Pulp and Paper Sector Survey Overview

6/8/10

This survey overview document provides instructions for completing the
pulp and paper survey.  This overview is organized as follows: 

  TOC \o "1-3" \h \z \t "Head - special,1"    HYPERLINK \l
"_Toc262224031"  A.	Survey Coverage	  PAGEREF _Toc262224031 \h  3  

  HYPERLINK \l "_Toc262224032"  B.	Confidential Business Information
(CBI)	  PAGEREF _Toc262224032 \h  5  

  HYPERLINK \l "_Toc262224033"  C.	How to Submit Your Survey Response	 
PAGEREF _Toc262224033 \h  5  

  HYPERLINK \l "_Toc262224034"  C1. 	Submitting Your Non-CBI Response	 
PAGEREF _Toc262224034 \h  5  

  HYPERLINK \l "_Toc262224035"  C2. 	Submitting CBI	  PAGEREF
_Toc262224035 \h  6  

  HYPERLINK \l "_Toc262224036"  D.	How to Complete the Survey	  PAGEREF
_Toc262224036 \h  7  

  HYPERLINK \l "_Toc262224037"  D1.  	Flow diagrams	  PAGEREF
_Toc262224037 \h  7  

  HYPERLINK \l "_Toc262224038"  D2.  	NEI data:  Facility and Inventory
tabs	  PAGEREF _Toc262224038 \h  8  

  HYPERLINK \l "_Toc262224039"  a.  	Updating pre-populated NEI data (in
the Facility and Inventory tabs)	  PAGEREF _Toc262224039 \h  9  

  HYPERLINK \l "_Toc262224040"  b.  	Completing Facility and Inventory
tabs if not pre-populated by EPA	  PAGEREF _Toc262224040 \h  13  

  HYPERLINK \l "_Toc262224041"  D3.  	Process data	  PAGEREF
_Toc262224041 \h  14  

  HYPERLINK \l "_Toc262224042"  a. 	Facility tab	  PAGEREF _Toc262224042
\h  16  

  HYPERLINK \l "_Toc262224043"  b. 	Inventory tab (permit limit
information)	  PAGEREF _Toc262224043 \h  16  

  HYPERLINK \l "_Toc262224044"  c. 	Equip detail tab	  PAGEREF
_Toc262224044 \h  18  

  HYPERLINK \l "_Toc262224045"  d.  	Controls tab	  PAGEREF
_Toc262224045 \h  22  

  HYPERLINK \l "_Toc262224046"  e. 	Potential changes tab	  PAGEREF
_Toc262224046 \h  23  

  HYPERLINK \l "_Toc262224047"  f. 	Pulp prod tab	  PAGEREF
_Toc262224047 \h  23  

  HYPERLINK \l "_Toc262224048"  g. 	Byproducts tab	  PAGEREF
_Toc262224048 \h  23  

  HYPERLINK \l "_Toc262224049"  h. 	PCC tab	  PAGEREF _Toc262224049 \h 
23  

  HYPERLINK \l "_Toc262224050"  i. 	Kraft condensates tab	  PAGEREF
_Toc262224050 \h  24  

  HYPERLINK \l "_Toc262224051"  j. 	CCA tab	  PAGEREF _Toc262224051 \h 
24  

  HYPERLINK \l "_Toc262224052"  k. 	Bleaching tab	  PAGEREF
_Toc262224052 \h  25  

  HYPERLINK \l "_Toc262224053"  l. 	Paper prod tab	  PAGEREF
_Toc262224053 \h  25  

  HYPERLINK \l "_Toc262224054"  m. 	HAP additives tab	  PAGEREF
_Toc262224054 \h  26  

  HYPERLINK \l "_Toc262224055"  n.  	WW tab	  PAGEREF _Toc262224055 \h 
26  

  HYPERLINK \l "_Toc262224056"  D4.  	Test data	  PAGEREF _Toc262224056
\h  26  

  HYPERLINK \l "_Toc262224057"  a. 	Emissions test data tab	  PAGEREF
_Toc262224057 \h  27  

  HYPERLINK \l "_Toc262224058"  b. 	CEMS data spreadsheet (P&P CEMS
spreadsheet.xls)	  PAGEREF _Toc262224058 \h  27  

  HYPERLINK \l "_Toc262224059"  D5.  	Optional cost data	  PAGEREF
_Toc262224059 \h  29  

  HYPERLINK \l "_Toc262224061"  ATTACHMENT 1     HYPERLINK \l
"_Toc262224062"  Emission Units to Include in the Pulp and Paper Survey
Response	  PAGEREF _Toc262224062 \h  31  

  HYPERLINK \l "_Toc262224063"  ATTACHMENT 2     HYPERLINK \l
"_Toc262224064"  NSPS and NESHAP Definitions	  PAGEREF _Toc262224064 \h 
33  

  HYPERLINK \l "_Toc262224065"  ATTACHMENT 3     HYPERLINK \l
"_Toc262224066"  Small Business Size Standards	  PAGEREF _Toc262224066
\h  41  

  HYPERLINK \l "_Toc262224067"  ATTACHMENT 4     HYPERLINK \l
"_Toc262224068"  Acronyms and Abbreviations	  PAGEREF _Toc262224068 \h 
42  

  HYPERLINK \l "_Toc262224069"  ATTACHMENT 5     HYPERLINK \l
"_Toc262224070"  Resources for Estimating Emissions	  PAGEREF
_Toc262224070 \h  44  

  HYPERLINK \l "_Toc262224071"  ATTACHMENT 6     HYPERLINK \l
"_Toc262224072"  Emissions Test Data Request	  PAGEREF _Toc262224072 \h 
45  

 

A.	Survey Coverage  

This information request applies for pulp and/or paper/paperboard mills
that are a “major source” or “synthetic area source” of
hazardous air pollutant (HAP) emissions that:

(a) Perform chemical wood pulping (kraft, sulfite, soda, or
semi-chemical), or

(b) Perform mechanical, groundwood (e.g., thermomechanical pulping
(TMP), refiner mechanical pulping (RMP)), secondary fiber, and non-wood
pulping, or

(c) Perform bleaching, or

(d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

 “Major source” means any stationary source or group of stationary
sources located within a contiguous area and under common control that
emits or has the potential to emit considering controls, in the
aggregate, 10 tons per year or more of any hazardous air pollutant or 25
tons per year or more of any combination of hazardous air pollutants,
unless the Administrator establishes a lesser quantity, or in the case
of radionuclides, different criteria from those specified in this
sentence.

A “synthetic area source” is a stationary source which is subject to
federally-enforceable conditions that limit its potential to emit to
below major source thresholds.

If your mill is not a “major source” or “synthetic area source”
of HAP emissions, then you should send an email to Bill Schrock at
schrock.bill@epa.gov attaching documentation (such as a valid operating
permit) confirming the true area source status of your facility and
showing that you facility is not subject to either of the pulp and paper
NESHAP (40 CFR part 63, subpart S or MM).  You will receive e-mail
confirmation from EPA that you are not required to complete this survey
based upon EPA review and agreement with the true area source status
shown in the documentation. 

If your mill is a “major source” or “synthetic area source,” but
was not operational in 2009 (and remains closed) or does not produce
pulp, perform bleaching, or manufacture paper or paperboard products,
then you should send an email to Bill Schrock at schrock.bill@epa.gov
explaining the operational status of your mill.  Once EPA has reviewed
your notification, you will receive e-mail confirmation from EPA
regarding whether you should complete any portions of this survey.

This survey is to be completed in a Microsoft Excel spreadsheet file
that is divided into several worksheets (“tabs” within the
spreadsheet).  You must complete certain tabs of the survey spreadsheet
(depending on the type of mill you operate).  The Facility, Inventory,
and Equip detail tabs must be completed for all mills.  Table 1 below
denotes which survey spreadsheet tabs to complete depending on mill
type.  Additional spreadsheets are provided for submittal of continuous
emissions monitoring system (CEMS) data or control measure cost
information. 

Please complete the survey for the facility listed in the Section 114
letter you received in the mail. If you received more than one Section
114 letter for multiple facilities, you must create a separate survey
response for each facility. If you have not already received or
downloaded a copy of the survey spreadsheets, they can be downloaded
here:  http://icr2010.rti.org.

Use the 2009 calendar year as the base year for all survey responses
(e.g., 2009 emissions inventory, 2009 capacity, 2009 equipment
configurations, etc), unless another year is specified in the
instructions (e.g., for emissions test data).   

This survey asks questions about the emission units listed in Attachment
1 to this document.  Section D, How to Complete the Survey, explains how
to treat various configurations of emission units (e.g., multiple
emission units venting to the same stack, etc.) for each survey tab.   

For reference, Attachment 2 contains the regulatory definitions from the
kraft pulp mill new source performance standards (NSPS) (40 CFR Part 60,
subpart BB), chemical recovery combustion source national emissions
standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart
MM), and from the pulp and paper processing NESHAP (40 CFR Part 63,
subpart S).  Attachment 3 contains a listing of small business size
standards for North American Industry Classification System (NAICS) code
Subsector 322, Paper Manufacturing.  Attachment 4 contains acronyms and
abbreviations used throughout this Survey Overview Document and the
associated spreadsheets.  Resources that might be useful for estimating
emissions are identified in Attachment 5.  Finally, Attachment 6 of this
survey contains a table of emission units and pollutants for which
existing emission test data are requested. 

Table 1.  Survey Spreadsheets and Tabs to Complete

Spreadsheet and tab	Types of mills that should complete this spreadsheet
tab

P&P sector survey.xls

	Facility	All mills

Inventory	All mills

Equip detail	All mills

Controls	Mills with add-on air pollution controls on pulping emission
units, bleaching emission units, papermaking emission units, or boilers.


Potential changes	Chemical pulp mills

Pulp prod	Mills that produce any type of pulp (including chemical,
mechanical/groundwood, secondary fiber, including non-wood pulp)

Byproducts	Mills that produce turpentine or tall oil byproducts from
pulping processes

PCC	Mills that route lime kiln, boiler, or other process exhaust to a
precipitated calcium carbonate (PCC) plant

Kraft condensates	Mills that perform kraft pulping

CCA	Mills that perform kraft pulping and use the clean condensate
compliance alternative (CCA)

Bleaching	Mills that perform bleaching 

Paper prod	Mills the produce paper or paperboard products 

HAP additives	Mills the produce paper or paperboard products 

WW	Mills with onsite wastewater treatment plants

Emissions test data	Mills operating emission units subject to NESHAP
subparts S or MM, or NSPS subpart BB 

P&P CEMS spreadsheet.xls

CEMS data (separate tabs are included for different pollutants)	Mills
operating emission units subject to NESHAP subparts S or MM, or NSPS
subpart BB.  

P&P costs OPTIONAL.xls      (Completion of this spreadsheet is optional)

APCD costs	Mills that installed selected air pollution controls (see
section D5)

Equip change costs	Mills implementing selected process or equipment
changes (see section D5)



B.	Confidential Business Information (CBI)  

The EPA's procedures for handling CBI are described in the letter (and
attachments) accompanying the pulp and paper information collection
request (ICR).  If you believe that providing any specific information
to us would reveal a trade secret, please identify this information
clearly in your spreadsheet response by shading the spreadsheet cell
containing the “confidential business information (CBI)” information
with red highlight and indicating in the red block at the top of each
spreadsheet tab that the tab contains CBI.  Also, please clearly label
any flow diagrams or other attachments submitted with your survey that
contain CBI.  However, please do not label your entire response as CBI
if only a portion includes trade secrets.  The EPA is likely to
follow-up with a request for validation of CBI claims for mills claiming
large amounts of information as trade secret, especially information
that is readily reported by other mills without such claims.

C.	How to Submit Your Survey Response  

If your response to this information collection request includes data
with a claim of CBI, you should follow the instructions in this section
to ensure the protection of your data.  Please note that if you submit
CBI, you will be separating your data into two portions and sending your
data to EPA using two different mailing addresses.  

C1. 	Submitting Your Non-CBI Response

Follow these instructions for the non-CBI portions of your survey
response (or for responses that are entirely non-CBI.)

After you have completed and reviewed your survey response, remove the
CBI components from your survey as instructed in section C2.  Save the
Excel spreadsheet(s) containing the non-CBI portions of your completed
response, non-CBI flow diagrams, emission test reports, and any other
electronic non-CBI attachments on the flash drive you were provided with
your section 114 letter (or on a CD or DVD).  Assemble any non-CBI hard
copy attachments to your survey (such as hard copy flow diagrams, test
data, wastewater emissions modeling reports, etc.).  Mail the non-CBI
flash drive (or disk) and any non-CBI hard copy materials in one
envelope to EPA at the address specified below by the specified response
deadline in the Section 114 letter.  (Note:  If the
spreadsheet/diagrams/attachments contain CBI, use the address for Mr.
Morales provided in section C2 of this document.)

U.S. Environmental Protection Agency

		Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (E143-03)

Attn:  Mr. Bill Schrock

109 TW Alexander Drive

		Research Triangle Park, NC 27711

EPA recommends sending your non-CBI files via Registered U.S. Mail using
return receipt requested, Federal Express, or other method for which
someone must provide a signature upon receipt.

C2. 	Submitting CBI

Follow these instructions for any portion of your survey response that
contains CBI.  

Please create a separate CD or DVD containing a version of your
spreadsheet response with only the CBI portion of your data (i.e., only
the red highlighted data in the survey spreadsheet).  Include on the
disk any flow diagrams or pages of other attachments to your survey
response containing CBI, with the CBI portions of the diagrams/pages
clearly marked (e.g., highlighted or circled).  Clearly mark the disk
with the words “Confidential Business Information.”  Send only these
CBI files under separate cover to:

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn:  Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential
files to Mr. Morales via Registered U.S. Mail using return receipt
requested, Federal Express, or other method for which someone must
provide a signature upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.
 E-mail and facsimile are not secure forms of communication and should
never be used to transmit CBI.		

D.	How to Complete the Survey  

Your survey response will consist of flow diagrams and completed
Microsoft Excel spreadsheets.  Separate Excel spreadsheets are provided
for completion (P&P survey.xls; P&P CEMS Spreadsheet.xls; P&P costs
OPTIONAL.xls). You must complete certain tabs of the P&P survey.xls
spreadsheet (depending on the type of mill you operate) as shown in
Table 1 above.   The P&P CEMS Spreadsheet.xls is to be completed if you
have continuous emissions monitoring data to supply.  The P&P costs
OPTIONAL.xls spreadsheet is an optional spreadsheet that can be
completed to supply control measure cost information helpful for EPA’s
regulatory analyses.

D1.  	Flow diagrams

Please provide a process flow diagram (or diagrams) showing the
equipment listed in Attachment 1 as it appears in each of the following
areas of the mill.  Respondents should clearly label the emission unit
IDs on each submitted flow diagram.  The emission unit IDs should match
those provided in the survey spreadsheets.  Readily available block flow
diagrams (e.g., such as those used for permit applications) will
suffice.  Electronic or hard copies are acceptable.  

Chemical recovery area.  Show each chemical recovery furnace/combustion
unit, black liquor oxidizer (if used), smelt or ash dissolving tank,
causticizing equipment, and lime kiln/calciner.  Include liquor storage
tanks or ponds.

Pulping process. Include the equipment in all pulping lines including
the digester area, pulp washing lines, evaporator lines, and oxygen
delignification systems.   Show any brown stock washers, hoods, filtrate
tanks, vacuum pumps, screens, knotters, deckers, stock chests (including
open stock chests, pulp storage tanks), thickeners, and weak black
liquor storage tanks on the diagram.  Include deckers, screens,
knotters, stock chests, and pulp storage tanks following the last stage
of pulp washing and/or those located prior to the paper machines.  

Black liquor gasification.  If black liquor gasification is used,
provide a diagram and description of the system including any combustion
controls or add-on controls used to reduce air pollutants.  

Wastewater treatment plant (WWTP).  Provide a flow diagram of each WWTP
showing each wastewater handling/treatment unit.  

 

D2.  	NEI data:  Facility and Inventory tabs

The U.S. EPA is working to fulfill its obligation under CAA sections
112(f)(2) and 112(d)(6) to review residual risk and perform a technology
review of the pulp and paper industry NESHAP subparts S and MM.  Data
sets derived from the EPA’s 2005 National Scale Air Toxics Assessment
(NATA) National Emissions Inventory (NEI) will be used for EPA’s
residual risk and technology review (RTR).  The RTR data sets have been
developed for mills in the 2005 NATA NEI identified as having emission
units with the following NEI MACT codes:

1626-1	Pulp & Paper Production - Pulping and Bleaching Systems at Kraft,
Soda, Sulfite, and Semichemical Pulping Mills (Subpart S) and
Papermaking Systems at all mills.

1626-2	Pulp & Paper Production - Chemical Recovery Combustion Sources at
Kraft, Soda, Sulfite, and Stand-alone Semichemical Pulping Mills
(Subpart MM)

1626-3	Pulp and Paper Production - NonMACT Facilities

The 2005 NATA NEI data sets were compiled based on prior versions of the
NEI, updated with data collected by EPA’s Office of Air Quality
Planning and Standards.  Many pulp and paper mills have voluntarily
updated their NEI data sets for RTR purposes and few additional
refinements are needed.  However, there remain a number of pulp and
paper mills for which substantial updates to their NEI data sets are
requested in order for EPA to more accurately consider RTR for the pulp
and paper NESHAP standards.  In addition, there may be some mills for
which no prior pulp and paper MACT category NEI data are available.

If 2005 NATA NEI data exist for your mill, then two of the survey
spreadsheet tabs (Facility tab and Inventory tab) have been
pre-populated with your mill’s NEI data set.  You will need to review
and revise the NEI data in these two tabs as necessary following the
instructions provided below in section D2.a for “Updating
pre-populated NEI data (in the Facility and Inventory tabs).”  The
remaining spreadsheet tabs request information in addition to that
included in the NEI, and are to be completed based on the instructions
provided in section D3 of this document. 

If NEI data do not already exist for your major or synthetic area source
mill, then you will need to provide a full NEI update in the Facility
and Inventory tabs.  See the instructions below in section D2.b for
“Completing Facility and Inventory tabs if not pre-populated bv EPA”
below.  The remaining spreadsheet tabs request information in addition
to that included in the NEI, and are to be completed based on the
instructions provided in section D3 of this document.

Regardless of whether you are updating a pre-populated data set or
providing new inventory information, the following items should be
noted:

Unless specifically identified as permitted (i.e., “Allowable”) or
startup/shutdown emissions, all emissions reported in the survey /
inventory format should reflect ACTUAL, routine emissions for the
reported calendar year.  

Please pay particular attention when entering emission release point
stack parameters and locations.  EPA requires latitude/longitude for
each emission point provided in North American Datum (NAD) 83 with 6
digits to the right of the decimal point.  These data are critical
inputs to the modeling files that EPA will use to determine the risk
profile for the residual risk review process.

a.  	Updating pre-populated NEI data (in the Facility and Inventory
tabs)  

You will need to review and revise the NEI data contained in the
“Facility” and “Inventory” tabs as necessary.  The NEI data
appear to the left of the orange vertical line in each tab (column AF in
the Facility tab and column BZ in the Inventory tab).  Pulp and paper
survey data fields (in addition to those in the NEI) have been added to
the right of the orange vertical line in the tab and require completion
as described in the instructions in section D3 below for “Process
data.”  The instructions for updating the pre-populated NEI data in
the Facility and Inventory tabs are as follows.

NEI data are generally requested for the 2009 calendar year.  However,
EPA is sensitive to the time and effort required to update your NEI
inventory.  Thus, if you have previously reviewed and revised your NEI
data within the past 3 years and/or you believe the 2005 NATA NEI data
in the pre-populated data set provided by EPA is a reasonably complete
and accurate representation of your mill configuration and emissions,
then you do not need to update your NEI data for the sole purpose of
changing the emission estimates to reflect the 2009 calendar year. 
However, if you must substantially revise or add to your pre-populated
NEI data set to make it complete and reflective of the current mill
configuration, then it is requested that you use the 2009 calendar year
for your inventory update.

You will update one row of data in the Facility tab, and multiple rows
of data in the Inventory tab.  An “Instruction” row appears that the
top of each spreadsheet tab to provide a brief instruction for fields
requiring some description.  More detailed instructions appear in this
document where needed.  When updating the NEI data in the Facility and
Inventory tabs, please indicate changes only in the unshaded columns.  
Do not overwrite data in the gray shaded columns.  Guidance for revising
specific blocks of data in the Inventory tab is as follows:

Gray shaded columns.  The gray shaded columns have been locked to
prevent information in these columns from being overwritten.  If you
wish to change information in these gray columns, then you will need to
follow the instructions for adding and deleting a row.  Copy the entire
row with the locked cells and paste it below the existing, pre-populated
NEI inventory to add and update it.  Then mark the old row for deletion
by indicating your intent with an "X" in the “Delete” column.

Adding a row.  If you need to add a new emission unit or pollutant that
is not currently in the inventory, you should scroll to the last row and
enter any missing data.  You can copy any useful information from other
inventory rows and state in the "Process Comment" field "Adding new
process."  For additions, information does NOT need to be in a revised
field.  Specify “RTR09” in the “Data Source Code” column.

Deleting a row. If you need to delete a row indicate your intent with an
"X" in the “Delete” column and indicate your reason for deletion in
the “Delete Comment” column.   You may wish to delete rows, for
example, because an emission unit was decommissioned or is now collected
as part of the LVHC system; or because you cannot identify the source.

To revise or replace a whole row.  Add your new row and delete the old
row using the instructions for adding and deleting rows above.

To replace the whole inventory.  You may choose to submit a complete NEI
replacement.  To completely replace your NEI data, mark all existing NEI
rows for deletion with an "X" in the “Delete” column and note
“complete inventory replacement” in the “Delete Comment” column.
 Add your new inventory below the NEI data being replaced. 

 

For convenience, the spreadsheet entitled Lookups for P&P survey.xls
consolidates and provides the various codes associated with the NEI data
set you are requested to update.  This Lookups for P&P survey.xls
spreadsheet also contains source classification codes (SCC).  These
codes were extracted from the NEI data base lookup tables at   HYPERLINK
"http://www.epa.gov/ttn/chief/net/2005inventory.html" 
http://www.epa.gov/ttn/chief/net/2005inventory.html  and contain SCC
revisions made in the fall of 2009.  Note that the process of revising
the SCC list in the fall of 2009 involved both the addition and the
removal of pulp and paper-related SCCs.  For example, the SCC list
previously included the SCC: 30700118 Sulfate (Kraft) Pulping / Liquor
Clarifiers.  This SCC is now obsolete and has been replaced with the
more specific SCCs: 30700132 Sulfate (Kraft) Pulping / Green Liquor
Processing and 30700133 Sulfate (Kraft) Pulping / White Liquor
Processing.  Please use the most appropriate SCC from the provided
lookup table.  Similar updates (i.e., both additions and deletions) may
have been made to some of the other NEI code lookup tables.  If a code
that you have used in the past no longer appears in the appropriate
lookup table, please select the most appropriate code from those listed.
 You may clarify your entry by adding text in the “Comment –
Process” column.  Codes that are being phased out are shaded green in
some of the lookup tables (along with a note in the lookup table
explaining how to treat the green-shaded codes in your inventory
update).

Update the single row of NEI data in the Facility tab as needed
following the instructions that appear in each column. 

The NEI data in the Inventory tab should include all emission
units/points that emit hazardous air pollutants (HAP), criteria air
pollutants (CAP), or total reduced sulfur (TRS) at the mill, including
every emission point with HAP, CAP, and/or TRS emission limits in your
title V operating permit.  The Inventory tab contains separate rows of
data for each emission unit, emission point, and pollutant.  The types
of emission units listed in Attachment 1 to this document (that you
operate) must be included in the NEI revision even if these emission
units are not already included in your title V permit.  If emission
units/points included in your title V permit (or emission units/points
that you operate listed in Attachment 1) are not already included in the
NEI data, then you will need to add the missing emission units/points. 
There should be an NEI data entry for every emission unit/point and
pollutant permit limit listed in your title V permit.  You will also
need to add an accurate description of each emission unit in the
"REVISED Emission Unit Description" column.  In addition, every emission
unit will need to be assigned a descriptive SCC code.  If you review the
data in the Inventory tab and conclude that no revisions are needed,
then mark the “Is Reviewed With No Changes” column in the Inventory
tab accordingly.  Guidance for different emission unit/point
configurations and specific data columns are provided as follows.

 

Multiple emission units ducted to a single release point.  It is very
common for multiple emission units (or for multiple emission points from
a single emission unit) to be ducted to a common conveyance for purposes
of emissions capture and control.  The NEI provides parameters
associated with releases to the atmosphere (e.g., tpy emitted, stack
parameters) so it is acceptable to include each common emission release
point in the NEI (rather that listing each emission unit ducted to the
common release point separately).  For example, an LVHC collection
system may collect emissions from multiple emission points associated
with digesters 1, 2, and 3 and an evaporator.  You could either list
digesters 1, 2, and 3 and the evaporator separately in the NEI (and
provide data for each associated emission point, or you could simply
list the LVHC collection system emission point in the NEI).  

A similar approach can be taken for reporting emissions from two
distinct emission units that are vented through a common stack for
purposes other than capture and control.  In this scenario, apportion
the emissions to each process and insert a separate row or rows for each
distinct process.  Identify and enter the SCC code associated with each
emission unit and note the appropriate stack parameters on each row. 
Note the common stack in the "REVISED Emission Unit Description”
column.  For example, indicate the following where 2 recovery furnaces
share a common release point: Row 1 – emission unit ID 001 (EU001) No.
1 Recovery Furnace vents to emission release point ID 01 (ERP01) and
indicate in the “REVISED Emission Unit Description” column “No. 1
Recovery Furnace shares common stack with No. 2 Recovery Furnace.”  On
Row 2 – emission unit ID 002 (EU002) No. 2 Recovery Furnace vents to
emission release point ID 01 (ERP01) and indicate in the “REVISED
Emission Unit Description” column “No. 2 Recovery Furnace shares
common stack with No. 1 Recovery Furnace.”

Single emission unit with multiple emission release points.  Pulp and
paper emission units may have multiple emission points (e.g., paper
machines, digester blow gases and relief gases, boilers with two stacks)
that for various reasons may not be consolidated into a single emission
point before release to the atmosphere.  In these situations, the
emission unit should be repeated in the NEI and emissions data and stack
parameters provided for every emission point.  You may use the
“REVISED Emission Unit Description” column to distinguish among
emission points for each emission unit. 

Bypass stacks used only during certain times.  If your facility operates
an emission unit with a bypass stack that allows for emissions to bypass
the control system, then you can indicate the emissions associated with
these bypass stacks by entering the appropriate data in a new row (see
previous instructions for “adding a row”).  If you enter data for
bypass stacks, please indicate these emissions as “bypass” emissions
in the “REVISED Emission Unit Description” column.  Please also
indicate in the “REVISED Emission Unit Description” column the
release point associated with “normal” operations.  See also the
instructions below for routine and SSM emissions.

Backup controls.  Some facilities may have backup control system
configurations that provide flexible operating scenarios.  For example,
LVHC system gases may normally be collected and burned in a lime kiln,
but if the lime kiln that controls these emissions is shutdown, the
facility has the flexibility to send these same collected LVHC gases to
a power boiler.  For this type of scenario, a facility would indicate in
the “Control Measure” fields in the Inventory tab that the lime kiln
is the primary control device, but would also note in the “Control
Measure Comment” field that the power boiler serves as a backup
control.  

Routine emissions and startup, shutdown, and malfunction (SSM)
emissions. Startup, shutdown, and malfunction emissions are requested
because EPA is modeling both short- and long-term risks.  You are asked
to indicate the SSM annual and maximum hourly emissions in lb/hr and
tpy, respectively.  If you enter separate rows for an emission unit’s
routinely used stack and a bypass stack, then you should report SSM
emissions for the emission unit in the row(s) associated with the bypass
stack  (in order to prevent double counting of the SSM emissions that 
would occur if the SSM emissions are entered in both the routine and
bypass rows).

Control measures.  For EPA to better understand current control measures
that are in operation, we are requesting that reviewers indicate the
type of control measure associated with each emission unit. A list of
control measure codes and control measure descriptions is provided in
Lookups for P&P survey.xls.  If you do not provide control measure
information in your update, the emission unit will be considered
uncontrolled.  

Emission units vented into the building.  Do not include emissions units
that vent into the building in your NEI update unless these emission
units are permitted units in your Title V permit.  For example, if your
paper machine vents into the building housing the machine and emission
limits are contained your permit that are applicable to the building
vents, then you would included the paper machine in your inventory.

Fugitive emissions. Quantified sources of fugitive emissions are to be
included in your NEI update (e.g., fugitive emissions from wastewater
handling/treatment units modeled for permitting purposes).  Fugitive
emission parameters are reflected in the “Emission Release Point
Type” column and other columns related to the fugitive length, width,
and angle of the fugitive emissions.

Emission units unrelated to the pulp and paper NESHAP and NSPS source
categories.  Please note that the pre-populated NEI data sets contain
all emissions data for a facility identified as belonging to a MACT
category covered under the present RTR.  Thus, some of the emissions may
be from processes NOT associated with the pulp and paper MACT category.
The column labeled “MACT Code” indicates if the HAP pollutant
emissions are associated with the pulp and paper MACT category or
another MACT category at the facility (e.g., MACT code 0107-2 associated
with Industrial/Commercial/Institutional Boilers & Process Heaters –
gas.). A full list of MACT codes is included in Lookups for P&P
survey.xls.  Data from MACT categories other than the pulp and paper
NESHAP categories are shown in the pre-populated spreadsheets to provide
a complete dataset for the facility and/or to help you spot additional
processes which should be assigned to the pulp and paper MACT category.

In this survey we are seeking updates to the equipment used for pulp and
paper manufacturing (i.e., pulping processes, pulping byproduct
recovery, bleaching, papermaking, boilers, etc).  A list of the types of
equipment of interest for pulp and paper production is provided in
Attachment 1 to this document.  We are not seeking updates to collocated
operations that are not associated with pulp and paper manufacture
(e.g., a lumber mill, chemical plant, or wood products mill) at this
time, but would accept voluntary updates to these data since the data
could be considered in determining residual risk for the entire
facility.  

“Emission Unit Description,” “REVISED Emission Unit Description”
and “REVISED SCC” columns.  An “Emission Unit Description”
column was included in prior drafts of the NEI that mills were asked to
voluntarily review and update.  Every emission unit listed in your NEI
inventory should have an informative “Emission Unit Description”
that adequately describes the equipment or type of emission unit.  If no
“Emission Unit Description” is in the NEI for a given emission unit
then you will need to add one in the “REVISED Emission Unit
Description” column.  If you find that the “Emission Unit
Description” in the NEI is not informative, then you may revise it
using the “REVISED Emission Unit Description” column.  You may find
it helpful if the Emission Unit Description or your revision entered in
the “REVISED Emission Unit Description” column relates your emission
unit/process to your permit or process flow diagram.  

The SCCs in the NEI will be used by EPA to group similar emission units
and draw conclusions regarding the emission levels and residual risk
associated with each type of emission unit.  Proper assignment of SCCs
will allow EPA to pinpoint emission unit types that need to be examined
in more detail for residual risk rulemaking.  The SCC codes for pulp and
paper manufacturing have recently been updated to include more
descriptive codes and to provide some guidance on which codes should be
used for certain equipment types.  A crosswalk of the available SCC
codes with the types of equipment listed in Attachment 1 is included in
the P&P Att1 with SCC tab of “Lookups for P&P survey.xls”.  The full
list of SCC codes used for EPA’s Emissions Inventory System (EIS)/NEI
is included in the All 11575 SCC tab of “Lookups for P&P survey.xls”
(and is also available in data base form at   HYPERLINK
"http://www.epa.gov/ttn/chief/net/2005inventory.html" 
http://www.epa.gov/ttn/chief/net/2005inventory.html ).   The “Emission
Unit Description” and “REVISED Emission Unit Description” columns
will be used as a check for SCC code assignment.  

Revised SCCs are available for common collection systems (e.g., LVHC,
HVLC) and for various systems that are commonly comprised of multiple
emission points (e.g., 30700114 for bleach plants includes emissions
from the bleaching towers, washer hoods, filtrate tanks, and vacuum pump
exhausts). 

Use the SCC that best describes your process, and avoid use of generic
not-elsewhere-classified SCCs whenever possible. If you do not find an
SCC that matches your emission unit then be sure to include an accurate
description of your emission unit in the “REVISED Emission Unit
Description” column of the Inventory tab.

Please make every attempt to use SCCs specific to the pulp and paper
sector (e.g., use SCC 30700106 for pulp and paper lime kilns as opposed
to SCC 30501619 for the lime manufacturing sector). 

Please do not use generic not-elsewhere-classified (NEC) SCCs unless you
absolutely cannot find a specific SCC that resembles your emission unit.
 If you do choose a NEC SCC, then a description is required in the
"REVISED Emission Unit Description” column.  

“Emission Process Group” column.  The P&P Att1 with SCC tab of the
“Lookups for P&P survey.xls” spreadsheet contains an “Emission
Process Group” column associated with each SCC.  You are asked to
identify the “Emission Process Group” listed in the P&P Att1 with
SCC tab for any new emission units you add to your NEI.  These emissions
process groupings will be used in modeling risk and identifying general
areas of the mill for focus of the residual risk rulemaking effort.  For
existing NEI entries, if the “Emission Unit Description” or
“REVISED Emission Unit Description” adequately describes your
emission unit, it is not necessary to include additional or revised text
in the “Emission Process Group” column.

b.  	Completing Facility and Inventory tabs if not pre-populated by EPA 


A 2005 NATA NEI data set does not exist for your mill if the Facility
and Inventory tabs of the pulp and paper sector survey have not been
pre-populated.  There are various reasons why the NEI data set may be
unavailable.  For example, some States have not supplied NEI data for
major sources.  Also, NEI data may be unavailable for non-major sources,
or there may be no emission units in your NEI data set that correspond
with the pulp and paper MACT codes.  (Note: If your mill is not a major
or synthetic area source of HAP emissions, then follow the instructions
for notifying EPA of your non-major status in section A of this
document.)  

If your mill is a major (or synthetic area) source of HAP emissions,
then you will need to develop and supply the NEI data set requested in
the Facility and Inventory tabs of the pulp and paper sector survey. 
Useful starting points for providing the NEI data set may include your
air operating permit or permit application, an inventory of emission
sources for your mill developed for permitting purposes, or the emission
calculations developed for the Toxics Release Inventory (TRI) for your
mill.  Additional resources useful for estimating emissions are listed
in Attachment 5.

Populate the NEI information in the Facility and Inventory tabs by
adding your data to the left of the orange vertical line (column AF in
the Facility tab and column BZ in the Inventory tab).  Pulp and paper
survey data fields (in addition to those in the NEI) have been added to
the right of the orange vertical line in the tab and require completion
as described in the instructions for “Process data” in section D3 of
this document.  

You will add one row of data in the Facility tab, and multiple rows of
data in the Inventory tab.  An “Instruction” row appears that the
top of each spreadsheet tab to provide a brief instruction for fields
that require some description.  More detailed instructions appear in
this document where needed.  You will add data to all columns (including
the gray shaded columns).  If a gray shaded column is superseded by a
“REVISED” column, then you may enter your data in either the
“REVISED” column or the gray column (but you need not enter the same
data into both columns).

Add the single row of NEI data in the Facility tab as needed following
the instructions that appear in each column.  Use an NEI Site ID of
“NEW_____” where the blank is your mill’s zip code, as this will
(in all likelihood) provide a unique identifier for your mill.  Add data
to the Inventory tab by referring to the instructions (in this section
and section D2.a of this document) for updating the Inventory tab. 
Enter appropriate identifiers such as the “Facility Registry
Identifier” (text limited to 15 characters), and the Emission Unit ID,
Process ID, and Emission Release Point ID (all text limited to 6
characters).  

The spreadsheet entitled Lookups for P&P survey.xls provides various
codes associated with the NEI data.  This Lookups for P&P survey.xls
spreadsheet also contains SCCs.

D3.  	Process data 

Complete the Process data portion of the survey only after you have
updated your NEI inventory.  

 

In this portion of the survey you will continue to use the P&P sector
survey.xls spreadsheet, where you will: (1) add additional information
to the right of the orange vertical line in the Facility and Inventory
tabs, and (2) add data to most of the remaining survey tabs (as
applicable).  Many of the instructions you need for completing the
survey tabs are included in the “Instruction” row of each tab in the
P&P sector survey.xls spreadsheet.  However, more detailed instructions
for selected tabs are provided below to account for common situations
and to provide information on how the data will be used by EPA.  Each
survey tab includes fields with pull down menus for common entries.  Use
these pull-down menus whenever possible, or write in information if your
selection is not contained in the pull down menu.  

Several IDs are requested throughout the pulp and paper survey response
spreadsheet(s), including:   

NEI Site ID

Emission Unit ID

Collection system ID

Various Line IDs including: Pulping line ID, Bleaching line ID, or paper
machine Emission Unit ID

APCD_ID

The NEI Site ID and Emission Unit ID come from your NEI update in the
Facility and Inventory tabs.  You will specify the Collection system ID,
APCD_ID and the various Line IDs in the Equip detail and other
spreadsheet tabs.  The Line IDs are described as follows.

Pulping line ID.  Many mills have only one pulping line.  However, some
mills may have multiple pulping lines, and/or may have pulping lines of
different types (e.g., a kraft pulping line, semichemical line, and a
secondary fiber pulping line).  In general, a pulping line begins with
digesters (or chip steaming for TMP; repulping for secondary fiber
pulping; etc.) and ends with high density storage of pulp (prior to
bleaching and/or papermaking).  You may find it easier to specify the
Pulping line ID in the Pulp prod tab first before completing the Equip
detail tab or other spreadsheet tabs that use the Pulping line ID.

You will identify the different pulping lines in the Equip detail tab,
Pulp prod tab, and several other spreadsheet tabs.  There may be shared
equipment between multiple pulping lines (e.g., shared chemical recovery
equipment).  Indicate multiple pulping line IDs in “Line ID” or
“pulping line ID” columns for equipment shared between multiple
pulping lines.

Example 1:  Consider a kraft mill with two pulping lines (PULP2A AND
PULP3) that share equipment in the chemical recovery loop.  The Pulping
line ID column would contain “PULP2A_PULP3” in the for the shared
emission units in the chemical recovery loop.

Example 2: Consider a kraft mill with semichemical pulping collocated,
having pulping lines KRAFT1 and SEMICHEM1 that share an evaporator and a
recovery furnace.  The pulping line ID assigned for the evaporator and
recovery furnace could be KRAFT1_SEMICHEM1.  

If the Emission Unit ID or the Process ID identifier in the Inventory
tab uniquely describes your pulping line, then you may use this
alpha-numeric code as the Pulping line ID.  If the Inventory tab does
not contain a unique identifier for your pulping line, you can
independently assign this unique identifier.

If in doubt as to what ID to use, enter Pulping line IDs that make sense
for your mill.  The purpose of the Pulping line ID is to distinguish
among emission units used in the pulping area and on different pulping
lines.  Just make sure that the Line IDs you enter are consistent
throughout the spreadsheet.

Bleaching line ID.  A bleaching line is a group of bleaching stages
arranged in series such that bleaching of the pulp progresses as the
pulp moves from one stage to the next.  The Bleaching line ID is used to
identify which emission units appear in each bleaching line located at
the mill.  Most mills would have only one bleaching line (if any), but
there may be some mills with multiple bleaching lines (with each
bleaching line assigned a different Bleaching line ID).  The Bleaching
line ID entered in the Equip detail tab must match the Bleaching line ID
used in the Bleaching tab.

Paper machine Emission Unit ID. Paper mills may have multiple paper
machines (each identified with a paper machine Emission Unit ID). 
Emission units located in the paper mill should be assigned a Line ID
based on the paper machine the emission unit serves (as identified with
the paper machine Emission Unit ID).  For example, stock blending and
storage tanks serving paper machine PM1 would be assigned a Line ID of
“PM1” (where PM1 is the paper machine Emission Unit ID) would be
assigned for each stock blending and storage tank.  If stock blending
and storage tanks were shared among paper machines PM2 and PM3, then
“PM2_PM3” would be entered as the Line ID for each stock blending
and storage tank.

 

Follow the instructions below and in the “Instruction” rows of the
spreadsheet to complete the survey tabs.  Refer to Table 1 of this
document to determine which tabs you must complete depending on the type
of mill you operate.

a. 	Facility tab  

Complete the columns to the right of the orange line in the Facility
tab, following the instructions provided in the “Instruction” row. 
Your response in the Facility tab will consist of one row of data. 
These data will be used by EPA to characterize your facility and
identify applicable regulations.  

Size of entity. Attachment 3 to this document contains a listing of
NAICS codes and small business size standards or NAICS subsector 322. 
For private businesses, small entity is defined for each NAICS of the
owning entity based on number of employees and/or company revenue.  The
parent company number of employees is used for the pulp and paper
subsector (322).  Note that the “number of employees” is calculated
according to the Small Business Size Regulations codified at 12 CFR
§121.06 where all individuals employed on a full-time, part-time, or
other (e.g., temporary) basis are counted equally. 

Paper or paperboard processes/products.  Enter the total number of
operable paper machines located at the mill in 2009 (including any
machines that were temporarily idle due to economic conditions in 2009)
in the “Total number of paper machines” column.  Enter the total
paper/paperboard machine capacity as of 2009 in the "2009 total
paper/paperboard capacity, st/yr” column.  Note that capacity
represents the paper/paperboard production capability of the operable
machines and may be greater than 2009 actual production.   Next enter
the total 2009 capacity to produce each paper grade across all paper
machines (again, including machines temporarily idle in 2009).

Paper/paperboard capacity utilization.  You are asked to provide the
decimal percentage utilization for paper/paperboard production at your
mill for the survey base year (2009).  In addition, because 2009 was
characterized by short-term production curtailments at many mills due to
the U.S. economic situation, you are asked to provide a 5-year average
capacity utilization.    

b. 	Inventory tab (permit limit information)

Permit limits for each emission unit/point and pollutant are requested
to the right of the orange line in the Inventory tab (column BZ).  You
should include a row of data for every emission unit/point and pollutant
combination with a permit limit.  Do not include permit limits in rows
you marked for deletion of the NEI data.  If a pollutant appears in the
NEI, but is not listed in your permit with a specific permit limit, then
leave the permit limit information to the right of the orange line blank
since no permit limit applies.   

For each emission unit, refer to the NEI data “Pollutant Code,”
“REVISED Pollutant Code,” and/or “Pollutant_Code_Desc” columns
to the left of the orange line to determine which pollutant permit
limits to enter.

If available in the permit, provide limits in terms consistent with the
suggested units shown in Table 2 below.   These suggested units were
taken from existing Federal limits codified in 40 CFR part 60 subpart BB
or 40 CFR Part 63 subparts S or MM.  Specify permit limits as written in
the permit if the suggested limit units are not included in the permit.
You do not need to convert limits to the suggested units.  You may
specify limits for a given pollutant in multiple units/formats (e.g.,
ppmdv and/or % reduction) if the permit is written to include multiple
compliance options.  The survey spreadsheet allows for up to five
different permit limit formats for the same pollutant.  Permit limits of
most interest to EPA are concentration limits (ppmdv, gr/dscf, etc.),
percent reduction, mass per unit production (lb/ton of material
throughput, etc) because these limits can be compared from facility to
facility independent of emission unit or mill capacity.  Mass emission
rate limits (lb/hr or tpy) are not being requested unless this is the
only way in which limits are specified in the permit.

EPA will use the permit limit information you supply in comparing permit
limits across similar emission units nationwide.  Please be as specific
as possible when entering permit limit units.  Include any oxygen
correction factors (%O2).  Be sure to note if ppm values are on a dry
(d) or volume (v) or weight (w) basis if specified this way in your
permit (ppmdv, ppmdw, ppmv, ppmw). 

Table 2.  Suggested Units of Measure for Permit Limits

Pollutant	Suggested units

PM1	Recovery furnaces/chemical recovery combustion units:  gr/dscf @ 8%
O2

SDT: lb/ton BLS

LK: gr/dscf @10% O2

PM101	Other processes:  specify

PM2.51

	Opacity	%  (provide averaging time)

TRS	RF/combustion units:  ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S)

LK: ppmdv @ 10% O2

Other processes:  lb/ADT pulp and/or ppmdv

SO2	lb/MMBtu and/or ppmdv or limits on fuel S content

NOx	lb/MMBtu (as NO2) or ppmdv

CO	lb/MMBtu or ppmdv

Pb or other HAP metals	Specify units

VOC	lb/{production}, specify if as propane, etc. or ppmdv

THC	Report as carbon. 

RF/combustion units:   Lb/ton BLS

HCl	ppmdv and/or % reduction

Methanol and gaseous organic HAP	chemical recovery combustion sources:
lb/ton BLS

process sources: ppmv @ 10% O2, lb/ton ODP, and/or percent reduction

Chlorine and chlorinated  HAP	ppmv, lb/ton ODP, and/or percent reduction


Other speciated HAP (specify…)	Specify units

1Specify filterable and/or condensable if your permit limits distinguish
between the filterable and condensable PM fractions.

Permits restating NESHAP and NSPS limits.  Your permit may simply
restate the emission limits contained in Federal rules such as NESHAP
subparts S and MM and NSPS subparts BB or Db.  Some permits may list all
of the compliance options contained in the Federal rules as permit
limits.  If this is the case, you do not need to enter permit limits
that are exactly the same as Federal NESHAP or NSPS.  Instead, specify
the applicable Federal rule (not the specific numeric Federal limits) in
Column CF and skip the remaining permit questions/columns in the table. 
If your permit contains additional State limits in terms other than the
Federal limit, please indicate these limits in the appropriate column
(e.g., Column CG for permit limit 1, Column CJ for permit limit 2, etc.)
 Please do not enter State lb/hr or tpy emission limits in addition to
the Federal limits.

Particulate Matter (PM) fractions.  The NEI contains many variations and
fractions of PM (e.g., Primary PM10, Filterable Portion Only; Primary
PM10 (Includes Filterables + Condensibles), Primary PM2.5, Filterable
Portion Only, etc).  Enter your permit limit information for the
relevant fraction(s).   Leave the permit limit columns blank for any PM
fractions listed in the NEI data for which you do not have permit
limits.  

Opacity.  The NEI does not include opacity as a pollutant, but Federal
rules limit opacity for certain equipment, and states may have different
limits for opacity.  Please enter permit limits for opacity for the
emission units/points you included in the NEI with PM data.  Enter the
opacity data as an alternative permit limit format on the same row where
you specify your PM permit limit(s).  Your do not need to add separate
rows for opacity.  The opacity limits of most interest to EPA are those
for fuel fired equipment such as recovery furnaces, chemical recovery
combustion units, lime kilns, boilers, and thermal oxidizers. 

VOC, HAP, and other pollutant groupings.  There may be instances where
specific pollutants are listed in the NEI, but your permit limits
emissions of the specific pollutant through a limit on a larger grouping
of pollutants such as VOC, HAP, PAH, etc.  To reflect these types of
permit limits, enter the relevant numeric permit limit and note the
pollutant grouping limit in the “units for permit limit” column
(e.g., 50 ppmdv VOC).   [Note:  The converse of this situation – where
your permit contains limits for specific pollutants that are not listed
in the NEI  – should not be an issue if you have followed the NEI
update instructions in section D2 above.  You should have an NEI data
row for every emission unit/point and pollutant permit limit listed in
your title V permit.]  

c. 	Equip detail tab  

All mills are asked to complete the Equip detail tab.  This tab asks
for information for each individual emission unit.  The purpose of this
tab is to provide EPA with equipment-specific details needed for the
Agency to review the technology-based standards (i.e., nationwide
numbers of equipment, configuration of controls, pertinent equipment
details, and regulatory compliance options used).

The types of emission units listed in Attachment 1 that you operate
should be included in the Equip detail tab.  Columns A through AQ ask
generic questions for all emission units.  The columns to the right of
column AQ request design and operating details for specific types of
emission units (e.g., recovery furnaces, digesters, etc.).  The table
below summarizes the different types of equipment for which specific
questions are included in the Equip detail tab.



Equip detail tab columns  	Description of information requested



	A-AQ	Equipment, controls, and Federal rule applicability for each
emission unit and collection system.  Complete these columns for all
emission units. 



	AR-AT	Digesters

AJ-AY	Pulp washers

AZ-BA	Knotters, screens, and deckers

BB-BE	Evaporators

BF-BH	Oxygen delignification

BI-BR	Strippers

BS-BW	Pulp storage and liquor storage

BX-CA	Liquor storage ponds

CB-CF	Causticizing equipment

CG	Black liquor gasification

CH-CM	Black liquor oxidation systems

CN-DA	Recovery furnaces and recovery furnace ESPs

DB-DH	Semi-chemical combustion units (at stand-alone semichemical pulp
mills)

DI-DN	Smelt/ash dissolving tanks

DD-DV	Lime kilns (including rotary lime kilns and fluidized bed
calciners)

DW	Boilers and thermal oxidizers/incinerators

DX-DY	Identification of emission units incinerating NCG or SOG

DZ-FJ	Fuel types and amounts for fuel-fired equipment (e.g., for lime
kilns, recovery furnaces, boilers, thermal oxidizers, etc.)

FV-GB	Emission unit startup and shutdown.



Data are requested for each emission unit (and need not be broken out by
individual emission points for a given emission unit unless different
collection or control measures apply for the different emission points
from an emissions unit).  Specify the Line ID, Emission Unit ID and
Collection system ID (if applicable), and APCD_ID(s) by following the
directions in the “Instruction” row of the Equip detail tab.  Some
common configurations of emission units are addressed below.

Multiple emission units ducted to a single release point.  List each
emission unit separately in the Equip detail tab even if the exhaust
from the emission unit is ducted to a common conveyance.  For multiple
emission units ducted through a common conveyance to the same release
point, list each Emission Unit ID separately and provide the same
Collection system ID for the different Emission Unit IDs. 

For example, an LVHC collection system (Emission Unit ID LVHC01) may
collect emissions from multiple emission points associated with
digesters 1, 2, and 3 and an evaporator (Emission Unit IDs D1, D2, D3
and EVAP1).  You should list digesters 1, 2, and 3 and the evaporator on
four separate rows in the Equip detail tab (with 4 separate Emission
Unit IDs, as shown above) and provide the data requested for each
emission unit, indicating for each entry that the emissions are
collected by the LVHC collection system (Emission Unit ID LVHC01).  You
should also list the LVHC collection system in the in the Emission Unit
ID column (using the Collection system ID as the Emission Unit ID) so
you can provide control information and equipment details for the LVHC
collection system.

Single emission unit with multiple release points.  Repeat the Emission
Unit ID on separate rows and distinguish the release points using the
“Emission unit description” column in as many rows as needed to
reflect all of the release points associated with the emission unit in
the Equip detail tab.  For example, Emission Unit ID 001 (EU001) is
vented to two stacks with different controls.  Split EU001 to EU001a and
EU001b on separate rows of the Equip detail tab, and then indicate in
the “REVISED Emission Unit Description” column that EU001a and
EU001b vent through separate stacks.  Enter details associated with
emission release (APCD information and compliance options for subparts
S, MM, or BB) in each row.  Enter equipment details (year installed,
hr/yr, combustion controls, fuel data, equipment design and other
operating parameters) in only 1 row, leaving all other rows associated
with the Emission Unit ID blank.

Emission units vented into the building.  Include emissions units that
vent into a building in the Equip detail tab, and enter “BLDG” in
the “Configuration if not emitted through a conveyance” column.

Emission units that are not vented.  Include emissions units that are
not vented in the Equip detail tab, and enter “NV” in the
“Configuration if not emitted through a conveyance” column.

Emission units with fugitive emissions.  Include emissions units with
fugitive emissions in the Equip detail tab, and enter “FUGITIVE” in
the “Configuration if not emitted through a conveyance” column.

If an emission unit produces both fugitive emissions and emissions that
are emitted though a conveyance then you need to specify the fugitive
emissions on a separate row in the Equip detail tab (e.g., as a
“Single emission unit with multiple release points” as described in
the instructions immediately above for the Equip detail tab).

Bypass stacks used only during certain times.  Do not include data for
bypass stacks or control system bypasses in the Equip detail tab, except
as specified for backup controls below.

Air pollution control devices (APCD).  In the APCD columns, enter
primary air pollution control devices (i.e., the pollution control used
most frequently) in the sequence in which they are used to control
emissions from each emission unit (or collection system) identified in
the Emission Unit ID column.  Enter a description of the APCD in the
APCD “type” column and an ID code in the APCD_ID column.  The ID you
enter into the APCD_ID field will correspond with the APCD_ID you enter
in the Controls tab.  For example,

If you use an ESP (ESP1) followed by a scrubber (WSa), you would enter
APCD1 type = ESP and APCD2 type = scrubber, and APCD1_ID = ESP1 and
APCD2_ID = WSa. 

If a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG
prior to burning of the SOG in a lime kiln (Emission Unit ID = LK2),
then APCD1_ID = WLIQSBR and APCD2_ID = LK2.

Emission units routed to a boiler or lime kiln for emissions control. 
Enter the Emission Unit IDs for each emission unit in the Emission Unit
ID column.  Use the lime kiln’s Emission Unit ID  in the APCD columns.

Backup controls.  Backup controls include alternative controls used when
flow from an emission source (e.g., LVHC or HVLC collection system) is
diverted from the primary control device to a less frequently used
control device.  For example, the primary LVHC control may be lime kiln
1 and the backup control may be a boiler when lime kiln 1 is not
operating.  Enter backup controls in the “Back-up method of control”
column of the Equip detail tab.  Do not include backup controls in the
columns for APCD1 through APCD4.

Complete the applicable equipment-specific details requested in columns
AR through GB for each type of emission unit in the Equip detail tab by
following the directions in the “Instruction” row of the tab. 
Additional specific instructions are provided below for equipment
requiring instructions beyond what could be explained in the
“Instruction” row.  Leave columns that do not apply for a given
emission unit blank.

 

All emission units listed in Attachment 1.  Complete columns A through
AQ.  These columns ask generic questions for all emission units related
to how the emission units are vented and controlled, and related to
Federal rule applicability.  Additional questions in columns AR through
GB may also apply for selected emission unit types.

Pulp processing equipment. Information pertaining to pulp processing
equipment such as digesters, pulp washers, knotters, screens, deckers,
evaporators, and oxygen delignification is requested so EPA can
determine the population and characteristics of these emission units
following subpart S MACT compliance.  Capacities are requested so EPA
can estimate emissions and perform impacts analyses.

Strippers.  Information related to strippers is requested to provide an
understanding of the number and characteristics of strippers in use at
pulp and paper mills following subpart S compliance.

Pulp storage and liquor storage, and liquor ponds.  HAP emissions may be
associated with pulp and cooking liquor storage tanks, and liquor
storage ponds.  Questions pertaining to pulp and liquor storage are
asked to provide an inventory of storage equipment and to characterize
any storage processes that may require further analysis for subpart S
residual risk purposes. 

Causticizing equipment.  Limited questions are asked for equipment in
the causticizing loop of mills that perform kraft, soda, or semichemical
pulping.  Information on causticizing operations provides inventory
detail and process rates for purposes of emission calculations, and can
inform EPA of practices that could be used to reduce emissions from the
lime kiln or from other causticizing equipment.  

Recovery furnaces and chemical recovery combustion units.  Questions
pertaining to recovery furnaces have been combined for kraft, kraft with
co-located semichemical, soda, and sulfite pulps.  The
equipment-specific details will provide post-MACT recovery furnace and
chemical recovery combustion unit configurations.  Capacities and other
design parameters are requested for purposes of impacts analyses. 

Smelt tanks and lime kilns.  These questions will characterize the
population of smelt dissolving tanks and lime kilns following subpart MM
compliance.  Capacities and other design parameters are requested for
purposes of impacts analyses.

Wastewater handling/treatment units.  Complete the generic questions in
Columns A through AQ of the Equip detail tab for any wastewater
handling/treatment units that are closed and/or vent through a
conveyance.

Boilers. The EPA is requesting limited information on boilers in the
Equip detail tab because many pulp and paper mills use boilers for
primary or backup control of organics from pulping process and because
boilers currently contribute to the facility-wide risk levels at pulp
and paper mills.

Primary and supplemental fuels.  Fuel types are requested for fuel-fired
equipment because fuel type can have an effect on emissions.  The EPA
may consider fuel types and perform calculations based on fuel firing
rates for various nationwide impact analyses.  Because the types and
amounts of fuels fired can vary seasonally, EPA is requesting the amount
of each fuel type used in 2009 instead of hourly firing rates for each
fuel.  The annual fuel amount can be used with the 2009 emission unit
operating hours to derive an annual average fuel firing rate for
purposes of regulatory analyses.

Primary fuel information is requested for fuel-fired equipment such as
boilers, lime kilns, thermal oxidizers, and direct-fired dryers (e.g.,
pulp dryers or paper machine dryers).  Primary fuels are not requested
for recovery furnaces or other chemical recovery combustion units
because black liquor (or red liquor) is assumed to be the primary fuel
for these units.  Non-condensible gases (NCG) and SOG are not considered
to be either primary or supplemental fuels for purposes of this survey. 
Supplemental and other fuel information is requested for recovery
furnaces and chemical recovery combustion units in addition to other
fuel-fired equipment such as boilers, lime kilns, thermal oxidizers, and
direct-fired dryers.  Information for secondary and additional fuels
used routinely for multi-fuel fired equipment may be indicated in the
supplemental and other fuel columns.

Emission unit startup and shutdown.    Complete the startup and shutdown
questions for all emission units currently subject to Federal or State
emission limits or monitoring requirements.  Questions pertaining to
emission unit startup and shutdown are asked in order to provide EPA
with an understanding of the duration, emissions potential, work
practices, and control mechanisms of startup and shutdown events for the
wide variety of equipment used at pulp and paper mills.  The EPA is
considering standards that could apply during startup and shutdown
events (or whether the current standards developed for normal operation
should apply) in light of the December 2008 vacatur of the NESHAP
startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart
A.  The startup and shutdown questions would also identify pulp and
paper emission unit types for which startup and shutdown are not already
addressed with the current emission standards.  You are asked to supply
information for routine startup and shutdown events associated with
planned process or mill downtime.  (Do not provide information for
unplanned startup/shutdown events associated with equipment
malfunctions).  The startup and shutdown data in the Equip detail tab
are being sought for regulatory development purposes, and will not be
used for enforcement purposes.  

d.  	Controls tab 

Complete the Controls tab by following the instructions in the
“Instruction” row for add-on air pollution control devices used to
control pulp and paper emission units.  The data requested in the
Controls tab include pertinent control device design parameters that
will be used by EPA to distinguish among control devices (e.g., pressure
drop and L/G ratio can be used to identify high vs. low efficiency wet
scrubbers) and to understand the non-air environmental impacts
associated with the control devices (e.g., amount of wastewater or solid
waste generated and methods for handling).

Boilers.  You do not need to include air pollution control device
details for boilers in the Controls tab since NCGs combusted by boilers
are presumed to be destroyed in the boiler and are subsequently
unaffected by the boiler’s APCD. 

Control efficiency.  Actual and design control efficiencies are
requested for PM, TRS, HCl, SO2, and other HAP.  This information will
be used in determining the capability of different control devices for
reducing emissions.  If you have data from inlet/outlet emissions
testing used to determine a percentage reduction in the requested
pollutant across the control device, that you would enter this test
result as the “actual” control efficiency.  If you do not have test
data specifying the actual control efficiency, then the control device
manufacturer’s “design” control efficiency is requested for
applicable pollutants.  Please enter both the actual and design control
efficiency if available. Leave the control efficiency columns blank if
actual or design control efficiency is not known (or not applicable for
a given pollutant).     

Strippers.  Specific information for strippers used to reduce air
emissions from process liquid or wastewater streams is requested in the
Equip detail tab rather than in the Controls tab.

Thermal oxidizers.  Questions pertaining to thermal oxidizers are
included in both the Controls and Equip detail tabs.  The Equip detail
tab contains questions about heat input capacity, equipment incinerating
NCG or SOG, and primary or supplemental fuels.

Control device startup and shutdown.  The EPA is considering standards
that could apply during startup and shutdown events (or whether the
current standards developed for normal operation should apply) in light
of the December 2008 vacatur of the NESHAP startup, shutdown, and
malfunction exemption in 40 CFR Part 63 subpart A.  Questions pertaining
to control device startup and shutdown are asked in order to provide EPA
with an understanding of the duration and definition of startup and
shutdown events for the types of control devices used at pulp and paper
mills.  The EPA is seeking information on the integral nature of startup
and shutdown events for the different combinations of emission units and
control devices used in the pulp and paper industry.  In addition,
because Federal NSPS and NESHAP require continuous monitoring of
emissions or control device operating parameters, information is
requested to inform EPA of particular pulp and paper NSPS or NESHAP
control device parameter limits that cannot feasibly be met during
startup and shutdown events.  Certain parameters may be "instant on"
while others are more transient in nature (i.e., changing as startup or
shutdown progresses).  Examples could include control device temperature
that must heat up to a set point, or pressure drop that cannot be
achieved due to low exhaust gas flow from the emission unit.  The EPA
will use this information to evaluate which existing control device
parameter limits may remain in effect during startup and shutdown
events, and which parameter limits may need to be replaced with another
requirement during startup and shutdown.  In all of the control device
startup and shutdown questions, you are asked to supply information for
routine startup and shutdown events associated with planned equipment or
mill downtime.  (Do not provide information for unplanned
startup/shutdown events associated with equipment malfunctions).  The
startup and shutdown data in the Controls tab are being sought for
regulatory development purposes, and will not be used for enforcement
purposes.  

e. 	Potential changes tab

The Potential changes tab lists several types of mill changes that could
affect emissions or rule applicability.  This information will be used
by EPA in projecting the number of new emission units likely to be
installed for purposes of new source impacts analyses.  Most of the
questions in the Potential changes tab have yes/no answers, with
additional description requested for any planned changes.

Complete the Potential changes tab by following the instructions in the
“Instruction” row.

f. 	Pulp prod tab

The Pulp prod tab is to be completed by all mills that produce pulp
onsite using chemical, semichemical, mechanical, non-wood, and secondary
fiber pulping processes. This tab is arranged in a way to accommodate
multiple pulping lines and each pulping line should occupy only one row
(e.g. co-produces kraft and mechanical pulps use two rows).  Some data
fields apply for specific types of pulp (e.g., mechanical pulp, non-wood
pulp).  If a data field does not apply to a particular type of pulping
line, simply leave the field blank. Provide data for the 2009 operating
year.  The pulp production data will be used by EPA to understand the
general mill flow and in estimation of impacts and economic analyses. 

Complete the Pulp prod tab by following the instructions in the
“Instruction” row.

g. 	Byproducts tab   

Mills that recover turpentine or tall oil from pulping processes should
complete the Byproducts tab.  Basic turpentine and tall oil production
information are requested (hr/yr, gal/day and digesters supplying
byproduct production).  Turpentine recovery systems are covered under
subpart S.  Tall oil production may be considered in the review of pulp
and paper regulations.  The information requested may be used to
estimate emissions and in economic calculations.  

Complete the Byproducts tab by following the instructions in the
“Instruction” row.

h. 	PCC tab

Mills that route lime kiln, boiler, or other process exhaust to a
precipitated calcium carbonate (PCC) plant should complete the PCC tab. 
Information regarding the emission units involved, time, controls, and
portion of process exhaust routed to the PCC plant are requested. 
Questions regarding land ownership and permitting are also asked.  This
information would help regulation writers understand the nature of this
process should routing of exhaust to an onsite PCC plant need to be
mentioned (e.g., with a special provision, exemption, etc.) in a
regulation.

Complete the PCC tab by following the instructions in the
“Instruction” row.

i. 	Kraft condensates tab

Complete the Kraft condensates tab by following the instructions in the
“Instruction” row.  The kraft condensate control options are
summarized as follows.  This table corresponds with the pull down menu
options for condensates treated by steam strippers, biological
treatment, or other means. 

Control option	Applicability	Rule reference

92% total HAP reduction (by weight) 	 	§63.446(e)(3)

Remove 6.6 pounds/ton ODP	Mills that do not bleach	§63.446(e)(4)

210 ppmw at the outlet of the control device	Mills that do not bleach
§63.446(e)(4)

Remove 10.2 pounds/ton ODP	Mills that bleach	§63.446(e)(5)

330 ppmw at the outlet of the control device	Mills that bleach
§63.446(e)(5)

Remove prorated mass of ___ pounds/ton ODP.  {Respondent should specify
limit in blank}	Mills producing a mixture of bleached and unbleached
pulp	§63.446(i)



j. 	CCA tab

The CCA tab is divided into two portions: (1) Emission Balance to the
left of the orange vertical line (column I), and (2) CCA Equipment List
on the right of the orange vertical line. You will enter one row of data
for the Emissions Balance and multiple rows of data for the CCA
Equipment List.

The CCA tab must be completed once for each set of CCA compliance
calculations used by your mill.  Add another CCA tab if you need to
provide more than one set of CCA calculations.  As an alternative to
completing the CCA tab, you may attach separate documentation of your
CCA calculations used for purposes of showing compliance.  

Sources eligible for inclusion in the CCA as credit generators include:
pulping systems, bleaching systems, causticizing systems, and
papermaking systems.   Debit generating sources can include equipment
from the kraft mill HVLC system, including:  pulp washing systems,
knotter systems, screen systems, decker systems, O2 delignification
systems, and weak liquor storage tanks. Refer to the system definitions
in subpart S at §§63.441 and 63.447(a).  EPA is not requesting
detailed calculations used to show compliance with the CCA at this time.
 However, EPA reserves the right to request additional detail if needed
as a follow-up to this survey.  

Complete the CCA tab by following the instructions in the
“Instruction” row.

k. 	Bleaching tab 

All mills that perform bleaching should complete the portion of this tab
to the left of the orange vertical line (column O) to describe the
bleaching systems used at your mill.  Your response will consist of one
row for each bleaching line located at your mill.  Most mills will have
only one or two bleaching line rows.  

If your bleaching system includes any stages that use chlorine or
chlorinated compounds, then you must complete the portion of this tab to
the right of the orange vertical line. Extraction or other bleaching
stages that do not use chlorine or chlorinated compounds are not covered
by subpart S and should be reported with “NA (no chlorine or
chlorinated compounds used in this stage)” indicated.

Responses to these bleaching questions will be used to characterize
mills according to bleaching processes used, estimate nationwide
emissions, and identify subpart S compliance options commonly used
(e.g., to determine if any remaining residual risk is associated only
with bleaching at mills meeting certain compliance options). 
Information on how the mill uses the pulp exiting the bleach plant may
be used for economic modeling and in characterization of potential
emissions from paper machines (e.g., use of bleached/unbleached pulp
produced onsite, use of purchased pulp, effects of bleaching process on
paper machine emissions, etc).

Complete the Bleaching tab by following the instructions in the
“Instruction” row.

l. 	Paper prod tab 

All mills that produce paper should complete the Paper prod tab. Report
information for all operable paper machines (including idle machines
that are capable of operating in the future). Complete the Paper prod
tab by following the instructions in the “Instruction” row.

If multiple paper grades are produced on the same paper machine (e.g.,
coated free sheet produced some of the time, and uncoated freesheet
produced at other times), then you will need to include paper machine
information on separate rows.  Given the numerous specific grades of
paper and paper characteristics, EPA requests that you distinguish among
a relatively short list of generalized paper grades, including: 

coated free sheet	kraft packaging

uncoated free sheet	linerboard

coated groundwood	corrugating medium

uncoated groundwood	solid bleached board

tissue & sanitary	recycled board

specialty packaging & industrial	construction paper and board

	other *

*Respondents are asked to specify a general paper grade in the event
that one of the 

   general grades listed above is not representative.

	

Information on pulp type is requested because it is possible that pulp
type may have an effect on emissions (particularly for bleached versus
unbleached pulps).  Should EPA consider paper machines for residual risk
rulemaking, information such as pulp type, whether the pulp is bleached
or unbleached, paper grade, and liquid HAP concentration may be useful
for purposes of subcategorizing of paper machines. 

You are asked to specify the approximate makeup of each paper machine
furnish - specifically the approximate percentage of each pulp type.  We
recognize that the percentage can vary throughout the operating year,
and therefore, a specific percentage is not being requested.  It will be
sufficient to round to the nearest 5 or 10 percent.

m. 	HAP additives tab

Complete the HAP additives tab for any stock preparation and paper
machine additives that contain measurable concentrations of one or more
of the following HAP:  formaldehyde, acetaldehyde, napthalene, methylene
chloride, acrylamide, or benzene.  Only include in this tab additives
with measurable quantities of HAP as reported on the material safety
data sheet (MSDS) for the additive.  Although it is unclear whether
paper machine additives contribute significantly to paper machine
emissions (e.g., because additives may partition to the paper product or
white water, and not necessarily to the air) EPA is requesting
information for paper machine additives that contain HAP of significance
for purposes of residual risk.  EPA is not requesting information for
other paper machine additives (many of which contain no HAP).  The HAP
additives information would be used (e.g., along with emissions data for
paper machines) to identify HAP-containing additives that may contribute
significantly to paper machine HAP emissions or residual risk, and to
evaluate work practices related to additives.  

Complete the HAP additives tab by following the instructions in the
“Instruction” row.

n.  	WW tab  

All mills with onsite wastewater treatment plants (WWTP) should complete
the WW tab columns to the left of the orange vertical line (column W). 
The purpose of the WW tab is to provide EPA with information regarding
the status of permitting requirements and emissions measurement for pulp
and paper mill wastewater treatment plants.  This information will be
used by EPA for purposes of reviewing the pulp and paper regulations
(e.g., NSPS and/or NESHAP subpart S).  Use the WW tab to specify any
Federal/State/local requirements, permit limits, fence-line monitoring,
measurement methods (such as ambient measurements), or modeling methods
that apply for measurement or estimation of HAP and TRS (including H2S)
air emissions associated with the wastewater treatment system.

In addition to questions about measurement and permitting status, mills
are requested to submit a flow diagram of the WWTP (see section D1 of
these instructions) and to complete some basic questions regarding WWTP
capacity, the sequence of wastewater treatment units, and upstream
controls/practices that reduce air emissions from the WWTP.  Mills are
also asked to identify any wastewater treatment units that are closed to
limit emissions to the atmosphere, or equipped with a closed vent
collection system and APCD.  If any wastewater treatment units are
equipped with a closed vent collection system and APCD, then you should
also include the wastewater treatment unit in the Emission Unit ID
column of the Equip detail and Control tabs and indicate the APCD
information in those tabs.  

Mills with wastewater treatment plants that serve as the biological
treatment system for the subpart S kraft condensate standards must
complete the questions to the right of the orange vertical line in the
WW tab.  These questions request the subpart S quarterly biological
treatment system compliance testing results for the four quarters of
calendar year 2009.  This information will inform EPA of the performance
of biological treatment systems in destroying HAP.

Complete the WW tab by following the instructions in the
“Instruction” row.

D4.  	Test data

	Attachment 6 of this survey contains a table of emission units and
pollutants for which existing emissions data are requested.  Emissions
data are being requested in the form of emissions test reports or
continuous emissions monitoring, whichever may be available.  You are
not required to conduct any new emissions testing or continuous
emissions monitoring to respond to this survey.  Follow the instructions
below for the “Emissions test data tab” for emissions test reports. 
Follow the instructions for completing the “CEMS data spreadsheet (P&P
CEMS spreadsheet.xls)” if you have continuous emissions monitoring
system (CEMS) data instead of emission test reports for a given emission
unit and pollutant combination.  The emissions test data collected will
provide valuable information on current emissions levels and will allow
EPA to consider variability in emissions from mill to mill (and over
time for a given emission unit and pollutant) in reviewing and setting
emission standards.  When submitting test data, EPA is requesting full
test reports with field and lab data sheets and example calculations,
not just summary reports.

a. 	Emissions test data tab 

Attachment 6 of this survey contains a table of emission units and
pollutants for which existing emission test data are requested.  You are
not required to conduct any new emissions testing to respond to this
survey.  The EPA is only requesting existing emission test reports at
this time as they may already be available.   

Review the test data request table in Attachment 6 of this survey. 
Locate any existing emissions test reports in your files that match the
test method and other criteria for each emission unit and pollutant
combination requested.  Emissions test data representative of your
current operations are requested.  You are not required to supply
emissions data that are no longer representative of the current emission
unit and control system configuration.  For example, if you have
installed controls or made significant process changes expected to
change emissions, then you need not supply emissions data for the prior
configuration.  However, you may voluntarily supply emissions data for
prior configurations, as such information would be useful to EPA in
characterizing emissions in general (for non-site-specific uses), but we
request that you identify that such data are no longer representative in
the Emissions test data tab.

Cutoff dates are provided in Attachment 6 for certain emission unit and
pollutant combinations.   More recent cutoff dates are specified for
emission unit and pollutant combinations expected to be widely available
(e.g., 2001 or date of MACT compliance).  Longer cutoff dates are
included for emission unit and pollutant combinations for which data are
likely to be sparse (e.g., dating back to 1990).  Test data prior to the
cutoff dates are requested only if necessary to obtain results of at
least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff
date.  Multiple years of test data will allow EPA to examine and account
for variability in emissions in setting emissions standards.  

Supply both air pollution control device inlet and outlet data if
available.  

As noted above, submit full and complete copies of the emission test
reports, to include field and lab data sheets and example calculations,
meeting the criteria in Attachment 6 with your survey response.

Electronic (pdf) or hard copies are acceptable.  Include the summary
portion of the report and any appendices showing run-by-run test
parameters, method detection limits, laboratory data, production data,
example calculations, etc.  EPA will extract the test data from the
emission test reports for use in nationwide regulatory analyses.

Complete the Emission test data tab to identify the specific emission
units and control systems for which emission test reports are being
submitted, the pollutant tested, and the test method.  The Emission test
data tab will be used by EPA as the starting point for development of
the emissions test data base that EPA intends to construct based on the
emission test data received through this survey.

b. 	CEMS data spreadsheet (P&P CEMS spreadsheet.xls)

The EPA is requesting the most recent 30 days of existing CEMS data
and/or continuous opacity monitoring system (COMS) data from facilities
that have installed continuous monitoring systems in order to comply
with regulatory requirements or permit conditions.  You are not required
to install or operate any new CEMS or COMS to respond to this survey.

CEMS data that are representative of your current operations are
requested.  You are not required to supply CEMS data that are no longer
representative of the current emission unit and control system
configuration.  

A separate Microsoft Excel spreadsheet (P&P CEMS Spreadsheet.xls) is
provided for submittal of the requested CEMS data.  The spreadsheet
contains individual worksheets (tabs) designed specifically for TRS
(12-hour block average), TRS (hourly), Opacity, NOx, SO2, CO, Methanol,
Chlorine, and PM.  Each worksheet is designed to accommodate data from
one CEMS (including oxygen data).  If you have multiple CEMS of the same
type (e.g., two TRS CEMS on different emission units), then you must
copy the relevant worksheet in order to enter data for the additional
CEMS.

A brief introduction to each of the CEMS worksheets follows. 
Additional, field-specific instructions are included on each worksheet. 
An “EXAMPLE” completed worksheet is also provided as a separate tab
within the P&P CEMS Spreadsheet.xls.

TRS (12-Hour Average).  This worksheet is designed for recovery
furnaces, smelt dissolving tanks, lime kilns, digester systems, brown
stock washer systems, multiple effect evaporator systems, and condensate
stripper systems subject to the TRS monitoring requirements in NSPS
subpart BB, but can be used for any emission units with TRS CEMS.
Respondents are requested to specify the Emission_Unit_ID (or collection
system ID), the APCD_ID, and report the 12-hour averages of CEMS
concentration data for TRS for the most recent 30 days of operation.  In
addition, respondents are asked to provide the highest single 12-hour
average TRS concentration within the most recent calendar year (CY2009)
recorded: (a) under normal operating conditions, (b) under conditions of
startup or shutdown, and (c) under malfunction conditions.  (The data
for startup, shutdown, and malfunction may be included in the most
recent 30 days of CEMS data, or may be for a 12-hour period outside the
most recent 30 days).  [Note: The reported concentrations of TRS should
be corrected to 8% O2 for recovery furnaces and 10% O2 for lime kilns
and other equipment.]

TRS (1-Hour Average).  Same as above, except that this worksheet is
designed to accept the 1-hour average TRS data for the same 30-day
period as provided for the 12-hour averages.

 Opacity.  This worksheet is designed for recovery furnaces or lime
kilns equipped with COMS.  Respondents are requested to specify the
Emission_Unit_ID (or Collection system ID), the APCD_ID, and report the
6-minute and 1-hour averages of opacity for the most recent 30 days of
operation.  In addition, respondents are asked to provide the highest
single 6-minute average opacity recorded within the most recent calendar
year (CY2009) recorded: (a) under normal operating conditions, (b) under
conditions of startup or shutdown, and (c) under malfunction conditions.
 (The data for startup, shutdown, and malfunction may be included in the
most recent 30 days of COMS data, or may be for an hour outside the most
recent 30 days.)

NOx, SO2, and CO. These worksheets are designed for recovery furnaces or
lime kilns equipped with CEMS for NOx, SO2, or CO, but can be used for
other emission units equipped with these CEMS.  Respondents are
requested to specify the Emission_Unit_ID (or Collection system ID), the
APCD_ID (or type of combustion controls used), and report the 1-hour
averages of the CEMS data for these compounds for the most recent 30
days of operation.  In addition, respondents are asked to provide the
highest single 1-hour average concentration within the most recent
calendar year (CY2009) recorded: (a) under normal operating conditions,
(b) under conditions of startup or shutdown, and (c) under malfunction
conditions.  (The data for startup, shutdown, and malfunction may be
included in the most recent 30 days of CEMS data, or may be for an hour
outside the most recent 30 days.)

Total HAP or Methanol.  This worksheet is designed for total HAP or
methanol CEMS installed to demonstrate compliance with the NESHAP
subpart S limits for LVHC systems, HVLC systems, or steam strippers (but
can be used for other emission units equipped with these CEMS). 
Respondents are requested to identify the source of NCGs/SOGs being
controlled by Emission_Unit_ID (or Collection system ID), the APCD_ID,
and report the 1-hour averages of the CEMS data for the most recent 30
days of operation.  In addition, respondents are asked to provide the
highest single 1-hour average within the most recent calendar year
(CY2009) recorded: (a) under normal operating conditions, (b) under
conditions of startup or shutdown, and (c) under malfunction conditions.
(The data for startup, shutdown, and malfunction may be included in the
most recent 30 days of CEMS data, or may be for an hour outside the most
recent 30 days). 

Total Chlorinated HAP or Chlorine.  This worksheet is designed for total
chlorinated HAP or chlorine CEMS installed to show compliance with the
NESHAP subpart S limits for bleaching systems (but can be used for other
emission units equipped with these CEMS or HCl CEMS).  Respondents are
requested to indicate the Emission_Unit_ID (or Collection system ID)
being controlled, the APCD_ID, and report the 1-hour averages of the
CEMS data for the most recent 30 days of operation.  In addition,
respondents are asked to provide the highest single 1-hour average
within the most recent calendar year (CY2009) recorded: (a) under normal
operating conditions, (b) under conditions of startup or shutdown, and
(c) under malfunction conditions.  (The data for startup, shutdown, and
malfunction may be included in the most recent 30 days of CEMS data, or
may be for an hour outside the most recent 30 days). 

PM.  This worksheet is designed for any emissions unit equipped with a
PM CEMS.  Respondents are requested to specify the Emission_Unit_ID (or
Collection system ID), the APCD_ID, and report the 1-hour averages of
the CEMS data for the most recent 30 days of operation.  In addition,
respondents are asked to provide the highest single 1-hour average
concentration within the most recent calendar year (CY2009) recorded:
(a) under normal operating conditions, (b) under conditions of startup
or shutdown, and (c) under malfunction conditions.  (The data for
startup, shutdown, and malfunction may be included in the most recent 30
days of CEMS data, or may be for an hour outside the most recent 30
days).

OPTIONAL-CEMS cost.  Completion of this worksheet is OPTIONAL.  This
worksheet requests equipment cost data for CEMS or COMS installed within
the past 10 years.  EPA can use these data to estimate costs of CEMS or
COMS when evaluating monitoring options.

D5.  	Optional cost data

The EPA requests information related to the capital and operating costs
of selected air pollution controls or process/equipment changes. 
Providing this cost information to EPA is optional at this time.  As
noted in the Section 114 letter accompanying this survey, an additional
60 days beyond the due date for the other portions of your survey
response is allowed for submittal of the optional cost information.  The
Agency wishes to receive enough cost information on a voluntary basis to
perform regulatory analyses.  However, should additional cost
information be needed, EPA reserves the right to follow up with mills
that have installed equipment or implemented process changes of interest
to request cost information under CAA section 114 authority.  

The spreadsheet entitled “P&P costs OPTIONAL.xls” can be completed
to provide cost information. This spreadsheet contains two tabs (APCD
costs and Equip change costs).  The EPA recognizes that cost information
can be sensitive.  The “P&P costs OPTIONAL.xls” spreadsheet contains
a red block at the top of each tab where you can indicate if the tab
contains CBI, or if the entire tab should be treated as CBI.  Responses
containing CBI should be submitted according to the instructions in
section C1 of this document.

Any cost information that you provide would be very useful to EPA for
purposes of evaluating the costs of control measures that may be
considered as regulatory options.  These cost data will be used by EPA
to estimate the nationwide costs of any regulatory options based on the
control measure indicated.  Cost information from within the last 10-12
years is requested (e.g., costs dating back to 1998).  The cost
information could come from vendor quotes for APCD or equipment changes
that either have been implemented or were explored but not implemented. 


The EPA is particularly interested in costs of the following air
pollution control devices (APCD).  Please supply this information using
the APCD costs tab:

     - Recovery furnace scrubbers, dry sorbent injection/fabric filter
(DI/FF), selective catalytic reduction (SCR), or selective non-catalytic
reduction (SNCR)

     - Black liquor oxidizer incinerators or thermal oxidizers

     - Lime kiln electrostatic precipitators (ESP)

     - Bleach plant CO control devices

The EPA is particularly interested in costs of the following process
changes or equipment changes/upgrades.  Please supply this information
using the Equip change costs tab.

    - Changing from a direct contact evaporator (DCE) to non-direct
contact evaporator (NDCE) recovery furnace

    - Changing from a wet bottom ESP to a dry bottom ESP

    - Changing from a dry bottom/wet PM return ESP to a dry bottom/dry
PM return ESP

    - Adding chambers/fields to an existing ESP 

    - Installation of quaternary air ports in the recovery furnace to
improve combustion efficiency

    - Process changes to improve lime mud washing or to control makeup
water quality in the causticizing area

    - Replacing a recovery furnace with a black liquor gasification
system

Complete the APCD costs and Equip change costs tabs by following the
instructions in the “Instruction” rows of those tabs.  You may also
submit information in an alternative format (e.g., as an attachment to
your response) if needed.  Because the cost data will be used by EPA to
estimate the nationwide costs, please note if you believe that any
portion of the cost information that you supply would be completely
unrepresentative of costs that other mills may face for similar control
projects (e.g., if your project capital cost included installation extra
buildings, land purchases, etc. that may not be required for other
mills).   

  ATTACHMENT 1

Emission Units to Include in the Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your survey
response (Inventory and Equip detail tabs).  You may not operate all of
the emission units listed below.  Only include equipment operated at
your mill.  

The “Lookups for P&P survey.xls” file contains a crosswalk of the
equipment listed in this attachment with the available SCCs.

Chemical Recovery Combustion Equipment

Chemical recovery furnace

Chemical recovery combustion unit 

Black liquor oxidization system

Smelt or ash dissolving tank

Lime kiln or calciner  

Black liquor gasification systems

Sulfur burner

Causticizing Equipment

Green liquor clarifier

Green liquor storage tank

Green liquor surge tank

Slaker

Causticizers

White liquor clarifier

White liquor storage tank

White liquor pressure filter tank

White liquor/weak wash pressure filter

Weak wash storage tank

Dregs washer

Dregs filter exhaust

Salt cake mix tank

Lime mud washer

Lime mud filter system

Digester Area Equipment

Digester

Chip bin

Chip steaming vessel

Flash tank

Blow tank

Condenser

Turpentine decanter

Pulp Washing, Thickening, and Storage Equipment

Brown stock washers

Hoods

Filtrate tanks

Vacuum pumps

Screens

Knotters

Decker

Stock chests (including open stock chests)

Pulp storage tanks

Thickeners

Pulp dryers

Evaporators 

Black liquor storage tanks

Evaporator hot wells

Condensers

Boilout tanks

Soap storage tanks

Soap skimmer tanks

Other emission points associated with the evaporators.  

Oxygen Delignification Equipment

Oxygen delignification reactor

Oxygen delignification blow tank

Oxygen delignification washer

Post-oxygen washer filtrate tank

Pulp storage tanks 

Other oxygen delignification system emission points.

Non-condensable gas (NCG) Collection

LVHC system

HVLC system

Stripper System Equipment 

Stripper feed tanks

Condensers

Heat exchangers

Methanol Rectification Equipment

Rectifiers

Condensers

Decanters

Storage tanks  

Storage Tanks

Weak liquor storage tanks

Strong liquor storage tanks

Liquor storage ponds

Acid condensate storage tanks (at sulfite mills)

Tall Oil Production Equipment

Tall oil acidulation reactor

Storage tank

Dehydrator

Brine storage tank

Screen

Centrifuge tank

Other tall oil production vents    

Mechanical Pulping Equipment

Stone grinder

Refiner

Chip pre-steaming vessel

Chip cooker 

Screen  

Decker

Brightening/bleaching tower    

Non-wood Pulping Equipment

Secondary Fiber Pulping Equipment

Bleaching Equipment 

Tower vents

Washer hoods

Seal tank vents

Chemical and steam mixers

Paper Making Equipment

Paper machines

Pulp dryers

Machine chest

Repulpers

Stock blending and storage tanks

Broke tanks

Savealls

White water storage tanks

Wastewater treatment system units

Clarifiers

Settling ponds

Aerated stabilization basins

UNOX systems

Wastewater tanks

Other wastewater handling and treatment units 

Power boilers (including small package boilers)

Thermal oxidizers/incinerators

Woodyard operations

ATTACHMENT 2 

NSPS and NESHAP Definitions

NSPS Subpart BB Definitions (40 CFR Part 60, § 60.281). 

 (a) Kraft pulp mill means any stationary source which produces pulp
from wood by cooking (digesting) wood chips in a water solution of
sodium hydroxide and sodium sulfide (white liquor) at high temperature
and pressure. Regeneration of the cooking chemicals through a recovery
process is also considered part of the kraft pulp mill. 

(b) Neutral sulfite semichemical pulping operation means any operation
in which pulp is produced from wood by cooking (digesting) wood chips in
a solution of sodium sulfite and sodium bicarbonate, followed by
mechanical defibrating (grinding). 

(c) Total reduced sulfur (TRS) means the sum of the sulfur compounds
hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl
disulfide, that are released during the kraft pulping operation and
measured by Method 16. 

(d) Digester system means each continuous digester or each batch
digester used for the cooking of wood in white liquor, and associated
flash tank(s), blow tank(s), chip steamer(s), and condenser(s). 

(e) Brown stock washer system means brown stock washers and associated
knotters, vacuum pumps, and filtrate tanks used to wash the pulp
following the digester system. Diffusion washers are excluded from this
definition. 

(f) Multiple-effect evaporator system means the multiple-effect
evaporators and associated condenser(s) and hotwell(s) used to
concentrate the spent cooking liquid that is separated from the pulp
(black liquor). 

(g) Black liquor oxidation system means the vessels used to oxidize,
with air or oxygen, the black liquor, and associated storage tank(s). 

(h) Recovery furnace means either a straight kraft recovery furnace or a
cross recovery furnace, and includes the direct-contact evaporator for a
direct- contact furnace. 

(i) Straight kraft recovery furnace means a furnace used to recover
chemicals consisting primarily of sodium and sulfur compounds by burning
black liquor which on a quarterly basis contains 7 weight percent or
less of the total pulp solids from the neutral sulfite semichemical
process or has green liquor sulfidity of 28 percent or less. 

(j) Cross recovery furnace means a furnace used to recover chemicals
consisting primarily of sodium and sulfur compounds by burning black
liquor which on a quarterly basis contains more than 7 weight percent of
the total pulp solids from the neutral sulfite semichemical process and
has a green liquor sulfidity of more than 28 percent. 

(k) Black liquor solids means the dry weight of the solids which enter
the recovery furnace in the black liquor. 

(l) Green liquor sulfidity means the sulfidity of the liquor which
leaves the smelt dissolving tank.

(m) Smelt dissolving tank means a vessel used for dissolving the smelt
collected from the recovery furnace. 

(n) Lime kiln means a unit used to calcine lime mud, which consists
primarily of calcium carbonate, into quicklime, which is calcium oxide. 

(o) Condensate stripper system means a column, and associated
condensers, used to strip, with air or steam, TRS compounds from
condensate streams from various processes within a kraft pulp mill. 

NESHAP Subpart MM Definitions (40 CFR Part 63, § 63.861) 

Bag leak detection system means an instrument that is capable of
monitoring PM loadings in the exhaust of a fabric filter in order to
detect bag failures. A bag leak detection system includes, but is not
limited to, an instrument that operates on triboelectric, light
scattering, light transmittance, or other principle to monitor relative
PM loadings. 

Black liquor means spent cooking liquor that has been separated from the
pulp produced by the kraft, soda, or semichemical pulping process. 

Black liquor gasification means the thermochemical conversion of black
liquor into a combustible gaseous product. 

Black liquor oxidation (BLO) system means the vessels used to oxidize
the black liquor, with air or oxygen, and the associated storage
tank(s). 

Black liquor solids (BLS) means the dry weight of the solids in the
black liquor that enters the recovery furnace or semichemical combustion
unit. 

Black liquor solids firing rate means the rate at which black liquor
solids are fed to the recovery furnace or the semichemical combustion
unit. 

Chemical recovery combustion source means any source in the chemical
recovery area of a kraft, soda, sulfite or stand-alone semichemical pulp
mill that is an NDCE recovery furnace, a DCE recovery furnace system, a
smelt dissolving tank, a lime kiln, a sulfite combustion unit, or a
semichemical combustion unit. 

Chemical recovery system means all existing DCE and NDCE recovery
furnaces, smelt dissolving tanks, and lime kilns at a kraft or soda pulp
mill. Each existing recovery furnace, smelt dissolving tank, or lime
kiln is considered a process unit within a chemical recovery system. 

Direct contact evaporator (DCE) recovery furnace means a kraft or soda
recovery furnace equipped with a direct contact evaporator that
concentrates strong black liquor by direct contact between the hot
recovery furnace exhaust gases and the strong black liquor. 

Direct contact evaporator (DCE) recovery furnace system means a direct
contact evaporator recovery furnace and any black liquor oxidation
system, if present, at the pulp mill. 

Dry electrostatic precipitator (ESP) system means an electrostatic
precipitator with a dry bottom (i.e., no black liquor, water, or other
fluid is used in the ESP bottom) and a dry particulate matter return
system (i.e., no black liquor, water, or other fluid is used to
transport the collected PM to the mix tank). 

Fabric filter means an air pollution control device used to capture PM
by filtering a gas stream through filter media; also known as a
baghouse. 

Hazardous air pollutants (HAP) metals means the sum of all emissions of
antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead,
manganese, mercury, nickel, and selenium as measured by EPA Method 29
(40 CFR part 60, appendix A) and with all nondetect data treated as
one-half of the method detection limit. 

Hog fuel dryer means the equipment that combusts fine particles of wood
waste (hog fuel) in a fluidized bed and directs the heated exhaust
stream to a rotary dryer containing wet hog fuel to be dried prior to
combustion in the hog fuel boiler at Weyerhaeuser Paper Company’s
Cosmopolis, Washington facility. The hog fuel dryer at Weyerhaeuser
Paper Company’s Cosmopolis, Washington facility is Emission Unit no.
HD–14. 

Kraft pulp mill means any stationary source that produces pulp from wood
by cooking (digesting) wood chips in a solution of sodium hydroxide and
sodium sulfide. The recovery process used to regenerate cooking
chemicals is also considered part of the kraft pulp mill. 

Kraft recovery furnace means a recovery furnace that is used to burn
black liquor produced by the kraft pulping process, as well as any
recovery furnace that burns black liquor produced from both the kraft
and semichemical pulping processes, and includes the direct contact
evaporator, if applicable. Includes black liquor gasification. 

Lime kiln means the combustion unit (e.g., rotary lime kiln or
fluidized-bed calciner) used at a kraft or soda pulp mill to calcine
lime mud, which consists primarily of calcium carbonate, into quicklime,
which is calcium oxide (CaO). 

Lime production rate means the rate at which dry lime, measured as CaO,
is produced in the lime kiln. 

Method detection limit means the minimum concentration of an analyte
that can be determined with 99 percent confidence that the true value is
greater than zero. 

Modification means, for the purposes of § 63.862(a)(1)(ii)(E)(1), any
physical change (excluding any routine part replacement or maintenance)
or operational change (excluding any operational change that occurs
during a start-up, shutdown, or malfunction) that is made to the air
pollution control device that could result in an increase in PM
emissions. 

Nondetect data means, for the purposes of this subpart, any value that
is below the method detection limit. 

Nondirect contact evaporator (NDCE) recovery furnace means a kraft or
soda recovery furnace that burns black liquor that has been concentrated
by indirect contact with steam. 

Particulate matter (PM) means total particulate matter as measured by
EPA Method 5, EPA Method 17 (§ 63.865(b)(1)), or EPA Method 29 (40 CFR
part 60, appendix A). 

Process unit means an existing DCE or NDCE recovery furnace, smelt
dissolving tank, or lime kiln in a chemical recovery system at a kraft
or soda mill. 

Recovery furnace means an enclosed combustion device where concentrated
black liquor produced by the kraft or soda pulping process is burned to
recover pulping chemicals and produce steam. Includes black liquor
gasification. 

Regenerative thermal oxidizer (RTO) means a thermal oxidizer that
transfers heat from the exhaust gas stream to the inlet gas stream by
passing the exhaust stream through a bed of ceramic stoneware or other
heat-absorbing medium before releasing it to the atmosphere, then
reversing the gas flow so the inlet gas stream passes through the heated
bed, raising the temperature of the inlet stream close to or at its
ignition temperature. 

Semichemical combustion unit means any equipment used to combust or
pyrolyze black liquor at stand-alone semichemical pulp mills for the
purpose of chemical recovery. Includes black liquor gasification. 

Similar process units means all existing DCE and NDCE recovery furnaces,
smelt dissolving tanks, or lime kilns at a kraft or soda pulp mill. 

Smelt dissolving tanks (SDT) means vessels used for dissolving the smelt
collected from a kraft or soda recovery furnace. 

Soda pulp mill means any stationary source that produces pulp from wood
by cooking (digesting) wood chips in a sodium hydroxide solution. The
recovery process used to regenerate cooking chemicals is also considered
part of the soda pulp mill. 

Soda recovery furnace means a recovery furnace used to burn black liquor
produced by the soda pulping process and includes the direct contact
evaporator, if applicable. Includes black liquor gasification. 

Stand-alone semichemical pulp mill means any stationary source that
produces pulp from wood by partially digesting wood chips in a chemical
solution followed by mechanical defibrating (grinding), and has an
onsite chemical recovery process that is not integrated with a kraft
pulp mill. 

Startup means, for the chemical recovery system employing black liquor
gasification at Georgia-Pacific’s facility in Big Island, Virginia
only, the end of the gasification system commissioning phase.
Commissioning is that period of time in which each part of the new
gasification system will be checked and operated on its own to make sure
it is installed and functions properly. Commissioning will conclude with
the successful completion of the gasification technology supplier’s
performance warranty demonstration, which proves the technology and
equipment are performing to warranted levels and the system is ready to
be placed in active service. For all other affected sources under this
subpart, startup has the meaning given in § 63.2. 

Sulfite combustion unit means a combustion device, such as a recovery
furnace or fluidized-bed reactor, where spent liquor from the sulfite
pulping process (i.e., red liquor) is burned to recover pulping
chemicals. 

Sulfite pulp mill means any stationary source that produces pulp from
wood by cooking (digesting) wood chips in a solution of sulfurous acid
and bisulfite ions. The recovery process used to regenerate cooking
chemicals is also considered part of the sulfite pulp mill. 

Total hydrocarbons (THC) means the sum of organic compounds measured as
carbon using EPA Method 25A (40 CFR part 60, appendix A). 

NESHAP Subpart S Definitions (40 CFR Part 63, § 63.441): 

All terms used in this subpart shall have the meaning given them in the
CAA, in subpart A of this part, and in this section as follows: 

Acid condensate storage tank means any storage tank containing cooking
acid following the sulfur dioxide gas fortification process. 

Black liquor means spent cooking liquor that has been separated from the
pulp produced by the kraft, soda, or semi-chemical pulping process. 

Bleaching means brightening of pulp by the addition of oxidizing
chemicals or reducing chemicals. 

Bleaching line means a group of bleaching stages arranged in series such
that bleaching of the pulp progresses as the pulp moves from one stage
to the next. 

Bleaching stage means all process equipment associated with a discrete
step of chemical application and removal in the bleaching process
including chemical and steam mixers, bleaching towers, washers, seal
(filtrate) tanks, vacuum pumps, and any other equipment serving the same
function as those previously listed. 

Bleaching system means all process equipment after high-density pulp
storage prior to the first application of oxidizing chemicals or
reducing chemicals following the pulping system, up to and including the
final bleaching stage. 

Boiler means any enclosed combustion device that extracts useful energy
in the form of steam. A boiler is not considered a thermal oxidizer. 

Chip steamer means a vessel used for the purpose of preheating or
pretreating wood chips prior to the digester, using flash steam from the
digester or live steam. 

Closed-vent system means a system that is not open to the atmosphere and
is composed of piping, ductwork, connections, and, if necessary,
flow-inducing devices that transport gas or vapor from an emission point
to a control device. 

Combustion device means an individual unit of equipment, including but
not limited to, a thermal oxidizer, lime kiln, recovery furnace, process
heater, or boiler, used for the thermal oxidation of organic hazardous
air pollutant vapors. 

Decker system means all equipment used to thicken the pulp slurry or
reduce its liquid content after the pulp washing system and prior to
high-density pulp storage. The decker system includes decker vents,
filtrate tanks, associated vacuum pumps, and any other equipment serving
the same function as those previously listed. 

Digester system means each continuous digester or each batch digester
used for the chemical treatment of wood or non-wood fibers. The digester
system equipment includes associated flash tank(s), blow tank(s), chip
steamer( s) not using fresh steam, blow heat recovery accumulator(s),
relief gas condenser(s), prehydrolysis unit(s) preceding the pulp
washing system, and any other equipment serving the same function as
those previously listed. The digester system includes any of the liquid
streams or condensates associated with batch or continuous digester
relief, blow, or flash steam processes. 

Emission point means any part of a stationary source that emits
hazardous air pollutants regulated under this subpart, including
emissions from individual process vents, stacks, open pieces of process
equipment, equipment leaks, wastewater and condensate collection and
treatment system units, and those emissions that could reasonably be
conveyed through a stack, chimney, or duct where such emissions first
reach the environment. 

Evaporator system means all equipment associated with increasing the
solids content and/or concentrating spent cooking liquor from the pulp
washing system including pre-evaporators, multi-effect evaporators,
concentrators, and vacuum systems, as well as associated condensers,
hotwells, and condensate streams, and any other equipment serving the
same function as those previously listed. 

Flow indicator means any device that indicates gas or liquid flow in an
enclosed system. 

HAP means a hazardous air pollutant as defined in § 63.2 of subpart A
of this part. 

High volume, low concentration or HVLC collection system means the gas
collection and transport system used to convey gases from the HVLC
system to a control device. 

High volume, low concentration or HVLC system means the collection of
equipment including the pulp washing, knotter, screen, decker, and
oxygen delignification systems, weak liquor storage tanks, and any other
equipment serving the same function as those previously listed. 

Knotter system means equipment where knots, oversized material, or
pieces of uncooked wood are removed from the pulp slurry after the
digester system and prior to the pulp washing system. The knotter system
equipment includes the knotter, knot drainer tanks, ancillary tanks, and
any other equipment serving the same function as those previously
listed. 

Kraft pulping means a chemical pulping process that uses a mixture of
sodium hydroxide and sodium sulfide as the cooking liquor. 

Lime kiln means an enclosed combustion device used to calcine lime mud,
which consists primarily of calcium carbonate, into calcium oxide.

Low volume, high concentration or LVHC collection system means the gas
collection and transport system used to convey gases from the LVHC
system to a control device. 

Low volume, high concentration or LVHC system means the collection of
equipment including the digester, turpentine recovery, evaporator, steam
stripper systems, and any other equipment serving the same function as
those previously listed. 

Mechanical pulping means a pulping process that only uses mechanical and
thermo-mechanical processes to reduce wood to a fibrous mass. The
mechanical pulping processes include, but are not limited to, stone
groundwood, pressurized groundwood, refiner mechanical, thermal refiner
mechanical, thermo-mechanical, and tandem thermomechanical. 

Non-wood pulping means the production of pulp from fiber sources other
than trees. The non-wood fiber sources include, but are not limited to,
bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf
fibers. 

Oven-dried pulp or ODP means a pulp sample at zero percent moisture
content by weight. Pulp samples for applicability or compliance
determinations for both the pulping and bleaching systems shall be
unbleached pulp. For purposes of complying with mass emission limits in
this subpart, megagram of ODP shall be measured to represent the amount
of pulp entering and processed by the equipment system under the
specified mass limit. For equipment that does not process pulp, megagram
of ODP shall be measured to represent the amount of pulp that was
processed to produce the gas and liquid streams. 

Oxygen delignification system means the equipment that uses oxygen to
remove lignin from pulp after high-density stock storage and prior to
the bleaching system. The oxygen delignification system equipment
includes the blow tank, washers, filtrate tanks, any interstage pulp
storage tanks, and any other equipment serving the same function as
those previously listed. 

Primary fuel means the fuel that provides the principal heat input to
the combustion device. To be considered primary, the fuel must be able
to sustain operation of the combustion de without the addition of other
fuels. 

Process wastewater treatment system means a collection of equipment, a
process, or specific technique that removes or destroys the HAPs in a
process wastewater stream. Examples include, but are not limited to, a
steam stripping unit, wastewater thermal oxidizer, or biological
treatment unit. 

Pulp washing system means all equipment used to wash pulp and separate
spent cooking chemicals following the digester system and prior to the
bleaching system, oxygen delignification system, or paper machine system
(at unbleached mills). The pulp washing system equipment includes vacuum
drum washers, diffusion washers, rotary pressure washers, horizontal
belt filters, intermediate stock chests, and their associated vacuum
pumps, filtrate tanks, foam breakers or tanks, and any other equipment
serving the same function as those previously listed. The pulp washing
system does not include deckers, screens, knotters, stock chests, or
pulp storage tanks following the last stage of pulp washing. 

Pulping line means a group of equipment arranged in series such that the
wood chips are digested and the resulting pulp progresses through a
sequence of steps that may include knotting, refining, washing,
thickening, blending, storing, oxygen delignification, and any other
equipment serving the same function as those previously listed. 

Pulping process condensates means any HAP-containing liquid that results
from contact of water with organic compounds in the pulping process.
Examples of process condensates include digester system condensates,
turpentine recovery system condensates, evaporator system condensates,
LVHC system condensates, HVLC system condensates, and any other
condensates from equipment serving the same function as those previously
listed. Liquid streams that are intended for byproduct recovery are not
considered process condensate streams. 

Pulping system means all process equipment, beginning with the digester
system, and up to and including the last piece of pulp conditioning
equipment prior to the bleaching system, including treatment with ozone,
oxygen, or peroxide before the first application of a chemical bleaching
agent intended to brighten pulp. The pulping system includes pulping
process condensates and can include multiple pulping lines. 

Recovery furnace means an enclosed combustion device where concentrated
spent liquor is burned to recover sodium and sulfur, produce steam, and
dispose of unwanted dissolved wood components in the liquor. 

Screen system means equipment in which oversized particles are removed
from the pulp slurry prior to the bleaching or papermaking system washed
stock storage. 

Secondary fiber pulping means a pulping process that converts a fibrous
material, that has previously undergone a manufacturing process, into
pulp stock through the addition of water and mechanical energy. The mill
then uses that pulp as the raw material in another manufactured product.
These mills may also utilize chemical, heat, and mechanical processes to
remove ink particles from the fiber stock. 

Semi-chemical pulping means a pulping process that combines both
chemical and mechanical pulping processes. The semi-chemical pulping
process produces intermediate yields ranging from 55 to 90 percent. 

Soda pulping means a chemical pulping process that uses sodium hydroxide
as the active chemical in the cooking liquor. 

Spent liquor means process liquid generated from the separation of
cooking liquor from pulp by the pulp washing system containing dissolved
organic wood materials and residual cooking compounds. 

Steam stripper system means a column (including associated stripper feed
tanks, condensers, or heat exchangers) used to remove compounds from
wastewater or condensates using steam. The steam stripper system also
contains all equipment associated with a methanol rectification process
including rectifiers, condensers, decanters, storage tanks, and any
other equipment serving the same function as those previously listed.

Strong liquor storage tanks means all storage tanks containing liquor
that has been concentrated in preparation for combustion or oxidation in
the recovery process. 

Sulfite pulping means a chemical pulping process that uses a mixture of
sulfurous acid and bisulfite ion as the cooking liquor. 

Temperature monitoring device means a piece of equipment used to monitor
temperature and having an accuracy of ±1.0 percent of the temperature
being monitored expressed in degrees Celsius or ±0.5 degrees Celsius
(C), whichever is greater. 

Thermal oxidizer means an enclosed device that destroys organic
compounds by thermal oxidation. 

Turpentine recovery system means all equipment associated with
recovering turpentine from digester system gases including condensers,
decanters, storage tanks, and any other equipment serving the same
function as those previously listed. The turpentine recovery system
includes any liquid streams associated with the turpentine recovery
process such as turpentine decanter underflow. Liquid streams that are
intended for byproduct recovery are not considered turpentine recovery
system condensate streams. 

Weak liquor storage tank means any storage tank except washer filtrate
tanks containing spent liquor recovered from the pulping process and
prior to the evaporator system.  

Selected definitions from 40 CFR Part 60 subpart A (NSPS General
Provisions):

Commenced means, with respect to the definition of new source in section
111(a)(2) of the Act, that an owner or operator has undertaken a
continuous program of construction or modification or that an owner or
operator has entered into a contractual obligation to undertake and
complete, within a reasonable time, a continuous program of construction
or modification.  [§60.2]

Construction means fabrication, erection, or installation of an affected
facility. [§60.2]

Modification means any physical change in, or change in the method of
operation of, an existing facility which increases the amount of any air
pollutant (to which a standard applies) emitted into the atmosphere by
that facility or which results in the emission of any air pollutant (to
which a standard applies) into the atmosphere not previously emitted.
[§60.2]

Reconstruction means the replacement of components of an existing
facility to such an extent that:  (1) The fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost that would be
required to construct a comparable entirely new facility, and (2) It is
technologically and economically feasible to meet the applicable
standards set forth in this part. [§60.15(b)]

Selected definitions from 40 CFR Part 63 subpart A (NESHAP General
Provisions):

Commenced means, with respect to construction or reconstruction of an
affected source, that an owner or operator has undertaken a continuous
program of construction or reconstruction or that an owner or operator
has entered into a contractual obligation to undertake and complete,
within a reasonable time, a continuous program of construction or
reconstruction. [§63.2]

Construction means the on-site fabrication, erection, or installation of
an affected source. Construction does not include the removal of all
equipment comprising an affected source from an existing location and
reinstallation of such equipment at a new location. The owner or
operator of an existing affected source that is relocated may elect not
to reinstall minor ancillary equipment including, but not limited to,
piping, ductwork, and valves. However, removal and reinstallation of an
affected source will be construed as reconstruction if it satisfies the
criteria for reconstruction as defined in this section. The costs of
replacing minor ancillary equipment must be considered in determining
whether the existing affected source is reconstructed. [§63.2]

Major source means any stationary source or group of stationary sources
located within a contiguous area and under common control that emits or
has the potential to emit considering controls, in the aggregate, 10
tons per year or more of any hazardous air pollutant or 25 tons per year
or more of any combination of hazardous air pollutants, unless the
Administrator establishes a lesser quantity, or in the case of
radionuclides, different criteria from those specified in this sentence.
[§63.2]

Reconstruction, unless otherwise defined in a relevant standard, means
the replacement of components of an affected or a previously nonaffected
source to such an extent that: (1) The fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost that would be
required to construct a comparable new source; and (2) It is
technologically and economically feasible for the reconstructed source
to meet the relevant standard(s) established by the Administrator (or a
State) pursuant to section 112 of the Act. Upon reconstruction, an
affected source, or a stationary source that becomes an affected source,
is subject to relevant standards for new sources, including compliance
dates, irrespective of any change in emissions of hazardous air
pollutants from that source. [§63.2]

ATTACHMENT 3

Small Business Size Standards

Small Business Size Standards for NAICS Subsector 322 – Paper
Manufacturing

NAICS

Codes

	NAICS U.S. industry title

	Size

standards in

number of

employees

322110	Pulp Mills	750

322121 	Paper (except Newsprint) Mills	750

322122	Newsprint Mills	750

322130 	Paperboard Mills	750

322211 	Corrugated and Solid Fiber Box Manufacturing	500

322212 	Folding Paperboard Box Manufacturing	750

322213	Setup Paperboard Box Manufacturing	500

322214	Fiber Can, Tube, Drum, and Similar Products Manufacturing	500

322215	Non-Folding Sanitary Food Container Manufacturing	750

322221 	Coated and Laminated Packaging Paper Manufacturing	500

322222	Coated and Laminated Paper Manufacturing	500

322223 	Coated Paper Bag and Pouch Manufacturing	500

322224	Uncoated Paper and Multiwall Bag Manufacturing	500

322225	Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses
500

322226 	Surface-Coated Paperboard Manufacturing	500

322231	Die-Cut Paper and Paperboard Office Supplies Manufacturing	500

322232	Envelope Manufacturing	500

322233 	Stationery, Tablet, and Related Product Manufacturing	500

322291	Sanitary Paper Product Manufacturing	500

322299 	All Other Converted Paper Product Manufacturing	500

Source:  U. S. Small Business Administration Table of Small Business
Size Standards Matched to North American Industry Classification System
Codes, Effective August 22, 2008.  Accessed June 16, 2009 at:
http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_ta
blepdf.pdf

ATTACHMENT 4

Acronyms and Abbreviations

acfm	actual cubic foot (feet) per minute 

ADTBP 	air-dried ton(s) of bleached pulp

ADTFP	air-dried ton(s) of finished paper

ADTP	air-dried ton(s) of pulp

APCD 	air pollution control device(s)

As	arsenic

AS	activated sludge

ASB	aerated stabilization basin(s)

atm	atmosphere(s)

Be	beryllium

BLO 	black liquor oxidation

BLS	black liquor solids

BOD	biochemical oxygen demand

BOD5	5-day BOD

Btu	British thermal unit(s)

°C	degrees Celsius

Ca	calcium

CaO	calcium oxide  (lime)

CBI	confidential business information

CCA	Clean Condensate Alternative

Cd	cadmium

CDD	chlorinated dibenzo-p-dioxin

CDF	chlorinated dibenzofuran

CEMS	continuous emissions monitoring system(s)

CERCLA  Comprehensive Environmental Response, Compensation, & Liability
Act

cfm	cubic feet per minute

CFR	Code of Federal Regulations

Cl2	chlorine

ClO2	chlorine dioxide

Co	cobalt

CO	carbon monoxide

CO2	carbon dioxide

COMS	continuous opacity monitoring system(s)

Cr	chromium

cu ft	cubic foot (feet)

CY	calendar year

d	day(s)

DCE	direct contact evaporator 

dscf	dry standard cubic foot (feet)

dscfm	dry standard cubic feet per minute

ECF	elemental chlorine free

EIS	Emissions Inventory System

EPA	U.S. Environmental Protection Agency

ESP	electrostatic precipitator(s)

°F	degrees Fahrenheit

ft	foot (feet)

ft2	square foot (feet)

g	gram(s)

gal	gallon(s)

gpm	gallon(s) per minute

gr	grain(s)

GW	groundwood

H2O	water

H2S	hydrogen sulfide

HAP	hazardous air pollutant(s)

HCl	hydrochloric acid

Hg	mercury

HHV	higher heating value

hr	hour(s)

HVLC	high volume low concentration

HW	hardwood 

in.	inch(es)

ISIS	Industrial Sector Integrated Solutions

kg	kilogram(s)

KMNO4 potassium permanganate

KOH	potassim hydroxide

kWh	kilowatt-hour(s)

l	liter(s)

lb	pound(s)

LK	lime kiln(s)

LVHC	low volume high concentration

MACT	maximum achievable control technology

MDL	method detection limit

MEE	multiple-effect evaporator(s)

mg	milligram(s)

Mg	megagram(s); magnesium

MLVSS	mixed liquor volatile suspended solids

MMBtu	million Btu

mmscf	million standard cubic feet

Mn	manganese

NA	not applicable

NAICS	North American Industry Classification System

NaOH	sodium hydroxide

NATA	National-Scale Air Toxics Assessment

NCASI	National Council of the Paper Industry for Air and Stream
Improvement

NCG	noncondensable gas(es)

NDCE	nondirect contact evaporator

NEC	Not Elsewhere Classified

NEI	National Emissions Inventory

NESHAP  National emissions standard(s) for hazardous air pollutants

NH3	ammonia

Ni	nickel

No.	number

NOx	nitrogen oxides

NSPS	new source performance standard(s)

NSSC	neutral sulfite semichemical

O2	oxygen

O3	ozone 

OCC	Old Corrugated Container

ODP	oven-dried pulp 

ODT	oven dried ton(s)

ONP	Old News Print

OTM	Other Test Method

PAH	polycyclic aromatic hydrocarbons

Pb	lead

PCC	precipitated calcium carbonate

PCF	processed chlorine free

PM	particulate matter

PM10	PM with an aerodynamic diameter of up to 10 µm

PM2.5	PM with an aerodynamic diameter of up to 2.5 µm

POM	polycyclic organic matter

ppm	part(s) per million

ppmdv	part(s) per million dry volume

ppmdw	part(s) per million dry weight

ppmv	part(s) per million by volume

ppmw	part(s) per million by weight

RF	recovery furnace(s)

RMP	refiner mechanical pulping

RTO	regenerative thermal oxidizer(s)

RTR	residual risk and technology review

Sb	antimony

SCA	specific collecting area

SCC	Source Classification Code

scf	standard cubic foot (feet)

scfm	standard cubic feet per minute

SDT	smelt dissolving tank(s)

Se	selenium

sec	second(s)

SIC	Standard Industrial Classification

SO2	sulfur dioxide

SOG	stripper offgas(es)

SSM	startup, shutdown, and malfunction

st 	short ton(s)

SW	softwood

TBD	To Be Determined

TCF	totally chlorine free

TCDD	tetrachlorodibenzo-p-dioxin

TEQ	2,3,7,8-TCDD toxic equivalent

THC	total hydrocarbon

TMP	thermomechanical pulping

ton	ton(s)

tph 	ton(s) per hour

tpy	ton(s) per year

TRI 	Toxics Release Inventory 

TRS	total reduced sulfur

UK	Unknown

U.S.	United States

VOC 	volatile organic compound

WESP	wet ESP

WS	wet scrubber

Wt% 	weight-percent 

WW	wastewater

WWT	wastewater treatment 

WWTP	wastewater treatment plant

Y/N 	yes/no

yr	year

µm	micrometer(s)

ug	micrograms

ATTACHMENT 5

Resources for Estimating Emissions

Compilation of air pollution emission factors. Volume I: Stationary
point and area sources (5th edition). AP-42. Section 10.2, Chemical Wood
Pulping, September 1990. Research Triangle Park, NC: U. S. Environmental
Protection Agency, Office of Air Quality Planning and Standards. 
Available at http://www.epa.gov/ttn/chief/ap42/ch10/index.html

Compilation of air pollutant emission factors. Volume I: stationary
point and area sources  (Chapter 1, External Combustion Source). AP-42.
2001.  Research Triangle Park, NC. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Available at
http://www.epa.gov/ttn/chief/ap42/ch01/index.html

National Council for Air and Stream Improvement, Inc. (NCASI). 2002.
Compilation of speciated reduced sulfur compound and total reduced
sulfur emissions data for kraft mill sources. Technical Bulletin No.
849. Research Triangle Park, NC. Available to NCASI members at
www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2003.
Compilation of ‘air toxic’ and total

hydrocarbon emissions data for sources at kraft, sulfite and
non-chemical pulp mills – An update. Technical

Bulletin No. 858. Research Triangle Park, N.C.   Available to NCASI
members at www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI).  2004. 
Compilation of criteria air pollutant emissions data for sources at pulp
and paper mills including boilers.  Technical Bulletin No. 884. 
Research Triangle Park, N.C. Available to NCASI members at
www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2010.
Compilation of ‘air toxic’ and total

hydrocarbon emissions data for sources at kraft, sulfite and
non-chemical pulp mills – A Second update. Technical

Bulletin No. 973. Research Triangle Park, N.C.   Available to NCASI
members at www.ncasi.org.

ATTACHMENT 6

Emissions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the
emission test reports, to include field and lab data sheets and example
calculations.)Attachment 6.  Pulp and Paper emission units and
pollutants for which existing representative emission test data are
requested

Emission Unit	Particulate matter (PM)1	Speciated HAP metals2	PM2.5 

(fil.)

	PM2.5 (cond.)

	Chlorinated HAP (Cl)1	Hydrochloric acid (HCl)	Methanol1	Total
hydrocarbon (THC) as carbon	CDD/CDF

and

POM/PAH	Total reduced sulfur (TRS)1,3	Nitrogen oxides (NOx)1	Sulfur
dioxide (SO2)1	Carbon monoxide (CO)1

Test methods	M5, M29, M17

PM CEMS, COMS	M29	EPA OTM 27

	EPA OTM 28	Chlorine (Cl2) via M26A with modifications described in
subpart S

Cl2 CEMS	M26 or 26A	Method 308 (part 63)

Methanol CEMS	M25 or M25A

	M23	M16 or

TRS CEMS

Provide total TRS data.  Also provide speciated TRS data, if available.
M7

CEMS	M6

CEMS	M10

CEMS

Recovery furnaces (NDCE and DCE)

	Supply data from 2001 and more recent following subpart MM MACT
compliance	Supply data from 1990 or more recent

	Supply most recent data

Not requested

	Supply data from 1990 or  more recent



	Supply any CDD or POM data and note if equipment config. has changed

	Supply most recent data



	Black liquor oxidizer (BLO)

Note:  The BLO vent is included in definition of DCE, but listed
separately in case data are available for only the BLO)	Not requested





Supply data from 1990 or more recent

Not requested	Supply most recent data



Not requested

	Chemical recovery combustion units  - sulfite	Supply data from 2001 and
more recent following subpart MM MACT compliance

	Supply data from 1990 or more recent	Supply most recent data

Not requested	Supply data from 1990 or  more recent



Not requested	Supply most recent data



Chemical recovery combustion units  - stand alone semichemical

	Supply data from 1990 or more recent

Supply most recent data

Not requested	Supply data from 1990 or more recent



Not requested	Supply most recent data



Smelt dissolving tanks (SDT) or ash dissolving tanks	Supply data from
2001 and more recent following subpart MM MACT compliance	Supply data
from 1990 or more recent	Supply most recent data

Not requested

Supply data from 1990 or more recent

	Supply most recent data	Not requested



Lime kilns/fluidized bed calciners

	Supply data from 2001 and more recent following subpart MM MACT
compliance	Supply data from 1990 or more recent	Supply most recent data

Not requested

Supply data from 1990 or more recent

	Supply most recent data



	Black liquor gasification systems

	Supply most recent data

	Not requested	Supply most recent data







	Thermal oxidizers	Supply most recent data

	Not requested





Supply most recent data



Digesters, Pulp washers, Evaporators, Turpentine recovery, Strippers, O2
delignification, Knotters and screens, Deckers (high density storage),
and Weak and strong liquor storage tanks (or their associated LVHC
and/or HVLC collection systems)	Not requested





Supply most recent data following MACT compliance

Not requested	Supply most recent data following MACT compliance	Not
requested



Sulfite pulping sources

	Not requested





Supply most recent data following MACT compliance

Not requested

	Supply most recent data

	Not requested

Wastewater Treatment Systems	Not requested





Supply most recent modeling or measurement data (as requested in WW tab)

Not requested	Supply most recent modeling or measurement data (as
requested in WW tab)	Not requested



Bleaching systems subject to

 subpart S

	Not requested



Supply most recent data following MACT compliance

	Not requested



	Not requested



Supply most recent data following MACT compliance



Paper machine

emission points

	Not requested





Supply most recent data



Not requested





Causticizing area sources	Not requested





Supply most recent data



Not requested





Stand alone semichemical, mechanical, nonwood, and secondary fiber
pulping	Not requested





Supply most recent data



Not requested





1. If your emission unit is equipped with a continuous emissions
monitoring system (CEMS) or continuous opacity monitoring system (COMS),
supply the CEMS data using the CEMS data spreadsheet (P&P CEMS
spreadsheet.xls)

2. The HAP metals include antimony, arsenic, beryllium, cadmium,
chromium, cobalt, lead, manganese, mercury, nickel, and selenium. 
Include chromium VI (Cr+6) and speciated mercury (Hg) test data if
available.

3. Speciated TRS would include:  hydrogen sulfide (H2S), methyl
mercaptan, dimethyl sulfide, and dimethyl disulfide.

Emissions test data representative of your current operations are
requested as described in the survey instructions.

M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17,
23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A.  EPA Method 308
appears in Part 63, Appendix A. 

The “OTM” test methods can be found at
http://www.epa.gov/ttn/emc/prelim.html

For more information about the 2005 NEI, please go to: 
http://www.epa.gov/ttn/chief/net/2005inventory.html.  

Latitude measure in decimal degrees of the angular distance on a
meridian north or south of the equator.  Positive (+) data point for
North America. Example: +78.123456.  For point sources, this represents
the center of the source; for fugitive sources, this is the southwest
corner if the fugitive angle is zero or the western most corner if the
fugitive angle is greater than zero.  Longitude measure in decimal
degrees of the angular distance on a meridian east or west of the prime
meridian.  Negative (-) data point for North America.  Example:
-123.234561.  For point sources this represents the center of the
source; for fugitive sources, this is the southwest corner if the
fugitive angle is zero, or the western most corner if the fugitive angle
is greater than zero. 

 

	Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

	Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

Why can’t I over-write existing data? 

EPA maintains a record of all changes and "matches" existing NEI entries
(i.e., those in the attached spreadsheet) to new entries (your
revisions).  So if a line (record) in the spreadsheet/database does not
match our existing files, both the old and the new records are
incorporated into the NEI which can result in double counting.  For
these reasons, any changes must be recorded in one of the unshaded
fields and you cannot (successfully) change data by over-writing
existing data in a field.    

Why do I have to add every emission unit and/or emission point?

The NEI currently includes both HAP and CAP data.  Updates to the list
of emission units, descriptions, and SCC codes would improve the
accuracy and completeness of the NEI data for use in EPA’s HAP
residual risk efforts.  Updated information will allow EPA to focus
residual risk regulatory analyses on the specific types of emission
units with questionable risk.  The CAP and TRS data will be used in
determining the magnitude of emissions for purposes of reviewing the
NSPS.

What if I do not know the answer to a survey question? 

There may be survey questions that you do not know the answer to, or for
which information is not readily available.  If you do not know an
answer and cannot reasonably locate an answer, then you may enter
“UK” for unknown.  However, note that survey respondents providing
an excessive number of “UKs” will most likely receive follow-up
inquiries related to their survey response.    

Why does EPA need more data than are included in the NEI?

Facility and equipment details are being requested in addition to the
NEI update to inform the technological review of the pulp and paper
NESHAP and NSPS and to provide information on means of reducing residual
risk.  While the NEI provides EPA with data related to emissions release
points (e.g., mass emission rate and stack exit parameters used for risk
analysis and tracking nationwide trends), the technological review of
the NESHAP and NSPS standards considers emission unit and control
equipment details specific to the processes employed and matches these
details to emissions levels that are achieved (e.g., emission
concentrations).  Applicability of the NESHAP and NSPS compliance
options depend on the specific process equipment. 

How detailed must my diagram(s) be? 

The EPA will use the diagram(s) to aid in understanding the general mill
flow, and any unique characteristics in the mill layout.  It is not
necessary to show every single vent of every emission unit on the
diagrams.  However, the diagram should provide enough information such
that it is clear how emissions are collected and controlled.  For
example, if all digester vents are routed to LVHC, then it is not
necessary to show each individual digester vent when one line drawn from
a digester “block” to the LVHC collection system is informative.

A Note About Identification Numbers (IDs)

It is imperative that you use the same IDs to describe the same
facility, process line, equipment/emission unit, and emission release
point throughout the survey.  These ID codes will be used to link the
various pulp and paper data base tables together into a functional and
informative data base to be used for regulatory analyses.  You may
choose your own IDs (e.g., based on IDs already included in the NEI, IDs
from existing process flow diagrams, IDs in your air permit, etc.), but
the IDs you choose must be consistent throughout your survey response.  
If you wish to avoid follow-up calls regarding your survey data, please
make every effort to ensure that your IDs match throughout the
spreadsheet(s).

Also, please be sure that no extra spaces or characters are included in
the ID cells.  For example, Emission Unit ID “DIG1” is not read the
same as “DIG-1” or “DIG-1_” by data base software.

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