.3 Flow Meter. To monitor accurately sample loop flow rate of 100 ml/min.
6.3.4 Regulators. Two-stage regulators used on gas cylinders for GC and for cylinder
standards.
6.3.5 Recorder. To record, integrate, and store chromatograms.
6.3.6 Syringes. 1.0- and 10-microliter (1) size, calibrated, for injecting samples.
6.3.7 Tubing Fittings. Stainless steel, to plumb GC and gas cylinders.
6.3.8 Vials. Two 5.0-ml glass vials with screw caps fitted with Teflon*-lined septa for each
sample.
6.3.9 Pipettes. Volumetric type, assorted sizes for preparing calibration standards.
6.3.10 Volumetric Flasks. Assorted sizes for preparing calibration standards.
6.3.11 Vials. Glass 40-ml with TeflonMined septa, to store calibration standards (one per
standard).
B-34
-------
7.0 Reagents and Standards
Note: Unless otherwise indicated, all reagonts must conform to the specifications established
by the Committee on Analytical Reagents of the American Chemical Society. Where such
specifications are not available, use the best available grade.
7.1 Sampling. The following are required for sampling:
7.1.1 Water. Deionized distilled to conform to the American Society for Testing and Materials
(ASTM) Specification D 1193-77, Type 3. At the option of the analyst, the potassium
permanganate (KMnOJ test for oxidizable organic matter may be omitted when high
concentrations of organic matter are not expected to be present.
7.1.2 Silica Gel. Deactivated chromatographic grade 20/40 mesh silica gel packed in glass
adsorbent tubes. The silica gel is packed in two sections. The front section contains 520
milligrams (mg) of silica gel, and the back section contains 2'60 mg.
7.2 .Analysis. The following are required for analysis:
7.2.1 Water. Same as specified in section 7.1.1.
7.2.2 n-Propanol. 3 Percent. Mix 3 ml of n-propanol with 97 ml of water.
7.2.3 Methanol Stock Standard. Prepare a methanol stock standard by weighing 1 gram of
methanol into a 100-ml volumetric flask. Dilute to 100 ml with water.
7.2.3.1 Methanol Working Standard. Prepare a methanol working standard by pipetting 1 ml
of the methano! stock standard into a 100-ml volumetric flask. Dilute the solution to 100 ml with
water.
7.2.3.2 Methanol Standards For Impinger Samples. Prepare a series of methanol standards by
pipetting 1. 2. 5. 10. and 25 ml of methanol working standard solution respectively into five
50-ml volumetric flasks. Dilute the solutions to 50 ml with water. These standards will have 2. 4,
10. 20. and 50 ng/ml of methanol. respectively. After preparation, transfer the solutions to 40-ml
glass vials capped with Teflon1' septa and store the vials under refrigeration. Discard any excess
solution.
7.2.3.3 Methano! Standards for Adsorbent Tube Samples. Prepare a series of methanol
standards by first piperting 10 ml of the methanol working standard into a 100-ml volumetric
flask and diluting the contents to exactly 100 ml with 3 percent n-propanol solution. This
standard will contain 10 ug/ml of methanol. Pipette 5. 15. and 25 ml of this standard,
respectively, into four 50-ml volumetric flasks. Dilute each solution to 50 ml with 3 percent
n-propanol solution. These standards will have 1, 3, and 5 ug/ml of methanol. respectively.
Transfer all four standards into 40-ml glass vials capped with Teflon^-lined septa and store under
refrigeration. Discard any excess solution.
7.2.4 GC Column. Capillary column. 30 meters (100 feet) long with an inside diameter (ID)
of 0.53 mm (0.02 inch), coated with DB 624 to a film thickness of 3.0 micrometers, (um) or an
equivalent column. Alternatively, a 30-meter capillary column coated with polyethylene glycol to
a film thickness of 1 m such as AT-WAX or its equivalent.
7.2.5 Helium. Ultra high purity.
7.2.6 Hydrogen. Zero grade.
7.2.7 Oxygen. Zero grade.
B-35
-------
8.0 Procedure
8.1 Sampling. The following items are required for sampling:
8.1.1 Preparation of Collection Train. Measure 20 ml of water into the midget impinger. The
adsorbent tube must contain 520 mg of silica gel in the front section and 260 mg of silica gel in
the backup section. Assemble the train as shown in Figure 308-1. An optional, second impinger
that is left empty may be placed in front of the water-containing impinger to act as a condensate
trap. Place crushed ice and water around the impinger.
BILLING CODE 6560-50-P
[GRAPHIC] [TIFF OMITTED] TR15AP98.014 - Sampling train schematic
BILLING CODE 6560-50-C
8.1.2 Leak Check. A leak check prior to the sampling run is optional; however, a leak check
after the sampling run is mandatory. The leak-check procedure is as follows: Temporarily attach
a suitable (e.g., 0-to 40-ml/min) rotameter to the outlet of the DGM, and place a vacuum gauge at
or near the probe inlet. Plug the probe inlet, pull a vacuum of at least 250 mm (10 inch) Hg. and
note the flow rate as indicated by the rotameter. A leakage rate not in excess of 2 percent of the
average sampling rate is acceptable.
Note: Carefully release the probe inlet plug before turning off the pump.
8.1.3 Sample Collection. Record the initial DGM reading and barometric pressure. To begin
sampling, position the tip of the Teflon® tubing at the sampling point, connect the tubing to the
impinger. and start the pump. Adjust the sample flow to a constant rate between 200 and 1000
ml min as indicated by the rotameter. Maintain this constant rate (±10 percent) during the entire
sampling run. Take readings i DGM. temperatures at DGM and at impinger outlet, and rate
meter) at least ever.' 5 minutes. Add more ice during the run to keep the temperature of the gases
leaving the last impinger at 20 deg.C (68 deg.F) or less. At the conclusion of each run. turn off
the pump, remove the Teflon* tubing from the stack, and record the final readings. Conduct a
leak check as in section 8.1.2. (This leak check is mandatory.) If a leak is found, void the test run
or use procedures acceptable to the Administrator to adjust the sample volume for the leakage.
8.2 Sample Recovery. The following items are required for sample recovery:
8.2.1 Impinger. Disconnect the impinger. Pour the contents of the midget impinger into a
graduated cylinder. Rinse the midget impinger and the connecting tubes with water, and add the
rinses to the graduated cylinder. Record the sample volume. Transfer the sample to a glass vial
and cap with a Teflon* septum. Discard any excess sample. Place the samples in an ice chest for
shipment to the laboratory.
8.2.2. Adsorbent Tubes. Seal the silica gel adsorbent tubes and place them in an ice chest for
shipment to the laboratory.
B-36
-------
9.0 Quality Control
9.1 Miscellaneous Quality Control Measures. The following quality control measures are
required:
Section
8.1.2,8.1 3 10.1.
10.2
Quality control measure
Sampling equipment leak check
and calibration.
GC calibration.
. Effect
Ensures accurate measurement of
sample volume;
Ensures precision of GC analysis.
9.2 Applicability. When the method is used to analyze samples to demonstrate compliance
with a source emission regulation, an audit sample must'be analyzed, subject to availability.
9.3 Audit Procedure. Analyze an audit sample with each set of compliance samples.
Concurrently analyze the audit sample and a set of compliance samples in the same manner to
evaluate the technique of the analyst and the standards preparation. The same analyst, analytical
reagents, and analytical system shall be used both for the compliance samples and the EPA audit
sample.
9.4 Audit Sample Availability. Audit samples will be supplied only to enforcement agencies
for compliance tests. Audit samples may be obtained by writing: Source Test Audit Coordinator
(MD-77B). Air Measurement Research Division. National Exposure Research Laboratory, U.S.
Environmental Protection Agency. Research Triangle Park. NC 27711; or by calling the Source
Test Audit Coordinator (STAC") at (919) 541-7834. The audit sample request must be made at
least 30 days prior to the scheduled compliance sample analysis
9.5 Audit Results. Calculate the audit sample concentration according to the calculation
procedure provided in the audit instructions included with the audit sample. Fill in the audit
sample concentrator, and the analyst's name on the audit response form included with the audit
instructions. Send one cop;, to the EPA Regional Office or the appropriate enforcement agency
and a second copy to the STAC.. The EPA Regional office or the appropriate enforcement agency
will report the results of the audit to the laboratory being audited. Include this response with the
results of the compliance samples in relevant reports to the EPA Regional Office or uhe
appropriate enforcement agency.
10.0 Calibration and Standardization
10.1 Metering System. The following items are required for the metering system:
10.1.1 Initial Calibration.
10.1.1.1 Before its initial use in the field, first leak-check the metering system (drying tube,
needle valve, pump, rotameter, and DGM) as follows: Place a vacuum gauge at the inlet to the
drying tube, and pull a vacuum of 250 mm (10 inch) Hg; plug or pinch off the outlet of the flow
meter, and then turn off the pump. The vacuum shall remain stable for at least 30 seconds.
Carefully release the vacuum gauge before releasing the flow meter end.
10.1.1.2 Next, remove the drying tube, and calibrate the metering system (at the sampling
flow rate specified by the method) as follows: Connect an appropriately sized wet test meter
(e.g., 1 liter per revolution (0.035 cubic feet per revolution)) to the inlet of the drying tube. Make
B-37
-------
three independent calibrations runs, using at least five revolutions of the DGM per run. Calculate
the calibration factor, Y (wet test meter calibration volume divided by the DGM volume, both
volumes adjusted to the same reference temperature and pressure), for each run, and average the
results. If any Y-value deviates by more than 2 percent from the average, the metering system is
unacceptable for use. Otherwise, use the average as the calibration factor for subsequent test
runs.
10.1.2 Posttest Calibration Check. After each field test series, conduct a calibration check as
in section 10.1.1 above, except for the following variations: (a) The leak check is not to be
conducted, (b) three, or more revolutions of the DGM may be used, and (c) only two independent
runs need be made. If the calibration factor does not deviate by more than 5 percent from the
initial calibration factor (determined in section 10.1.1), then the DGM volumes obtained during
the test series are acceptable. If the calibration factor deviates by more than 5 percent, recalibrate
the metering system as in section 10.1.1, and for the calculations, use the calibration factor
(initial or recalibration) that yields the lower gas volume for each test run.
10.1.3 Temperature Sensors. Calibrate against mercury-in-glass thermometers.
10.1.4 Rotameter. The rotameter need not be calibrated, but should be cleaned and maintained
according to the manufacturer's instruction.
10.1.5 Barometer. Calibrate against a mercury barometer.
10.2 Gas Chromatograph. The following procedures are required for the gas chromatograph:
10.2.1 Initial Calibration. Inject 1 jal of each of the standards prepared in sections 7.2.3.3 and
7.2.3.4 into the GC and record the response. Repeat the injections for each standard until two
successive injections agree within 5 percent. Using the mean response for each calibration
standard, prepare a linear least squares equation relating the response to the mass of methanol in
the sample. Perfonn the calibration before analyzing each set of samples.
10.2.2 Continuing Calibration. At the beginning of each day. analyze the mid level calibration
standard as described in section 10.5.1. The response from the daily analysis must agree with the
response from the initial calibration within 10 percent. If it does not. the initial calibration must
be repeated.
11.0 Analytical Procedure
11.1 Gas Chromatograph Operating Conditions. The following operating conditions are
required for the GC:
11,1.1 Injector. Configured for capillary column, splitless. 200 deg.C (392 deg.F).
11.1.2 Carrier. Helium at 10 ml/min.
11.1.3 Oven. Initially at 45 deg.C for 3 minutes; then raise by 10 deg.C to 70 deg.C; then
raise by 70 deg.C/min to 200 deg.C.
11.2 Impinger Sample. Inject 1 |il of the stored sample into the GC. Repeat the injection and
average the results. If the sample response is above that of the highest calibration standard, either
dilute the sample until it is in the measurement range of the calibration line or prepare additional
calibration standards. If the sample response is below that of the lowest calibration standard.
prepare additional calibration standards. If additional calibration standards are prepared, there
shall be at least two that bracket the response of the sample. These standards should produce
approximately 50 percent and 150 percent of the response of the sample.
11.3 Silica Gel Adsorbent Sample. The following items are required for the silica gel
adsorbent samples:
B-38
-------
11.3.1 Preparation of Samples. Extract the front and backup sections of the adsorbent tube
separately. With a file, score the glass adsorbent tube in front of the first section of silica gel.
Break the tube open. Remove and discard the glass wool. Transfer the first section of the silica
gel to a 5-ml glass vial and stopper the vial. Remove the spacer between the first and second
section of the adsorbent tube and discard it. Transfer the second section of silica gel to a separate
5-ml glass vial and stopper, the vial.
11.3.2 Desorption of Samples. Add 3 ml of the 10 percent n-propanol solution to each of the
stoppered vials and shake or vibrate the vials for 30 minutes.
11.3.3 Inject a l-^il aliquot of the diluted sample from each vial into the GC. Repeat the
injection and average the results. If the sample response is above that of the highest calibration
standard, either dilute the sample until it is in the measurement range of the calibration line or
prepare additional calibration standards. If the sample response is below that of the lowest
calibration standard, prepare additional calibration standards. If additional calibration standards
are prepared, there shall be at least two that bracket the response of the sample. These standards
should produce approximately 50 percent and 150 percent of the response of the sample.
72.0 Data Analysis and Calculations
12.1 Nomenclature.
Ca,=Concentra;:cT; of methanol in the front of the adsorbent tube, ug/ml.
Cab=Concentrauon of niLihanoI in the back of the adsorbent tube, ug/ml.
C.=Ccncentration of methane! in the impinger portion of the sample train, ug/ml.
E=Mass emission rate of methariol. ug/hr (Ib/hr).
M,0,=Tota! mass of methano! collected in the sample train, g.
Pbar=Barometric pressure at the exit orifice of the DGM. mmHg (in. Ha).
Pstd=Standard absolute pressure. 760 mm Hg (29.92 in. Hg).
Q^=Dry volumetric s::_k gas flow rate corrected to standard conditions, dscm/hr (dscf/hr).
Trt,=Average DGM absolute temperature, degrees K. ( deg.R).
Tsia=Standard absolute temperature. 293 degrees K. (528 deg.R).
Vaf=Volume of front half adsorbent sample, ml.
Vab=Volume of back half adsorbent sample, ml.
V^Volume of impinger sample, ml.
Vm=Dry gas volume as measured by the DGM. dry cubic meters (dcm), dry cubic feet (dcf).
Vm(std)=Dry gas volume measured by the DGM, corrected to standard conditions, dry standard
cubic meters (dscm). dry standard cubic feet (dscf)-
12.2 Mass of Methanol. Calculate the total mass of methanol collected in the sampling train
using Equation 308-1.
Ho, - V,C, * VafCar * v,bcab .Equation 308-1
12.3 Dry Sample Gas Volume. Corrected to Standard Conditions. Calculate the volume of gas
sampled at standard conditions using Equation 308-2.
B-39
-------
VJstd) = -= 2L^ Equation 308-2
n> -r p T
'ni'ad
12.4 Mass Emission Rate of Methanol. Calculate the mass emission rate of methanol using
Equation 308-3.
P H*0"" • * ' • w
t —— Equation jOSo
Vm(sid)
13.0 Method Performance [Reserved]
14.0 Pollution Prevention [Reserved]
15.0 Waste Management [Reserved]
16.0 Bibliography
1. Rom. J.J. "Maintenance. Calibration, and Operation of Isokinetic Source Sampling
Equipment." Office of Air Programs, Environmental Protection Agency. Research Triangle Park.
NC.APTD-0576 March 1972."
2. Annual Book of ASTM Standards. Part 31: Water. Atmospheric Analysis. American
Society for Testing and Materials. Philadelphia. PA. 1974. pp. 40-42.
3. Westlin. P.R. and R.T. Shigehara. "Procedure for Calibrating and Using Dry Gas Volume
Meters as Calibration Standards." Source Evaluation Society Newsletter. 3(1): 17-30. February
1978.
4. Yu. K.K. "Evaluation of Moisture Effect on Dry Gas Meter Calibration." Source Evaluation
Society Newsletter. 5vi) :24-28. February- 1980.
5. N1OSH Manual of AnaMical Methods. Volume 2. U.S. Department of Health and Human
Services National Institute for Occupational Safety and Health. Center for Disease Control. 4676
Columbia Parkway. Cincinnati. OH 45226. (available from the Superintendent of Documents.
Government Printing Office, Washington. DC 20402.)
6. Pinkerton. J.E. "Method for Measuring Methanol in Pulp Mill Vent Gases." National
Council of the Pulp and Paper Industry for Air and Stream Improvement, Inc., New York. NY.
17.0 Tables, Diagrams. Flowcharts, and Validation Data
[Reserved].
B-40
-------
Appendix C
Flowchart Summary of the NESHAP
NOTE: The following eleven diagrams provide only a summary of the requirements of the
standards and do not supersede the standards in any manner. Compliance
determinations are based on the standards published in the Code of Federal
Regulations.
-------
FIGURE 1. MILL APPLICABILITY (§63.440)
Does this facility produce pUp. paper, or
paperboard?
NO
Not subject to
WsnJe.
YES
T
Is this facility a major source of HAP? (Does the facility
emit more than 10 tons per year of a single HAP or more
than 25 tons per year of aggregate HAPs?)
NO
YES
i
Appticao rty anc compliance schedule (see Figure 2)
Kraft, serni-cher-ica and soda pulping system standards (see Figure 3)
Surfite pulping system standards (see Figure 4)
Bleaching system standards (see Figure 5)
Kraft pulping process condensate standards (see Figure 6)
Monitonng requirements (see Figure 8}
Monitoring parameters (see Figure 9)
Reporting and recordceeping requirements (see Figure 10)
Reporting and recordkeeping requirements (Continued) (see Figure 11)
C-l
-------
FIGURE 2. APPLICABILITY AND COMPLIANCE SCHEDULE (§63.440)
KRAFT, SEMI-CHEMICAL.
SODA. AND SULRTE
PULPING MILLS
Existing Source Applicability
• Pulping and bleaching
systems
New Source Applicability
• Pulping and bleaching
systems constructed or
reconstructed after
December 17, 1993
• Additional pulping or
bleaching lines constructed
after December 17, 1993
MECHANICAL. NON-WOOD
FIBER, AND SECONDARY
FIBER PULPING MILLS
Existing Source
Applicability
• Bleaching systems
New Source Applicability
• Bleaching systems
constructed or reconstructed
after March 8,1996
• Additional bleaching lines
constructed after March 8,
1996
New Sources Must Achieve Compliance Upon Startup or June 15, 1998
Whichever is Later.
Existing Sources Must Achieve Compliance by April 16, 2001 With the
Following Exceptions:
HVLC* Systems
At Kraft Mills
1 Compliance Within 8
Years After Promulgation
of This Rule.
' Mill Must Provide and
Update Compliance
Milestones.
Bleaching Systems
at Dissolving-Grade
Kraft and Sulfite Mills
Compliance Within 3
Years After the
Promulgation of the
Effluent Limitations
Guidelines (expected
compliance date of
2003-2005).
Bleaching Systems in the
Voluntary Advanced Technology
Incentives Program
• Compliance Within 6 Years After
Promulgation of The NESHAP
• 'No backsliding* provision in effect
3 years after promulgation (e.g., mill
must not increase the application
rate of chlorine of hypochlorite)
• Mill Must Provide and Update
Compliance Milestones.
High volume, low-concentration systems include knotters,
screens, deckers, pulp washers, oxygen delignification systems,
and weak liquor storage tanks.
C-2
-------
FIGURE 3, PULPING SYSTEM STANDARDS FOR KRAFT, SEM-CHEMCAL,
AND SODA PULPING MILLS (§63.443, §63.450)
KRAFT PULPING SYSTEMS*
Basting Sources
•LVHC systems"
• HVLC systems
"Knotter and screen systems with: _
•Kroner systems with emissions ;: 0.05 kj"*/Mg OOP and
screen systems with emissions i0.1kg***/M3COP
•Combined tattler and screen systems win emissions
-Pulp wasting systems
° Decker systems that use any process water other than fresh
weter. or paper rrachne whte water or process voter with
toBHftP~:>400pFmw
"Oxygen oetignficaicn systerrB
New Sources
• Existing sources
• Al knoaer systems
• Al screen systems
• Al decKer systems
' Weak liquor storage tanks
SBWI-CHEMICALAND
SODA PtJL PINIR SYSTEMS
HVLC SYSTEMS .
VENT CONTFOL OPTIONS
Choose One or a Combination of
the Following-
LVHC SYSTEMS
1
Clean Condensate Attema;. .
(se~ ".gu^ "
Staling Sources
•LVHC system-
New Sources
•LVHC system
• PUp washing systems
ROUTE VENTS TO A
CLOSED-VENT COLLECTION
SYSTEM
• Negawe pressire at eacti
enciosu re/hood openng
• No detectaae leaks >500 ppmv~'
(postive oressure systems cnfy)
• 8>pass vapor ires
- Instal ttowndcalDr, or
- Secxre Dypass line
• Vsisly nspect every 30 oays
• Repair leaks as soon as practicable
(begn reparwthmSaa^sand
ccmpletewthn 15 days after
loennficatoni
CONTFOL OPTIONS
Choose One of the Following:
^'c Reduction by
Wagnr-
Route to a Thermal Ctafeer At One of the
FdloMrig Condtons;
tmroobce vent stream with prmery tual,
irto flame zxie, or wiffi tne combustiai
air of a boiler. Irne kin, or recovery
furnace.
Mnrrun temperaoie of 1600°F and
Q 75 seconds resttence time
20 ppnV- outlet concertraicn
(correded>o10%O2)
* Kraft pJpng systems rrust also cortroi puling process condensates (see Rgire 6).
• LVHC systems induoe digesters, turpenOne recovery, evaporators, steam stripper systems, and any other
equpmert seiving the same function as those previously mentioned.
* All measuremerts as total HAP or methanol
C-3
-------
FIGURE 4. PULPING SYSTEM STANDARDS FOR SULFTIE PULPING MILLS (§61443, §63,450)
SULFITE PULPING SYSTEMS
Existing Sources:
• Digester system vents
• Evaporator system vents
• Pulp washing system vents
New Sources
• Same as existing sources, plus
• Weak liquor storage tank vents
• Strong liquor storage tank vents
• Acid condensate storage tank vents
Route Vents to a Closed-Vent Collectjon System
(see Figure 3)
Calcium-based and Sodium-based
Pulping Systems
Control Options
Choose One o* the Following:
Ammonium-based and Magnesium-based
Pulping Systems
Control Options
Choose One of the Following:
1
Outlet Emission Levels
SO. 44 kg'/Mg OOP
i Remove 92%
byWeignr
! r
Outlet Emission Levels [ \
S1.1 kg'/MgODP j j
i
Remove 87%
by Weight*
manured as tot* HAP or MMhmd. Outtet tmmon level and peroart laducbon raqjrameno
mdudv •muioiift dun nyJtttA•yjpnwv syu0rns and HAP r*JMn> (rant wtt, oondvium, and
MMmoHr araariB frem oonM devices used to reduce HAP arnsians.
C-4
-------
RGURE 5. BLEACHING SYSTEM STANDARDS (§63.445)
BLEACHING SYSTEMS
Are chlorine or chlorinated
compounds used?
NO
No Control Requirements
YES
KRAFT. SODA.' AND SULFTTE
PULPING MILLS
SEMI-CHEMICAL MILLS
MECHANICAL, NON-WOOD
RBER, AND SECONDARY
RBER PULPING Mil I S
Existing and New Sources
• Bleaching stages that ure chiorne
or chlonnatea c
Existing and New Sources
• Bleaching stages thai use
chlorine
Existing and New Sources
« Bleaching stages that use
chlorine or chlorine dioxide
_L
CHLOROCOF',' CONTROL OPTIONS
Choose C-.e o' tne
CHLORINATED HAP CONTROL OPTIONS
(excluding chloroform)
• Route vents to a closed-vent collection
system (see Figure 3) and choose one of
the following:'
1
*
i Comply With the
! Effluent Limitations
• Guidelines j
Use No Chlorine or
HypochtorrtB In Any
Bleaching Stage
I
99%
Reduction
by Weight"
i
i
T-— l-l
Outlet Erri
Concentration L&
S10 ppmv" i 40.
Outlet
sson
/els
001
IgODP
• Enclosures ana ooseo-vera systarm are not required tar
laoMes thai use process modfxaDora to comply witn the
umuMNiMiuii ot toot HAP fnass ofnsson im&.
~/W values measured as total cHonnated HAP or <«ohne.
C-5
-------
FIGURE 6. KRAFT PULPING PROCESS CONDENSATE STANDARDS (§63.446)
KRAFT PULPING PROCESS CONDENSATES
New andBMtngSarac
•OoBster system
•CorriBnsates from
lajCT feed stage vapors* tie
• LVHC collection syst em
•HVLCcdtetcmsvaem
Convey condensates in ackaed cdacBon system meeting the
requremerts tar individual drain systems as specified in Subpatt RR (40
CFR 63.446(d)) until the condensates reach one d the treament options.
CONTROL OPTIONS
Choose One of the Folowrr;
CONTKX THE ENTIRE
VOLUME OF
OONDENSATES FROM
ALL LISTED SOURCES
VOLUME REDUCTION OPTION 1:
Control the rtgTvHAP streams that
cottectrvely cortan a least 65 percent of
the total HAP mass from trie dgester.
turpentine recovery, ana evaporator
systems and al condensates from the
LVHC and HVuC collection systems.
VOLUME REDUCTION OPTIOre
(Condensate Segiegaton)
Seo/egate concfensate streams no low-HAP and
ricfi-HAP streams. Choose one of the folowing:
LOW-HAP STREAMS
• No further MACT
retirements
• Retun to mill or sewer
~H TREATMENT OPTIONS
-*j Choose One of the Folowng
VOLUME REDUCTION OPTION Z j
Control the rio>HAP streams that |
(X*ledrve(y cortan >Z.G ko/Mq |
COP (uiUeached mite) or " ,
>S5ko/Mg.COP
(bteachea mis)
from all listed soirees.
RECYCLE
RoOB condensates to a
controlled piece of process
epucment meeting the
puCng vent standards
BKXOGICALTREATMEf^T
Remove 92% of total HAPs*
or 5.1 Ig/Mg (bleached mils)
or 3 J kp/Mg (urbeached mils)
using a botogcaJ treament
system.
STEAM STRIPPING"
(or control devices other than
bobgcal treatment)
Choose One or the Folcvung
Reduce total HAP
by92%byvMigrir*
• MMBued as acecaHehyde. methansl, rrrthyl ety katona, and proponaWBhydB.
• HAPs removed from pufcing process oondensates by steam stripping (or control
kraft puling vent standaids.
' Maasured as ether the sum of acetaJdehyde, methanoi. methyl ethyl ketone.and
propDnaJdehyOe. or as met hand.
Bleached Wife:
• Remove at least 51 kg—/Mg OOP,
or
• Reduce total HAPS"* to 330 ppmw
Unbleached Mis
• Remove at least 33 kg—/Mg OOP.
or
»Reduce total HAPs— to 210 ppmw
C-6
-------
RGURE 7. CLEAN CONDENSATE ALTERNATIVE FOR
KRAFT MILLS (§63.447)
CLEAN COMPENSATE ALTERNATIVE (CCA)
• Atanwkw tar »MJC*yitom vans standards in Hgura 3
(tor indhMuri Mntoor comttntfon oi v«nts)
• Ojnospt-Ftaduction of HAP i
al HAP cancentnban in p
i tiwDuor) reduction
• Ftaurting HAP emission reductions on be used as
partial of comptoto fulfiltm6nt of tha amavon
raqund by th» Kraft pulping sy
SOURCES AT KRAFT MILS BJSIBLE FOR
INCLUSION IN THE CCA
• Pulping systems
• Bleaching systems
• Causnaang systems
• Papermaking systems
CALCULATE BASEUNE EMISSIONS
.Baseline emissions are to be measured after compliance has
been achieved with:
• K/ati pulping process ccodensate standards, and
• Revised effluent limitation guidelines and standards in 40
CFR 430 subpart B
MEASL = E EMISSIONS OED'JCTiONS ACHIEVED
. 'HE CCA
Emissors Rec-jctKjr--; ^-wvea Throuo": tne CCA
• Basei'ne ETHSSKXK mnjs emisson >eveis
Treasured aner tne CCA nas Been implemented
• E«*uding
-amssKn reductions annlxitatxe to control
technology requited by local. Staie. or Federal
agenoes
•• ujUiui eojuipment installed and opwdlinQ on
Decemoer 17 1933
CALCULATE EMISSIONS REDUCTIONS
EXPECTED THROUGH COMPUAfJCE WITH THC
KRAFT PULPING VENT STANDARDS
Compkance mrough t» CCA is OBtermined by Prowng That
Emascn Reductions
Acneved Througn tne CCA >
(kg wa1 HAP/Mo. OOP) ~
Enusion Rsducfions
&«MCted TTvough Comptevxa
With ttw Kraft PulpinQVBrt SysMfn
Standsidi (kg total HAFVMg OOP)
C-7
-------
FIGURE 8. MONITORING REQUIREMENTS (§63.453)
MSTAU. AND OPERATE:
ContirtKW Motoring System (CMS)
ALLOWABLE OPERATING/EMISSION PARAMETERS
FOR SPECIFIED SOURCES AND CONTROLS
• Use named parameters in Figure 9 tor specified
sources and controls.
• Altematrve parameters to those specified are alowed
only with EPA approval
DETERMINING OPERATING/EMISSION PARAMETERS
FOR OTHER SOURCES AND CONTROLS
• Only for the sources and controls listed below:
•SuJfite pulping vent controls,
•Kraft condensate segregation techniques: and
• Kraft clean condensate alternative controls.
•Bleaching systems using process mode features
• Establish parameters:
• Mentor parameters during performance test and
•Supplement the performance test results with
engineering assessment and manufacturer's
recommendations.
• Provide the rationale and data to Admnstrator
' inctcating that the chosen parameter(s) demonstrate
compliance with the emission standard.
SETTING PARAMETER:
VALUE, AVERAGING TIME, AND MONITORING FREQUENCY
> Establish parameter value
= Continuous monitoring data collected during performance test, and
= Sucptement the performance test results with engineenng
assessment and manufacturer's recommendations.
• Provide rationale and data to Administrator indoafing that the chosen
parameter value demonstrates commence w*h emisaon standard.
EXCEEDING THE MONITORING PARAMETER VALUES OR PROCEDURES
• Shall constitute a violation of the applcaUe emission standard, and
• Must be reported as excess emissions
•Except
- Biological treatment systems that are tested and comply with percent reduction
or mass removal standards
•Control devices (except biological treatment) excess emissions must not exceed
10% of operating time including startup, shutdown, or malfunction, and
- Kraft, soda and serm-chemca1 vent controls must not exceed (excluding
startup, shutdown, or malfunction):
•1% for LVHC systems controls .
• 4% for HVLC or combined LVHC and HVLC system controls
C-8
-------
FIGURE 9. MONITORING PARAMETERS (§63.453)
I Thermal Oxjdizer
I • For compliance with the 98 percent reduction option; measure, maintain,
I and record fire box temperature with a CMS*
i-u n mi /•> ' * For compliance with the 20 ppmv outlet option; measure, maintain, and
PULPING ' record fire box temperature or outlet HAP concentration with a CMS
SYSTEMS • For compliance with the 1600°F design temperature option; measure.
maintain, and record fire box temperature with a CMS
• No monitoring requirements for pulping vent system vents routed to a
i power boiler, lime kiln, or recovery furnace
BLEACHING
SYSTEMS
Bleaching Vent Scrubbers
• Measure and record the following parameters using a CMS:
=pH or oxidation/reduction potential of scrubber effluent,
=gas scruDber fan speed, and
=gas scrubber liquid influent flowrate
-or-
=Chiorne outlet concentration
Systems participating in the extended compliance time of the
Voluntary Advanced Technology Incentives Program:
«Monitor chlorine and hypochlorite application rates (kg/Mg OOP) during
extended compliance period
Steam Strippers
• Measure and record the following parameters using a CMS:
" Process water feed rate.
=Stearr feed rate, and
= Column feed temperature
-or-
= Outie! metranol concentration
PULPING
PROCESS
CONDENSATES
ic.-C'ca! Treatment Systems
Dai'v monitoring
^Iv- e: soluble 3005
= Mxec sauor vdatie suspended soiCs
"Horsecewer of aerator in <(s';
•lni€'. liOUId'lOW
"Liquid temperature
=Collect and store inlet and outlet grab samples
-or-
= Monitor site-specific parameters
Quarterly monitoring
-Every 1st quarter demonstrate percent reduction or mass removal of acetaktehyoe.
methanoi, methyl ethyl kstone, and propionaldenyde
•= Remaining quarters: percent reduction or mass removal of the four HAP (metnanol
can be measured if a relationship between the four HAP and methanol reduction
is established during the 1 st quarter).
CLOSED VENTT
SYSTEMS
-and-
CLOSED
COLLECTION
SYSTEMS
(Condensates)
E^ry 30 days:
• Visual inspection
»Inspect bypass line valve or closure mechanism
Initially and Annually
• Demonstrate no detectable leaks in positive pressure portions
• Demonstrate negative pressure at enclosure openings
' CMS = Continuous Mentoring System
C-9
-------
FIGURE 10. RECORDKEEPING AND REPORTING REQUIREMENTS (§63.454, §63.455)
INTT1AL NOTIRCATION REPORT
Existing Major Sources: Within 1 year
after becoming subject to rule
New or Reconstructed Major Sources No
later than 120 days after initial startup
• Name & address of owner or operator.
• Address of the source.
• Identification of the rule and source's
compliance date.
• Description of operations, design
capacity, and HAP emission points
• Statement of whether a major or area
source.
• Notification of intent to construct or
startup date for new or reconstructed
sources.
• Control strategy report (HVLC systems
at kraft mills).
• Control strategy report (bleaching
systems part>cipating in tre Effluent
Incentives Program;
. NOTIFICATION OF COMPLIANCE
STATUS REPORT
60 Days Following Compliance
Demonstration
• Methods used to determine compliance.
• Results of performance tests and/or
CMS performance evaluations.
• Methods to be used to determine
continuous compliance.
• Type and quantity of HAP emitted.
• Analysis demonstrating whether a major
or area source.
• Description of control equipment and
efficiencies.
• Statement as to whether source has
complied with standard.
• Data, calculations, engineering
assessments, and manufacturer's
recommendations used to determine
operating parameter value.
C-10
-------
FIGURE 11. RECORDKEEPING AND REPORTING REQUIREMENTS (§63.454, §63.455)
PERIODIC REPORTS
QUARTERLY
(Excess Emissions)
SEMt-ANNUAUY
(No Excess Emissions)
BI-ANNUALLY
• Requirements specified in Subpart A
• No additional requirements under Subpart S
• Requirements specified in Subpart A
• Mills participating in the Voluntary Advanced Technology
Incentives Program must report dairy application rates of
chlorine and hypochlorite
• Mills with extended compliance schedules (some kraft
pulping systems and lor mills participating in the Effluent
Incentives Program) must update control strategy reports
RECORDKEEPING
1 Comply with recorcxeepmg requirements specified in Subpart A
• Mills # Mills par:;;pating witn the Voluntary Advanced Technology Incentives Program
shall 'ecuro oanv average chlorine and hypochionte application rates (kg/Mg
OOP)
> Mills shai! record all CMS parameters included in the monitoring requirements
>S6t F;gjres 9 anc 9)
C-ll
-------
-------
Appendix D
List of EPA Region Office Contacts
-------
Susan Lancey
EPA Region I (CAP)
J.F.K. Federal Building
Boston, MA 02203-2211
PH: (617) 565-3587
FAX: (617) 565-4940
Umesh Dholakia
EPA Region II
290 Broadway
New York, NY 10007-1866
PH: (212) 637-4023
FAX: (212) 637-3901
Diane Walker
EPA Region II! (3AP11)
1650 Arch Street
Philadelphia. PA 19103-2029
PH: (215) 814-3297
FAX: (215) 814-2124
Lee Page
EPA Region !V(AR-4)
61 Forsyth S:.
Atlanta. GA 30303-3415
PH: (404)562-9131
FAX: (404)562-9095
BriicC Yarner
EPA Region V(AE-i"J:
7" \V. Jackson Blvd.
Chicago. IL 60604-359:
PH: (312)886-6793
FAX: (312) 353-8289
Robert Todd
EPA Region VI (6PD-AP,
1445 Ross Avenue. Suite 700
Dallas, TX 75202-2733 -
PH: (214) 665-2156
FAX: (214) 665-7263
REGIONAL AJR TOXICS CONTACTS
Richard Tripp
MC ARTD/APC
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
PH: (913) 551-7566
FAX: (913) 551-7065
Victoria Parker-Christensen (8P-AR)
Ann-Marie Patrie
Heather Rooney (8ENF-T)
EPA Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2466
Victoria: (303) 312-6064
Ann Marie: (303) 312-6524
FAX: (303) 312-6064
Heather: (303)312-6971
FAX: (303) 312-6409
Mae Wang
AIR-4
EPA Region IX
75 Hawthorne Street
San Francisco. CA 94105
PH: (415)744-1200
FAX: (415) 744-1076
Andrea Wullemveber
EPA Region X (OAQ-107)
1200 Sixth Avenue
Seattle. WA 98101
PH: (206)553-8760
FAX: (206) 553-0404 '
D-l
-------
Appendix E
Equipment Diagrams For Pulp and Paper Mills
-------
List of Figures
Figure 1 Example Overview of a Kraft Pulping Mill with a Papermaking System
Figure 2 Example Kraft Pulping System
Figure 3 • Example Kraft Digester System (batch)
Figure 4 Example Kraft Digester System (continuous)
Figure 5 Example Kraft Turpentine Recovery System
Figure 6 Example Kraft Knotter System
Figure 7 Example Kraft Pulp Washing System
Figure 8 Example Kraft Screen System and Decker System
Figure 9 Example Kraft Oxygen Delignification System (medium consistency)
Figure 10 Example Kraft Oxygen Delignification System (high consistency)
Figure 11 Example Kraft Weak Liquor Storage Tank
Figure 12 Example Kraft Evaporator System
Figure 13 Example Semi-Chemical Pulping System
Figure 14 Example Semi-Chemical Digester System (batch)
Figure 15 Example Semi-Chemical Digester System (continuous)
Figure 16 Example Semi-Chemical Pulp Washing System
Figure 17 Example Semi-Chemical Evaporator System
Figure 18 Example Soda Pulping System
Figure 19 Example Soda Digester System (batch)
Figure 20 Example Soda Pulp Washing System
Figure 21 Example Soda Evaporator S> stem
Figure 22 Example Saline Pulping System .
Figure 25 Example Sulfite Digester System (batch)
Figure 24 Example Sulfite Pulp Washing System
Figure 25 Example Sulfite Weak Liquor Storage Tank
Figure 26 Example Sulfite Evaporator System
Figure 2" Example Sulfite Strong Liquor Storage Tank
Figure 2S Example Sulfite Acid Condensate Storage Tank
Figure 29 Ex.rr.ple Bleaching S\ stem
Figure 30 Example Steam Stripping System with Methanol Rectification
Figure 31 Example Biological Treatment System
E-l
-------
SUMMARY OF FIGURES
These figures are intended to serve as an overview of the various processes that
exist at kraft, semi-chemical, soda, and sulfite pulp and paper mills. Figure 1 provides an
overview of the entire pulp and papermaking process at a kraft mill. This general process
is followed at semi-chemical, soda, and sulfite mills, therefore, process overviews are not
repeated for those mills. Figures 2,13,18, and 22 illustrate the various processes within
pulping systems at kraft, semi-chemical, soda, and sulfite mills, respectively. Process
blocks in these figures that list collection systems indicate the processes that are subject
to the Pulp and Paper NESHAP. Alternatively, process blocks that do not list collection
systems are not subject to the Pulp and Paper NESHAP. The figures that follow
Figures 2,13,18 and 22 provide greater detail about the specific processes and equipment
in these pulping systems. Figures 29,30, and 31 illustrate the processes and equipment
used in bleaching systems, steam stripper systems, and biological treatment systems,
respectively.
Disclaimer
The following figures are representations of pulping and bleaching systems and
processes for the purpose of clarifying the Pulp and Paper NESHAP. They are intended
to provide the reader with a general understanding of processes at pulp and paper mills:
not pulping and bleaching systems at specific mills. .
. E-2
-------
&JO
B
c.
vtri
fi.
o
Si
"E
v a
£ IE
no 6
C O
2 ±
a L.
E Mi
e * .s «
-= - 33 u
co a v
5 £ f. «•> .5
«3> £S
a- c £ «j a
2J k. ? "ti .
~ 5 >£ >.= o =
4. - ~ IT! U -»
*im±f
ini-l§
C. — 5i — -^ r -
"5 "3 a > y -z -s
-
E-3
1 5 c g^E
c « i c -a i
^ O-ir "e c •»
•o-o )
§ 5 £ 8 g «
c a; £ •£ -s *
u at > u. a. C
-------
Figure 2 - Example Kraft Pulping System
Wood Chips
Chemical
Recovery
System
Digester System
(Figure 3 & 4)
Collection System:
•LVHC
• Condensates
Knotter System
(Figure C)
Collection System:
•HVLC
Pulp Washing System
• (Figure 7)
Col lection System
• HVLC
Screen System
and Decker System
fFigure ^.'
Collection System.
• HVLC
T
Relief
Gas
Oxygen Delignification
System
(Figure 9 & 10)
Collection System:
•HVLC
'Affected source only at new sources
/""Pulp to Pulp Dryers "X
Xor Papermaking System.,/
Turpentine
Recovery System
ffigure 5)
Collection Systems:
•LVHC
• Condensates,
pulp How
liquid streams
gas streams
HVLC* high volume.
low concentration
LVHC » low volume.
high concentration
E-4
-------
V
S 8
51
5 all
W tfa M ^
2 s^il
-it! I
It
§1
(/3CJ
CO 5: CO C
I !
^
o
,
c
I
.
c
5
x
sl
x =
T.
>-,
V
C c
I -2
IX §•
£. — M
E-5
t
A ^5
-------
o
9
ja
1
t
o>
ts
«
x
u;
i
I
5
E-6
-------
V "K
i &
Ji 5 5
-: ^ c
to — ^
= 2^
« = c
111
©
&
e
^.
H
E
K
I
LI
£ E
^ fl
E-7
-------
S
D
to
c
u.
i
cc
u
5:
v>
e
i 3
c JJ
a 5
1 1
t!
i
.1
& ^
5 S
"5 S
> s
•a *
2^
u
a
'; ,
:;! v£
. X.
E-8
-------
I
s
&
re
1
1 I
a 2
B. A
tl
{ - 1
3 E 15
! g ||
i "* ~ e
= M > w
•& *
i
E-9
-------
3 5-
s
0)
0>
Q
•o
re
e
QJ
a
re
I
00
&J
cr.
E-10
-------
•_ ^
u s s
isi
«2 =
•5 » S
o o
„ S' E 3
I 5 S gg
= _ i Eg
tlill
t
A fl
S 5
£
Tc
•w
1?
5FS
"5 -
?1
t- c
£ =
x £
O s
£
,
i
Ci
£
BC
E
E-ll
-------
f
1}
® 1
14
£
re
x
u;
r.
u
E-12
-------
5
CJ
ise
2
o
55
o
p*
c-
cc
I
c
£
.
=
te
E-13
-------
i
1.
C/5
c
2
Sc
E-14
-------
Figure 13 - Example Semi-chemical Pulping System
Wood Chips
Chemical
Recovery
System
Evaporator
System
(Figure 17)
Weak Liquor
Storage Tank
Digester System
(figure 14 & 15)
Refiners
T
Pulp Washing System*
(Figure in)
Collection System
• HVLC
Refiners
pulp flow
liquid streams
HVLC= high volume, -
low concentration
LVHC = low volume,
high concentration
Pulp to Pulp Dryers
or Papermaking System.
"Affected source only at neu sources.
E-15
-------
II
o
o
5
I
g
I
o
"3
V
C/5
—
"E.
«
i
•*r
-r
D- 5
I -i
•«
i^
^ ?-
« c
s,e
Cl
a:
{
*
\
o
3
CT
O
O
* i «
_0 -5 »;
t
A' ^2
E-16
-------
o
1
C
I
Q
"re
V
I
S
>?
u.
I
ir.
£. S.
~ Ss
t
S "3:
A s:
C
E-17
-------
t
c
IS
^
J3.
£
"re
5
re
x
u:
i
•c
"c
II
IS
^•\
/"\
••=:
<^*
Jt
/.
V
^
V
/
V
Jj:-:-;-. ::=-:s5s~-=— =
• :=:= gjj nr.:-^::=:::
£|2
r ^HH|=::|H|=^=~g
7?n;u^;-:^:^:r:r;:;:r^:n^:
-'"•: _ _se '. • -.••-.
-"• <5 c • .•:':',.,
:, C/J t—
— ^e '.'..- • '
'. ^£ •' .- •
_ .^
ra s
<^(2
s=^
=H=SS
^..iii i .»—
H~H~
Si^rst:
1
1 \
1. ?
I j
II
ft
=
i 1
3 •£
3 *"
r a
, A
§
rfl
1 |
> g
"5i $
2.2
O
£ &.
H
E-18
-------
C/3
c
e
o
O.
iT:
I
g £ t
•=
E-19
-------
Figure 18 - Example Soda Pulping System
Cooking
Liquor
Chemical
Recovery-
System
Evaporator
System
CFIgure 21)
Collection System
• LVHC
Weak Liquor
Storage Tank
Digester System
(Figure 19)
Collection System:
- »LVHC
Knotter System
Pulp Washing System'
(Figure 20)
Collection System:
Screen System
and Decker Svstem
pulp flow
liquid streams
HVLC = nigh volume,
low concentration
LVHC - low volume,
high concentration
'Affected source only at new sources.
i.
Oxygen Delignification
System
E-20
-------
•o
S
§•?
sl
U O
u
o
5
JS
V
13
e
=
c
Jlj
I
u:
i
c.
.f-
5 -S
— >
c
5~
a.
1 1
E £ £
5 g B-|
"5 t;; = '-
t
*i>
A A ^:
E-21
-------
81
1!
a?
f 3
> o
H
*
V
5/3
c
o.
re
T3
c
5/5
O
"o.
S
Er
E-22
-------
C/5
c
O
t!
>
u;
y.
c
"E,
c
Jc
E-23
-------
Figure 22 - Example Sulfite Pulping System
Acid
Making
System
Chemical
Recovery
System
Strong Liquor
Storage Tank*
Acid Condensate
Storage Tank*
(Figure 2S)
Evaporator System
(Figure 2P
Wood Chips
i
Digester System
(Figure 23)
pulp flow
liquid streams
---> gas streams
Knotter
System
Pulp Washing System
(Figure 24J
T
Screen System
and Decker Svstem
T
Pulp to Bleaching Systems, Pulp
Dryers, or Papermaking System^
'Affected source only at neu: sources
E-24
-------
is -
S 3
o C
fi
e
C
01
•o
o
u
I
5
A
^
_ c
= ^
r CC o
0>
IOC
s
CJ
u.
i
c
s s i
^ S i
a
D. =
t
S I g
ae > "
A ^^
E-25
-------
3 S.
oo -n
£ *
I
«
1
c
"E.
=
I
I
o
£r.
E-26
-------
2
o
*••
C/5
J8J
"E
£
E-27
-------
;aL"7 "
1 ISI - -
i y
M~M « MM n":S*n «j >»
-" ~ _ "ii™ "S'Sj., rrg]JM «.
' i
r\
L
0-K
-J •— *»
w
ti
I
1
§.
V
£
•M
c/5
c
5r.
E-28
-------
2
o
ft
a; I
u:
i
C
f A
E-29
-------
I
0)
M
2
o
s
5
"5 'u
S y
'*-t '£•
%&
X;
o
"E
re
x
u:
i
x
N
c;
5
E-30
-------
fcf.
e
a
re
x
u.
I
c;
CM
iZ
E-31
-------
«
c
1
x *
w j=
c'i
C
s 1
i *
me.
cen
llj
. %y
A 2.S.
V
if!
E-32
-------
Figure 31 — Example Biological Treatment System
i—•— •
^7 Pulping Process Condensates
Bar Screen
Grit Chamber
Primary Clarifier
pH Adjustment
Biological Treatment System
(e.g., activated siucL'e. aerated stabilization basin,
anaerobic system, pure Ch. etc.)
Secondary Settling
Discharge to
Receiving Stream
-*• liquid streams
Oi = Oxygen
E-33
-------
Appendix F
List of Equipment Affected by the NESHAP
-------
• ^::. -J, For Purposes 0f Determining Applicability to the NESHAP (Sabpart S)
Tfce Following System-. Inttindes...
Decker
Digester
Evaporator
Knotter
Oxygen delignification
Pulp washing
Screen
Steam stripper
Turpentine recover.
decker vents, filtrate tanks, and vacuum pumps*
continuous or batch digester, associated flash
tanks, chip steamers not using fresh steam, blow
heat recovery accumulators, relief gas
condensers, and prehydrolysis units preceding the
pulp washing system*
pre-evaporators, multi-effect evaporators,
concentrators, vacuum systems, associated
condensers, hotwells, and condensate streams*
knotter. knot drainer tanks, and ancillary tanks*
blow tank, washers, filtrate tanks, and interstage
pulp storage tanks*
vacuum drum washers, diffusion washers, rotary
pressure washers, horizontal belt filters,
intermediate stock chests, associated vacuum
pumps, filtrate tanks, foam breakers or tanks*
equipment in which oversized particles are
removed from the pulp slurry prior to bleaching
or papermaking system washed stock storage*
stripper column, associated stripper feed tanks.
condensers, heat exchangers, methano!
rectification equipment (which includes rectifiers.
condensers, decanters, and storage tanks)*
condensers, decanters, and storage tanks*
and any other equipment sen ing the same function
F-l
-------
-------
Appendix G
Pulp and Paper NESHAP Control Requirements
-------
-------
C
0)
Q.
a
(0
4-«
o
o-
0)
GC
C
o
o
CL
<
T.
C/5
LU
Z
a.
re
D.
•D
C
re
m
IK
$&
i
p
P-:.
t ^
te- •
:
fl3
K
C
_c
1
Cu
C
c
"S
e
c
•^
c:
~
'|!
1
h.
O
?s
1^
i|liu
1 ill 1
w 00^ "° =
!!>!!
ilf»i
U E n.£ 2i
0
u. 2
°"o
it 1
•28- 1
£> ° -r
u .H . =
t. ^ ^
o ^ c
» -. t<—
— - •C-
^ — •--
a'5 <
E o -
0 - I
^ — '~
^ >% "
— p c
'— ** H
o 3 |
1 fe E
0.7- ~
^ —
i J! t =
c '= '~ Zl
rr _ ^ ^
,^_ '-_ - ;
>. 2 ' Z =
p ^ - i ="
•^ - - ? -
i '=• =• c -
•?• c § c = -•
g J J S - |
— ^ C- *^ *** "j
5 < < t ._ -
S V U ^ - =
"5 = 3 5 = —
" ~ "^ CM — —
iS ? ? ^ 'E —
§llsi5
t
'E,
5 BO
c. c
n '_£.
.sl
ic/3
u
1
1.
2 ao
" c
11
c '=
o s
U E
u.
6 -A
1 i
c ••->
i j
2 —
^ V
£ ."
^ f
Sfi 3
u ^
5 i
>
— _?'
.£ 5
^5
~ ^:
^~ £i
i^~ s^r
— ~ ~
s ~Z , ~
'-1 Z s Z
rr ^ £ ~~
O -~ ~ -~
- Z C ^
~ — '— ~
= ~ > ~
5 ?- "' §
~ ~ s
— .^ "T~ J^
1 i 1 i
y- C ^ —
1 = 5 =
~0- 0 ~"^. ~
<-.<•=
- t, ~ E
5 i 2 i
— S — S
— _• T" . '
•^ ~ ~ —
c i 5 i
^ ^ "^ ec
s = I =
Sulfitc Pulping
• Calcium-based and
based pulping syste
Ammonium-based i
sodium-based pulpi
systems
S
;>,
~^
r~
|
p-
M
^
^
U
ffi
| Mechunicul Pulping
S
;>
s.
^
'd.
J.)
M
'.£
i
b
S
en
'E.
i
c
Z
^
>;
^
^
H
p-
=0
c
IE
^
o
S
en
| Secondary Fibci Pulpin
u
C
1
'£ oo
N
c o
c'e
31
..
Vi
v 1
of 10 ppmv o
oroform cont
C -C
O ^
11
5 E.
u o
S *"'
u -^
~
-
S —
" c
~- i?
•p-.
- 5-
~ ^
"5 .E
§1
1-5
£ 3
C C
C C
0 o
.E >
5 .i •/?
3^ u C.
C\ 0 C
Bleaching"
u
Q.
"*~bo
o.S
3 ^
il
u s
2-
'S ^
"5
•O O
f 1
Q 3
O £
o E
•§ 0.
— ' c
vq _
i«
o
^ Vi
--• ~
'= '§
"S °
~ a
X ••-
£. ~
5: 1
w ^r
S ~
- = v
oliE '"§
"•" > ^ "^
5 i? — ~
E ^ > o
• ~ v^_ ^ ?i
^ ^ ^ ^
IK ^
b =^- E
•1"| "i %
3cT E E
1 < 1 1
s-i'i i
£ B - i_ ra
— ">""!>
'J ™> y ^-*, Q
H "? •? = •?
K a < '1 <
Kraft Pulping Process
Condensates
I
o
u
.8
I
t3
C
— •£• =
I H
« - ^
c.
'5
o-
u
£
&
'•/t
c
o s:
•u
•a -.5
Hi
^€S
1 i u
§ k O •
^ V) ^ '
»0u c1
lii
S a.=
s S7
5
>
u
•o
ID
•o 6
P
II
as- o.
Ml P
.5 5.
o-o
C- 3
J £
o -*t
E "&•
iii
E 1 J
si §
•^: O —
EH:
5 ^~ '
— ^ "3
c-
•o
w -1
-J-. T"
>~p —
^ " ^ "Z —
& 2.
M-
p = •= .
Jli:
^^.Ct^
E =: < 5
TJ ^T — •£ -
U ~ O
Is* £
•i $5 ^
|!I1
o
c ^
£ E
>, ^ -
0 I
^r <2
u
Sill
s i:
P»E^
fc«^ =
3 g"S i
^O-So
a JB o •=
"811 a
•2 O.TJ
u ^ = s
s-g-
li
c
u "^5
C u
•il
2-S
= S
II
r; M
G-l
-------
Appendix H
Compliance Milestones Timeline for Existing Sources
-------
-------
C Q_
C/5
UJ
C/5
P CD
.E 0-
r= co
LL D_
C C
CD CD-^
(/) Q. Q)
C -= U
O -J k_
CD
o .^
CD 'c/J X
S 5 tbi
CO C
c. rc
< c
M- C
o c
G t3
E o
P ^
HI |l| .lir
Mi Hi
11
-* S
-K
§
I-I 5 J I I
S. -
E «
_ _
ji Hi H
cli
S S
'I «
S f
1 i
H-l
-------
CO.
<
.£ Q.
= *° "h
U.Q. §
"O "D 5
C C .C
CD CO •t^
«2 Q. §
g-o
.y c
H- £0
'
o
_
111
= Q- X
Q._ UJ
o. ro ^~-
< o
™
"o
E
i-
11]
it li
I
lit!
11 il
if il
i i-
J s-
il is 1
ii
'.I I
tl
c ;
11
i t-
1 1
II
-I
"I II'.
H-2
-------
C Q_
§<
"
>_
D> 0
.£ o.
= CO >>
u-Q- §
•D -a 5
c c .$
CU CD >~
S-o
en
— ._ r-
-Q > •=
o 2 £2
~ £l! 'x
D. _ UJ
C. ^ —
< C
«- C
c o
CH
O ^
~ -
"c —.
E o
*
l&l
•=- *>
£.=.>• ?•
1l-
o ^
"c ?
H-3
-------
CO.
<
» °-
E £ "§
•O-O-5
C C .C
CD CD •*-
r~ — ^
l£*
CD
0)
O
^ o v'
CD 'w O)
— •— c
s 11
— CL 'x
Q II I
C. CD —
< C.
"c o
i
ts I
if il
i
g
J •
12= fe^ C-
•"!_ § s I
-§"5 -£
1
J
I
ll
:-s I
l!
III
H-4
-------
C Q_
D<
wX
tC/D
P UJ
^ *"
.E Q.
:= CO >,
u-Q. §
-D -O ^
C C .g
CO CO +-
H- CU >-
' o o
CD 'to P3
Z '> •-
S 2«
~ Q. x
D __ LLJ
Q. ro • —
< C
H- C
O CO
o ^
E o
I
g 1.
ir ii
ll II
CL. O
|1 |_|
i §-
•f E
ir
If
i
I
H-5
-------
Appendix I
Summary of Effluent Limitations Guidelines for
Bleached Papergrade Kraft Mills
-------
2
0
TS
•O
O
o
(0
.2
m
•
m
n
Q.
X)
3
I
I
"o
a
0) TO
o
i.
£
(f.
c
O
v>
c
TO
0)
I
LU
(Q
E
to
c
tfi
T3
^
-3
:C
y
e
1
:r
~
.s
s
u
o
"S
'g
"5!
"e
=
=
?j
s
=.
£
u.
o
31
£
41
«
S
^f
_>,
•^
c
I
=
S
s
•~
^
^
5
"~
2
s
_
i
c
o
1
c
re
0.
^g^
u
re
CQ
1
^
O
c
u
c
E
u
c
C3
a.
j«
ca
<£
03
!
^
—
—
U.
Q
r-
^
u
1
re'
0.
^g
W
1>
cc
1C
T
~~
—
-•'-
if
^
r"
-^
1
s
_o
T^
C
u
U
re
O.
•C
re
o
CO
!
•—
"o
00
c
J5
JZ
u
c
u
3
E
u
re
o.
.e
u
CJ
CQ
1
^
_--
'_^
|
_C
v,
^J
c
u
3
E
U]
c
eg
a.
f
o
i)
CQ
:
^
—
_£
\J
U
C
_0
"S
0
5
c
u
3
E
u
c
re
a.
j]
re
0
03
r
^
—
•j
to
to
50
O
_o
"o
1
s
c
E
UJ
c
re
0.
^
Cl>
ffl
!
2
—
•j
CO
re
00
O
_o
u
^s
"r^
C
U
3
E
c
«
c_
JJJ
u
CO
u
03
1
^>
—
•_>
CO
00
0
_O
U
so
^
c
u
I
c
eg
*C
U
4>
ffl
i
^
—
^
"o.
0
L.
_o
w1-,
CN
C
U
1
c
eg
j=
u
Q>
CQ
i
^
Q
H
o
S
u
so
(N
C
E
u
«
j:
u
CO
CQ
!
^
1
loroca
o
e
§
E
u
c
eg
J=
u
re
o
CQ
1
^
_
C
u
.2
're
1
_o
_c
u
u
c
s
tLJ
c
eg
jjj
re
o>
CQ
|
^
^^
o
c
y
c.
1
.c
1
vq
••a-'
3
c
V
E
u
c
eg
J=
^
CQ
1
^
"5
0)
"S.
u
re
c
u
X
X
X
X
O
-o
V
i
«j
H&
-a
o
>
o
(^
.^.
s
o
li
~s
D
0
U
C
a>
Ef
eg
•g
v>
T3
CJ
.t
^
C
i
. o
jj -1-t
•Sa •
1"!
C. 5>
re o
«3 3
o «
^ I—
^ 5£
.~ '—
jr .;^
^ x
• "5 ^
2 £P ^
till
J £ .= c-
5 ^ r "5
V -~) -= "-J
^ CJ O *~-
F = "i -=
I Z- § =?
'— i E^'S
-TT ^ -— 3
c "c S ;J
^ :/•" O~"^~
^^' ' ~ ~— "
= ~ X -3
• — • ^ ^* "
b § ^ g
= '-s '— 2
~ '5 ro .=
"o ^ el 5
> on t? -O
i> •— -j
-" ^ ~ ^
= ,>. CO J5
3 <^
E U U 1-
•= o c «
= &.= «
~ "5 0 .-S
et> 2 *~ .«
™— ^ Sl"^
*" ?J VI "^
ci c c «
« "^ .2 **
ills
— re r; ~
W5 *™ ~ *™ ' (J
C ~* 3
re 5P c "O
w K „ o
C VI J^ ^ |
' Z E ,,
j — LL: "
^3
/ =' X Z
C
a>
Ef
eg
J=
u
V)
T3
CJ
.t
^
••*
g
L«
o
0
J, .
T3
o
1
1
TO
o
ap
•J-.
X
•J".
E -
^ "E.
r "5
JZ O
o ^
"> H
,— ~"
~ CJj
aC'5
.E ^*
™ "H
^ c.
~"E
X Tr
"^ ;i
cc
^ O
^ 5
||
; i §
t? -o
1>
~ ^
> CO ^_f
g =
-— «
u .t:
.•= -
S o
?i
xz
'
-
i«
fa
>*•»• *•
— i ^8
i- *~*
•Q. *•
z
v;
0
£f
. "
• ^
£
v:
- *
; s
-' • C
o
^
w
' s
"e.
r
£:
o .
^:
1
4»
"n
3
"
-<
Ix
2
<
^>
—
c
2
*r*
~
Z..
~
C
z
S
x
w
?3
S
^x
so
3<
^1
J^
BJ;
-— Tl
£ «
3 2
-*ws
s
i
!=
U
3
E
u
"3
c
iZ
so
i
(N
ITl
O
^
.S3
^j
o
—
SO
Jjt.-
"s/J
!£
=
j2
o
I3
13
•5
J
-3
oa
'x
u
L.
o
If
<
ca
1
1
c
re
a.
r*
U
S
ca
z
so
S
—
*.
SO
_^
^'
T
^
ul
SO
•5
.1
•3
_c
00
V3
'x
^
V3
00
a.
"
c:
3
E
w
"re
c
iZ
50
^
CC
o
(N
d
SO
~SO
n
^•]
—
s/.
• s
~£
r-
°
ct dischargers
.2
•5
a
^
00
0.
oo
Z
c
u
E
u
c
re
a.
JM
U
ffl
Z
SO
J*P
-r
sc
— '
s/.
^^
^r.
.—
v^
L.
reel discharge
•3
c
CD
C
o
IS
oo
on
e_
— '
"5.
"o
_o
_c
i
™
SO
_c
«3
"c
0
c.
— -
-=
o
U—
at,
b 5
w "3
*— y;
b! J
is
li
L- -p
O ^
ll
l_r O
< B
zz
1-1
-------
Appendix J
Compliance Checklists
NOTE Tne following fifteen checklists provide only a summary of the requirements o*
tne standards and do not supersede the standards in any manner. Compliance
determinations are based on the standards published in the Code of Federal
-------
-------
Summary of Pulping System Vent Inspection Checklists
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The table below explains which inspection checklists you should use for determining compliance
with the pulping system vent requirements:
If you are complying Using this control device or Then use the Starting on
with this emission technique... ' following page
standard ... checklistsa'b... number . . .
Pulping systems at A thermal oxidizer 2 5
kraft, soda, and semi-
chemical processes ^ boiler, lime kiln, or recovery 3 7
furnace in which the vent gases are
introduced with the primary fuel or
into the flame zone
A boiler or recovery furnace with a 3 7
heat inp'.it rate greater than 44
megawatts in which the vent gases
are introduced with the combustion
air
An\ other control device 4 8
Pulping systems at "1 r.e clean condensate alternative 5 10
kraft processes
Pulping systems at A gas scrubber 7 13
sulfite processes
Any control device other than a gas 8 15
scrubber
aChecklist 1 applies only if the extended compliance period is used for high volume, low
concentration (HVLC) pulping system vents at kraft mills.
bChecklist 9 applies to all vent control options. '
-------
Summary of Bleaching System Vent Inspection Checklists
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The table below explains which inspection checklists you should use for determining compliance
with the bleaching system vent requirements for total chlorinated HAP.
If you are using this device ... Then use the following Starting on page
checklists1*... number...
A gas scrubber 7 13
Any other control device or technique 8 15
"Checklist 6 applies only if the extended compliance period is used for bleaching systems
participating in the Voluntary Advanced Technologies Incentives Program.
bChecklist 9 applies to all vent control options.
-------
Checklists for Kraft Pulping System Condensate Inspections
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The table below explains which inspection checklists you should use for determining compliance
with the pulping system condensate requirements.
If you are complying with this control device or Then use the following Starting on page
using this technique to comply with the checklists"-15.. number...
standards ...
A steam stripper
An open biological treatment system
Recycling to a controlled piece of pulping
system process equipment
Any other control device
11
12
13
14
23
25
28
29
"Checklist 10 applies orJ> if the volume reduction options are used to segregate regulated kraft
pulping system condense streams for treatment.
bChecklis: 15 applies to all condensate control options.
-------
Checklist 1:
Kraft Pulping Vent Extended Compliance Periods (§63.440(d)(l))
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The questions in the tables below are applicable to existing high volume, low concentration
(HVLC) pulping system vents that receive the extended compliance period (April 17,2006). The
questions are also applicable to HVLC pulping system vents that achieve compliance using the
Clean Condensate Alternative. A "no" response to any question in this checklist means
noncompliance with the HVLC pulping system standards.
A, Recordkeeping and Reporting Requirements Comments
1. Did you submit an initial control strategy report D Yes D No
with your Notification of Compliance Status
Report 1§63.9fh>. §63.455(b)
2. For verits that have not achieved compliance, do °Yes a NO
you update the control strategy report every two
years'? §63.45 5
3. Do vou maintain records for 5 vears? *63.]0(bi D Yes D No
-------
Checklist 2:
Requirements for Thermal Oxidizers (§63.443(d)(l) through (d)(3))
Facility Name:
Facility Location: •
Facility TRI ID #:
Inspector:
Date:
Note: A "no" response to any question in this checklist means noncompliance with the pulping
system vent standards.
WU)iiit«riiig and Inspection Requireim&nts
Comments
1. Do you measure the firebox temperature, the
temperature in the ductwork immediately
downstream of the firebox (before any heat
exchange occurs), or the outlet total HAP
concentration during the periods that the device is
being used to comply with the pulping vent
standards? §63.453(bt
D Yes D No
Do you check the zero (low-level) and high-level
calibration drifts at least once per day in
accordance with your continuous monitoring
system (CMS) performance evaluation test plan?
Yes
!No
B. Record keeping and Reporting Requirements
Comments
Did you submit in your Notification of
Compliance Statu- Report all of the following:
• results of the initial performance test or
design evaluation? §63.9(h)
• documentation to establish the minimum
firebox or ductwork temperature or total
HAP concentration monitoring parameter
value, monitoring frequency, and
averaging time? §63.453(n)
• results of CMS performance evaluation?
§63.10(e)(2)(i)
- Yes
n Yes
"No
No
D Yes D No
(Continued)
-------
Checklist 2: (Concluded)
Requirements for Thermal Oxidizers (§63.443(d)(l) thro
Do you keep records of the firebox or ductwork
temperature or outlet total HAP concentration
measurements? §63. W(c)
Yes D No
3. Do you submit in your Excess Emission and
Summary Reports all of the following
§63.10(e)
• all monitoring data for all operating days
or blocks when the average firebox or
ductwork temperature is lower than the
minimum temperature established during
the initial or subsequent performance
tests?
• identification of all operating days or
blocks when insufficient monitoring
parameter data were collected0
Excess emissions allowances (including periods of
monitoring parameter deviations and periods \\ hen the
thermal oxidizer was inoperable} during a semi-annual
reporting period are 1 percent for LVHC system vents
and 4 percent for H\"LC and combined HI 'LC and
LVHC system venu. The excess emissions do not
include periods of startup, shutdown, and malfunction.
$63.4-43
Yes D No
D Yes D No
4. Do vou maintain records for 5 vears? $63 l
n Yes D No
-------
Checklist 3:
Requirements for Boilers, Lime Kilns, and Recovery Furnaces (§63.443(dX4))
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector: '
Date:
Note: A "no" response to any question in this checklist means noncompliance with the pulping
system vent standards.
A. Recordkceping and Reporting Requirements Comments ,
1. Did you submit results of the design evaluation in DYes DN°
your Notification of Compliance Status
Report °o6
2. Do you identify in your Excess Emission and a Yes
Summary Reports all of the operating days or
blocks when the boiler, lime kiln, or recover-
furnace was not operable? $63. lOle)
Excess emission* a:!uv,'ances f including periods oj
monitoring parameter deviations and periods when th^
combustion device v\as inoperable) during a semi-
annual reporting period are ] percent for L VHC
system vents and -4 pcrccn: lor Hl'LC and combined
HI 'LC and L > 7/C s\sier>: \\ ni*. The excess emission*
do not include per iuds oj start up. shutdown, and
mall arid: on. §b3 4~3u
Do vou maintain records for 5 Years'? $63. 1Q< ~. c Yes a No
-------
Checklist 4:
Requirements for Other Kraft Pulping System Vent Control Devices (§63.443(d)(l))
Facility Name:
Facility Location:
Facility TRI ID #: ._
Inspector:
Date; .
Note: A "no" response to any question in this checklist means noncompliance with the pulping
system vent standards.
A. Moaitorfng and inspectioa Requtremeafe Comments
1. Did you get approval from the Administrator for D Yes D No
the parameters to be monitored and the parameter
value(s)? §63.453(n>
Did you install a continuous monitoring system
(CMS) to measure approved monitoring
parameters? §63.453
Yes D No
Do you measure the approved monitoring
parameter(s) during the periods that the device is
being used to comply with the pulping vent
standards? §63.453tb>
c Yes D No
Do you check the zero (low-level) and high-level
calibration drills at least once per day in
accordance with your continuous monitoring
system (CMS) performance evaluation test plan?
LJ Yes n No
Recordkeeping and Reporting Requirements
Comments
Did you submit all of the following in your
Notification of Compliance Status Report:
• results of the initial performance test or
design evaluation? §63.9(h)
D Yes a No
documentation to establish the monitoring n Yes D No
parameter value(s), monitoring frequency,
and averaging time? §63.453(n)
(Continued)
-------
Checklist 4: (Concluded)
Requirements for Other Kraft Pulping System Vent Control Devices (§63.443(d)(l))
"«"•—» ^^k ---- -~ ----- .... .ff^.ffffffff,^^, w^, •Utt-w- —f •Ml " ffff^tffffffffffff^ffff.V.f- ~ — «A
B* B^or^k«epiagaa^RqK>rtipg Requirements
• results of CMS performance evaluation? DYes
2. Do you keep records of the monitoring parameter DYes QNo
measurements? § 63. 10(c)
3. Do you submit in your Excess Emission and
Summary Reports all of the following:
§63.10(e)
all monitoring data for all operating days ' D Yes D No
or blocks when the monitoring
parameter(s) are outside the value(s) or
range* s) established during the initial or
subsequent performance tests?
identification of all operating days or • ~ Yes DN°
s blocks when insufficient monitoring
; parameter data were collected0
Excess emissions a!!o~'.\\:nces (including periods of
monitoring paramett. ' d^'.'iations and periods when the
control device was inoperable . during a semi-annual
reporting period u>\ / ;\ >v. '.>;.' U»' LVHC system vents
and 4 perccn: ^^- 1", 7 -: ./>:./ combined HI 'LC and
Ll'HC system ven:.- Ti\ L.CCI. . emissions do not
include periods oj sit;1'::;?'' shittdown. and malfunain''.
p63-t-3>e>
4. Do you maintain records for 5 years? §63.10ib, D Yes D No
-------
Checklist 5:
Requirements for the Clean Condensate Alternative (§63.447)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The questions below are applicable to HVLC pulping system vents that achieve compliance
using the Clean Condensate Alternative (CCA). A "no" response to any question in this
checklist means noncompliance with the HVLC pulping system standards.
A. Monitoring and Inspection Requirements
Comments
1. Did you install a continuous monitoring system
(CMS) to measure approved monitoring
parameters? §63.447'(b)
n Yes a No
2.
Did you get approval from the Administrator for
the parameters to be monitored and the parameter
value(s)0 t6
a Yes D No
Do you measure the approved monitoring
parameter!s') during the periods which the CCA
is being used to demonstrate compliance with the
HYLC pulping system vent requirements?
^ Yes n No
Do \ou check the zero (low-level) and high-leve!
calibration drift- at least once per day in
accordance with your continuous monitoring
system (CMS) performance evaluation test plan?
$63.8(0(6)
c Yes Hi No
|B, Recordkeeping and Reporting Requirements
Comments
1. Did you submit an initial control strategy report?
§63.447 (g)
D Yes D No
2. Did you update the control strategy report every
two years? §63.447(g)
a Yes D No
(Continued)
10
-------
Checklists: (Concluded)
Requirements for the Clean Condensate Alternative (§63.447)
B. RecordkeepiagapdReportiggltettoiremcBts " . Coauneats
3. Did you report the rationale, calculations, test DYes °No
procedures, and data documentation used to
demonstrate compliance using the CCA?
§63.447 (h)
4. Did you submit in your Notification of
Compliance Status Report all of the following:
results of the initial performance test? D Yes D No
§63.9(h)
documentation to establish the monitoring D Yes D No
parameter value(s). monitoring frequency.
and averagi:;.; time? §63.453(n)
results of CMS performance evaluation? D Yes - No
§63.IQi <;:
5. Do you submit in your Excess Emission and
'Summary Reports al! of the following:
.?63 IQtei
all monitoring data for all operating days
or blocks when the monitoring
parameter s > .::>: outside the value(s) or
ranges i e>:^; ;;shed during the initial or
subsequent performance tests9
idcntifcatio:, cf all operating days or
blocks \vhe:~. insufficient monitoring
parameter da:.: were collected?
6. Do you maintain records for 5 years? §63.1 Oft) D Yes n No
11
-------
Checklist 6:
Bleaching System Vent Extended Compliance Periods (§63.440(d»
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The questions in the tables below are applicable to existing bleaching systems that receive the
extended compliance period (April 15,2004) by limiting the application rates of chlorine and
hypochlorite. A "no" response to any question in this checklist means noncompliance with the
bleaching systems standards.
A. Monitoring and Inspection Requirements Comments
1. Do you monitor the average daily application
rates (kilograms bleaching agent per megagram
of oven-dried pulp) of chlorine and hypochlorite?
§63.45 3tei
D Yes a No
JS. Recordkeeping and Reporting Requirements
Comments
1. Do you record the average daily application rates
of chlorine .and hypochlorite? §63.454(ci
c-Yes D No
2.
Did you submit an initial control strategy report
with your Notification of Compliance Status
63 9ih>. s6? 4:5
-------
Checklist 7:
Requirements for Gas Scrubbers (§63.444(c), §63.445(c))
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The questions in the table below apply to gas scrubbers used to control HAP emissions from
bleaching system and sulfite pulping system vents. Gas scrubbers have the option of monitoring
either operating parameters (question 1 .a.) or outlet concentration (question 1 .b.)- A "no"'
response to any question in this checklist means noncompliance with the bleaching or sulfite
pulping systems standards.
A. Monitoring and Inspection Requirements Comments
1 .a Do you measure the following parameters during
the periods that the gas scrubber is being used to
comply with the applicable standard:
§634?3fc'
• pH or the oxidation'reduction potential of D Yes c NO
the gas scrubber effluent?
gas scrubber vent gas inlet flow rate? D Yes D No
gas scrubber liquid influent flow rate1? D Yes - N"°
l.b Do \ ou measure the gas scrubber outlet c.\es o No
concentration dv.rir,-' the periods that the gas
scrubber is be in-, used to comply with the
applicable standard?
$63->:3i~
Note: Gas scnihbc'\<
-------
Checklist?: (Concluded)
Requirements for Gas Scrubbers (§63.444(c), §63.445(c»
Do vou maim.;::, records for 5 years0 §63.lO
• all monitoring data for all operating days D Yes D ^:°
or blocks when the monitoring
parameter s) are outside the value(s) or
range(s) established during the initial or
subsequent performance tests?
• identification of all operating days or a Yes • o No
blocks when insufficient monitoring
parameter data were collected? -
14
-------
Checklist 8:
Requirements for Other Sulfite Pulping and Bleaching System Vent Control Devices
(§63.444(c) and §63.445(c))
Facility Name:
Facility Location-:
Facility TRI ID #:
Inspector:
Date:
A "no" response to any question in this checklist means noncompliance with the bleaching
system or sulfite pulping systems standards.
A. Monitoring and Inspection Requirements
JL
i.
Comments
1 . Did you get approval from the Administrator for D Yes n No
the parameters to be monitored and the parameter
value(S)? §63.4?3'n.
Did you install a continuous monitoring system
(CMS ) to measure approved monitoring
parameter-0 .-v -i3(m:
Yes D No
Do vou measure th^ approved monitoring D Yes
v - - w
parameter! s i dur;:v the periods that the device is
being used to comr:; \\ith the applicable
standard'? •:>': -.-.•- >
Do you check the z-.~ • i"\\-!eve!') and high-level a Yes c No
calibration dri*:-. a: ie«.-; once per day in
accordance ui;h > our continuous monitoring
s}'stem (CM> ;vr;,c::,.,:we evaluation test plan0
§63 tic>i6,
Recordkeeping and Reporting Requirements
Comments
Did you submit in your Notification of
Compliance Status Report all of the following:
• results of the initial performance test or
design evaluation? §63.9(h>
D Yes
No
documentation to establish the monitoring D Yes D No
parameter value(s). monitoring frequency,
and averaging time? §63.453(n)
(Continued)
15
-------
Checklists: (Concluded)
Requirements for Other Sulfite Pulping and Bleaching System Vent Control Devices
(§63.444(c) and §63.445(c))
results of CMS performance evaluation? DYes DN°
2. Do you submit in your Excess Emission and
Summary Reports all of the following:
§63.W(e)
• all monitoring data for all operating days D Yes D N°
or blocks when the monitoring
parameter(s) are outside the value(s) or
range(s) established during the initial or
subsequent performance tests?
• identification of all operating days or D Yes D No
blocks when insufficient monitoring
parameter data were collected?
3. Do you maintain records for 5 years0 §63.10(b> D Yes °N°
16
-------
Checklist 9:
Requirements for Enclosures and Closed-vent Systems (All Vent Control Options)
Facility Name: .
Facility Location:
Facility TRI ID #:
• Inspector:
Date: .
A "no" response to any question in this checklist means noncompliance with the closed-vent
system standards.
A. Monitoring and I us pec tionReqiurem«its . Comments
1. Do you visually inspect each enclosure opening D Yes D No
every 30 days to ensure that the opening is
maintained in the closed position and sealed,
except when necessary for sampling, inspection,
maintenance, or repair?? ;^.? 450(bj, §63.453(kj(lj
Note: Enclosure openings that were not closed during
the initial or subsequent performance tests are not
required to be doted ur.u seuL\i
2. Do you visualh in.--pi.-ct the closed-vent system D Yes D No
(including duel v^.;K. piping, enclosures, and
connections to covers) ever- 30 days for visible
evidence of defect . . '•.•" -?}>ki<2i
For closed-ver. '..-•;<.:::: i or portions of systems) n Yes c
that are operated unJvv positive pressure, do you
demonstrate annually that no detectable leaks
exist? ff.' ~?5'~>-..
4. Do you demonstrate annually that each enclosure DYes DNo
is maintained at negct:\ e pressure? §63.453(kj(4)
5. Do you visual!) inspect the bypass line valve or n Yes c-No
closure mechanism e\ ery 30 days to ensure the
valve is maintained in the closed position?
§63.453(k)(5)
(Continued)
17
-------
Checklist 9:
Requirements for Enclosures and Closed-vent Systems (All Vent Control Options)
,A.
6. If your closed-vent system has bypass lines that
• could divert a vent stream away from the control
device, have you done one of the following:
• used a flow indicator that takes a reading D Yes a No
at least every 15 minutes? §63.450(d)(l)
• for non-computer controlled bypass line DYes nNo
. valves, secured the bypass line valve in
the closed position with a car-seal or a
seal placed on the valve in such a way that
the valve cannot be opened without
breaking the seal0 §63.450(d}(2)
7. For any defects identified during the inspections:
§63.453(k)(6}
• did you make the first effort of repair D Yes D No
within 5 calendar days after detection?
• did you complete the repair within 15 QYes nNo
calendar days'?
8. Recordkeeping and Reporting Requirements Comments
1. For each enclosure opening, do you have all of
the following records
§63.454tb>
date of visual inspections'? °Yes oNo
the enclosure type and identification? - D Yes n No
• position of opening (i.e.. open or closed D Yes D No
and sealed)'?
• results of negative pressure tests? DYes oNo
• the nature of any defects and method of D Yes D No
detection (i.e.. visual inspection or
instrument detection)?
(Continued)
18
-------
Checklist 9:
Requirements for Enclosures and Closed-vent Systems (All Vent Control Options)
• the cUte the defect was detected and the DYes QNo
date of each attempt to repair the defect?
• repair methods applied in each attempt to °Yes °N°
repair the defect?
• the reason for delay if the defect was not °Yes DNO
repaired within 15 days after discovery?
• the date of successful repair of the defect . °Yes oNo
if the repair was not completed within 15
days after discovery?
For each closed-vent system, do you have all of
the following records:
§63.4 541 hi
date of visual inspections? D Yes c No
the closed-vent system type and o.Yes n No
identification0
results of leak detection tests (only for D Yes D No
systems or portions of system operated
under positive pressure)0
• the natu-x of any defects or leak and G Yes n ^°
method of de'.-jction (i.e.. visual
inspection or instrument detection)?
• the date the defect or leak was detected c Yes D ^'°
and the date of each attempt to repair the
defect0
• repair methods applied in each attempt to D Yes D N°
repair the defect or leak?
• the reason for delay if the defect or. leak D Yes D No
was not repaired within 15 days after
discovery?
(Continued)
19
-------
Checklist 9: (Concluded)
Requirements for Enclosures and Closed-vent Systems (AM Vent Control Options)
B. RecordkeepiagiittdR^rtingReguirt^ite , ' Commits
the date of successful repair of the defect D Yes D No
or leak if the repair was not completed
within 15 days after discovery?
3. For each bypass line valve that is not computer-
controlled, do you have all of the following
records:
§63.4'54(b)
• date of visual inspections? D Yes a No
condition of any valve seals? DYes DNo
• position of the bypass line valve? nYes .DNo
• duration of bypass line valve opening? n Yes ° No
4. For each bypass line valve that is computer-
controlled, do you have all of the following
records:
15 minute readings9 D Yes D No
• times and durations of periods when the D Yes • o No
flow indicator is not operating0
• times and durations of periods when the c Yes o No
vent stream is diverted from the control
device?
5. Do you maintain records for 5 years? $63.10(bj(l) D Yes D No •
20
-------
Checklist 10:
Requirements for Condensate Volume Redaction Options (§63.446(c))
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
A "no" response to any question in this checklist means noncompliance with the kraft pulping
system condensate standards.
A.
ion Re<|ui.reroMagts
Comments
1. Did you get approval from the Administrator for D Yes D No
the parameters to be monitored and the parameter
value(s)? $63 -!53^^: e^;;:inuous monitoring
system (CMS) performanee evaluation test plan1?
$6 3.8'c, 16,
c Yes a No
Recordkeeping and Reporting Requirements
Comments
Did you submit in your Notification of
Compliance Status Report all of the following:
• results of the initial performance test or
design evaluation? §63.9(h>
• documentation to establish the monitoring
parameter value(s). monitoring frequency,
and averaging time? §63.453(nj
(Continued)
n Yes a No
a Yes a No
21
-------
Checklist 10: (Concluded)
Requirements for Condensate Volume Reduction Options (§63.446(c))
results of CMS performance evaluation?
§63.10(e)(2)(i)
oYes DNo
Do you submit in your Excess Emission and
Summary Reports all of the following:
§63.10(e)
• all monitoring data for all operating days
or blocks when the monitoring
parameter(s) are outside the value(s) or
range(s) established during the initial or
subsequent performance tests?
• identification of all operating days or
blocks when insufficient monitoring
parameter data were collected?
D Yes D No
n Yes D No
Do you maintain records for 5 years? §63 10'b.
Yes D No
22
-------
Checklist 11:
Requirements for Steam Strippers (§63.446(e)(2) through (e)(5))
Facility Name: - -
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Steam strippers have the option of monitoring either operating parameters (question l.a) or outlet
concentration (question l.b). A "no" response to any question in this checklist means
noncompliance with the kraft pulping system condensate standards.
A. IMftttttorgig sad Inspection Requirements ^ Comments
l.a. Do you measure the following parameters during
the periods that the steam stripper is removing
HAP from pulping system condensates:
§63.453 (gi
• process wastewater feed rate0 D Yes n No
steam feed rate? c Yes DNO
• process wastewater column feed D Yes D N°
temperature?
l.b. Do you measure the steam stripper outlet ° Yes ONO
methanol concentrate:, during the periods that
the steam stripper i- removing HAP from
pulping system condensate^?
§63.-!i3:h,
Xotc: Steam stripper ou'\ i methanol concentration
can be measured as a': •:••; 'ion to measuring th^
parameters listed in question l.a.
2. Do you check the zero (low-level) and high-level D Yes a No
calibration drifts of the steam stripper
continuous monitoring system (CMS) at least
once per day in accordance with your CMS
performance evaluation test plan? §63.8(c>(6>
(Continued)
23
-------
Checklist 11: (Concluded)
Requirements for Steam Strippers (§63.446(e)(2) through (e)(5»
& l^c^rdlMeputg and Reporting Requireiaeitttos Comments
1 . Did you submit all of the following in your
Notification of Compliance Status Report:
results of the initial performance test? " DYes QNo
§63.9(h) -
documentation used to establish the DYes °No
monitoring parameter values? §63.453(n)
results of CMS performance evaluation? D Yes D No
2. Do you submit in your Excess Emission and
Summary Reports all of the following:
§63.10(e),§63.446igi
• all monitoring data for all operating days D Yes D No
or blocks when the monitoring
parameters ) are outside the value(s > or
range(s) established during the initial or
subsequent performance tests'?
• identification of all operating days or D Yes oNo
blocks when insufficient monitoring
parameter data were collected'7
The excess emission allowances for steam strippers is
10 percent. The excess emissions include periods of
monitoring parameter deviations, periods when the
steam stripper was inoperable, and periods of startup.
shutdown, and malfunction. §63.443(e)
3. Do you maintain records for 5 years? §63.1 Of hi D Yes ° No
24
-------
Checklist 12:
Requirements for Open Biological Treatment Systems (§63.446(e)(2))
Facility Name; .. -
Facility Location:
Facility TRI ID £
Inspector:
Date:
Open biological treatment systems have the option of monitoring either the parameters specified
in the NESHAP or site-specific parameters (see question 1). A "no" response to any question in
this checklist means noncompliance with the kraft pulping system condensate standards.
A. Monitoring aad Inspection Requirements
1. Do you measure the following parameters during
the periods that the open biological treatment
system is removing HAP from pulping system
condensates:
§63453(j,<1.>
composite daily sample of composite . c Yes DNo
BOD5 outle; concentration sample0
• mixed liquor volatile suspended solids? - Yes D No
• horsepower of aerator unit(s)? c Yes D No
inlet liquid flow -Yes n No
liquid ;crnpera:ure c Ygs °*o
daily inlet and outlet grab samples from c Yes D No
each biological treatment unit (only if
procedure 3 in Appendix C of Pan 63 is
used to demonstrate compliance)
Note: Site-specific monitoring parameters can be
measured as an option to measuring the parameters
listed above.
2. If procedure 3 in Appendix C of Part 63 is used DYes DNo
to demonstrate compliance, do you store the
grab samples for five days at a maximum
temperature of 4°C (40°F)? §63.457(n)
(Continued)
25
-------
Checklist 12:
Requirements for Open Biological Treatment Systems (§63.446(e)(2))
.
Comments V
3 . Do you check the zero (low-level) and high-level D Yes n No
calibration drifts of the open biological
treatment system continuous monitoring system
(CMS) at least once per day in accordance with
your CMS performance evaluation test plan?
§63.8(c)(6) _ . _ | _ •
B. Recardkeeping and Reporting Rcqulrriaents Comments
I . Did you submit all of the following in your
Notification of Compliance Status Report:
results of the initial performance test? . D Yes DN<>
documentation to establish the D Yes n No
monitoring parameter value(s).
monitoring frequency, and averaging
time0 §63.->53(2)(i)
2. Did you prepare a written record of the specific D Yes , a No
conditions that would expose a worker to
dangerous, hazardous, or otherwise unsafe
conditions when conducting a performance test1?
§63.454ie>
3. Do you prepare a written record specifying the D Yes D No
results of all performance tests conducted in
response to a monitoring parameter deviation?
§63.454(fj
(Continued)
26
-------
Checklist 12: (Concluded)
Requirements for Open Biological Treatment Systems (§63.446(e)(2))
4. If you used .the results of a performance test, °Yes a NO
conducted in response to a monitoring parameter
deviation, to revise the approved ranges or
values of monitoring parameters, did you submit
an initial notification of the performance test as
soon as practicable, but no later than 15 days,
before the test was scheduled?
§63.455(e)
5. Do you notify the Administrator as soon as ' °Yes oNo
practicable, but within 24 hours, of the onset of
the dangerous, hazardous, or otherwise unsafe
conditions and specify the reasons that the
compliance determination cannot be made?
t63 455(ft
6. Do you maintain record? for 5 years? §63. lOibi c Yes Q No
27
-------
Checklist 13:
Requirements for Recycling Kraft Pulping Process Condensate to Controlled Pulping
System Process Equipment (§63.446(e)(l)) ,
Facility Name:
Facility Location:
Facility TRI ID #: ^
Inspector:
Date: '
There are no monitoring requirements for mills using the recycle option to treat condensates. A
"no" response to any question in this checklist means noncompliance with the kraft pulping
system condensate standards.
B. Recordkceping and Reportiag Requirements Comments
1. Did you submit the results of the design DYes DNo
evaluation in your Notification of Compliance
Status Report? §63.9(hi
28
-------
Checklist 14:
Requirements for Other Kraft Pilping Process Condensate Control Devices
(§63.446(e)(3),(4),and(5))
Facility Name:
Facility Location:
Facility TR1 ID #:
Inspector:
Date:
A "no" response to any question in this checklist means noncompliance with the kraft pulping
system condensate standards.
A. Monitoring and InspectioaUcQuiremeats
Comments
1. Did you get approval from the Administrator for
the parameters to be monitored and the parameter
value(s)0 S*3.453
Yes D No
Did you install a continuous monitoring system
(CMS t to measure approved parameters?
§63 4?3
-------
Checklist 14: (Concluded)
Requirements for Other Kraft Pulping Process Condensate Control Devices
(§63.446(e)(3),(4),and(5))
results of CMS performance evaluation? D Yes D No
§63.10(e)(2)(i)
2. Do you submit in your Excess Emission and
Summary Reports all of the following:
§63.10(e),§63.446(g)
• all monitoring data for all operating days D Yes D No
or blocks when the monitoring
parameter(s) are outside the value(s) or
range(s) established during the initial or
subsequent performance tests?
identification of all operating days or nYes DNo
blocks when insufficient monitoring
parameter data were collected?
The excess emission allowances for control devices
other than open biological treatment systems is 10
perceni. The excess emissions include periods of
monitoring parameter deviations, periods when the
control device was inoperable, and periods of startup.
shutdown and malfunction. §63.443(e>
3. Do you maintain records for 5 years? §63.lOt'bi c Yes D No
30
-------
Checklist 15:
Requirements for Closed Collection Systems (All Condensate Control Options)
Facility Name:
Facility Location: .
Facility TRI ID fc
Inspector:
Date: •
A "no" response to any question in this checklist means noncompliance with the kraft pulping
system condensate standards..'
A.Monitorlpg and Inspection Requirements
1. Do you visually inspect each closed collection D Yes D No
system even,' 30 days for evidence of defects?
§63.4 5 3(1) (1,1 '
2. For each condensate tank:
§63.446idiCir., jmi .•;/;. /63 453(l)(l)
• do you demonstrate annually that no c Yes ONO
detectable leaks exist?
• do you \ erify that each tank opening is D Yes G No
maintained in a closed, sealed position0
Note: Tank* ma) he opened for condensate sampling
or removal, or jor diuipm^nt inspection, maintenance.
or repair.
For drains controlled by water seals, do you c Yes G ^
verif} that ti'.e appropriate liquid levels are being
maintained and Jo you inspect for any other
defects that could reduce the water seal control
effectiveness0 §63.453(l>(l), §63.964(a)(l)(i)(A)
4. For drains controlled using a closure device, do D Yes G No
you verify' that the closure device is in place and
that there are no defects in the closure device?
§63.453(1^(1^ §63 964(a)(])(i)(B)
5. For junction boxes, do you verify that the closure D Yes D No
device(s) is in place and that there are no defects
in the closure device0 f63. 453(1)(1), §63.964(a)(l)(ii)
(Continued)
31
-------
Checklist 15:
Requirements for Closed Collection Systems (All Condensate Control Options)
ring and InagefctloH
Comments
"For unburied portions of the closed collection
system, do you visually inspect the system to
verify that all closure devices are in place and that
there are no defects? §63.453(l)(2), §63.964(a)(l)(iii)
o Yes o No
For any defects identified during the inspections:
§63.453(1) (3), §63.964(b)
• did you make the first effort of repair
within 5 calendar days after detection?
• did you complete the repair within 15
calendar days?
a Yes D No
D Yes o No
Recordkeeping and Reporting Requirements
Comments
For each closed collection system, do you have
all of the following records:
$63.45-1/hi
• date of \ isual inspections?
• the nature of the defect and method of
detection i i.e.. visual inspection or
instrument detectionV?
the dak the defect was detected and the
date of each attempt to repair the defect0
repair method-, applied in each attempt to
repair the defect?
• the reason for delay if the defect was not
repaired \vithin 15 days after discovery?
• the date of successful repair of the defect
if the repair was not completed within 15
days after discovery?
• repair methods applied in each attempt to
repair the defect or leak?
(Continued)
Yes D No
Yes D No
a Yes o No
c Yes D No
D Yes D No
n Yes a No
D Yes a No
32
-------
Checklist 15: (Concluded)
Requirements for Closed Collection Systems (All Condensate Control Options)
the reason for delay if the defect or leak D Yes a No
was not repaired within 15 days after
discovery?
the date of successful repair of the defect o Yes a NO
or leak if the repair was not completed
within 15 days after discovery?
duration of bypass line valve opening? D Yes D No
33
-------
1. REPORT NO.
EPA-456/R-01-002
4. TITLE AND SUBTITLE
Pulp and Bleaching System
Industry: A Plain Englis
TECHNICAL REPORT DATA
(please rtad instructions on the reverse before completing)
2.
NESHAP for the Pulp and Paper
h Description
7. AUTHORfS)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENTS ACCESSION NO.
S. REPORT DATE
September 2001
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NC.
10203A
11. CONTRACT/GRANT NO.
68-D6-0011
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
National emission standards for hazardous air pollutants (NESHAP) were
promulgated for the pulp and paper industry under authority of Section
112 (d) of the Clean Air Act as amended in 1990. This document provides
plain English descriptions of the pulping and bleaching processes, the
requirements of the NESKA? (Subpart S) , the scope of effluent limitations
guidelines and standards and additional references and sources of
information about pulr and paper mills.
5. ..I.:?,..-...-....-...
• ~" "•• • " • ...... —
: IDEI.'TI TIERS .'OrEN ENDED TERMS c. COSATI Fiel
d/C-rcur
Air pollution Air pollution 13b
MACT KACT
NESHAP subparts NESHAP subparts
Pulp and paper mi lit- Pulp and paper mills
Hazardous air pollutant Hazardous air pollutant
Pulp Mills Pulp Mills
Paper mills Paper mills
16. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report, 21. KG. OF PAGES
UNCLASSIFIED 157
20. SECURITY CLASS (This Page) 22 PRICE
UNCLASSIFIED
EPA Form 2220-1 (Rev. a-77) PREVIOUS EDITION IS OBSOLETE
------- |