Pulp and Paper Sector Survey

Overview

Survey coverage.  The pulp and paper sector survey is a three-part
information request that 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.

Mills exempt from the pulp and paper sector survey.  If your mill is not
a “major source” or “synthetic area source” of HAP emissions,
then you should complete the form in Attachment 1 and email (or fax) it
to Bill Schrock of the U.S. Environmental Protection Agency (EPA) at  
HYPERLINK "mailto:schrock.bill@epa.gov"  schrock.bill@epa.gov .  If your
mill is a true area source, then your operating permit should reflect
that your mill is not  subject to either of the pulp and paper national
emissions standards for hazardous air pollutants (NESHAP) (40 CFR Part
63, subpart S or MM).  You are not required to complete any part of the
pulp and paper sector survey if you submit valid documentation of true
area source status.

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 complete the form in Attachment 1 and email (or fax) it
to Bill Schrock of EPA at schrock.bill@epa.gov explaining the status of
your mill.  You are not required to complete any part of the pulp and
paper sector survey.

Survey structure and due dates.  The pulp and paper sector survey is to
be completed in a series of Microsoft Excel spreadsheet files that are
divided into several worksheets (“tabs” within each spreadsheet). 
You must complete certain portions of the survey, depending on the type
of mill you operate.  Parts I and II apply for all mills, except true
area source and non-operational mills, as noted above.  Parts I and III
request process data for the emissions units listed in Attachment 1 of
the instructions for each part.  Part II requests an NEI update for all
emissions units.  Additional spreadsheets are provided for submittal of
continuous emissions monitoring system (CEMS) data or control measure
cost information (for Part I and Part III). 



The pulp and paper sector survey is divided into three parts, each with
different due dates as specified in Table 1 below.

Table 1.  Components of the Three-Part Pulp and Paper Survey

Part	Short Description	Deadline1	Contents of Data Submittal

I	Mill Overview and Subpart S Data



	a. Notification of true area source, non-operational, or non-applicable
status	20 days	-Attachment 1 of survey overview

	b. Completion of Part I data submittal	30 days	-P&P survey_PI.xls

-P&P CEMS _PI.xls

-P&P costs OPTIONAL_PI.xls

-Flow diagrams

-Test reports

-Water modeling

II	NEI Update	100 days	-P&P NEI update.xls 

III	Chemical Recovery Combustion Sources	180 days	-P&P CEMS _PIII.xls

-P&P costs OPTIONAL_PIII.xls

-P&P survey_PIII.xls

-Test reports

1 The deadlines indicated are in terms of calendar days following the
date stamped on the Section 114 letter accompanying this survey. 
Specific dates are specified in the letter.

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:    HYPERLINK "https://icr2010.rti.org/Industries/PulpPaper.aspx" 
https://icr2010.rti.org/Industries/PulpPaper.aspx 

Base year for survey data.  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).   

Definitions.  For reference, Attachment 2 to this overview contains the
regulatory definitions from the kraft pulp mill new source performance
standards (NSPS) (40 CFR Part 60, subpart BB), chemical recovery
combustion source NESHAP (40 CFR Part 63, subpart MM), and pulp and
paper production NESHAP (40 CFR Part 63, subpart S), and selected
definitions from the NSPS and NESHAP General Provisions.  

Acronyms/abbreviations.  Attachment 3 to this overview contains acronyms
and abbreviations used throughout the survey instruction documents and
associated spreadsheets.

Certification form.  Attachment 4 to this overview contains a
certification form that you must complete, sign, date, and submit
separately with each completed part of the survey, certifying that the
statements and information provided in your responses to Part I, Part
II, and Part III of the survey are (to the best of your knowledge) true,
accurate, and complete.  ATTACHMENT 1

DOCUMENTATION OF TRUE AREA SOURCE, NON-OPERATIONAL, OR NONAPPLICABLE
STATUS

Facility Name on the Letter from EPA:



	Corrected Facility Name (if applicable):



	Address:	





□

	

I certify that the facility listed above is not a “major source” or
“synthetic area source” of hazardous air pollutant emissions (HAP)
emissions.  The facility is a “true area source” of HAP emissions.
Documentation (such as a valid operating permit) confirming the true
area source status is attached.



□

	

I certify that that facility listed above was not operational in 2009
(the base year for the pulp and paper sector survey), and that the
facility remains non-operational (closed).  A brief explanation is
provided in the area below: 



□

	

I certify that the facility listed above does not produce pulp, perform
bleaching, or manufacture paper or paperboard products.  A brief
explanation is provided in the area below:





Signature: ____________________________________________

Printed name: _________________________________________

Email and/or fax completed form to:  	Bill Schrock (USEPA)

schrock.bill@epa.gov

Fax: (919) 541-3470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): 

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

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

µg	micrograms

µm	micrometer(s)ATTACHMENT 4

SIGNED CERTIFICATION FORM

Instructions:  Submit a hard (or electroinic) copy this completed form
with each part of your survey response (Part I, Part II, and Part III).

□

	

Based on information and belief formed after reasonable inquiry, I
certify that the statements and information provided in my response to
Part I of this survey are (to the best of my knowledge) true, accurate,
and complete.



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nd belief formed after reasonable inquiry, I certify that the statements
and information provided in my response to Part II of this survey are
(to the best of my knowledge) true, accurate, and complete.



□

	

Based on information and belief formed after reasonable inquiry, I
certify that the statements and information provided in my response to
Part III of this survey are (to the best of my knowledge) true,
accurate, and complete.





Signature: ____________________________________________

Printed name: _________________________________________

Title: _________________________________________________

Company: _____________________________________________

Date signed: ___________________________________________

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Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

  PAGE   \* MERGEFORMAT  1 

