Pulp and Paper Sector Survey

Instructions for Part I: 

Mill Overview and Subpart S Data

11/16/10

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

  TOC \o "1-3" \h \z \t "Head - special,1"    HYPERLINK \l
"_Toc276021983"  A.	Part I Introduction	  PAGEREF _Toc276021983 \h  2  

  HYPERLINK \l "_Toc276021984"  B.	Confidential Business Information
(CBI)	  PAGEREF _Toc276021984 \h  4  

  HYPERLINK \l "_Toc276021985"  C.	How to Submit Your Part I Survey
Response	  PAGEREF _Toc276021985 \h  4  

  HYPERLINK \l "_Toc276021986"  C1. 	Submitting Your Non-CBI Response	 
PAGEREF _Toc276021986 \h  4  

  HYPERLINK \l "_Toc276021987"  C2. 	Submitting CBI	  PAGEREF
_Toc276021987 \h  4  

  HYPERLINK \l "_Toc276021988"  D.	How to Complete the Part I Survey	 
PAGEREF _Toc276021988 \h  5  

  HYPERLINK \l "_Toc276021989"  D1.  	Flow diagrams	  PAGEREF
_Toc276021989 \h  5  

  HYPERLINK \l "_Toc276021990"  D2.  	Process data (P&P survey_PI.xls)	 
PAGEREF _Toc276021990 \h  6  

  HYPERLINK \l "_Toc276021991"  a. 	Mill tab	  PAGEREF _Toc276021991 \h 
7  

  HYPERLINK \l "_Toc276021992"  b. 	PI Equip detail tab	  PAGEREF
_Toc276021992 \h  8  

  HYPERLINK \l "_Toc276021993"  c.  	PI Permit limits tab	  PAGEREF
_Toc276021993 \h  12  

  HYPERLINK \l "_Toc276021994"  d.  	PI Controls tab	  PAGEREF
_Toc276021994 \h  13  

  HYPERLINK \l "_Toc276021995"  e. 	Pulp prod tab	  PAGEREF
_Toc276021995 \h  14  

  HYPERLINK \l "_Toc276021996"  f. 	Byproducts tab	  PAGEREF
_Toc276021996 \h  15  

  HYPERLINK \l "_Toc276021997"  g. 	Kraft condensates tab	  PAGEREF
_Toc276021997 \h  15  

  HYPERLINK \l "_Toc276021998"  h. 	CCA tab	  PAGEREF _Toc276021998 \h 
16  

  HYPERLINK \l "_Toc276021999"  i. 	Bleaching tab	  PAGEREF
_Toc276021999 \h  16  

  HYPERLINK \l "_Toc276022000"  j. 	Paper prod tab	  PAGEREF
_Toc276022000 \h  17  

  HYPERLINK \l "_Toc276022001"  k. 	HAP additives tab	  PAGEREF
_Toc276022001 \h  17  

  HYPERLINK \l "_Toc276022002"  l.  	WW tab	  PAGEREF _Toc276022002 \h 
18  

  HYPERLINK \l "_Toc276022003"  D3.  	Test data	  PAGEREF _Toc276022003
\h  18  

  HYPERLINK \l "_Toc276022004"  a. 	PI Emissions test data tab	  PAGEREF
_Toc276022004 \h  18  

  HYPERLINK \l "_Toc276022005"  b. 	CEMS data spreadsheet (P&P
CEMS_PI.xls)	  PAGEREF _Toc276022005 \h  19  

  HYPERLINK \l "_Toc276022006"  D4.  	Optional cost data	  PAGEREF
_Toc276022006 \h  21  

  HYPERLINK \l "_Toc276022008"  PART I - ATTACHMENT 1     HYPERLINK \l
"_Toc276022009"  Emission Units to Include in the Part I Pulp and Paper
Survey Response	  PAGEREF _Toc276022009 \h  23  

  HYPERLINK \l "_Toc276022010"  PART I - ATTACHMENT 2     HYPERLINK \l
"_Toc276022011"  Small Business Size Standards	  PAGEREF _Toc276022011
\h  25  

  HYPERLINK \l "_Toc276022012"  PART I - ATTACHMENT 3     HYPERLINK \l
"_Toc276022013"  Part I Emissions Test Data Request	  PAGEREF
_Toc276022013 \h  26  

 

A.	Part I Introduction 

The pulp and paper sector 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.

Certain mills are not required to complete the pulp and paper sector
survey.  If your mill meets one of the following conditions, then you
should complete the form in Attachment 1 of the Survey Overview document
and email (or fax) it to Bill Schrock at   HYPERLINK
"mailto:schrock.bill@epa.gov"  EPA  (contact information is provided on
the form).  Conditions for exemption from all parts of the pulp and
paper sector survey are as follows: 

Your mill is not a “major source” or “synthetic area source” of
HAP emissions, or

Your mill was not operational in 2009 (and remains closed), or 

Your mill does not produce pulp, perform bleaching, or serve as a
primary manufacturer of paper or paperboard products.

You are required to complete Part I of the pulp and paper sector survey
unless you meet one of the three criteria listed above for exemption
from the 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).  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:    HYPERLINK "https://icr2010.rti.org/Industries/PulpPaper.aspx" 
https://icr2010.rti.org/Industries/PulpPaper.aspx 

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).   

Part I of this survey asks questions about the emission units listed in
Attachment 1 to this document.  Part I covers essentially all emission
units except for chemical recovery combustion sources (which are covered
in Part III).  Section D, How to Complete the Part I 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.  
Attachment 2 contains a listing of small business size standards for
North American Industry Classification System (NAICS) code Subsector
322, Paper Manufacturing.  Finally, Attachment 3 of this survey contains
a table of emission units and pollutants for which existing emission
test data are requested under Part I. 

Use the following attachments to the Survey Overview document for
reference:

Attachment 2:  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), the pulp
and paper processing NESHAP (40 CFR Part 63, subpart S), and selected
definitions from the NSPS and NESHAP General Provisions.  

Attachment 3:  Acronyms and abbreviations used throughout the survey and
associated spreadsheets.  

Table 1.  Part I Survey Spreadsheets and Tabs to Complete

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

P&P survey_PI.xls

	Mill	All mills

PI Equip detail 	All mills

PI Permit limits	All mills

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

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

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 that produce paper or paperboard products 

HAP additives	Mills that produce paper or paperboard products 

WW	Mills with onsite wastewater treatment plants

PI Emissions test data	Mills operating emission units for which test
data are requested in Attachment 3 to this document. 

P&P CEMS_PI.xls

CEMS data1	Mills operating CEMS on emission units listed in Attachment 1
to this document.

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

APCD costs	Mills that installed selected air pollution controls (see
section D4)

Equip change costs	Mills implementing selected process or equipment
changes (see section D4)

1Separate tabs are included for different pollutants and for CEMS cost.

B.	Confidential Business Information (CBI)  

The U.S. Environmental Protection Agency’s (EPA's) procedures for
handling confidential business information (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 CBI 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
secrets, especially information that is readily reported by other mills
without such claims.

C.	How to Submit Your Part I 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, sign and
date the certification form in Attachment 4 of the Survey Overview
document.  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 the signed certification form, 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 Part I Survey  

Your survey response will consist of flow diagrams, test reports, and
completed Microsoft Excel spreadsheets.  Separate Excel spreadsheet
files are provided for completion (P&P survey_PI.xls; P&P CEMS_PI.xls;
P&P costs OPTIONAL_PI.xls). You must complete certain tabs of the P&P
survey_PI.xls spreadsheet file (depending on the type of mill you
operate) as shown in Table 1 above.   The P&P CEMS_PI.xls spreadsheet
file is to be completed if you have continuous emissions monitoring data
to supply.  The P&P costs OPTIONAL_PI.xls spreadsheet file is an
optional spreadsheet file 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 (to both survey Parts I and III).   No
additional diagrams are requested in Part III, so please include
chemical recovery combustion sources in the diagrams submitted in
response to Part I.  

Readily available block flow diagrams (e.g., such as those used for
permit applications) will suffice.  Electronic or hard copies are
acceptable.  You need not prepare any new flow diagrams.  It is
acceptable to hand-mark changes on an older diagram that may no longer
be completely reflective if current operations.  Examples of diagrams
that would be helpful for EPA are as follows:

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

Pulping process. A diagram showing the equipment in all pulping lines,
including the digester area, pulp washing lines, evaporator lines, and
oxygen delignification systems, would be useful.   The diagram could
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. 
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 are also of interest.  

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

Wastewater treatment plant (WWTP).  A flow diagram of each WWTP showing
each wastewater handling/treatment unit would be useful.  

 

D2.  	Process data (P&P survey_PI.xls)

In this portion of the survey, you are asked to add data to the various
tabs in the P&P survey_PI.xls spreadsheet.  Many of the instructions you
need for completing the survey tabs are included in the
“Instruction” row of each tab in the P&P survey_PI.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

Bleaching line ID (if needed)

APCD_ID

The NEI Site ID and Emission Unit ID should correspond with the IDs used
in the NEI update (Part II of this survey) where such IDs exist.  If no
NEI Site ID already exists (e.g., in cases where no previous NEI data
exists for your mill), then you should use “NEW_____” for the NEI
Site ID where the blank is your mill’s zip code, as this will (in all
likelihood) provide a unique identifier for your mill.  If Emission Unit
ID(s) for selected process units do not already exist in the NEI data
set, then you may use any Emission Unit ID you choose (for example, the
ID used in your permit), and this same ID should be used throughout all
parts of the survey.  You will specify the Collection system ID and
APCD_ID in the PI Equip detail and other spreadsheet tabs.  The
Bleaching line ID would be used in the Bleaching tab, if needed, for
plants with multiple bleaching lines.

 

 

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. 	Mill tab  

Complete the columns following the instructions provided in the
“Instruction” row.  Your response in the Mill 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 2 to this document contains a listing of
North American Industry Classification System (NAICS) codes and small
business size standards for NAICS subsector 322.  For private
businesses, small entity is defined for each NAICS code 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 (air dried short tons/year)” column.  Note
that capacity represents the paper/paperboard production capability of
the operable machines and may be greater than 2009 actual production. 
Nominal production capacity will suffice.  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.  For example, suppose a mill has 3 paper machines
but one of these machines was shut down due to economic reasons for half
of 2009.  The capacity utilization could be figured as follows:   

	A	B	C	D	E	F

Paper machine	Nominal production capacity (air dried st/day) 	Maximum
production days/yr	Actual production days/yr	2009 capacity, air dried
st/yr 

(= A x B)	2009 actual production, air dried st/yr*

(= A x C)	2009 decimal percent utilization*

(= E / D)

#1	400	360	340	144,000	136,000

	#2	500	360	355	180,000	177,500

	#3	200	360	175	72,000	35,000

	TOTAL	1,100

	396,000	348,500	0.88

st = short tons (1 st = 2000 pounds)

*The EPA recognizes the potential for actual production or actual
utilization by machine to be considered as sensitive information (e.g.,
to be CBI).  Therefore, EPA is asking that you report the overall
decimal percent utilization aggregated across all machines instead. 

b. 	PI Equip detail tab  

All mills are asked to complete the PI 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 PI Equip detail tab.  Essentially, you are
requested to provide information for most of the equipment at your mill
in Part I (except for chemical recovery combustion sources which are
covered in Part III).  However, if you operate chemical recovery
combustion sources that burn pulp mill non-condensable gases (NCGs) or
stripper off gases (SOG), then you will need to identify these
combustion sources as the air pollution control device (APCD) in the PI
Equip detail tab.

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

PI Equip detail tab columns  	Description of information requested



	A-AO	Equipment, controls, and Federal rule applicability for each
emission unit and collection system.  



	AP-AR	Digesters

AS-AW	Pulp washers

AX-AY	Knotters, screens, and deckers

AZ-BB	Evaporators

BC-BE	Oxygen delignification

BF-BO	Strippers

BP-BS	Pulp storage and liquor storage

BT-BW	Liquor storage ponds

BX-CA	Causticizing equipment

CB	Fuel-fired equipment (e.g., boilers, thermal oxidizers, direct-fired
dryers, etc.) 

CC-CD	Equipment incinerating NCG or SOG

CE-DM	Primary and supplemental fuels for fuel-fired equipment (e.g., for
boilers, thermal oxidizers, direct-fired dryers, etc.)  

DN-DT	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 Emission Unit ID and Collection
system ID (if applicable), and APCD_ID(s) by following the directions in
the “Instruction” row of the PI 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 PI 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 PI 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 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 PI 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 PI Equip detail tab, and then indicate in
the “Emission Unit Description” column that EU001a and EU001b vent
through separate stacks.  Enter details associated with emission release
(APCD information and NSPS/NESHAP compliance options) in each row. 
Enter equipment details (year installed, hours per year [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 PI 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 PI 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 PI 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 PI Equip detail tab (e.g., as a
“Single emission unit with multiple release points” as described in
the instructions immediately above for the PI Equip detail tab).

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

Air pollution control devices (APCDs).  In the APCD columns, enter
primary APCDs (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 electrostatic precipitator (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, lime kiln, or recovery furnace for
emissions control.  Enter the Emission Unit IDs for each emission unit
(e.g., digester) in the Emission Unit ID column.  Use the boiler, lime
kiln, or recovery furnace’s Emission Unit ID as the APCD_ID in the
APCD columns.  The same Emission Unit ID (e.g., for the lime kiln or
recovery furnace) should be used in Part III when equipment-specific
details are provided for these equipment.

Backup controls.  Backup controls include alternative controls used when
flow from an emission source (e.g., high-volume, low-concentration
(HVLC) or LVHC 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 PI Equip detail tab.  Do
not include backup controls in the columns for APCD1 through APCD4.

Complete the applicable equipment-specific details requested in columns
AP through DT for each type of emission unit in the PI 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
AO.  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 AP through
DT 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 or soda 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.  

Boilers, thermal oxidizers, and direct-fired dryers. The EPA is
requesting limited information on boilers (and other fuel-fired
equipment such as thermal oxidizers and dryers) in the PI Equip detail
tab.  Many pulp and paper mills use boilers for primary or backup
control of organics from pulping process, and some mills use thermal
oxidizers for this purpose. Boilers (and other fuel-fired equipment)
currently contribute to the facility-wide risk levels at pulp and paper
mills.

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

Other equipment. Complete the generic questions in Columns A through AO
of the PI Equip detail tab for any pulp and paper production equipment
not elsewhere specified in the tab.

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
approximate percent of annual heat input capacity in million British
thermal units per year (MMBtu/yr) supplied by each fuel.

Primary and supplemental fuel information is requested for fuel-fired
equipment such as boilers, thermal oxidizers, and direct-fired dryers
(e.g., pulp dryers or paper machine dryers).  NCG and SOG are not
considered to be either primary or supplemental fuels for purposes of
this survey.  Information for secondary and additional fuels used
routinely for multifuel-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 PI Equip detail tab
are being sought for regulatory development purposes and will not be
used for enforcement purposes.  

c.  PI Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of
this document are requested.  You are only asked to include permit
limits for the emission units listed in Part I Attachment 1 at this
time.  However, you may also include permit limits for the chemical
recovery combustion source emission units listed in Part III Attachment
1 (and, therefore, would not need to include these limits in Part III).

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 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.  However, you do not need to provide every
unit/format for pollutants with multiple limits in different units of
measure or formats (e.g., only provide ppmdv and gr/dscf at specified %
oxygen (O2) for a combustion unit sulfur dioxide (SO2) limit specified
in the permit in terms of  ppmdv, lb/hr, lb/day, and tpy, gr/dscf at
specified % O2, etc.). 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.  Please note:

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 F 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 G for permit limit 1, Column J for permit limit 2, etc.) 
Please do not enter State lb/hr or tpy emission limits in addition to
the Federal limits.

Opacity.  The opacity limits of most interest to EPA are those for
fuel-fired equipment such as recovery furnaces, semichemical combustion
units, lime kilns, boilers, and thermal oxidizers.  You do not need to
include State opacity limits for every emission unit (only the
fuel-fired units).

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). 

While we would prefer to receive data in the PI Permit limits tab, we
will accept a copy of your operating permit (e.g., title V operating
permit) instead of the completed PI Permit limits tab.  Other complete
and up-to-date summaries of permit limits, such as a mill-specific
summary of permit limits or compliance matrix, would be acceptable as
well. 

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:  lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm,
or 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.

d.  	PI Controls tab 

Complete the Controls tab by following the instructions in the
“Instruction” row for add-on APCDs 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). 

Baghouses, cyclones, and other material handling equipment.  The EPA is
most interested in details for control systems used to reduce HAP
emissions (for equipment in the NESHAP source categories) and criteria
air pollutant emissions from equipment in the NSPS subpart BB source
category.  You do not need to include the specific details requested in
the Controls tab for control devices used solely for wood/material
handling operations (e.g., baghouses or cyclones on pneumatic wood
handling systems, etc.).

Boilers.  You do not need to include APCD 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 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, then you would enter this test result as the
“actual” control efficiency.  Leave the control efficiency columns
blank if actual 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
PI Equip detail tab rather than in the Controls tab.

Thermal oxidizers.  Questions pertaining to thermal oxidizers are
included in both the Controls and PI Equip detail tabs.  The PI 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. 	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 processes or pulping lines (if applicable) and each
pulping process/line should occupy only one row (e.g. a mill that
co-produces kraft and mechanical pulps should 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 capacity data will be used by EPA to understand the general
mill flow and in estimation of impacts and economic analyses.  In the
Pulp prod tab, the 2009 pulp capacity (ADTP/d) and capacity utilization
refer to unbleached pulps (i.e., pulp exiting the pulping line prior to
any brightening or bleaching).  [Note: Capacity of bleached pulp (e.g.,
pulp exiting the bleaching/brightening line) is requested in the
Bleaching tab.]  An example of how to calculate the pulp capacity
utilization percentage requested in the Pulp prod tab is as follows:

	A	B	C	D	E	F

Pulping process	Pulp capacity ADTP/d in 2009	Maximum d/yr	Actual 2009
operating d/yr when pulp was produced	2009 capacity, ADTP/yr

(= A x B)	2009 actual production, ADTP/yr*

(= A x C)	Pulp capacity utilization decimal

percentage in 2009

(= E / D)

kraft	950	365	340	346,750	323,000	0.93

mechanical	300	365	250	109,500	75,000	0.68

ADTP/d = air dried tons of pulp per day.  *The 2009 actual pulp
production could be determined by multiplying columns A x C or by other
means.  The EPA is not asking that you report the 2009 actual
production.

In the Pulp prod tab, EPA asks questions regarding how various pulps are
used by the mill in order to understand the mill flow for purposes of
economic modeling.  With these questions, EPA seeks the amount of
unbleached pulp from the pulping line that typically:

goes to an onsite bleaching/brightening line (if applicable)

is sold (or transferred to another mill within the same company) as
unbleached market pulp

is used onsite to manufacture unbleached paper/paperboard

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

f. 	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 equipment 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.

g. 	Kraft condensates tab

Complete the Kraft condensates tab by following the instructions in the
“Instruction” row.  Enter the Emission Unit IDs or Collection system
IDs for each kraft condensate stream. Common condensate sources are
listed in the Kraft condensates tab (e.g., digester systems, turpentine
recovery systems, evaporator systems, HVLC and LVHC collection systems).
 Complete the questions in table headings I through VII as applicable
(depending on the condensate treatment method your mill uses to comply
with subpart S).  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)



If your mill uses multiple treatment methods for a given kraft
condensate stream, please answer the questions for each treatment method
(under table headings III, IV, V, and/or VI) and the question in table
heading VII.  For example, if your mill normally treats condensates with
a steam stripper but relies on biological treatment when the stripper is
down, then you would respond to the questions under table headings IV
(stripping), V (biological treatment), and VII (multiple treatment
methods).      

h. 	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.  This information is being requested to inform EPA of
the mill-specific emission units involved in CCA compliance
calculations.

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).  If equipment other than that
listed above is included in your CCA calculations, please include that
equipment in the CCA tab.  EPA is interested in identifying which mills
are using the CCA option and the mill-specific equipment used in CCA
calculations.  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.

i. 	Bleaching tab 

All mills that perform bleaching or brightening of chemical, mechanical,
secondary fiber, or non-wood pulps should complete the portion of the
Bleaching tab to the left of the orange vertical line (column M) to
describe the bleaching (or brightening) systems used at your mill.  Note
that, for brevity, the terms “bleaching” and “brightening” are
used interchangeably in the Bleaching tab (e.g., the word
“bleaching” can be read to me “brightening” if that is the
process your mill uses).  

Your response in the Bleaching tab will consist of one row for each
bleaching/brightening line located at your mill.

 Most mills will have only one or two bleaching line rows.  For example,
a mill that produces bleached chemical pulp, bleached secondary fiber
pulp, and brightened mechanical pulp could include three rows (one for
each type of pulp that is bleached/brightened using separate
bleaching/brightening processes).

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 in the Bleaching tab with “NR (no
chlorine or chlorinated compounds used in this stage)” indicated.  

When specifying controls used for the various bleaching stages, enter
not applicable “NA” for stages without control.  Enter the APCD_ID
used in the PI Equip detail and PI Controls tabs when referring to any
control device.  Each bleaching stage includes several vents:  the tower
vent, washer hood, seal tank vent, chemical and steam mixers, and vacuum
pumps.  If all vents from a particular bleaching stage are not routed to
the control device indicated for that stage, then you should describe
the control system configuration in the control methods column.

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.

j. 	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). Do not include pulp dryers
in the Paper prod tab.  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, stock consistency, 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
within paper grades (due to specific product variations), and therefore,
a specific percentage is not being requested.  It will be sufficient to
round to the nearest 5 or 10 percent.

k. 	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.  For purposes of this survey,
“measurable” is defined consistent with OSHA requirements that
chemical suppliers provide specific constituent amounts in Material
Safety Data Sheets for any carcinogens that are present in amounts
greater than 0.1 percent and any non-carcinogens that are present in
amounts greater than 1 percent.  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), except in
determining any non-HAP substitutes for the additives.  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.

l.  	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 X). 
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 PI Equip detail and Control tabs and indicate the APCD
information in those tabs.  

The series of questions seeking an approximate volume percentage of WWTP
capacity from various mill areas will inform EPA of the overall nature
of the wastewaters generated by pulp and paper mills for treatment.  For
this series of questions, if the WWTP is a joint treatment facility and
treats process wastewater from several mills owned by the same company,
then the questions should be answered for each individual pulp and paper
mill in their survey response considering the total volume of wastewater
sent to the WWTP by that mill. 

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.

D3.  	Test data

	Attachment 3 of this Part I 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 data, 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_PI.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. 	PI Emissions test data tab 

Attachment 3 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.   

Emissions test data are not requested for power boilers unless the power
boiler is used to control NCGs or SOGs (in which case the test data
requested are for the pulping systems controlled by the power boiler,
assuming these emissions points have been tested).

Review the test data request table in Attachment 3 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 PI Emissions test data tab.

Cutoff dates are provided in Attachment 3 for certain emission unit and
pollutant combinations.   More recent cutoff dates (e.g., 2001 or date
of MACT compliance) are specified for emission unit and pollutant
combinations expected to be widely available.  Longer cutoff dates
(e.g., dating back to 1990) are included for emission unit and pollutant
combinations for which data are likely to be sparse.  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 APCD 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 3 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 PI Emissions 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 PI
Emissions 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 emissions test data received through this survey.

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

The EPA is requesting existing CEMS data and/or continuous opacity
monitoring system (COMS) data for calendar year 2009 (CY2009) operations
from facilities that have installed continuous monitoring systems.  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.  

You do not need to supply CEMS data for power boilers unless the boiler
has a CEMS installed to show compliance with a NESHAP subpart S (or
subpart MM) or NSPS subpart BB emission limit.  

A separate Microsoft Excel spreadsheet file (P&P CEMS_PI.xls) is
provided for submittal of the requested CEMS data.  The spreadsheet file
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_PI.xls spreadsheet file.

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 (e.g.,
for compliance with State emissions standards which may be based on the
TRS emissions guidelines). 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 CY2009
operations.  In addition, respondents are asked to provide the highest
single 12-hour average TRS concentration recorded in CY2009: (a) under
normal operating conditions, (b) under conditions of startup or
shutdown, and (c) under malfunction conditions.  [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 sametime period
as provided for the 12-hour averages.

Opacity.  This worksheet is designed for recovery furnaces or lime kilns
equipped with COMS but may be used for thermal oxidizers and other
equipment.  Respondents are requested to specify the Emission Unit ID
(or Collection system ID) and the APCD_ID, and report the 6-minute
average opacity for CY2009 operations.  An optional column is also
included for hourly average opacity for mills that calculate an hourly
average.  In addition, respondents are asked to provide the highest
single 6-minute average opacity recorded in CY2009: (a) under normal
operating conditions, (b) under conditions of startup or shutdown, and
(c) under malfunction conditions.    

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) and
the APCD_ID (or type of combustion controls used), and report the 1-hour
averages of the CEMS data for these compounds for CY2009 operations.  In
addition, respondents are asked to provide the highest single 1-hour
average concentration recorded in CY2009: (a) under normal operating
conditions, (b) under conditions of startup or shutdown, and (c) under
malfunction conditions.  

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 by Emission Unit ID (or Collection
system ID) the source of the NCGs/SOGs being controlled, specify the
APCD_ID, and report the 1-hour averages of the CEMS data for CY2009
operations.  In addition, respondents are asked to provide the highest
single 1-hour average recorded in CY2009: (a) under normal operating
conditions, (b) under conditions of startup or shutdown, and (c) under
malfunction conditions. 

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 and APCD_ID, and report the 1-hour averages of the CEMS
data for CY2009 operations.  In addition, respondents are asked to
provide the highest single 1-hour average recorded in CY2009: (a) under
normal operating conditions, (b) under conditions of startup or
shutdown, and (c) under malfunction conditions. 

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) and the APCD_ID, and report the 1-hour averages of
the CEMS data for CY2009 operations.  In addition, respondents are asked
to provide the highest single 1-hour average concentration recorded in
CY2009: (a) under normal operating conditions, (b) under conditions of
startup or shutdown, and (c) under malfunction conditions.  

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.

 

D4.  	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.  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_PI.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_PI.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 C2 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. 


For Part I, the EPA is particularly interested in costs of the following
APCDs.  Please supply this information using the APCD costs tab:

     - Paper machine HAP control devices

     - Controls that reduce HAP emissions from wastewater handling and
treatment systems  

     - 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.

    - Process changes that reduce HAP emissions from wastewater handling
and treatment systems  

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

    - Process changes that reduce paper machine HAP emissions

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 of
extra buildings, land purchases, etc. that may not be required for other
mills).     

PART I - ATTACHMENT 1

Emission Units to Include in the Part I Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your Part I
survey response.  You may not operate all of the emission units listed
below.  Only include equipment operated at your mill.  [Note:  Chemical
recovery combustion units are included in Part III.]  

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 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 

Bleaching Equipment 

Tower vents

Washer hoods

Seal tank vents

Chemical and steam mixers

Vacuum pumps

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

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 – PI Equip detail tab only

Thermal Oxidizers/Incinerators

Woodyard Operations

PART I - ATTACHMENT 2

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

PART I - ATTACHMENT 3

Part I 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.)Part I - Attachment 3.  Pulp and Paper Emission Units and
Pollutants for Which Existing Representative Emission Test Data Are
Requested

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

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

(fil.)

	PM2.5 (cond.)

	Chlorinated HAP (Cl)1	Acetaldehyde, Formaldehyde, and Methanol1	Total
hydrocarbon (THC) as carbon	Total reduced sulfur (TRS)1,3	Nitrogen
oxides (NOx)1	Sulfur dioxide (SO2)1	Carbon monoxide (CO)1

Test methods4	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	Methanol: Method 308 (part 63) or Methanol CEMS

Other methods (e.g., for acetaldehyde & formaldehyde)	M25 or M25A

	M16 or

TRS CEMS

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

CEMS	M6

CEMS	M10

CEMS

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

Supply most recent data following MACT compliance	Not requested



Sulfite pulping sources	Not requested



	Supply most recent data following MACT compliance



Supply most recent data

	Not requested

Wastewater treatment systems	Not requested



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

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





Supply most recent data following MACT compliance

Paper machine emission points	Not requested



	Supply most recent data





	Causticizing area sources	Not requested



	Supply most recent data





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



	Supply most recent data





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

4 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

Part I	Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

Part I						Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

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

There may be survey questions that you do not know the answer to, or for
which information is not readily available.  The following codes may be
used:  

Unknown (UK):  If you do not have the requested information, cannot
obtain the information without extraordinary effort, and cannot provide
a reasonable estimate, then you may enter “UK” for unknown.  

Not Applicable (NA):  If a question is not applicable to your
operations, then you may enter “NA” for not applicable.

Survey respondents are reminded that their certification of the accuracy
of their response includes a certification that any identification of
information as "unknown" or "not applicable" is accurate.  Further,
survey respondents providing an excessive number of responses as “UK
or “NA” are likely to receive scrutiny and follow-up inquiries from
EPA related to their survey response.

What averaging period should be used in responding to process detail
questions?

Several questions in the PI Equip detail and other survey tabs ask for
process parameters such as exhaust flow rate (acfm), temperature, etc. 
Unless otherwise specified, typical values are requested, and are
subject to the respondent’s discretion.  For example, if you measure a
particular parameter with an online meter and you have data available
for most operating hours of the year, then you may choose to supply an
annual average for the parameter.  However, if the parameter is only
measured periodically, then you may want to provide the most recent
measurement. 

Why does EPA need process data?

Facility and equipment details are being requested to inform the
technology review of the pulp and paper NESHAP and NSPS and to provide
information on means of reducing residual risk.  While the NEI update
(requested in Part II of this survey) 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
technologyl review of the NESHAP and NSPS 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 depends 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 a low-volume,
high-concentration (LVHC) collection system, 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.

What if my data are not in a form that can be inserted into P&P
CEMS_PI.xls? 

It is very helpful for EPA’s data analysis purposes if data are
entered into the P&P CEMS_PI.xls template provided.  However, we
understand that some CEMS software may not be configured to provide
output that can be easily converted to our preferred spreadsheet format.
 We also understand that, in some cases, the hourly production data
requested in the CEMS spreadsheet may not be coupled with the CEMS data
or may not be available in a manner to be easily linked to the CEMS
data.  If you face these or related issues, please note that EPA is not
asking you to hand enter hard copy CEMS data into the spreadsheet.  You
may provide CEMS data in an alternative format if you are unable to
convert it to our spreadsheet format within the timeframe for this
survey.  We request that you provide CEMS data in a form suitable for
analysis if possible (e.g., spreadsheet or data base format is preferred
over read-only pdf format).  We’d accept more recent CEMS data (e.g.,
from the most recent 6 months) if 2009 CEMS data are no longer in
electronic form due to company records retention policies.  Further, you
may omit the production data if they cannot reasonably be included in
your CEMS spreadsheet.  Estimates of production data are acceptable
(e.g., if you have a daily production rates, you may divide by 24
operating hours in a day to estimate hourly production). 

A Note About Identification Numbers (IDs)

The different parts of the pulp and paper survey include the following
IDs: 

NEI Site ID

Emission Unit ID

Collection system ID 

APCD_ID

It is imperative that you use the same IDs to describe the same
facility, equipment/emission unit, and emission release point throughout
all parts of this 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 Emission Unit 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) and in each part of your survey response. 
 For example, any Emission Unit ID or APCD_ID you create/specify in Part
I should also be used when referring to the same piece of equipment in
Parts II and III for this survey response.

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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