PULP AND PAPER CHEMICAL RECOVERY COMBUSTION SOURCES

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

40 CFR PART 63 SUBPART MM

INSPECTOR CHECKLIST

NOVEMBER 2003

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Note: This checklist is a tool to evaluate compliance with the Pulp and Paper NESHAP. It does
not contain an exhaustive list or description of all federal environmental regulations that may
apply to a pulp and paper facility. Additionally, some facilities have separate standards as
outlined in the Federal Register. Check the regulations for applicable rules for the
Weyerhaeuser Paper Company's Cosmopolis, Washington facility.

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TABLE OF CONTENTS

TOPIC	PAGE

LIST 01 APPENDICES	 4

INTRODUCTION	 6

TERMS	 6

STAGES OF THE INSPECTION	 7

APPROACH	 7

COMPLIANCE REQUIREMENTS FORMS	 8

OTHER CUSTOM FORMS	 9

GENERIC FORMS	 10

APPLICABILITY DETERMINATION	 10

OBSERVING / REVIEWING THE INITIAL PERFORMANCE TEST	 10

COMPLIANCE INSPECTIONS	 11

SAMPLE CALCULATIONS	 12

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LIST OF APPENDICES

APPENDIX A-l
APPENDIX A-2

APPENDIX A-3
APPENDIX A-4
APPENDIX A-5
APPENDIX A-6
APPENDIX A-7

APPENDIX A-8
APPENDIX A-9

APPENDIX A-10

APPENDIX A-l 1

APPENDIX A-12
APPENDIX A-13
APPENDIX A-14

APPENDIX A-15

NEW KRAFT AND SODA NDCE RECOVERY FURNACE-ESP

NEW KRAFT AND SODA NDCE OR DCE RECOVERY FURNACE-WET

SCRUBBER

NEW KRAFT AND SODA DCE RECOVERY FURNACE-ESP

NEW KRAFT OR SODA SMELT DISSOLVING TANK-WET SCRUBBER

NEW KRAFT OR SODA LIME KILN-ESP

NEW KRAFT OR SODA LIME KILN-WET SCRUBBER

ALL NEW STAND ALONE SEMICHEMICAL (ALL RECOVERY

METHOD S)-RT O

ALL NEW SULFITE COMBUSTORS - WET SCRUBBERS

EXISTING KRAFT AND SODA DCE OR NDCE RECOVERY FURNACE-

ESP

EXISTING KRAFT AND SODA DCE OR NDCE RECOVERY FURNACE-
WET SCRUBBER

EXISTING KRAFT AND SODA SMELT DISSOLVING TANK-WET
SCRUBBER

EXISTING KRAFT OR SODA LIME KILN-ESP

EXISTING KRAFT OR SODA LIME KILN-WET SCRUBBER

ALL EXISTING STAND ALONE SEMICHEMICAL (ALL RECOVERY

METHOD S)-RT O

ALL EXISTING SULFITE COMBUSTORS-WET SCRUBBER

APPENDIX B-l

PM COMPLIANCE BUBBLE ALTERNATIVE

APPENDIX C-l
APPENDIX C-2
APPENDIX C-3
APPENDIX C-4
APPENDIX C-5
APPENDIX C-6
APPENDIX C-l
APPENDIX C-8
APPENDIX C-9
APPENDIX C-10

START UP, SHUTDOWN AND MALFUNCTION PLANS

RECORDKEEPING REQUIREMENTS

CMS REPORTING REQUIREMENTS

START UP, SHUTDOWN AND MALFUNCTION REPORT

GENERAL REPORTING REQUIREMENTS

EXCESS EMISSIONS REPORTING REQUIREMENTS

OPERATION AND MAINTENANCE REQUIREMENTS

SEMI-ANNUAL REPORTS

IMMEDIATE REPORTING

MONITORING REQUIREMENTS

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APPENDICES - continued

APPENDIX D-l

INSPECTING PM COMPLIANCE BUBBLED SOURCES

APPENDIX E-l
APPENDIX E-2

APPLICABILITY ASSESSMENT
FORM SELECTION PROTOCOL

APPENDIX F-l
APPENDIX F-2
APPENDIX F-3
APPENDIX F-4
APPENDIX F-5
APPENDIX F-6
APPENDIX F-7
APPENDIX F-8

INSPECTING ELECTROSTATIC PRECIPITATORS
SINGLE PASS, 2 FIELD ESP
SINGLE PASS, 3 FIELD ESP
2 CHANNEL, 2 FIELD ESP
2 CHANNEL, 3 FIELD ESP
2 CHANNEL, 4 FIELD ESP
2 CHANNEL, 5 FIELD ESP
2 CHANNEL, 6 FIELD ESP

APPENDIX G-l
APPENDIX G-2
APPENDIX G-3
APPENDIX G-4

APPENDIX G-5

APPENDIX G-6
APPENDIX G-l
APPENDIX G-8

APPENDIX G-9

APPENDIX H-l
APPENDIX H-2

INSPECTING WET SCRUBBERS
EXAMPLE OF DATA FORM FOR
EXAMPLE OF DATA FORM FOR
EXAMPLE OF DATA FORM FOR
VIEW)

EXAMPLE OF DATA FORM FOR WET SCRUBBER (PLAN AND FRONT
VIEW)

EXAMPLE OF DATA FORM FOR
EXAMPLE OF DATA FORM FOR
EXAMPLE OF DATA FORM FOR
(FRONT VIEW)

EXAMPLE OF DATA FORM FOR VENTURI WET SCRUBBER (PLAN
VIEW)

REGENERATIVE THERMAL OXIDIZERS
INSPECTING REGENERATIVE THERMAL OXIDIZERS

WET SCRUBBER (PLAN VIEW)
WET SCRUBBER (FRONT VIEW)
WET SCRUBBER (PLAN AND FRONT

WET SCRUBBER (PLAN VIEW)
WET SCRUBBER (PLAN VIEW)
PACKED TOWER WET SCRUBBER

APPENDIX 1-1
APPENDIX 1-2
APPENDIX 1-3

SAMPLE CALCULATIONS FOR ELECTROSTATIC PRECIPITATORS
SAMPLE CALCULATIONS FOR WET SCRUBBERS
SAMPLE CALCULATIONS FOR REGENERATIVE THERMAL
OXIDIZERS

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INTRODUCTION

On January 12, 2001, EPA promulgated the final rule for the National Emission Standards for
Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite and
Stand-Alone Semi chemical Pulp Mills. This is Subpart MM of 40 CFR part 63. On July 19, 2001,
EPA issued several technical corrections to the final rule. Subpart MM of 40 CFR part 63 was
subsequently amended on February 18, 2003, May 8, 2003, and Julyl8, 2003. The compliance date for
new affected sources is March 13, 2001, and the compliance date for existing affected sources is
March 13, 2004.

The items contained in this document are geared towards inspecting the facility, hence, a number of
requirements contained in 40 CFR part 63 and Subpart MM, such as permitting protocols, definitions
and ancillary information, are not included. For example, many of the notification requirements are
not included as they pertain to the permitting of the source. However, those notifications necessary for
compliance purposes are included.

TERMS

The term, "new", as used in Subpart MM should not be confused with the "new source" category of
the New Source Performance Standards program. (The NSPS Subpart BB applies only to new Kraft
pulping sources with a commencement of construction or modification date after September 24, 1976.)
For Subpart MM, a new source is one that began construction or reconstruction after April 15, 1998.

For the purposes of this Subpart, there are two types of Hazardous Air Pollutants (HAPs). §63.862(a)
and §63.862(b) address "HAP metals" (from existing and new sources, respectively) and §63.862(c)
address "gaseous organic HAPs" from new sources. Gaseous organic HAPs from existing sources are
not regulated.

Throughout this document the term "the facility" is used in place of "the owner or operator". The
meaning is still clear and fewer words are used. It also uses "emission unit" in place of "affected
source", "process unit", "combustion unit" and "combustion device" unless the meaning is not clear.

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STAGES OF THE INSPECTION

Prior to visiting the mill, a thorough pre-inspection file review should be done. This should include
reviewing any reports submitted since the last inspection, the Start-up, Shutdown, and Malfunction
Plan (SSM), data from Performance Tests, and the history of exceedances, violations and compliance.

Finally, the on-site inspection allows the inspector to see first hand how the facility operates, to
evaluate the operation of the process and control equipment, review the records required by this
subpart and to discuss specific issues of concern to the inspector.

APPROACH

The Subpart MM regulations cover new and existing units, various pulping methods including Kraft,
Soda, Sulfite and Semi-chemical, different control technology including Electrostatic Precipitators
(ESPs), Wet Scrubbers, and Regenerative Thermal Oxidizers (RTOs), as well as allowing alternative
emission control methods and emission limits. For this reason, the approach taken in this document is
to create custom forms for each of the possible combinations so the user can cull out only those forms
that apply to the configuration they are working with at a mill. Each form provides only the
requirements specific to those units.

Forms are also presented for mill-wide recordkeeping and reporting requirements. There are
contingencies in Subpart MM that allow a facility to combine existing emission units under a
compliance bubble and adjust individual emission limits from these regulated sources. Further, they
can petition for different control device type and methods other than those specified in the subpart.
A "FORM SELECTION" flow chart, located in Appendix E, is used to select the forms needed for each
emission unit. By using the flowchart, a package of forms can be assembled that is a custom fit for the mill
being inspected for compliance with Subpart MM. The necessary forms are located in the appropriate
appendices.

There are three types of forms in this manual, custom, generic and supporting. Custom forms are unique to
a given situation (e.g. the combination of new or existing, process type and control equipment type or
specific option) and are grouped as COMPLIANCE REQUIREMENTS or OTHER REQUIREMENTS.

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The later applies to specific options allowed in the subpart. These allow one to only have to deal with
the requirements that apply to that combination.

Generic forms apply to items that apply to all combinations. These save repeating the same information on
each custom form. They are also found in the appendices.

COMPLIANCE REQUIREMENT FORMS

These forms are found in Appendix A. They list the compliance requirements that are unique to a specified
combination of emission unit, process type and air pollution control method. If a facility elects to use an
alternative emission control system, operating parameters, emission standards for HAP Metal in new
Recovery Furnaces or a PM Compliance Bubble, these forms would not apply in their entirety. These
forms are as follows:

APPENDIX A-l
APPENDIX A-2

APPENDIX A-3
APPENDIX A-4
APPENDIX A-5
APPENDIX A-6
APPENDIX A-l

APPENDIX A-8

NEW KRAFT AND SODA NDCE RECOVERY FURNACE-ESP
NEW KRAFT AND SODA NDCE OR DCE RECOVERY FURNACE-
SCRUBBER

NEW KRAFT AND SODA DCE RECOVERY FURNACE-ESP
NEW KRAFT OR SODA SMELT DISSOLVING TANK-SCRUBBER
NEW KRAFT OR SODA LIME KILN-ESP
NEW KRAFT OR SODA LIME KILN-SCRUBBER

ALL NEW STAND ALONE SEMICHEMICAL (ALL RECOVERY METHODS)-
RTO

ALL NEW SULFITE COMBUSTORS -WET SCRUBBER

APPENDIX A-9
APPENDIX A-10

APPENDIX A-11
APPENDIX A-12
APPENDIX A-13
APPENDIX A-14

APPENDIX A-15

EXISTING KRAFT AND SODA DCE OR NDCE RECOVERY FURNACE-ESP
EXISTING KRAFT AND SODA DCE OR NDCE RECOVERY FURNACE-
SCRUBBER

EXISTING KRAFT AND SODA SMELT DISSOLVING TANK-SCRUBBER

EXISTING KRAFT OR SODA LIME KILN-ESP

EXISTING KRAFT OR SODA LIME KILN-SCRUBBER

ALL EXISTING STAND ALONE SEMICHEMICAL (ALL RECOVERY

METHODS)-RTO

EXISTING SULFITE COMBUSTORS-SCRUBBER

OTHER CUSTOM FORMS

There are some options in the subpart that only apply to an emission unit if the facility chooses to use
them. The forms for these options are found in Appendix B. They are the following:

Custom forms include:

APPENDIX B-1 PM COMPLIANCE BUBBLE ALTERNATIVE

These forms are provided to verify the validity the PM Compliance Bubble emission limits and to
evaluate the mill against these limits. There are also forms that contain the requirements associates
with this alternative.

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GENERIC FORMS

All those requirements that apply to all combinations are contained in generic forms. They are found
in Appendix C and are:

APPENDIX C-l
APPENDIX C-2
APPENDIX C-3
APPENDIX C-4
APPENDIX C-5
APPENDIX C-6
APPENDIX C-l
APPENDIX C-8
APPENDIX C-9
APPENDIX C-10

START UP, SHUTDOWN AND MALFUNCTION PLANS

RECORDKEEPING REQUIREMENTS

CMS REPORTING REQUIREMENTS

START UP, SHUTDOWN AND MALFUNCTION REPORT

GENERAL REPORTING REQUIREMENTS

EXCESS EMISSION REPORTING REQUIREMENTS

OPERATION / MAINTENANCE REQUIREMENTS

SEMI-ANNUAL REPORTS

IMMEDIATE REPORTING

MONITORING REQUIREMENTS

APPLICABILITY DETERMINATION

APPENDIX E-l APPLICABILITY ASSESSMENT

There are two criteria for applicability to Subpart MM. One is the appropriate Chemical Recovery
technologies as discuss above. The other is the amount of HAPs emitted by the facility. The appendix
can be used to assess this applicability:

APPENDIX E-2 FORM SELECTION PROTOCOL

Since the appendices contain custom forms for each combination of age, pulping process and type of
control equipment, a selection protocol is provided in this appendix.

OBSERVING / REVIEWING THE INITIAL PERFORMANCE TEST

Since the IPT is the basis for showing compliance, establishing operational ranges for air pollution
control equipment and establishing emission limits for the PM compliance bubble, there are forms
available to use in evaluation the IPT and the data resulting form it. Part of evaluation the IPT is to
determine that the air pollution control equipment is operating as designed. There are forms showing
how to make these calculations.

Prior to inspecting a facility for 40 CFR part 63 Subpart MM requirements, the inspector should
observe the Initial Performance Test or review the results (any supporting Performance Tests) to serve
as a baseline for the inspection.

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There are three main important values of the Initial Performance Test:

This provides data to determine that air pollution control equipment is being operated in a
manner consistent with good air pollution control practices for minimizing emissions at least to
the levels required by all relevant standards [§40CFR63.6(e)]

It is the basis of the operation ranges for the surrogate operation parameters.

It demonstrates whether or not the control unit is capable of operating in compliance with
emission standards.

Where applicable, the alternative methods and standards can be substantiated.

There is a discussion and package of forms in the appendices for each of the three types of air pollution
control equipment specifically referenced in the subpart, Electrostatic Precipitators (ESP), Wet
Scrubbers and Regenerative Thermal Oxidizers (RTO). For each emission unit, the applicable package
can be selected and used.

COMPLIANCE INSPECTIONS

Since emission units in bubbled sources each have their own emission limit, the inspector needs to
confirm that the volumetric flow rate observed during the compliance inspection is consistent with the
flow rate observed during the IPT.

APPENDIX D-l INSPECTING PM COMPLIANCE BUBBLED SOURCES

There are three main important values of compliance inspections:

• Determine that the facility is in compliance with all MACT requirements at the time of the
inspection.

Judge whether or not the facility has been in continuous compliance since the last inspection
and the likelihood it will be in continuous compliance in the future.

Verify all reporting requirements are being complied with.

During inspections, the air pollution control equipment needs to be evaluated and there are forms for
that.

APPENDIX F-1 INSPECTING ELECTROSTATIC PRECIPITATORS

Whether observing the IPT or evaluating the operation of the control equipment during an inspection,
forms are needed to record the pertinent data. Appendix F contains forms and theory for this
evaluation. The locations of forms for the various ESPs normally encountered are:

APPENDIX F-2
APPENDIX F-3
APPENDIX F-4
APPENDIX F-5

SINGLE PASS, 2 FIELD ESP
SINGLE PASS, 3 FIELD ESP
TWO CHANNEL, 2 FIELD ESP
TWO CHANNEL, 3 FIELD ESP

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APPENDIX F-6 TWO CHANNEL, 4 FIELD ESP
APPENDIX F-7 TWO CHANNEL, 5 FIELD ESP
APPENDIX F-8 TWO CHANNEL, 6 FIELD ESP

APPENDIX G-l

INSPECTING WET SCRUBBERS

Whether observing the IPT or evaluating the operation of the control equipment during an inspection,
forms are needed to record the pertinent data. This Appendix contains forms and theory for this
evaluation.

APPENDIX G-2
APPENDIX G-3
APPENDIX G-4

APPENDIX G-5

APPENDIX G-6
APPENDIX G-l
APPENDIX G-8

APPENDIX G-9

FORM FOR WET SCRUBBER (PLAN VIEW)
FORM FOR WET SCRUBBER (FRONT VIEW)
FORM FOR WET SCRUBBER (PLAN AND FRONT

FORM FOR WET SCRUBBER (PLAN VIEW)
FORM FOR WET SCRUBBER (PLAN VIEW)
FORM FOR PACKED TOWER WET SCRUBBER

EXAMPLE OF DATA
EXAMPLE OF DATA
EXAMPLE OF DATA
VIEW)

EXAMPLE OF DATA FORM FOR WET SCRUBBER (PLAN AND FRONT
VIEW)

EXAMPLE OF DATA
EXAMPLE OF DATA
EXAMPLE OF DATA
(FRONT VIEW)

EXAMPLE OF DATA FORM FOR VENTURI WET SCRUBBER (PLAN
VIEW)

APPENDIX H-l
APPENDIX H-2

REGENERATIVE THERMAL OXIDIZERS
INSPECTING REGENERATIVE THERMAL OXIDIZERS

SAMPLE CALCULATIONS

APPENDIX 1-1
APPENDIX 1-2
APPENDIX 1-3

SAMPLE CALCULATIONS FOR ELECTROSTATIC PRECIPITATORS

SAMPLE CALCULATIONS FOR WET SCRUBBERS

SAMPLE CALCULATIONS FOR REGENERATIVE THERMAL
OXIDIZERS

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APPENDIX A

APPENDIX A-l. NEW KRAFT AND SODA NDCE RECOVERY

FURNACE - ESP

Compliance date: 3/13/01
Limits

PM:	0.015 gr/dscf @ 8% 02. [63.862(b)(1)] Method 5

or Method 29 in Appendix A of 40 CFR part 60 must be used, except
that Method 17 may be used if the stack temperature is no greater than
400 ° F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] (Since it has a NDCE, if the ESP is the dry type, no IPT
is needed for PM.) Method 3 A or 3B in Appendix A of 40 CFR part 60
must be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

HAPS:	0.025 lbs/ton black liquor solids fired (As Methanol.)

[63.862(c)(1)] Only one exceedance can be attributed to any given 24-
hour period for purposes of determining the number of nonopacity
monitoring exceedances.

Opacity:	20%

TRS (NSPS):	5 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	ESP - Monitor Opacity at least once every 10 seconds or

administrative approved alternative
Dry ESP - No monitoring required

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	ESP- Average of 10 consecutive 6-minute averages results in a

measurement greater than 20% opacity.

Performance Criteria for Violation (Tier II)

PM:	ESP - Opacity is greater than 20% for 6 percent or more of the

operating time within any quarterly period (no more than one exceedance per 24
hours) in addition to excused periods under the start-up, shutdown or
malfunction provisions.

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APPENDIX A

APPENDIX A-2. NEW KRAFT AND SODA NDCE OR DCE RECOVERY

FURNACES - WET SCRUBBER

Compliance date: 3/13/01
Limits

PM:	0.015 gr/dscf @ 8% 02. [63.862(b)(1)] Method 5

or Method 29 in Appendix A of 40 CFR part 60 must be used, except
that Method 17 can be used if the stack temperature is no greater than
400 ° F and a constant value of 0.004 gr/dscf if added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

HAPS:	0.025 lbs/ton black liquor solids fired (As Methanol.)

[63.862(c)(1)] Only one exceedance can be attributed to any given 24-
hour period for purposes of determining the number of nonopacity
monitoring exceedances. Method 308 in Appendix A of 40 CFR part 60
must be used as well as Methods 1 through 4 in Appendix A of part 60 to
determine compliance. The sampling time and sample volume for each
Method 308 run must be at least 60 minutes and 0.50 dscf, respectively.
[63.865(c)]

Opacity (NSPS): 35%

TRS (NSPS):	5 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative. (Both monitoring
devices must be accurate within the limits proscribed in 63.864(3)(10))

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value is outside

the range established during the IPT within a 6 month reporting period (no more
than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

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APPENDIX A

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values outside the range established during the IPT within a 6 month reporting
period (no more than one exceedance per 24 hours) in addition to excused
periods under the start-up, shutdown or malfunction provisions.

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APPENDIX A

APPENDIX A-3. NEW KRAFT AND SODA DCE RECOVERY

FURNACE - ESP

Compliance date: 3/13/01
Limits

PM:	0.015 gr/dscf @ 8% 02. [63.862(b)(1)] Method 5

or Method 29 in Appendix A of 40 CFR part 60 must be used, except
that Method 17 may be used if the stack temperature is no greater than
400 ° F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

HAPS:	0.025 lbs / ton black liquor solids fired (As Methanol.)

[63.862(c)(1)] Only one exceedance can be attributed to any given 24-
hour period for purposes of determining the number of nonopacity
monitoring exceedances. [63.864(c)(3)] Method 308 in Appendix A of
40 CFR part 60 must be used as well as Methods 1 through 4 in
Appendix A of part 60. The sampling time and sample volume for each
Method 308 run must be at least 60 minutes and 0.50 dscf, respectively.
[63.865(c)]

Opacity:	20%

TRS (NSPS):	5 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	ESP - Monitor Opacity at least once every 10 seconds or

administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	ESP- Average of 10 consecutive 6-minute averages results in a

measurement greater than 20%.

Performance Criteria for Violation (Tier II)

PM:	ESP - Opacity is greater than 20% for 6 percent or more of the

operating time within any quarterly period (no more than one exceedance per 24
hours) in addition to excused periods under the start-up, shutdown or
malfunction provisions.

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APPENDIX A

APPENDIX A-4. NEW KRAFT OR SODA SMELT DISSOLVING TANK -

WET SCRUBBER

Compliance date: 3/13/01
Limits

PM:	0.12 lb/ton black liquor solids fired. [63.862(b)(2)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be used,
except that Method 17 may be used if the stack temperature is no greater
than 400 ° F and a constant 0.004 gr/dscf is added to the results.
[63.865(b)(1)]

TRS (NSPS):	0.033 lb/ton black liquor solids fired (Post

September 24, 1976).

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value is outside

the ranges established during the IPT within a 6 month reporting period (no
more than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values within any 6 month reporting period are outside the range established
during the IPT (no more than one exceedance per 24 hours) in addition to
excused periods under the start-up, shutdown or malfunction provisions.

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APPENDIX A

APPENDIX A-5. NEW KRAFT OR SODA LIME KILN - ESP

Compliance date: 3/13/01
Limits

PM:	0.010 gr/dscf @ 10% 02. [63.862(b)(3)] Method

5 or Method 29 in Appendix A of 40 CFR part 60 must be used, except
Method 17 may be used if the stack temperature is no greater than 400 °
F and a constant 0.004 gr/dscf is added to the results. [63.865(b)(1)]
Method 3 A or 3B in Appendix A of 40 CFR part 60 must be used to
determine the oxygen concentration. [63.865(b)(3)] The oxygen
correction must be made with equation 7. [63.865(b)(2)]

Opacity:	20%

TRS (NSPS):	8 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	ESP - Monitor Opacity at least once every 10 seconds or

administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	ESP- Average of 10 consecutive 6-minute averages results in a

measurement greater than 20% opacity.

Performance Criteria for Violation (Tier II)

PM:	ESP - Opacity is greater than 20% for 6% or more of the

operating time

within any quarterly period (no more than one exceedance per 24 hours) in
addition to excused periods under the start-up, shutdown or malfunction
provisions.

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APPENDIX A

APPENDIX A-6. NEW KRAFT OR SODA LIME KILN - WET

SCRUBBER

Compliance date: 3/13/01
Limits

PM:	0.010 gr/dscf@ 10% 02. [63.862(b)(3)] Method

5 or Method 29 in Appendix A of 40 CFR part 60 must be used, except
Method 17 may be used if the stack temperature is no greater than 400 °
F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

Opacity:	20%

TRS (NSPS):	8 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value is outside

the range of values established during the IPT within a 6 month reporting period
(no more than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values outside the ranges established during the IPT within a 6 month reporting
period (no more than one exceedance per 24 hours) in addition to excused
periods under the start-up, shutdown or malfunction provisions.

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APPENDIX A

APPENDIX A-7. ALL NEW STAND ALONE SEMI-CHEMICAL (ALL

RECOVERY METHODS) - RTO

Compliance date: 3/13/01
Limits

HAPS:	Reduce gaseous organic HAPS to 2.97 lbs/ton Black

Liquor Solids fired, as measured as total hydrocarbons reported as
carbon [63.862(c)(2)(i)] or,

Reduce gaseous organic HAPS by 90%, as measured as total
hydrocarbons reported as carbon. [63.862(c)(2)(ii)] Use equation 12 and
measure both inlet and outlet mass loadings. [63.865(d)(2)] Method 25A
as well as Methods 1 through 4 in Appendix A of 40 CFR part 60 must
be used and the sampling time for each Method 25 run must be at least
60 minutes. [63.865(d)] The emission rate must be determined using
Equation 11. [63.865(d)(1)]

Performance Monitoring Requirement

PM:	RTO - Monitor Temperature at least once every 15-minute period

using the procedures in §63.8(c) or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	RTO - 1-hour average temperature falls below the temperature

established during the IPT.

Performance Criteria for Violation (Tier II)

PM:	RTO - 3-hour average temperature falls below the temperature

established during the IPT.

19


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APPENDIX A

APPENDIX A-8. ALL NEW SULFITE COMBUSTORS - WET

SCRUBBER

Compliance date: 3/13/01
Limits

PM:	0.020 gr/dscf @ 8% 02. [63.862(b)(4)] Method 5

or Method 29 in Appendix A of 40 CFR part 60 must be used, except
that Method 17 may be used if the stack temperature is greater than 400
° F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value is outside

the range established during the IPT within any 6 month reporting period (no
more than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values are outside the range established during the IPT within any 6 month
reporting period (no more than one exceedance per 24 hours) in addition to
excused periods under the start-up, shutdown or malfunction provisions.

20


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APPENDIX A

APPENDIX A-9. EXISTING KRAFT AND SODA DCE OR NDCE

RECOVERY FURNACE - ESP

Compliance date: 3/13/04
Limits

PM:	0.044 gr/dscf @ 8% 02.[63.862(a)(l)(i)(A)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be used,
except that Method 17 may be used if the stack temperature is no greater
than 400 ° F and 0.004 gr/dscf is added to the result. [63.865(b)(1)]
Method 3 A or 3B in Appendix A of 40 CFR part 60 must be used to
determine the oxygen concentration. [63.865(b)(3)] The oxygen
correction must be made with equation 7. [63.865(b)(2)]

Opacity:	20%/35%

TRS (NSPS):	5 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	ESP - Monitor Opacity at least once every 10 seconds or

administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	ESP- Average of 10 consecutive 6-minute opacity readings is

greater than 20%.

Performance Criteria for Violation (Tier II)

PM:	ESP - Opacity is greater than 35% for 6% or more of the

operating time

within any quarterly period (no more than one exceedance per 24 hours) in
addition to excused periods under the start-up, shutdown or malfunction
provisions.

21


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APPENDIX A

APPENDIX A-10. EXISTING KRAFT AND SODA DCE OR NDCE
RECOVERY FURNACE - WET SCRUBBER

Compliance date: 3/13/04

Limits

PM:	0.044 gr/dscf @ 8% 02.[63.862(a)(l)(i)(A)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be used,
except that Method 17 may be used if the stack temperature is no greater
than 400 ° F and a constant value of 0.004 gr/dscf is added to the result.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

Opacity:	35%

TRS (NSPS):	5 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3 hour average scrubber parameter value outside the

range established during the IPT within a 6 month reporting period (no more
than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3 hour average scrubber parameter

values outside the range established during the IPT within a 6 month reporting
period (no more than one exceedance per 24 hours) in addition to excused
periods under the start-up, shutdown or malfunction provisions.

22


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APPENDIX A

APPENDIX A ll. EXISTING KRAFT AND SODA SMELT DISSOLVING

TANK - WET SCRUBBER

Compliance date: 3/13/04
Limits

PM:	0.20 lb/ton black liquor solids fired.

[63.862(a)(l)(i)(B)] Method 5 or Method 29 in Appendix A of 40 CFR
part 60 must be used, except that Method 17 may be used if the stack
temperature is no greater than 400 ° F and a constant value of 0.004
gr/dscf is added to the results. [63.865(b)(1)]

TRS (NSPS):	0.033 lb/ton black liquor solids fired (Post

September 24, 1976).

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value outside the

range established during the IPT within a 6 month reporting period (no more
than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values outside the range established during the IPT within a 6 month reporting
period (no more than one exceedance per 24 hours) in addition to excused
periods under the start-up, shutdown or malfunction provisions.

23


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APPENDIX A

APPENDIX A-12. EXISTING KRAFT OR SODA LIME KILN - ESP

Compliance date: 3/13/04
Limits

PM:	0.064 gr/dscf @ 10% 02.[63.862(a)(l)(i)(C)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be used,
except that Method 17 may be used if the stack temperature is no greater
than 400 ° F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

Opacity:	20%

TRS (NSPS):	8 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	ESP - Monitor Opacity at least once every 10 seconds or

administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	ESP- Average of 10 consecutive 6-minute averages results in a

measurement greater than 20% opacity.

Performance Criteria for Violation (Tier II)

PM:	ESP - Opacity is greater than 20% for more than 6% of the

operating time

within any quarterly period (no more than one exceedance per 24 hours) in
addition to excused periods under the start-up, shutdown or malfunction
provisions.

24


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APPENDIX A

APPENDIX A-13. EXISTING KRAFT OR SODA LIME KILN - WET

SCRUBBER

Compliance date: 3/13/04

Limits

PM:	0.064 gr/dscf @ 10% 02.[63.862(a)(l)(i)(C)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be used,
except that Method 17 may be used if the stack temperature is no greater
than 400 ° F and a constant value of 0.004 gr/dscf is added to the results.
[63.865(b)(1)] Method 3A or 3B in Appendix A of 40 CFR part 60 must
be used to determine the oxygen concentration. [63.865(b)(3)] The
oxygen correction must be made with equation 7. [63.865(b)(2)]

Opacity (NSPS):	20%

TRS (NSPS):	8 ppmdv @ 8% 02 (Post September 24, 1976)

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the scrubber

(inches of water) and the scrubbing liquid into it (gallons per minute) at least
once every 15 minutes or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value is outside

the ranges established during the IPT within the 6 month reporting period (no
more than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber parameter

values outside the range of values established during the IPT within a 6 month
reporting period (no more than one exceedance per 24 hours) in addition to
excused periods under the start-up, shutdown or malfunction provisions.

25


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APPENDIX A

APPENDIX A-14. ALL EXISTING
STAND ALONE SEMICHEMICAL (ALL RECOVERY METHODS) - RTO

Compliance date: 3/13/04
Limits

HAPS:	Reduce gaseous organic HAPS to 2.97 lbs/ton Black

Liquor Solids, as measured as total hydrocarbons reported as carbon
[63.862(c)(2)(i)] or,

Reduce gaseous organic HAPS by 90%, as measured as total
hydrocarbons reported as carbon. [63.862(c)(2)(ii)] Use equation 12 and
measure both inlet and outlet mass loadings. [63.865(d)(2)] Method 25A
as well as Methods 1 through 4 in appendix A of 40 CFR part 60 must be
used and the sampling time for each Method 25 run must be at least 60
minutes. [63.865(d)] The emission rate must be determined using
Equation 11. [63.865(d)(1)]

Performance Monitoring Requirement

PM:	RTO - Monitor Temperature at least once every 15-minute period

using the procedures in §63.8(c) or administrative approved alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	RTO - 1-hour average temperature falls below the temperature

established during the IPT.

Performance Criteria for Violation (Tier II)

PM:	RTO - 3-hour average temperature falls below the temperature

established during the IPT.

26


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APPENDIX B

APPENDIX A-15. ALL EXISTING SULFITE COMBUSTORS - WET

SCRUBBER

Compliance date: 3/13/04
Limits

PM:	0.040 gr/dscf @ 8% 02. [63.862(a)(2)]

Method 5 or Method 29 in Appendix A of 40 CFR part 60 must be
used, except that Method 17 may be used if the stack temperature
is no greater than 400 ° F and a constant value of 0.004 gr/dscf is
added to the results. [63.865(b)(1)] Method 3A or 3B in Appendix
A of 40 CFR part 60 must be used to determine the oxygen
concentration. [63.865(b)(3)] The oxygen correction must be
made with equation 7. [63.865(b)(2)]

Performance Monitoring Requirement

PM:	Wet Scrubber - Monitor Pressure Differential across the

scrubber (inches of water) and the scrubbing liquid into it (gallons per
minute) at least once every 15 minutes or administrative approved
alternative.

Performance Monitoring Criteria for Corrective Action to be Taken (Tier I)

PM:	Wet Scrubber - Any 3-hour average scrubber parameter value

outside the range established during the IPT within a 6 month reporting
period (no more than one exceedance per 24 hours).

Performance Criteria for Violation (Tier II)

PM:	Wet Scrubber - Six or more 3-hour average scrubber

parameter values outside the range established during the IPT within a 6
month reporting period (no more than one exceedance per 24 hours) in
addition to excused periods under the start-up, shutdown or malfunction
provisions.

27


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APPENDIX B

APPENDIX B-l. PM COMPLIANCE BUBBLE ALTERNATIVE

Compliance date: 3/13/04

[63.862(a)(l)(ii)] As an alternative to meeting the requirements of 63.862(a)(l)(i), each kraft or
soda facility may establish PM emission limits for each recovery furnace, smelt dissolving tank
and lime kiln that operated 6,300 hours per year or more by:

establishing an overall PM emission limit for each existing process unit using methods in
§63.865(a)(1) and §63.865(a)(2)

the emission limits for each kraft process unit cannot be less stringent than those in
§60.282 (Note. This is NSPS Subpart BB)

the facility must ensure that PM emissions emitted are less than or equal to limits
established using methods in §63.865(a)(1)
the facility must reestablish emission limits if
an emission unit is

modified as defined in §63.861, or

shut down for more than 60 consecutive days

§63.865 Performance test requirements and test methods

[63.865(a)] The facility seeking to comply with a PM emission limit under 63.862(a)(l)(ii)(A)
(existing sources only) must use the procedures in paragraphs 63.865(a)(1) through 63.865(a)(4).

§63.867 Reporting requirements

[63.867(b)(1)] The facility must submit the PM emissions limits determined in 63.865(a) for
each affected Kraft or Soda recovery furnace, smelt dissolving tank, and lime kiln to the
Administrator for approval. The emission limits must be submitted as part of the notification of
compliance status required under Subpart A of this part This is 63.9(h).

[63.867(b)(2)] The facility must submit the calculations and supporting documentation used in
63.865(a)(1) and 63.865(a)(2) to the Administrator as part of the notification of compliance
status required under subpart A of this part [63.9(h)],

[63.867(b)(3)] After the Administrator has approved the emissions limits for any process unit,
the facility must notify the Administrator before:

the air pollution control system for any process unit is modified or replaced

any Kraft or Soda recovery furnace, smelt dissolving tank, or lime kiln is shut down for

more than 60 consecutive days

a continuous monitoring parameter or the value or range of values of a continuous
monitoring parameter for any process unit is changed

28


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APPENDIX B

the black liquor solids firing rate for any Kraft or Soda recovery furnace during any 24-
hour averaging period is increased by more than 10 percent above the level measured
during the most recent performance test

[63.867(b)(4)] A facility seeking to perform the actions in 63.867(b)(3)(i) or 63.867(b)(3)(ii)
must recalculate the overall PM emissions limit for the group of process units and resubmit the
documentation required in 63.867(b)(2) to the Administrator. All modified PM emissions limits
are subject to approval by the Administrator.

29


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APPENDIX C

APPENDIX C-l. STARTUP, SHUTDOWN, AND MALFUNCTION

PLANS

The facility must develop and implement a written Startup, Shutdown, and Malfunction (SSM)
Plan [§63.866(a)] no later than

March 13, 2004, for existing emission units. [§63.866(a)]

March 12, 2001, for emission units that had an initial startup date after March 13, 2001,
[§63.866(b)]

The purpose of the SSM plan is to

ensure that, at all times, including periods of startup, shutdown, and malfunction,
facilities operate and maintain affected sources, including associated air pollution control
equipment, in a manner consistent with good air pollution control practices for
minimizing emissions at least to the levels required by all relevant standards
[§63.6(e)(l)(i)]

ensure that facilities are prepared to correct malfunctions as soon as practicable after their
occurrence in order to minimize excess emissions of hazardous air pollutants in
accordance with the startup, shutdown, and malfunction plan.[§63.6(e)(l)(ii)]
reduce the reporting burden associated with periods of startup, shutdown, and
malfunction (including corrective action taken to restore malfunctioning processes and air
pollution control equipment to its normal or usual manner of operation.) [§63.6(e)(3)(i)]
provide procedures under which the facility must operate and maintain its equipment
(including associated air pollution control equipment) during periods of start up,
shutdown, and malfunction. [§63.6(e)(3)(ii)]

The SSM Plan

shall describe, in detail:

procedures for operating and maintaining the source during periods of startup,
shutdown, and malfunction

a program of corrective action for malfunctioning process and air pollution
control equipment used to comply with the relevant standard
must identify all routine or otherwise predictable CMS malfunctions.

(For the purposes of this subpart CMSs include:

for any Kraft or Soda recovery furnace or lime kiln equipped with an ESP

o Continuous Opacity Monitor (COM)
for any Kraft or Soda recovery furnace, smelt dissolving tank or lime kiln or
sulfite combustion unit equipped with a wet scrubber

o CMS for pressured drop of the gas stream across the scrubber
o CMS for the scrubbing liquid flow rate
for any semichemical combustion unit equipped with an Regenerative Thermal
Oxidizer (RTO)

o CMS for the operating temperature at the point of incineration
for any alternative air pollution control system approved by the Administrator

30


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APPENDIX C

o CMS for monitoring equipment or process parameters approved by the
Administrator.)

must be incorporated by reference into the source's Title V permit. [§63.6(e)(3)(i)].
shall include

procedures for responding to any process parameter level that is inconsistent with
the level(s) established under §63.864(j) including
procedures to determine and record

the cause of an operating parameter exceedance
the time the exceedance began
the time the exceedance ended
corrective actions to be taken in the event of an operating parameter
exceedance, including procedures for recording the actions taken to
correct the exceedance.[§63.866(a)(1)]
a maintenance schedule for each control technique that is consistent with but not
limited to

the manufacturer's instructions
• recommendations for routine and long term maintenance
an inspection schedule for each CMS required under §63.864 to ensure, at least
once in each 24-hour period, that each continuous monitoring system is properly
functioning. §63.866(a)(1).
may be part of the facility' s

standard operating procedures (SOP) manual, OSHA plan or other plan provided
the alternative plans

meet all the requirements for an SSM plan

are made available for inspection when requested by the Administrator.
[§63.6(e)(3)(vi)]

shall be kept on record and made available for inspection, upon request, by the
Administrator for the life of the emission unit or until the emission unit is no longer
subject to the provision of this part. If the SSM plan is revised, any previous (i.e.
superseded) versions shall, likewise, be made available for a period of 5 years after each
revision to the plan. [§63.6(e)(3)(v)]

The Administrator may require reasonable revisions to a SSM plan, under the authority of
§63.6(e)(2)

if the Administrator finds that the plan does not provide adequate procedures for
correcting malfunctioning process and or air pollution control equipment as quickly as
practicable [§63.6(e)(3)(vii)]

it must be revised within 45 days after the event to include

detailed procedures for operating and maintaining the source during similar
malfunction events

program of corrective action for similar malfunctions of process or air pollution
control equipment. [§63.6(e)(3)(viii)]

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APPENDIX C

The SSM Plan must include

procedures for responding to any process parameter level that is inconsistent with the
level(s) established under §63.864(j) including

procedures to determine and record the cause of an operating parameter
exceedance and the time the exceedance began and ended [§63.866(a)(l)(i)]
corrective actions to be taken in the event of an operating parameter exceedance,
including procedures for recording the actions taken to correct the exceedance.
[§63.866(a)(l)(ii)]
schedules

a maintenance schedule for each control technique that is consistent with, but not
limited to, the manufacturer's instructions and recommendations for routine and
long term maintenance [§63.866(a)(2)(i)]

an inspection schedule for each CMS required under §63.864 to ensure, at least
once in each 24-hour period, that each CMS is properly functioning.
[§63.866(a)(2)(ii)]

32


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APPENDIX C

APPENDIX C-2. RECORDKEEPING REQUIREMENTS

[§63.866(b)] The facility must maintain records of any occurrence when corrective action is
required under §63.864(k)(l) and when a violation is noted under §63.864(k)(2)

Facility must maintain files of all required information in a form suitable and readily available
for expeditious inspection and review. (Note: these files must be maintained at least 5 years with
the most recent 2 years being on site.) Electronic and microform formats are acceptable.
[§63.10(b)(1)]

The facility shall maintain relevant records of:

the occurrence and duration of each startup, shutdown and malfunction of the processes
and air pollution control equipment and all maintenance performed on the air pollution
control equipment. [§63.10(b)(2)(i), (ii) and (iii)]

actions taken during startup, shutdown or malfunction that are not covered by the SSM
Plan. [§63.10(b)(2)(iv)]

sufficient information necessary to demonstrate conformance with the SSM
[§63.10(b)(2)(v)]

each period (???) during which a CMS malfunction or inoperative (including out-of-
control periods as defined in §63.8(c)(7)(i)). [§63.10(b)(2)(vi)]
all measurements needed to demonstrate continuous compliance (including but not
limited to):

required CMS data averages including where appropriate [§63.10(b)(2)(vii)]
10-second average opacity

15-minute average pressure drop and scrubbing liquid flow in wet
scrubbers

15-minute average incineration temperature in a RTO
any control equipment or process parameter averaging time specified
under alternative air pollution control measures approval by the
Administrator

(Note: If a Continuous Emission Monitoring system is in use and the
data averages include periods of CEMS breakdown or malfunction,
then less data needs to be maintained on file unless the regulatory
authority decides otherwise. [§63.10(b)(2)(vii)].

If the CEMS data analysis is automated, only the most recent (???)
consecutive three hour average period of subhourly measurement
need to be retained and a file of the algorithm used to reduce the
measurement data into the reportable form. (Note: "automated"
means a computerized data acquisition system that records and
reduces the data.) [§63.10(b)(2)(vii)(A)]

If the CEMS data analysis is manually reduced, only the subhourly
measurements for the most recent reporting period need to be

33


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APPENDIX C

retained. This data set needs to be retained for 120 days from the
date of the most recent summary or excess emission report.
[§63.10(b)(2)(vii)(B)]

results of performance tests, CMS performance evaluations and opacity and visibility
emission observations. [§63.10(b)(2)(viii)]

(Note: "Performance testing" includes the execution of a test method (usually
three emission test runs) used to demonstrate compliance with a relevant emission
standard.)

(Note: "Performance evaluations" are relative accuracy testing, calibration error
testing and other measurements used in validating the CMS data.)
measurements necessary to determine the condition of performance tests and
performance evaluations. [§63.10(b)(2)(ix)]

CMS calibration checks as well as all adjustments and maintenance performed on CMS.
[§63.10(b)(2)(x) and §63.10(b)(2)(xi)]

data demonstrating whether a source is meeting the requirements of any waiver.
[§63.10(b)(2)(xii)]

relating to obtaining permission to use an alternative to the relative accuracy test if
granted such option. [§63.10(b)(2)(xiii)]

documentation supporting initial notifications and notifications of compliance status.
[§63.10(b)(2)(xiv)]
records of

black liquor solids firing rate (tons per day) for all recovery furnaces and
semichemcial combustion units were applicable [§63.866(c)(1)]

CaO production rates in tons/day for all lime kilns where applicable
[§63.866(c)(2)]

parameter monitoring data required under §63.864 including

any period when the operating parameter levels were inconsistent with the
levels established during the initial performance test

with a brief explanation of the cause of the deviation
the time the deviation occurred
the time corrective action was initiated
the time corrective action was completed
the corrective action taken. [§63.866(c)(3)]
and documentation of supporting calculations for compliance
determinations made under §63.865(a) through §63.865(e).

[§63.866(c)(4)]

monitoring parameter ranges established for each affected source or
process unit. [§63.866(c)(5)]

only in the case of new recovery furnaces equipped with a dry ESP
system, records certification of this fact. [§63.866(c)(6)]

34


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APPENDIX C

APPENDIX C-3. CMS REPORTING REQUIREMENTS

§63.10(c) Additional recordkeeping requirements for sources with continuous monitoring
systems

A facility that must install a CMS shall maintain records of:

all required CMS measurements (including monitoring data recorded during

unavoidable CMS breakdowns and out-of-control periods. [63.10(c)(1)]

the date and time identifying each period during which the CMS was inoperative

except zero (low-level) and high-level checks.[63.10(c)(5)]

the date and time identifying each period during which the CMS was out of

control as defined in 63.8(c)(7). [63.10(c)(6)]

the specific identification (i.e. the date and time of commencement and
completion) of each period of excess emissions and parameter monitoring
exceedances that occurs during startups, shutdowns and malfunctions.
[63.10(c)(7)]

the specific identification (i.e. the date and time of commencement and
completion) of each period of excess emissions and parameter monitoring
exceedances that occurs during periods other than startups, shutdowns and
malfunctions. [63.10(c)(8)]

the nature and cause of any malfunction (if known). [63.10(c)(10)]
the corrective action taken or preventative measures adopted. [63.10(c)(l 1)]
the nature of the repairs or adjustments to the CMS that was inoperative or out of
control. [63.10(c)(12)]

the total process operating time during the reporting period. [63.10(c)(13)]
all procedures that are part of a quality control program developed and
implemented for CMS under 63.8(d). [63.10(c)(14)]

Some of the reporting may be satisfied with elements of the startup, shutdown and malfunction
plant reports.

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APPENDIX C

APPENDIX C-4. STARTUP, SHUTDOWN, AND MALFUNCTION

REPORT

[§63.6(e)(3)(iii)part] (If the SSM Plan is followed and the CMS repaired immediately, this action
shall be reported in the semiannual startup, shutdown, and malfunction report required under
63.10(d)(5)(i).)

[§63.6(e)(3)(iii) When actions taken by the facility during a startup, shutdown, or malfunction
(including actions taken to correct a malfunction) are consistent with the procedures specified in
the affected source's SSM plan, the facility shall keep records for that event that demonstrate that
the procedures specified in the plan were followed. These records may take the form of a
"checklist", or other effective form of recordkeeping, that confirms conformance with the SSM
plan for that event. In addition, the owner or operator shall keep records of these events as
specified in §63.10(b) (and elsewhere in this part), including records of the occurrence and
duration of each startup, shutdown, or malfunction of operation and each malfunction of the air
pollution control equipment. Furthermore, the facility shall confirm that actions taken during the
relevant reporting period during periods of startup, shutdown and malfunction were consistent
with the affected source's SSM plan in the semiannual (or more frequent) SSM report required in
§63.10(d)(5).

[§63.6(e)(3)(iv) If an action taken by the facility during a SSM (including an action taken to
correct a malfunction) is not consistent with the procedures specified in the affected source's
SSM plan, the facility shall record the actions taken for that event and shall report such actions
within 2 working days after commencing actions inconsistent with the plan, followed by a letter
within 7 working days after the end of the event, in accordance with §63.10(d)(5) (unless the
facility makes alternative reporting arrangements, in advance, with the Administrator (see
§63.10(d)(5)(ii)).

§63.866(b) REQUIRED GENERAL RECORDS

[§63.866(b)] The facility must maintain records of any occurrence when corrective action is
required under §63.864(k)(l) and when a violation is noted under §63.864(k)(2).

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APPENDIX C

APPENDIX C-5. GENERAL REPORTING REQUIREMENTS

[63.867(a)] The facility must submit the applicable notifications from subpart A of this part
(§63.1 through §63.15) as specified in Table 1 of this subpart.

CMS REPORTING

§63.10(c) Additional recordkeeping requirements for sources with continuous monitoring
systems

A facility that must install a CMS shall maintain records of:

all required CMS measurements including monitoring data recorded during

unavoidable CMS breakdowns and out-of-control periods. [63.10(c)(1)]

the date and time identifying each period during which the CMS was inoperative

except zero (low-level) and high-level checks.[63.10(c)(5)]

the date and time identifying each period during which the CMS was out of

control as defined in 63.8(c)(7). [63.10(c)(6)]

the specific identification (i.e. the date and time of commencement and
completion) of each period of excess emissions and parameter monitoring
exceedances that occurs during startups, shutdowns and malfunctions.
[63.10(c)(7)]

the specific identification (i.e. the date and time of commencement and
completion) of each period of excess emissions and parameter monitoring
exceedances that occurs during periods other than startups, shutdowns and
malfunctions. [63.10(c)(8)]

the nature and cause of any malfunction (if known). [63.10(c)(10)]
the corrective action taken or preventative measures adopted. [63.10(c)(l 1)]
the nature of the repairs or adjustments to the CMS that was inoperative or out of
control. [63.10(c)(12)]

the total process operating time during the reporting period. [63.10(c)(13)]
all procedures that are part of a quality control program developed and
implemented for CMS under 63.8(d). [63.10(c)(14)]

Some of the reporting may be satisfied with elements of the startup, shutdown and malfunction
plan reports.

Summary report see 63.10(e)(3)(vi)

The facility must notify the Administrator before

any air pollution control system for any process unit is modified or replaced.
[§63.867(b)(3)(i)]

a CMS parameter or the value or range of values of a CMS for any process unit is
changed

37


-------
APPENDIX D

APPENDIX C-6. EXCESS EMISSIONS REPORTING

REQUIREMENTS

§ 63.867 (c) The owner or operator must report quarterly if measured parameters meet any of the
conditions specified in paragraph (k)(l) or (2) of § 63.864. This report must contain the
information specified in § 63.10(c) of this part as well as the number and duration of occurrences
when the source met or exceeded the conditions in § 63.864(k)(l), and the number and duration
of occurrences when the source met or exceeded the conditions in § 63.864(k)(2). Reporting
excess emissions below the violation thresholds of § 63.864(k) does not constitute a violation of
the applicable standard.

§ 63.867 (c)(1) When no exceedances of parameters have occurred, the owner or operator must
submit a semiannual report stating that no excess emissions occurred during the reporting period.

§ 63.867 (c)(2) The owner or operator of an affected source or process unit subject to the
requirements of this subpart and subpart S of this part may combine excess emissions and/or
summary reports for the mill.

38


-------
APPENDIX D

APPENDIX C-7. OPERATION AND MAINTENANCE

REQUIREMENTS

§63.6(e) Operation and maintenance requirements.

§63.8(c)(l)(i) The facility shall

ensure the immediate repair or replacement of Continuous Monitoring System (CMS)
parts to correct "routine" or otherwise predictable CMS malfunctions as defined in the
source's startup, shutdown, and malfunction plan required by §63.6(e)(3)
keep the necessary parts for routine repairs of the affected equipment readily available

Determination of whether acceptable operation and maintenance procedures are being used will
be based on information available to the Administrator which may include, but is not limited to
monitoring results, review of operation and maintenance procedures (including the startup,
shutdown, and malfunction plan required in paragraph 63.6(e)(3) , review of operation and
maintenance records, and inspection of the source. [§63.6(e)(2)]

Operation and maintenance requirements established pursuant to section 112 of the Act are
enforceable independent of emissions limitations or other requirements in relevant standards.
[§63.6(e)(l)(iii)]

39


-------
APPENDIX D

APPENDIX C-8. SEMI-ANNUAL REPORTS

§63.8(c)(l)(i) requires that if actions are taken during a startup, shutdown or malfunction
(including actions taken to correct a malfunction) are consistent with the procedures specified in
the SSM plan they shall be reported by the 30th day following the end of each calendar half (or
other calendar reporting period, as appropriate.)

The report shall consist of a letter with the name, title and signature of the owner or operator or
other reasonable official who is certifying its accuracy.

40


-------
APPENDIX D

APPENDIX C-9. IMMEDIATE REPORTING

§63.10(d)(5)(ii) requires that if actions are taken during a startup, shutdown or malfunction
(including actions taken to correct a malfunction) are not consistent with the procedures
specified in the SSM plan they shall be reported within 2 working days (by telephone call or
FAX) after commencing actions inconsistent with the SSM Plan followed by a letter within 7
days after the end of the event.

The report shall consist of a letter with the name, title and signature of the owner or operator or
other reasonable official who is certifying its accuracy, explaining
the circumstances of the event
the reasons for not following the SSM Plan

whether any excess emissions and/or parameter monitoring exceedances are believed to
have occurred.

41


-------
APPENDIX D

APENDIX C-10. MONITORING REQUIREMENTS

§63.864(j) Determination of operating ranges (1) During the initial performance test required in
§63.865, the owner or operator of any affected source or process unit must establish operating
ranges for the monitoring parameters in paragraphs (e)(10) through (14) of this section; or

§63.864(j)(2) The owner or operator may base operating ranges on values recorded during
previous performance tests or conduct additional performance tests for the specific purpose of
establishing operating ranges, provided that test data used to establish the operating ranges are or
have been obtained using the test methods required in this subpart. The owner or operator of the
affected source or process unit must certify that all control techniques and processes have not
been modified subsequent to the testing upon which the data used to establish the operating
parameter ranges were obtained.

§63.864(j)(3) The owner or operator of an affected source or process unit may establish
expanded or replacement operating ranges for the monitoring parameters values listed in
paragraphs (e)(10) through (14) of this section and established in paragraph (j)(l) or (2) of this
section during subsequent performance tests using the test methods in §63.865.

§63.864(k) On-going compliance provisions (1) Following the compliance date, owners or
operators of all affected sources or process units are required to implement corrective action, as
specified in the STARTUP, SHUTDOWN, AND MALFUNCTION PLAN section AND IN
§63.866(a) if the monitoring exceedances identified as Tier I in Appendix A occur. (Also see
§63.864(k)(l)(i) through (vii))

§63.864(k)(2) Following the compliance date, owners or operators of all affected sources or
process units are in violation of the standards of §63.862 if the monitoring exceedences
identified as Tier II in Appendix A occur. (Also see §63.864(k)(2)(i) through (vii))

§63.864(k)(3) For the purposes of determining the number of nonopacity monitoring
exceedences, no more than one exceedance will be attributed in any given 24-hour period.

§63.865 The owner or operator of each affected source or process unit subject to the
requirements of this subpart is required to conduct an initial performance test using the test
methods and procedures listed in §63.7 and paragraph (b) of this section except as provided in
paragraph 63.865(c)(1)

§63.865(c)(1) The owner or operator complying through the use of an NDCE recovery furnace
equipped with a dry ESP system is not required to conduct any performance testing to
demonstrate compliance with the gaseous organic HAP standard.

42


-------
APPENDIX D

APPENDIX D-l. INSPECTING PM COMPLIANCE BUBBLED

SOURCES

(§63.862 (a)(l)(ii)(A) - Existing kraft or soda pulp mill PM emission limits)

This applies to recovery furnace, smelt dissolving tanks and like kilns that operate 6,300 hours
per year or more. The equation to be used is as follows:

ELpm = [(Cref, RF)(QRFtot)+(Cref, LK)(QLKtot)](Fl)/(BLStot)+ERlref, SDT

Where:

ELpm

Cref, RF

= overall PM emission limit for all existing process units in the chemical
recovery system at the kraft or soda pulp mill, kg/Mg (lb/ton) of black liquor
solids fired.

= reference concentration of 0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent
oxygen for existing kraft or soda recovery furnaces.

QRFtot	= sum of the average volumetric gas flow rates measured during the performance

test and corrected to 8 percent oxygen for all existing recovery furnaces in the
chemical recovery system at the kraft or soda pulp mill, dry standard cubic meters
per minute (dscm/min) (dry standard cubic feet per minute [dscf/min]).

Cref, lk	= reference concentration of 0.15 g/dscm (0.064 gr/dscf) corrected to 10 percent

oxygen for existing kraft or soda lime kilns.

Qijctot	= sum of the average volumetric gas flow rates measured during the performance

test and corrected to 10 percent oxygen for all existing lime kilns in the chemical
recovery system at the kraft or soda pulp mill, dscm/min (dscf/min).

F1	= conversion factor, 1.44 minutes ;kilogram/day gram (min kg/d g) (0.206

minutes pound/day grain [min lb/d gr]).

BLStot	= sum of the average black liquor solids firing rates of all existing recovery

furnaces in the chemical recovery system at the kraft or soda pulp mill measured
during the performance test, megagrams per day (Mg/d) (tons per day [tons/d]) of
black liquor solids fired.

ER1 ref, sdt reference emission rate of 0.10 kg/]V[g (0.20 lb/ton) of black liquor solids fired
for existing kraft or soda smelt dissolving tanks.

43


-------
APPENDIX D

Verify overall PM emission limit (ELPM)

Data from performance tests.

Recovery Furnaces
(Identification)

Average QRF
(dscf/min)

Average BLS fired
(tons/day)

QfRi

tot

Lime Kilns
(Identification)

BLS

tot

Average Qlk
(dscf/min)

QLKtot —

Calculation

A- [(Cref, Rf)(	QRFtot	) + (Cref,LK)( QLKtot )](F1)

A = [(0.044)(	) + (0.064)(	)] (1.44)

ELpm = [( A	)/(	BLStot )] + ERlref, SDT

ELpm = [(	)/(	)] + 0.20 =

44


-------
APPENDIX D

Verify established emission limits for recovery furnaces (ERrf)

ERrf = (F1)(Cel, rf )(Qrf )/(BLS)

Where:

ERrf = emission rate from each recovery furnace, kg/Mg (lb/ton) of black liquor solids.

F1 = conversion factor, 1.44 min kg/d g (0.206 min /d gr).

Cel, rf = PM emission limit proposed by the facility for the recovery furnace, g/dscm
(gr/dscf) corrected to 8 percent oxygen.

Qrf = average volumetric gas flow rate from the recovery furnace measured during the
performance test and corrected to 8 percent oxygen, dscm/min (dscf/min).

BLS = average black liquor solids firing rate of the recovery furnace measured during the
performance test, Mg/d (ton/d) of black liquor solids.

Data from performance tests.

Recovery Furnaces F1	Proposed	Average	/Average	ERrf

Furnaces	Limit	QRF	BLS fired

(Identification)	(gr/dscf)	(dscf/min)	(tons/day)

	 1.44					/	

	 1.44					/	

	 1.44					/	

	 1.44					/	

1.44	/

45


-------
APPENDIX D

Verify established emission limits for smelt dissolving tanks (ERSDT)

ERsdt = (F1)(Cel, sdt)(Qsdt )/[(BLS)(R)]

Where:

ERsdt = emission rate from each smelt dissolving tank, kg/Mg (lb/ton) of black liquor
solids fired.

F1 = conversion factor, 1.44 min kg/d g (0.206 min /d gr).

Cel, sdt = PM emission limit proposed by the facility for the recovery furnace, g/dscm
(gr/dscf).

Qsdt = average volumetric gas flow rate from the smelt dissolving tank measured during
the performance test, dscm/min (dscf/min).

BLS = average black liquor solids firing rate of the associated recovery furnace measured
during the performance test, Mg/d (ton/d) of black liquor solids. If more than one SDT is
used to dissolve the smelt from a given recovery furnace, then the black liquor solids
firing rate of the furnace must be proportioned according to the size of the SDT.

R = Ratio of SDT tank size to the other SDT that are used to dissolve the smelt from a
given recovery furnace.

Data from performance tests.

Smelt Dissolving	F1	Proposed	Average	/(Average	Size)	ERsdt

Tanks	Limit	Qsdt	BLS fired	Ratio

(Identification)	(gr/dscf)	(dscf/min)	(tons/day)	of SDT

		1.44					/(			)		

		1.44					/(			)		

		1.44					/(			)		

		1.44					/(			)		

		1.44					/(			)		

		1.44					/(			)		

		1.44					/(			)		

46


-------
APPENDIX D

Verify established emission limits for lime kilns (ERLK)

ERlk = (F1)(Cel, lk)(Qlk )(CaOtot/BLStot)/(CaOLK)

Where:

ERlk = emission rate from each lime kiln, kg/Mg (lb/ton) of black liquor solids.
F1 = conversion factor, 1.44 min kg/d g (0.206 min /d gr).

Cel, lk=PM emission limit proposed by the facility for the lime kiln, g/dscm (gr/dscf)
corrected to 8 percent oxygen.

Qlk = average volumetric gas flow rate from the lime kiln measured during the
performance test and corrected to 10 percent oxygen, dscm/min (dscf/min).

CaOtot = sum of the average lime production rates of all existing lime kilns in the
chemical recovery system at the mill measured as CaO during the performance test,
Mg/d(lb/ton).

BLStot = sum of the average black liquor solids firing rate of the recovery furnaces in the
chemical recovery system at the mill measured as CaO during the performance test, Mg/d
(ton/d).

CaOuc = lime production rate of the lime kiln, measured as CaO during the performance
test, Mg/d(lb/ton) of CaO.

Data from performance tests.

Lime	F1	Proposed	Average	(Total	/Total )/Lime	ERrf

Kilns	Limit	Qlk	CaO	BLS fired

(ID)	(gr/dscf)	(dscf/min)	(tons/day)

		1.44					(			)/			

		1.44					(			)/			

		1.44					(			)/			

		1.44					(			)/			

		1.44					(			)/			

		1.44					(			)/			

47


-------
APPENDIX D

Verify established overall PM emission rate (ERPUtot)

(i.e. group by process types)

ERputot= (ERpui)(PRpui / PRtot) + . . . + (ERpui)(PRpui / PRtot)

Where:

ERputot = overall PM emission rate from all similar process units, kg/Mg (lb/ton) of black
liquor solids fired.

ERpui = PM emission rate from process unit No. 1, kg/Mg (lb/ton) of black liquor solids
fired, calculated using Equation 2, 3, or 4 in paragraphs (a)(2)(i) through (iii)
of §63.865.

PRpui = black liquor solids firing rate in Mg/d (ton/d) for process unit No. 1, if process
unit is a recovery furnace or SDT. The CaO production rate in Mg/d (ton/d) for process
unit No. 1, if process unit is a lime kiln.

PRtot = total black liquor solids firing rate in Mg/d (ton/d) for all recovery furnaces in the
chemical recovery system at the kraft or soda pulp mill if the similar process units are
recovery furnaces or SDT, or the total CaO production rate in Mg/d (ton/d) for all lime
kilns in the chemical recovery system at the mill if the similar process units are lime
kilns.

ERpui = PM emission rate from process unit No. i, kg/Mg (lb/ton) of black liquor solids
fired.

PRpui = black liquor solids firing rate in Mg/d (ton/d) for process unit No. i, if process
unit is a recovery furnace or SDT. The CaO production rate in Mg/d (ton/d) for process
unit No. i, if process unit is a lime kiln.

i = number of similar process units located in the chemical recovery system at the kraft or
soda pulp mill.

48


-------
Recovery Furnaces

Data from performance tests.

Recovery	ERrf	(PRrf	/ PRtot) =

Furnaces	BLS fired	BLS fired

(ID)	(lb/ton)(tons/day)	(tons/day)

( / )

/

/

/

/

/

/

/

/

/

/

/

ERRFtot

APPENDIX D

49


-------
Smelt Dissolving Tanks

Data from performance tests.

Recovery	ERSdt	(PRrf	/ PRtot) =

Furnaces	BLS fired	BLS fired

(ID)	(lb/ton)(tons/day)	(tons/day)

( / )

/

/

/

/

/

/

/

/

/

/

/ 	

ERsDTtot

APPENDIX D

50


-------
APPENDIX D

Lime Kilns

Data from performance tests.

Lime
Kilns
(ID)

ERlk	(PRlk	/ PRtot) ~

CaO production CaO production
(lb/ton)(tons/day)	(tons/day)

ER,

LKtot

51


-------
APPENDIX D

Verify established overall PM emission rate (ERPUtot)

ERtot — ERRFtot ERsDTtot ERLKtot

Where:

ERtot = overall PM emission rate for the chemical recovery system at the mill, kg/Mg
(lb/ton) of black liquor solids fired.

ERRFtot = PM emission rate from all kraft or soda recovery furnaces, calculated using
Equation 2 or 5 in paragraphs (a)(2)(i) and (iv) of this section, where applicable, kg/Mg
(lb/ton) of black liquor solids fired.

ERsoxtot = PM emission rate from all smelt dissolving tanks, calculated using Equation 3
or 5 in paragraphs (a)(2)(ii) and (iv) of this section, where applicable, kg/Mg (lb/ton) of
black liquor solids fired.

ERLKtot = PM emission rate from all lime kilns, calculated using Equation 4 or 5 in
paragraphs (a)(2)(iii) and (iv) of this section, where applicable, kg/Mg (lb/ton) of black
liquor solids fired.

52


-------
APPENDIX E

APPENDIX E-l APPLICABILITY ASSESSMENT

Does the facility recover chemicals

from its pulping process by
combusting spent pulping liquor?

Note: the SIC codes for these
were 2611, 2621 & 2631
(NAICS codes are 32211,
32212 & 32213).

U

Is the pulping process kraft, soda,
sulfite or stand alone
semi-chemical?

Does the mill emit or have the potential to emit
at least 10 tons per year of a single or at least
25 tons per year of any combination of gaseous
organic HAP(s) and HAP metal emissions?

Note: Potential to emit
means the maximum
capacity of a stationary
source to emit a pollutant

under its physical and
operational design. Any
federally enforceable
emissions limitation
shall be treated as
part of the design.

Note: You must consider all HAPs,
however, the most common gaseous
organic HAPs are:

•Benzene
•Formaldehyde
•Hydrochloric Acid
•Methanol
•Methyl Ethyl Ketone
•Methyl Isobutyl Ketone
•Phenol
•Toluene
•Xylene

53

Note: You must consider all HAPs,
however, the most common metal
HAPs are:

•Antimony

•Arsenic
•Beryllium
•Cadmium
•Chromium

•Lead
•Manganese
•Mercury

•Nickel
•Selenium


-------
	APPET'JDIj

Note: You must consider all HAPs.	Tons

Per Year

Most common gaseous organic HAPs:

Benzene
Formaldehyde
Hydrochloric Acid
Methanol

Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Phenol
Toluene
Xylene

Most common metal HAPs:

Antimony
Arsenic
Beryllium
Cadmium
Chromium
Lead

Manganese
Mercury
Nickel
Selenium

Additional HAPs:

Total Tons Per Year of HAPs

54


-------
APPENDIX E

APPENDIX E-2 FORM SELECTION PROTOCOL

Was the affected unit
constructed or reconstructed
with commencement of
construction or reconstruction
occurring after April 14,1998?

NO

EXISTING
SOURCES

Yes

NEW
SOURCES

55


-------
APPENDIX E

NEW
SOURCES

Kraft or Soda Chemical Recovery
System?

NDCE Recovery Furnace?

Electrostatic Precipitator?

Use forms:

APPENDIX A-l. NEW KRAFT OR SODA NDCE RECOVERY
FURNACE - ESP

APPENDIX 1-1. SAMPLE CALCULATIONS FOR

ELECTROSTATIC PRECIPITATORS

APPENDIX Fl. INSPECTING ELECTROSTATIC

PRECIPITATORS

APPENDIX C.

Scrubber?

Use forms:

APPENDIX A-2. NEW KRAFT OR SODA NDCE RECOVERY
FURNACE - SCRUBBER
APPENDIX C.

APPENDIX F-2. SAMPLE CALCULATIONS WET SCRUBBERS
APPENDIX Gl. INSPECTING SCRUBBERS

56


-------
APPENDIX E

DCE Recovery Furnace?

Electrostatic Precipitator?

Use forms:

APPENDIX A-3. NEW KRAFT OR SODA DCE RECOVERY
FURNACE - ESP
APPENDIX C.

APPENDIX 1-1. SAMPLE CALCULATIONS
ELECTROSTATIC PRECIPITATORS

APPENDIX F. INSPECTING ELECTROSTATIC PRECIPITATORS
Scrubber?

Use forms:

APPENDIX A-2. NEW KRAFT OR SODA NDCE OR DCE
RECOVERY FURNACE - WET SCRUBBER
APPENDIX C.

APPENDIX 1-2. SAMPLE CALCULATIONS WET SCRUBBERS
APPENDIX H-2. INSPECTING REGENERATIVE THERMAL
OXIDERS

Smelt Dissolving Tank?

Scrubber?

Use Form

APPENDIX A-4 NEW KRAFT OR SODA SMELT DISSOLVING
TANK - WET SCRUBBER
APPENDIX C.

APPENDIX 1-2. SAMPLE CALCULATIONS FOR WET SCRUBBERS
APPENDIX G-l. INSPECTING WET SCRUBBERS

57


-------
APPENDIX E

Lime Kiln?

Electrostatic Precipitator?

Use Forms:

APPENDIX A-5. NEW KRAFT OR SODA LIME KILN - ESP
APPENDIX C. IPT ELECTROSTATIC PRECIPITATORS
APPENDIX 1-1. SAMPLE CALCULATIONS ELECTROSTATIC
PRECIPITATORS

APPENDIX F. INSPECTING ELECTROSTATIC PRECIPITATORS
Scrubber?

Use Forms:

APPENDIX A-6. NEW KRAFT OR SODA LIME KILN - SCRUBBER
APPENDIX C. IPT WET SCRUBBERS

APPENDIX 1-2. SAMPLE CALCULATIONS FOR WET SCRUBBERS
APPENDIX G-l. INSPECTING WET SCRUBBERS

58


-------
APPENDIX E

Sulfite pulping?

Recovery Furnace?



Scrubber?



Use Forms:



APPENDIX A. NEW SULFITE RECOVERY

FURNACE - SCRUBBER

APPENDIX C



APPENDIX 1-2. SAMPLE CALCULATIONS

WET SCRUBBERS

APPENDIX G-l. INSPECT SCRUBBERS

•



59


-------
APPENDIX E

Stand alone Semi-chemical pulping?



Regenerative Thermal Oxidizer?

Use Forms:

•

APPENDIX A-14. ALL EXISTING STAND ALONE SEMICHEMICAL



(ALL RECOVERY METHODS) - RTO

•

APPENDIX H-l. IPT REGENERATIVE THERM AT, OXIDIZERS

•

APPENDIX 1-3. SAMPLE CALCULATIONS REGENERATIVE



THERMAL OXIDIZERS

•

APPENDIX 1-3. INSPECTING REGENERATIVE THERM AT,

•

OXIDIZERS

60


-------
APPENDIX E

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61


-------
APPENDIX E



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62


-------
APPENDIX E

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63


-------
APPENDIX E

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64


-------
APPENDIX E

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65


-------
APPENDIX F

APPENDIX F-l. INSPECTING ELECTROSTATIC PRECIPITATORS

Electrostatic precipitators (ESP) are designed for sufficient collection plate area to ensure capture
of particulate matter at a given volumetric flow rate. The principle design parameter is the
Specific Collection Area (SCA). The SCA is defined as the total square footage of collecting
area per 1000 acfm of flue gas flow rate. For pulp mills this variable typically range from 200 to
800 square feet per 1,000 actual cubic feet per minute.

COLLECTION PLATE AREA

Total Number of collection plates (N)		

Height of each collection plate (H)		ft

Width of collection each plate (W)		ft

Use the following formula to calculate the Total Collection Plate Area(TCPA) of
the Electrostatic Precipitator

TCP A = (N-1)*2*W*L		sq ft

(Note: Some parts of the ESP may have different collection plate dimensions than in other parts.
In those cases, use the above formula for each part to determine the collection plate area for each
part and add them together to obtain the total collection plate area.)

VOLUMETRIC FLOW RATE AT ESP

During the source test, the volumetric flow rate in the stack (QS) is calculated. This, with the
stack temperature (FS) and the temperature at the inlet of the scrubber (FCD), can be used to
calculate the volumetric flow rate at the inlet which is needed to calculate the SCA. The
volumetric flow rate at the ESP (QCD) is determined by the following equation:

QCD = (QS * (FCD + 459.67))/(FS + 459/67)

where the measured temperatures are in degrees F. The ESP volumetric flow rate can then be
correlated with some measure of fan performance such as motor RPMs, amperes or kilowatts. In
this way, volumetric flow rates can be estimated at any time.

Aside from verifying proper design, another important operational element of ESP performance
is the electrical charging and collection of particulate matter. This should be evaluated for each
field in the unit.

CORONA GENERATION

66


-------
APPENDIX F

Before the ESP can charge and capture particles, a corona must be established at the electrodes
that provides the requisite rich field of electrons. The electrical component that controls this is
the Transformer - Rectifier Control (TRC). There is a minimum threshold of primary power that
must be applied to ensure the corona has been established. During each run of the source test,
the voltage applied and the amperes flowing through the primary side of the transformer are
recorded for each TRC and checked against design specifications. The primary watts (PW), the
product of the volts and the amperes) are then calculated for each field.

SECONDARY WATTS

There may be sufficient power applied to the primary side of the transformers but this does not
mean the corona is established. Consequently, voltage (kilovolts) and current (milliamperes)
occurring on the secondary side of the transformer are likewise recorded for each field and
compared to the design specifications. The secondary watts (SW) are also calculated.

POWER FACTOR

The measure of the electrical performance of the ESP are the voltage and current readings of the
TRC. It is vital that the meters are operating correctly. One method of "discovering" ESP
operation problems is to calculate the power factor for each field. By establishing a Power
Factor baseline for each field, these can be referred to during other times. The power factor is
calculated by the following equation:

PF = SW/PW

The Power Factor is typically between 0.75 and 0.85. It can never be greater than unity. If the
Power Factor is abnormally low or high, there may be reason to suspect the meters, the rapper
system or distributor plate problems.

TOTAL SECONDARY WATTS

The Total Secondary Watts (TSW) is a good measure of the overall performance of the ESP in
terms of particle collection. This is calculated by totaling the Secondary Watts for all the fields.

POWER DISTRIBUTION IN ESP

An important baseline evaluation is to compare the Secondary Watts for corresponding fields in
the channels of the ESP. (Some ESPs are single channel units and, in those, side by side
comparison would, of course, not be possible.) For example, in a two channel unit the two inlet
fields should generate equal or nearly equal Secondary Watts in each. By comparing each to the
total of the two, a percentage split can be calculated with a 50:50 split being ideal. A large

67


-------
APPENDIX F

difference in the two might indicate inaccurate meters or malfunctioning TRC units. If these are
working correctly then the rapper system may be suspect. Finally, unbalanced power
distribution could indicate significant wear or plugging of the flue gas flow distributor plates.
These side by side comparisons should be made for each field set. Finally, the Total Secondary
Watts should be calculated for each channel and the overall split calculated. Again, this should
be a 50:50 split. Once the baseline splits are calculated they will serve as the basis for future
evaluation of the unit to ensure it is not deteriorating.

POWER DENSITY

Another more universal parameter to calculate during the Initial Performance Test is the Power
Density (PD), in Watts per Square Foot, of the ESP. This is calculated by the following formula:

PD = TSW / TCP A
RAPPERS

In order for the ESP to operate at design efficiencies, it is important that collected particulate
matter be periodically removed from the collection plates to ensure there is sufficient electrical
potential difference between the particles the plate to attract them sufficiently. These units are
equipped with a physical removal system that provide mass shock to various components of the
ESP. This is normally done either by a hammer drop system or vibrator system or a combination
of both. These systems are located on the top of the ESP and consist of a large number of
individual units. These need to be observed individually to ensure they are operating correctly.
Each rapper is visited and observed being actuated. Through a combination of visual and audio
observation, it can be determined that is operating correctly. (If it does not physically move or
make solid contact with the momentum transfer rods extending through the roof the ESP, then
maintenance is necessary. If there is contact but the sound of the contact is significantly
different than with other rappers, then maintenance may be needed.) Finally, with vibrator
systems, there is a compressed air system providing the necessary energy. The compressed air
pressure (psi) of this system should be recorded during the source test for subsequent review.

RAPPER SEQUENCE

Obtain a plot of the rapping sequence from the company for each ESP. During the inspections,
the inspector "walks" the sequencing rappers to be sure they are operating correctly and sound
proper. It is normal for the outlet end of an ESP to have a less frequent rapping than the inlet
end. This is because the collection efficiency of each section is very high. For example, in most
designs, over 90% of the flue gas laden particulate matter is collected in the first field.
Consequently, only about 10% moves on to the second field where over 90% of that is removed.
By the time the flue gas reaches the outlet, there is little particulate matter left to remove and the
lighter accumulation requires less rapping frequency. Any time the rapping system is actuated,

68


-------
APPENDIX F

however, some of the previously captured particulate matter is re-entrained to be partially
captured down stream. From the outlet field, any re-entrained particulate matter will not be
captured so the rapping frequency ought to be minimized at the outlet.

69


-------
APPENDIX F

APPENDIX F-2. SINGLE PASS, 2 FIELD ESP

Power Factor Primary Watts

Primary Volts

Primary Amps

1 1

Secondary Watts

Secondary Kilovolts

Secondary Milliamps

Power Factor Primary Watts

Primary Volt

Primary Amps

Secondary Watts

Secondary Kilovolts

Secondary Milliamps

Total Secondary Watts

Total Plate Area (Square Feet) Total Secondary Watts per Square Foot of Plate Area

70


-------
APPENDIX F

APPENDIX F-3. SINGLE PASS, 3 FIELD ESP

Power Factor	Primary Watts

Secondary Watts

Power Factor	Primary Watts

Secondary Watts

Power Factor	Primary Watts

Secondary Watts

Total Plate Area (Square Feet)
Area

Primary Volts

Primary Amps

Secondary Kilovolts

Secondary Milliamps

Primary Volts

Primary Amps

Secondary Kilovolts

Secondary Milliamps

Primary Volts

Primary Amps

Secondary Kilovolts

Secondary Milliamps

Total Secondary Watts

Total Secondary Watts per Square Foot of Plate

71


-------
APPENDIX F

APPENDIX F-4. 2 CHANNEL, 2 FIELD ESP

Power Factor Primary Watts
Factor

% Split Secondary Watts

Power Factor Primary Watts
Factor

% Split Secondary Watts
Split

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Secondary Kilovolts

Secondary Milliamps

Secondary Kilovoli

; Secondary Milliamps

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Secondary Kilovolts

Secondary Milliamps

Secondary Kilovolt

Secondary Milliamps

Primary Watts Power

IZZIIZZI

Secondary Watts % Split

Primary Watts Power

Secondary Watts %

Overall
% Split

Channel

Secondary Watts

IZZI i	1

Total Secondary Watts

i	1

Channel	Overall

Secondary Watts % Split

I	1

Total Plate Area (Square Feet)

Total Secondary Watts per Square Foot of Plate Area

72


-------
APPENDIX F

73


-------
APPENDIX F

APPENDIX F-5. 2 CHANNEL, 3 FIELD ESP	

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Overall
% Split

Channel

Secondary Watts

Total Secondary Watts

Channel

Secondary Watts

Overall
% Split

Total Plate Area (Square Feet)

Total Secondary Watts per Square Foot of Plate Area

74


-------
APPENDIX F

APPENDIX F-6. 2 CHANNEL, 4 FIELD ESP

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Overall Channel	Channel	Overall

% Split		Secondary Watts	Total Secondary Watts	Secondary Watts % Split

Total Plate Area (Square Feet)	Total Secondary Watts per Square Foot of Plate Area

75


-------
APPENDIX F

APPENDIX F-7. 2 CHANNEL, 5 FIELD ESP

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Overall
% Split

Channel

Secondary Watts

Total Secondary Watts

Channel	Overall

Secondary Watts % Split

~

Total Plate Area (Square Feet)

Total Secondary Watts per Square Foot of Plate Area

76


-------
APPENDIX F

APPENDIX F-8. 2 CHANNEL, 6 FIELD ESP

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

Power Factor

Primary Watts

Primary Volts

Primary Amps

Primary Volts

Primary Amps

Primary Watts

Power Factor

% split

Secondary
Watts

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Kilovolts

Secondary
Milliamps

Secondary
Watts

% split

77


-------
APPENDIX F

Overall
% Split

Channel

Secondary Watts

Total Secondary Watts

Channel	Overall

Secondary Watts % Split

~

Total Plate Area (Square Feet)

Total Secondary Watts per Square Foot of Plate Area

78


-------
APPENDIX G

APPENDIX G-l. INSPECTING WET SCRUBBERS

LIQUID TO GAS RATIO

The principle design variable for a scrubber is the Liquid to Gas Ratio (in Gallons of Scrubbing
Liquid pumped to the nozzles per 1000 Actual Cubic Feet per Minute of gas flow through the
unit). This sets the proper balance between sufficient liquid to contact the pollutant with
sufficient volumetric flow rate to ensure fracturing the moisture into the proper droplet size.
Typically, this variable ranges from 3 to 10 gallons per 1,000 actual cubic feet.

SCRUBBING LIQUID FLOW RATE

During the source test, the scrubbing liquid flow rate, in gallons per minute, should be recorded
during each test run.

SCRUBBING LIQUID PRESSURE

In some NSPS applications, such as for Smelt Dissolver Tank Vents in Kraft Pulp Mills, the line
pressure of the scrubbing liquid is required to be logged. Consequently, some mills meter this
parameter for non NSPS scrubbers even if not specifically required. It does not equate to the
liquid to gas ratio nor does it relate to the pressure differential across the unit. It does, however,
relate to the energy transfer in the scrubber not unlike the momentum change indicated by the
pressure differential. If this parameter is being metered, it should be recorded during the runs of
the Initial Performance Tests and during inspections.

VOLUMETRIC FLOW RATE AT SCRUBBER

During the source test, the volumetric flow rate in the stack is calculated. This, with the stack
temperature and the temperature at the inlet of the scrubber, can be used to volumetric the
volumetric flow rate at the inlet which is needed for the liquid to gas ratio. The volumetric flow
rate at the scrubber (Qcd) is determined by the following equation:

Qcd = (Qs * (Fcd + 459.67))/(Fs + 459.67)

The scrubber volumetric flow rate can then be correlated with some measure of fan performance
such as motor RPMs, amperes or kilowatts. In this way, volumetric flow rates can be estimated
at any time.

DIFFERENTIAL PRESSURE ACROSS THE SCRUBBER

Provided there is sufficient scrubbing liquid and volumetric flow rate to theoretically capture the
pollutants, another variable, the scrubber differential pressure, or pressure drop, suggests the
momentum lost in the gas stream as the particles are captured in the liquid.

79


-------
APPENDIX G

NOZZLE PLUGGING

Scrubber nozzles are subject to plugging since they have a very small orifice through which the
liquid is forced. The head of the flue gas environment around the outside of the nozzles
contributes to the build up of solids that will eventually plug it. A plugged nozzle allows an area
in the cross section of the water spray matrix to be devoid of water which lets the flue gas pass
through untreated. Whether or not a nozzle is plugged or plugging can be evaluated by noting
the temperature of the nozzle pipe as it enters the scrubber and comparing it to the pipe
temperature of the main scrubbing liquid feed. Typically, a different temperature of one nozzle
pipe comparted to the others indicates plugging.

INITIAL PERFORMANCE TEST EVALUATION - WET SCRUBBER

Data

Scrubbing liquid flow rate (gallons per minute)

Pressure Drop across scrubber (inches W.C.)

Scrubbing liquid pressure (psi)

Volumetric flow rate at stack (acfm)

Flue gas temperature in stack (F)

flue gas temperature at inlet to scrubber (F)

Measured volumetric flow rate at inlet to scrubber (acfm), and/or

Fan Motor Amperes (amperes), and/or

Fan Motor Kilowatts (kilowatts), and/or

Fan RPMs (rpms), and/or

RPM reduction reading (%), and/or

Other variable

Evaluation of nozzles (plugging/plugged)

Calculations

Volumetric flow rate at scrubber

acfm in stack * (

o

F at scrubber + 459.67)

(.

o

F in stack + 459.76)

Volumetric Flow Rate Surrogate

	acfm at scrubber

80


-------
APPENDIX G

	amperes, or, kilowatts, or, rpm, or %, or other

Liquid to Gas Ratio

(	gallons per minute * 1000)

acfm

81


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APPENDIX G

APPENDIX G-2. EXAMPLE OF DATA FORM FOR WET
SCRUBBER (PLAN VIEW)

NOZZLE

NOZZLE

NOZZLE

NOZZLE

NOZZLE

NOZZLE

o

F

PSI	HEADER PIPE

SCRUBBER LIQUID PRESSURE

82


-------
APPENDIX G

APPENDIX G-3. EXAMPLE OF DATA FORM FOR WET
SCRUBBER (FRONT VIEW)

NOZZLE

=o

PSI

=o

GPM

83


-------
APPENDIX G

APPENDIX G-4. EXAMPLE OF DATA FORM FOR WET
SCRUBBER (PLAN AND FRONT VIEW)

NOZZLE

NOZZLE

I D. FAN RATING

GEAR SETTING

ACFM

HEADER
PIPE


-------
APPENDIX G

APPENDIX G-5. EXAMPLE OF DATA FORM FOR WET
SCRUBBER (PLAN AND FRONT VIEW)

G

NOZZLE

D

NOZZLE

GPM

BLACK LIQUOR



FLOW RATE





LB/HR

INDUCTION FAN





RPMS



GPM

85


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APPENDIX G

APPENDIX G-6. EXAMPLE OF DATA FORM FOR 8 NOZZLE WET

SCRUBBER (PLAN VIEW)

NOZZLE TEMPERATURE

(COLD, WARM OR HOT)





BLACK LIQUOR
FIRING RATE



GPM

FIRING TEMPERATURE

F

PERCENT SOLIDS

%

LIQUOR DENSITY

LB/GAL



86


-------
APPENDIX G

APPENDIX G-7. EXAMPLE OF DATA FORM FOR 6 NOZZLE WET

SCRUBBER (PLAN VIEW)

F

BLACK LIQUOR
FIRING RATE

FIRING TEMPERATURE

PERCENT SOLIDS	~

LIQUOR DENSITY	

GPM
F

0 /„

LB/GAL

87


-------
APPENDIX G

APPENDIX G-8. EXAMPLE OF DATA FORM PACKED TOWER
WET SCRUBBER (FRONT VIEW)

GPM

I.D. FAN RATING

ACFM

GPM

INCHES

ON/OFF?

88


-------
APPENDIX G

APPENDIX G-9. EXAMPLE OF DATA FORM FOR VENTURI WET

SCRUBBER (PLAN VIEW)

89


-------
APPENDIX H

APPENDIX H-l. REGENERATIVE THERMAL OXIDIZERS

There are a number of issues regarding RTOs. For example, emissions containing significant
amounts of moisture, particulate matter and other contaminants can cause the RTO and
monitoring equipment to experience operational problems.

Likely operating parameters include chamber temperature and outlet air flow, static pressure at
the inlet of the ID fan and isolation damper position.

An important consideration is the balance needed between high temperatures (that causes high
NOx emissions) and low temperatures (that cause high CO emissions.)

Plugging and media failure are always a problem. For example, metal oxides (especially those
of potassium and sodium) melt and fuse to the media. One monitoring parameter to consider in
this regard is the pressure drop across the unit.

Another parameter to consider is the combustion temperature of each chamber, the average of
them, the volumetric flow rate through it (or some other variable indicative of volumetric flow
rate such as ID fan RPS, Amps or Watts, or inlet static pressure. Also important is the damper
positions of the isolation dampers.

90


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APPENDIX H

APPENDIX H-2. INSPECTING REGENERATIVE THERMAL

OXIDIZERS

RTOs are oxidation technology devices that use two or more ceramic heat transfer beds that act
as smaller heat exchangers and a thermal destruction (oxidation) chamber where the organics are
oxidized. It can often recovery 90 to 95% of the heat generated by oxidation of the organics in
the retention chamber. The combustion gases are passed through one of the heat transfer beds
which consist of a ceramic or metallic structured (monolith) or random packing which becomes
heated to near the combustion temperature of the process stream. The air flow is then changed to
allow the process stream to flow through the heated matrix into the oxidation chamber. Hence,
little additional heat is needed in the oxidation chamber to initiate thermal destruction. During
this period, another heat transfer bed is being heated by combustion gases. Typically, the flow is
changed every 4 to 5 minutes or is controlled by a thermal sensor. Oxidation temperatures are
typically between 1,400 ° F and 2,000 ° F and inlet air flows can range from 100 scfm to
200,000 scfm.

RESIDENCE TIME IN COMBUSTION CHAMBER

Effective volume of combustion chamber (Vox)

Flow of process air at combustion temperature (Qox)

Use the following formula to calculate the residence time (T0x)

Tox = (Vox * 60) / Qox		seconds

PRESSURE DROP

The monolith design allows lower pressure drops derived from the greater void fraction and its
inherent laminar flow characteristics. Typically, pressure drop across a system is about 22
inches W.C. for a random based unit and 15 inches W.C. for a monolith unit. RTOs are designed
to allow sufficient residence time in the oxidation chamber at a specified temperature to allow
complete combustion.

BED VELOCITY

The typical bed velocity is between 200 and 250 fpm (70 ° F and 15 psi) with random packing or
300 to 350 fpm with structured packing. The range of heat transfer surface area is 160 ft2 to 200
ft2 per cubic foot. Gas velocities are typically 400 scfm / ft2 or higher.

START-UP FUEL

ft3
acfm

91


-------
APPENDIX H

For start-ups and providing supplemental energy to initiate and/or sustain combustion in the
oxidation chamber, electric heating is used or fossil fuel is burned. The latter can be natural gas,
LPG or fuel oil.

VOLUMETRIC FLOW RATE IN OXIDATION CHAMBER

During the source test, the volumetric flow rate in the stack (Qs) is calculated. This, with the
stack temperature (Fs) and the combustion temperature in the oxidation chamber (F0x), can be
used to calculate the volumetric flow rate in the oxidation chamber (Qox)- The volumetric flow
rate in the oxidation chamber is determined by the following equation:

Qox = (Qs * (Fox + 459.67))/(Fs + 459.67)

where the measured temperatures are in degrees F. A similar equation can also be used to
calculate a volumetric flow (entering the RTO) to be correlated with some measure of fan
performance such as motor RPMs, amperes or kilowatts. In this way, volumetric flow rate
entering the unit can (Qin) be estimated at any time. The volumetric flow into the unit at ambient
temperature (Fin) is

Qin = (Qs * (Fin + 459.67))/(Fs + 459.67)

RESIDENCE TIME IN OXIDATION CHAMBER

During the source test, once the volumetric flow rate in the oxidation chamber (Qox) is
calculated and since the volume (Vox) of the oxidation chamber is known, the residence time can
be calculated (in seconds) as follows:

Tox = (Vox * 60) / Qox

As the system is operating, there may be a build up of condensed organics in the cooler portion
of the unit. Many units are designed to prevent his condensation or "backing out" processes,
such as a purge system, for removing them.

Some systems have a "roughing filter" to remove larger sized material ahead of the heat transfer
chambers. The pressure drop is monitored across the filter unit to indicate when it needs to be
replaced.

To maintain the proper residence time in the oxidization chamber, the volumetric flow rate into
the RTO is monitored and control by some method.

During the switching process between heat transfer chambers, some organics may not be
destroyed prior to being exhausted out of the stack. Many units have provisions for preventing
this.

92


-------
APPENDIX H

Stack temperature can be monitored continuously to ensure that the heat transfer beds are
functioning properly.

INITIAL PERFORMANCE TEST EVALUATION - RTO
Data

•	Packing type (structured or random)

•	Substrate type (ceramic, metallic, saddles, monolith, etc.)

•	How often is substrate replaced?

•	Volume of oxidation chamber (Vox)

•	Number of heat transfer chambers

•	Heat transfer chamber switching frequency

•	Criteria switching (set frequency, thermal sensor, etc.)

•	Design oxidation chamber combustion temperature

•	Design residence time (seconds)

•	Is residence time determined by flow rate or design data?

•	How is flow into the RTO controlled?

•	Volumetric flow rate at stack (F)

•	Flue gas temperature in stack (F)

•	Flue gas temperature at inlet to RTO (F)

•	Measured volumetric flow rate at inlet to RTO (acfm), and/or

•	Fan Motor Amperes (amperes), and/or

•	Fan Motor Kilowatts (kilowatts), and/or

•	Fan RPMs (rpms), and/orRPM reduction reading (%), and/or

•	Other variable for volumetric flow rate

•	Pressure drop across the RTO

•	Pressure drop across the roughing filter

•	Auxiliary fuel type (electric, natural gas, LPG, fuel oil)

•	Is stack temperature measured?

Calculations

•	Volumetric flow rate in oxidation chamber of RTO

acfm in stack * (

o

Fox + 459.67)

(.

o

Fs + 459.76)

93


-------
APPENDIX H

Volumetric Flow Rate Surrogate

acfm at inlet to RTO

	amperes, or, kilowatts, or, rpm, or %, or other

Residence Time in Combustion Chamber

(	cubic feet of oxidization chamber * 60)

calculated acfm in oxidation zone

94


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APPENDIX I

APPENDIX 1-1. SAMPLE CALCULATIONS FOR ELECTROSTATIC

PRECIPITATORS

Example. An Electrostatic Precipitator at a pulp mill consists of two chambers (one designated by
the mill as NORTH and the other designated as SOUTH). Each has three sections, designated "1,2
and 3" for the inlet, middle and outlet, respectively. Each section is controlled by a separate
Transformer-Rectifier Control. This particular unit is unusual in that the outlet sections have
different collection plate dimensions than the inlet and mid sections. Each inlet and mid section
has 17 collecting plates, each 25 feet high and 8 feet, 7.5 inches wide. Each outlet section has 17
plates, each 25 feet high and 8 feet 2 inches wide.

PLATE AREA

SectionNumber Height Width	Area	Total Area

Designation

of Plates

Feet

Feet

of Plate

Square Feet

N1

17

25

8.625

215.625

6,900

N2

17

25

8.625

215.625

6,900

N3

17

25

8.167

204.167

6,533

SI

17

25

8.625

215.625

6,900

S2

17

25

8.625

215.625

6,900

S3

17

25

8.167

204.167

6,533

Total	40,666

VOLUMETRIC FLOW RATE

During the Initial Performance Test, the average Volumetric Flow Rates and flue gas temperatures
during the three test runs were:

RUN #QS	TS	TCD

1

58,094 acfm

341 °F

355

°F

2

57,500 acfm

352 °F

358

°F

3

55,750 acfm

351 °F

361

°F


-------
APPENDIX I

VOLUMETRIC FLOW RATE AT THE INLET TO THE ESP

RUN#	STACK FLOW TEMP RATIO INLET FLOW

1	58,094 acfm	814.670/800.670 59,110 acfm

2	57,500 acfm	817.670/811.670 57,925 acfm

3	55,750 acfm	820.670/810.670 56,438 acfm

CALCULATION OF THE SCA

RUN#

PLATE AREA

1000s OF ACFM SCA

1

2

3

AVERAGE

40,666
40,666
40,666

59.110
57.925
56.438

688
702
721
704

It can be concluded that the SCA of the ESP is about 700.

ESP ELECTRICAL DATA DURING IPT

V

NORTH
A

KV

SOUTH
A

INLET

PRIMARY	366

SECONDARY 60

77
296

366
63

104
201

MIDDLE

PRIMARY	379

SECONDARY 53

119
646

436
56

129
584

OUTLET

PRIMARY	419

SECONDARY 59

169
850

413
43

124
809

96


-------
APPENDIX I

PRIMARY WATTS

INLET

MIDDLE

OUTLET

NORTH
WATTS

28,182

45,101
70,811

SOUTH
WATTS

38,064

56,244
51,212

SECONDARY WATTS

INLET

MIDDLE

OUTLET

NORTH
WATTS

17,760

34,238
50,150

SOUTH
WATTS

12,663

32,704
34,787

POWER FACTOR

INLET	0.630

MIDDLE

OUTLET

TOTAL SECONDARY WATTS

NORTH

0.759
0.708

0.333

SOUTH

0.581
0.679

17,760 + 12,663 + 34,238 + 32,704 + 50,150 + 34,787 = 182,302 WATTS

97


-------
APPENDIX I

POWER DISTRIBUTION

INLET
MIDDLE
OUTLET
TOTAL

POWER DENSITY

NORTH

WATTS

17,760

34,238

50,150

102,148

SOUTH

WATTS

12,663

32,704

34,787

80,154

TOTAL

WATTS

30,423

66,942

84,937

182,302

SPLIT

58.4/41.6
51.1/48.9
59.0/41.0
56.0/44.0

182,302 WATTS / 40,666 SQUARE FEET = 4.483 WATTS PER SQUARE FOOT

98


-------
APPENDIX I

iData fprm filled out.

Primary Vraits



.. ^ttj

0.630

Yo Spilt

28182

secondary Watts



58.4

17760



u. ov

Yo Split

1U1

Secondary Watts



51.1

¦Viwei Faului '

34238

—Piinidiv Walls '

366

60

Primary Volts

379

Secondary Kilovolts

53

(J. yU8 7U811

'/o Spilt

Secondary Watts

419

^econd^^Kilovolt^

Primary Amps

Primary Vraits

77	366

Secondary Milliamps Secondary Kilovolts

296	63

Primary Amps	Primary Volts

119	436

Secondary Milliamps Secondary Kilovolts

646

Primary Amps

56

Primary Vnltc

169	413

^econdai^^nijamg^^^econdai^^owlt^

Primary Amps

104

Secondary Milliamps

201

Primary Amps

129

Secondary Milliamps

584

Primary Amps

124





-Piimaiy vVaus



38064

Secondary Watts

0.333

% Split



12663

41.6

j. i i aiu. 1 Ul,u 		

56244

Secondary Watts

0.581

% Split



32704

48.9



TTTTl

ary Watte! | % Split

0.6/9

59.0 50150

59

850

43

809

34787

41.0

Overall

Channel







Channel

Overall

-o Split

Secondary Watt:

T

)tal Secondary W;

tts

Secondary Watts

% Split

56.0

102148



182302



80154

44.0

otal Plate Area (Square Feet)

40666

Total Secondary Watts per Square Foot of Plat: Area

4.483

99


-------
APPENDIX I

APPENDIX 1-2. SAMPLE CALCULATIONS FOR WET SCRUBBERS

Example. During the Initial Performance Test, during three runs, scrubber data was as follows:
RUN# VOLUMETRIC SCRUBBER	PRESSURE

FLOW RATE	LIQUID FLOW	DIFFERENTIAL

ACFM GPM	INCHES OF WATER

1

2

3

5,771
5,705
5,708

2,110
2,107
2,112

5.2
5.1
5.1

VOLUMETRIC FLOW RATES

During the Initial Performance Test, the average Volumetric Flow Rates and flue gas temperatures
during the three test runs were:

RUN #QS

TS

TCD

1

2

3

5,771 acfm
5,705 acfm
5,708 acfm

90 °F
130 °F
126 °F

250	°F

251	°F
250 °F

VOLUMETRIC FLOW RATE AT THE INLET TO THE SCRUBBER

RUN#

TEMP RATIO INLET FLOW

1

2

3

709.670/549.670
710.670/589.670
709.670/585.670

7,451 acfm
6,876 acfm
6,917 acfm

TO GAS RATIO FOR THE SCRUBBER

LIQUID

RUN#	SCRUBBING VOLUMETRIC LIQUID

LIQUID	GAS FLOW	TO GAS

GPM	1000s OF ACFM RATIO

1	2,110	7.451	283

2	2,107	6.876	306

3	2,112 6.917	305
AVERAGE	298
It can be concluded that the Liquid to Gas Ratio is about 300.

100


-------
APPENDIX I

APPENDIX 1-3. SAMPLE CALCULATIONS FOR REGENERATIVE
THERMAL OXIDIZERS

Example. With a combustion chamber size of 15 cubic feet, during the Initial Performance Test,
the average Volumetric Flow Rates and flue gas temperatures during the three test runs were:

RUN #QS

TS

TCD

1

2

3

3,001 acfm
3,215 acfm
3,750 acfm

550 °F
547 °F
602 °F

85 °F
90 °F
95 °F

VOLUMETRIC FLOW RATE AT THE INLET TO THE SCRUBBER

RUN#

TEMP RATIO INLET FLOW

1

2

3

544.670/ 1,009.670
549.670/ 1,006.670
554.670/ 1,061.670

1,619 acfm
1,755 acfm
1,959 acfm

TO GAS RATIO FOR THE SCRUBBER

RUN#	COMBUSTION

CHAMBER VOLUME

INLET RESIDENCE
FLOW TIME



FT3

ACFM SECONDS

1

15

1,619 0.56

2

15

1,755 0.51

3

15

1,959 0.46

LIQUID

AVERAGE

0.51

The average residence time is 0.51 seconds.

101


-------