Pulp and Paper Sector Survey

Instructions for Part II: NEI Update

11/16/10

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

  TOC \o "1-3" \h \z \t "Head - special,1"    HYPERLINK \l
"_Toc276042973"  A.	Part II Introduction	  PAGEREF _Toc276042973 \h  2  

  HYPERLINK \l "_Toc276042974"  B.	How to Submit Your NEI Update	 
PAGEREF _Toc276042974 \h  3  

  HYPERLINK \l "_Toc276042975"  C.	How to Complete the NEI Update	 
PAGEREF _Toc276042975 \h  4  

  HYPERLINK \l "_Toc276042976"  C1.  	Updating pre-populated NEI data	 
PAGEREF _Toc276042976 \h  11  

  HYPERLINK \l "_Toc276042977"  C2.  	Completing the NEI update if not
pre-populated by EPA	  PAGEREF _Toc276042977 \h  14  

  HYPERLINK \l "_Toc276042978"  PART II - ATTACHMENT 1     HYPERLINK \l
"_Toc276042980"  Emission Units to Include in the NEI Update 

  HYPERLINK \l "_Toc276042981"  PART II - ATTACHMENT 2     HYPERLINK \l
"_Toc276042982"  Resources for Estimating Emissions 

  HYPERLINK \l "_Toc276042981"  PART II - ATTACHMENT 3     HYPERLINK \l
"_Toc276042982"  Instructions for Accessing the Pulp and Paper NEI
Update FTP Site 

 

A.	Part II Introduction

Part II of 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 the U.S. Environmental
Protection Agency (  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 II of the pulp and paper sector survey
unless you meet one of the three criteria listed above for exemption
from the survey.

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 your National Emissions
Inventory (NEI) update, except as described in section C1 for those
mills that already recently provided NEI updates to EPA.

Part II of this survey asks questions about the emission units listed in
Attachment 1 to this document.  All of the emission units included in
both Parts I and III of the pulp and paper sector survey are listed in
Attachment 1 for inclusion in your Part II NEI update.  Section C of
this document, How to Complete the NEI Update, explains how to treat
various configurations of emission units.  Attachment 2 to this document
identifies resources that might be useful for estimating emissions for
your NEI update.   For convenience, a spreadsheet file entitled Lookups
for P&P survey.xls accompanies Part II of the survey.  This spreadsheet
file consolidates and provides the various codes associated with the NEI
data set you are requested to update.  

  

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.  

B.	How to Submit Your NEI Update  

Submit your NEI update on or before the date specified in the section
114 letter accompanying these instructions.  

After you have completed and reviewed your NEI update, sign and date the
certification form in Attachment 4 of the Survey Overview document. 
Save your NEI update file as “P&P NEI update_______.xls” or “P&P
NEI blank________.xls” where the blank is your NEI Site ID number (so
your file will be submitted to EPA with a unique filename that
identifies your facility).  Then, transmit your certification form and
NEI update file to EPA using one of the following methods:

(1) Email it to:  ppsurvey@rti.org 

(2) Post it to the pulp and paper survey FTP site (  HYPERLINK
"ftp://ftp.rti.org"  ftp.rti.org ).  Abbreviated instructions for
accessing the FTP are as follows. More detailed instructions with screen
shots are included in Attachment 3 of this document.

a. In Internet Explorer go to:    HYPERLINK "ftp://ftp.rti.org" 
ftp.rti.org 

b. Click “Page” and then “Open FTP Site in Windows Explorer”

c. Once it is open in Windows Explorer, Click on “File” and then
“Login As...”

d. Enter:	username:  pulppaper

password:  part2NEI

e. Once you're logged in, you will be automatically redirected to the
Pulp_Paper_NEI_Update folder where you will save your file under the
unique file name you specify (as described above).

(3) Save it on a CD or DVD and mail it to: 

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

If you mail your certification form and NEI update, EPA recommends using
Registered U.S. Mail with return receipt requested, Federal Express, or
other method for which someone must provide a signature upon receipt.

C.	How to Complete the NEI Update

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

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

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

1626-3	Pulp and Paper Production - NonMACT Facilities

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

If 2005 NATA NEI data exist for your mill, then the two spreadsheet tabs
in P&P NEI update.xls (Facility tab and Inventory tab) have been
pre-populated with your mill’s NEI data set.  You will need to review
and revise the NEI data in these two tabs as necessary following the
instructions provided below in section C1 for “Updating pre-populated
NEI data.” 

If NEI data do not already exist for your major or synthetic area source
mill, then you will need to provide a full NEI update using the P&P NEI
blank.xls spreadsheet file (New Facility and New Inventory tabs).  See
the instructions in section C2 below for “Completing the NEI update if
not pre-populated by EPA.”

General instructions that apply to your NEI update regardless of whether
you are asked to revise pre-populated NEI data (in P&P NEI update.xls),
or supply new NEI data (in P&P NEI blank.xls) are provided in the
paragraphs below.  Additional specific instructions are provided in
sections C1 and C2 (where needed).  “Instruction” rows are provided
in the NEI update spreadsheets. 

Emission units and MACT codes to include in your NEI update.  Part II of
this survey asks questions about the emission units listed in Attachment
1 to this document.  Attachment 1 lists all of the emission units
included in both Parts I and III of the pulp and paper sector survey
that should also be included in your Part II NEI update.  Updates to the
list of emission units, descriptions, and SCC codes in your NEI update
would improve the accuracy and completeness of the NEI data for use in
EPA’s HAP residual risk efforts.  Updated information will allow EPA
to focus residual risk regulatory analyses on the specific types of
emission units with questionable risk.

Regardless of whether you are updating a pre-populated data set or
providing new inventory information, you must review and supply, at a
minimum, HAP emissions inventory data for emission units falling within
the three pulp and paper MACT source categories (MACT codes 1626-1,
1626-2, and 1626-3).  Note that in some cases, certain emission units
may fall within a MACT source category but not have any applicable MACT
requirements.  The pulp and paper MACT codes applicable to the emission
units in Attachment 1 of this document have been identified to assist
you with determining the appropriate MACT code to use in your NEI update
(see Attachment 1).  Additional MACT codes for equipment outside of the
pulp and paper MACT source categories are included in the spreadsheet
entitled Lookups for P&P survey.xls (MACT Codes tab).

Pollutants to include in your NEI update.  The NEI currently includes
both HAP and criteria air pollutant (CAP) emissions data.  Criteria air
pollutants include particulate matter (PM), sulfur dioxide (SO2),
nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic
compounds (VOC).  Total reduced sulfur (TRS) emissions generally have
not been included in the NEI to date.  

The NEI data solicited through this pulp and paper survey will be used
by EPA for NESHAP RTR purposes.  Therefore, at a minimum, you must
review and supply HAP emissions data in your NEI update.  

Although we are focused on HAP for RTR purposes, EPA would also like to
receive any voluntary updates to CAP data and any new TRS emissions data
that you wish to provide.  Updated CAP and TRS data would be used in
determining the magnitude of emissions for purposes of reviewing the
subpart BB NSPS for kraft pulp mills.  Updates to the CAP data and
inclusion of TRS data in your NEI update are optional.  However, should
you substantially revise the configuration of emission units in your
pre-populated NEI for purposes of updating HAP emissions, you are
strongly encouraged to update the corresponding CAP emissions as well. 

Base year for your NEI update.  Use the 2009 calendar year as the base
year for your NEI update, except as described in section C1 for those
mills that have already recently provided NEI updates to EPA for RTR
purposes.

Emission Unit ID.  Emission units must be identified with an Emission
Unit ID in your NEI update.  To the extent possible, this same Emission
Unit ID should also be used throughout all parts of this pulp and paper
survey (Part I, Part II, and Part III).

 

Emission Release Point ID.  There may be one or more emission release
points for a given Emission Unit ID.  Methods for including various
configurations of emission units and release points are discussed in the
paragraphs below.  For each Emission Unit ID and Emission Release Point
ID, you will specify emission rates for each pollutant, emission release
parameters (e.g., stack gas parameters or fugitive release parameters),
and longitude/latitude coordinates. 

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

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

Single emission unit with multiple emission release points.  Pulp and
paper emission units may have multiple emission points (e.g., paper
machines, digester blow gases and relief gases, boilers with two stacks)
that for various reasons may not be consolidated into a single emission
point before release to the atmosphere.  In these situations, the
emission unit should be repeated in the NEI and emissions data and stack
parameters provided for every emission point.  You may use the
“Emission Unit Description2” column to distinguish among emission
points for each emission unit. 

Paper machine example:  For paper machines, it is recommended (at a
minimum) that different emission points be specified for the wet and dry
ends of the machine where discernable emission points exist.  However,
it may be necessary to depict paper machine emissions as fugitive
emissions as described below.  An accurate representation of paper
machine vent configurations will lead to more representative risk
modeling results.  For example, depicting paper machine emissions as
exiting from one vent will provide different (higher) risk modeling
results than would adding additional vent details that show more
accurately how paper machine emissions are dispersed. 

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

Bypass stacks used only during certain times.  If your facility operates
an emission unit with a bypass stack that allows for emissions to bypass
the control system, then you can indicate the emissions associated with
use of the bypass stacks by entering the appropriate data in a new row
(see previous instructions for “adding a row”).  If you enter data
for bypass stacks, please indicate these emissions as “bypass”
emissions in the “Emission Unit Description2” column.  Please also
indicate in the “Emission Unit Description2” column the release
point associated with “normal” operations.

 

Emission Release Point Type.  In the NEI, each emission release point is
characterized by an emissions release point type code that you will
either assign or revise.  Emission release point type code 1 applies for
fugitive emission sources, while other emission release point type codes
(2 through 6) apply for point source (e.g., stack) releases.  

The following emission release parameters apply for fugitive and point
source emission releases:

Emission Release Point Type	Applicable NEI emission release parameter
columns

Fugitive	Multiple emission rate columns

(code = 1)	Stack height (ft)

	Fugitive Length (E-W) (ft)

	Fugitive Width (N-S) (ft)

	Fugitive Angle (degrees)

	Latitude and Longitude columns

Point 	Multiple emission rate columns

(code = 2, 3, 4, 5, 6, or 99)	Stack height (ft)

	Exit Gas Temperature (f)

	Stack Diameter (ft)

	Exit Gas Velocity (ft/sec)

	Exit Gas Flow rate (cuft/sec)

	Latitude and Longitude columns



Note that the emission rate columns, stack height, and latitude and
longitude columns are the same for fugitive and point sources.  These
parameters are discussed further in the paragraphs below. 

Emission rates (TPY and lb/hr).  The “Routine Emissions (TPY)”
column should reflect ACTUAL routine emissions measured or estimated for
the reported calendar year.  Routine emissions reflect emissions exiting
the air pollution control system (for emission units with air pollution
controls). The “Routine Emissions Max hourly rate (lbs per hour)”
column should reflect the ACTUAL maximum hourly (lb/hr) emission rate
measured or estimated for the reported calendar year.  In addition to
the routine emissions, columns are included for startup and shutdown
emissions (tpy and max hourly rate in lb/hr), if available. 

Both the TPY and lb/hr data columns are requested because EPA is
modeling both short- and long-term risks.  Long-term risks would be
based on the annual routine emissions (tpy).  The routine emissions
(tpy) can be used in determining an average hourly emission rate for the
year (e.g., tpy divided by operating hours) for purposes of risk
modeling.  Short-term risks would be based on the maximum hourly
emission rate(s) (e.g., lb/hr data).

For routine emissions, the average hourly emission rate (e.g., tpy
divided by operating hours) can differ from the maximum hourly emission
rate due to fluctuations in production rates or other changes in other
routine operating conditions.  In the absence of site- or
process-specific information, it has been EPA’s practice to
conservatively assume that maximum hourly emissions are 10 times the
routine hourly emissions for purposes of risk modeling.  EPA would
prefer to have site-specific emissions measurements or estimates (where
available) than to apply this default factor-of-10 approach.  If these
data are unavailable and are not provided in the “Routine Emissions
Max hourly rate (lbs per hour)” column, then EPA will apply a default
approach (e.g., the factor-of-10 or similar approach derived for pulp
and paper processes).  

Startup and shutdown are conditions of operation that can occur
throughout the year (with the number of startups and shutdowns depending
on the type of process and equipment involved).  We understand that
emissions may differ (e.g., be higher or lower than routine emissions)
during periods of startup/shutdown, and that mills are unlikely to have
measured emissions during startup/shutdown.  Responses to the
startup/shutdown emission rate questions are OPTIONAL but are requested
from mills that may have previously measured (e.g., with CEMS) or
estimated such emissions. 

Stack height and fugitive release height.  Although labeled “Stack
height (ft),” this column applies more generically as the release
height for either stack or fugitive emission sources.  Therefore, you
should specify “stack” heights for emission sources that vent though
stacks, or the fugitive release height for fugitive emission sources. 
Generally, the higher the stack or fugitive release height, the greater
the dispersion of air emissions, which in turn leads to reduced risk to
the surrounding population.  The EPA will specify conservative default
release height parameters if you do not supply this information. 

Latitude/longitude coordinates.  In your NEI update, you are asked to
provide (or revise) the latitude/longitude for each emission release
point.  The latitude/longitude coordinates should correspond with the
actual location of each emission point (e.g., the location of each
stack–not the general street address of the mill).  For point sources,
latitude/longitude is specified at the center of the emission source. 
For fugitive sources, latitude/longitude is specified at the southwest
corner of the emission source if the fugitive angle is zero or the
western most corner if the fugitive angle is greater than zero.  EPA
requires latitude/longitude for each emission point provided in North
American Datum (NAD) 83 with 6 digits to the right of the decimal point.
  

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

The latitude and longitude for fugitive emission units are depicted in
the figures above.  When the fugitive angle is zero, the latitude/
longitude coordinates are specified at the southwest corner of the
fugitive emission unit.  If the fugitive angle is greater than zero,
then the coordinates are specified at the western most corner of the
emission unit.

Exit gas temperature, velocity, and flow rate.  For point sources (e.g.,
stacks or vents), you are asked to provide typical or representative
values for the exit gas temperature, exit gas velocity, and exit gas
flow rate based on information you have in hand.  For example, if you
have a one-time measurement of these parameters (e.g., from a stack
test), then you could use that measurement.  If you have continuous
monitoring data, then you may choose to use the annual average for the
parameter.  If you have periodic monitoring data (e.g., quarterly data),
then you could average the quarterly data for the year.  The exit gas
temperature, velocity, and flow rate influence dispersion of air
emissions and the risk modeling results (e.g., higher temperatures and
velocity/flow rates lead to greater dispersion, which in turn leads to
reduced risk to the surrounding population).  If you do not supply this
information, then EPA will specify conservative default parameters. 

Emission Unit Description. Every emission unit listed in your NEI
inventory should have an informative “Emission Unit Description”
that adequately describes the equipment or type of emission unit.  You
may find it helpful if the Emission Unit Description column relates your
emission unit/process to your permit or process flow diagram.  Your
“Emission Unit Description” will be used as a check for SCC code
assignment.

SCC and other NEI codes (Lookups for P&P survey.xls).  For convenience,
the spreadsheet entitled Lookups for P&P survey.xls consolidates and
provides the various codes associated with the NEI data set you are
requested to update.  These codes were extracted from the NEI data base
lookup tables at   HYPERLINK
"http://www.epa.gov/ttn/chief/net/2005inventory.html" 
http://www.epa.gov/ttn/chief/net/2005inventory.html .  

This Lookups for P&P survey.xls spreadsheet contains source
classification codes (SCCs).  The SCCs in the NEI will be used by EPA to
group similar emission units and draw conclusions regarding the emission
levels and residual risk associated with each type of emission unit. 
Proper assignment of SCCs will allow EPA to pinpoint emission unit types
that need to be examined in more detail for residual risk rulemaking. 
The SCC codes for pulp and paper manufacturing were updated in late 2009
to include more descriptive codes and to provide some guidance on which
codes should be used for certain equipment types.  The process of
revising the SCC list in 2009 involved both the addition and the removal
of pulp and paper-related SCCs.

For example, the SCC list previously included the SCC: 30700118 Sulfate
(Kraft) Pulping / Liquor Clarifiers.  This SCC is now obsolete and has
been replaced with the more specific SCCs: 30700132 Sulfate (Kraft)
Pulping / Green Liquor Processing and 30700133 Sulfate (Kraft) Pulping /
White Liquor Processing.  Please use the most appropriate SCC from the
provided lookup table.  

A crosswalk of the available SCC codes with the types of equipment
listed in Attachment 1 is included in the P&P Att1 with SCC tab of
Lookups for P&P survey.xls.  The full list of SCC codes used for EPA’s
Emissions Inventory System (EIS)/NEI is included in the All 11575 SCC
tab of Lookups for P&P survey.xls (and is also available in data base
form at   HYPERLINK
"http://www.epa.gov/ttn/chief/net/2005inventory.html" 
http://www.epa.gov/ttn/chief/net/2005inventory.html ).

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

Use the SCC that best describes your process and avoid using generic
not-elsewhere-classified (NEC) SCCs whenever possible.  Please make
every attempt to use SCCs specific to the pulp and paper sector (e.g.,
use SCC 30700106 for pulp and paper lime kilns as opposed to SCC
30501619 for the lime manufacturing sector).  If you do not find an SCC
that matches your emission unit, then be sure to include an accurate
“Emission Unit Description”.

Please do not use generic NEC SCCs unless you absolutely cannot find a
specific SCC that resembles your emission unit.  A detailed “Emission
Unit Description” is required if you choose a NEC SCC.

Updates (i.e., both additions and deletions) may have been made to some
of the other NEI code lookup tables (other than SCCs).  Codes that are
being phased out are shaded green in some of the lookup tables (along
with a note in the lookup table explaining how to treat the green-shaded
codes in your inventory update).  If a code that you have used in the
past no longer appears in the appropriate lookup table, please select
the most appropriate code from those listed.  You may clarify your entry
by adding text in the “Comment – Process” column.  

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

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

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

C1.  	Updating pre-populated NEI data  

You will need to review and revise the NEI data contained in the
“Facility” and “Inventory” tabs of the P&P NEI update.xls
spreadsheet file as necessary.  The instructions for updating the
pre-populated NEI data in the Facility and Inventory tabs are provided
below and in “Instruction” rows in the spreadsheet.

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

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

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

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

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

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

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

To indicate that no revisions needed.  If you review the data in the
Inventory tab and conclude that no revisions are needed, then mark all
existing NEI rows in the “Is Reviewed With No Changes” column in the
Inventory tab accordingly.



 

General steps for updating your pre-populated NEI data are as follows:

STEP 1.  Review and update the single row of NEI data in the Facility
tab as needed following the instructions above and that appear in each
column of the spreadsheet. 

STEP 2.  Review the pre-populated data in the Inventory tab, and the
specific instructions for updating pre-populated data in this document. 
You may find the following questions helpful for guiding your review:

Are all of required emission units included in the inventory?

Are the emission unit configurations depicted correctly (e.g., single
unit with multiple vents; common collection systems and stacks, etc.) 

Is the Emission Release Point Type specified correctly for each emission
unit?

Are all of the known pollutants (particularly HAP) that are emitted from
each emission unit included in the inventory?

Considering the inventory year (Start Date and End Date columns), are
the emissions of each pollutant included in the inventory representative
of the 2009 operating year?

Is the Emission Unit Description adequately filled in?

Is the SCC assignment correct, and Emission Process Group assigned?

Are MACT codes properly assigned for each emission unit?

Are the stack or fugitive release parameters correct?

Are latitude/longitude specified correctly for the location of each
emission point?

Are the control measures specified correctly?

What data do you have for specifying the Routine Emissions Max Hourly
Rate (lbs per hour) and for populating the startup/shutdown emissions
columns?

Are there other revisions that need to be made (e.g., SIC or NAICS code,
facility name changes, etc)?

STEP 3.  After you have reviewed the NEI data and assessed what changes
need to be made, proceed with making the changes following the
instructions in this document and the instructions that appear in each
column of the spreadsheet. 

STEP 4.  Submit your revised inventory following the instructions in
Section B of this document.

Additional detailed instructions for updating your pre-populated NEI
data are provided in the following paragraphs.

Emission units unrelated to the pulp and paper NESHAP (or NSPS) source
categories.  Please note that the pre-populated NEI data sets contain
all emissions data for a facility identified as having any equipment
belonging to the pulp and paper MACT categories (e.g., equipment with
MACT codes 1626-1, 1626-2, or 1626-3).  Some of the emissions may be
from processes NOT associated with the pulp and paper MACT category. 
The column labeled “MACT Code” indicates if the HAP pollutant
emissions are associated with the pulp and paper MACT category or
another MACT category at the facility (e.g., MACT code 0107-2 associated
with Industrial/Commercial/Institutional Boilers & Process Heaters –
gas.). A full list of MACT codes is included in the spreadsheet file
Lookups for P&P survey.xls.  Data from MACT categories other than the
pulp and paper NESHAP categories are shown in the pre-populated
spreadsheets to provide a complete dataset for the facility and/or help
you spot additional processes which should be assigned to the pulp and
paper MACT category.

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

Emission Unit IDs.  General instructions pertaining to Emission Unit IDs
are provided above.  Existing NEI Emission Unit IDs have been provided
for you in a gray shaded column of your pre-populated inventory.  These
Emission Unit IDs may have originated from states or other entities that
supplied data for the NEI.  For existing emission units, please use the
existing Emission Unit ID whenever possible to avoid confusion.  You may
create new Emission Unit IDs (text limited to 6 characters) for emission
units that you add in your NEI update. 

“Emission Unit Description” and “REVISED Emission Unit
Description” columns.  General instructions pertaining to Emission
Unit Descriptions are provided above.  An “Emission Unit
Description” column was included in prior drafts of the NEI that mills
were asked to voluntarily review and update.  If no “Emission Unit
Description” is in the NEI for a given emission unit, then you will
need to add one in the “REVISED Emission Unit Description” column. 
If you find that the “Emission Unit Description” in the NEI is not
informative, then you may revise it using the “REVISED Emission Unit
Description” column.  

“SCC” and “REVISED SCC” columns.  General instructions
pertaining to SCC assignments are provided above.  In some cases, you
may find that your pre-populated NEI data contains multiple SCCs for the
same emission unit (e.g., a multifuel-fired boiler with separate SCCs
indicated for each fuel type).  In their NEI updates, some States split
emission units by fuel type and specify separate SCCs for each fuel
type.  Although this is an option for reporting inventory data, for
simplicity, EPA would prefer that you assign the single most relevant
SCC to the emission unit (e.g., the SCC relating to the predominant
fuel) and report the emissions rates for the emission unit only once (as
opposed to attempting to apportion the emissions across different SCCs
for different fuel types).  You are not required to make revisions to
your inventory solely to aggregate emissions already apportioned across
multiple SCC codes for the same emission unit if you believe the
emissions are reasonable.  However, we suggest that you do not add any
new emission units with multiple SCCs for each fuel type.

“Start Date” and “End Date” columns.  The “Start Date” and
“End Date” columns indicate the dates for which NEI data are
provided.  For example, Start Date = 20020101 and End Date = 20021231
indicates that the pre-populated NEI data cover emissions for the 2002
operating year (e.g., from 1-1-2002 until 12-31-2002).  You are asked to
specify a “REVISED Start Date” and a “REVISED End Date.”  For
the 2009 operating year, this would be REVISED Start Date = 20090101 and
REVISED End Date = 20091231.

C2.  	Completing the NEI update if not pre-populated by EPA  

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

If your mill is a major (or synthetic area) source of HAP emissions,
then you will need to develop and supply the NEI data set requested in
the P&P NEI blank.xls spreadsheet of the pulp and paper sector survey. 
Useful starting points for providing the NEI data set may include your
air operating permit or permit application, an inventory of emission
sources for your mill developed for permitting purposes, or the emission
calculations developed for the Toxics Release Inventory (TRI) for your
mill.  Additional resources useful for estimating emissions are listed
in Attachment 2 to this document.  The spreadsheet file entitled Lookups
for P&P survey.xls provides various codes associated with the NEI data
(including SCCs).

General instructions for providing NEI data appear in section C of this
document (above).   The steps for providing a new NEI inventory are as
follows:

STEP 1.  Populate the NEI information in the New Facility tab of the P&P
NEI blank.xls spreadsheet following the instructions in Section C above
and that appear in each column of the spreadsheet. You will add a single
row of data in the New Facility tab.  

NEI Site ID.  Use an NEI Site ID of “NEW_____” where the blank is
your mill’s zip code, as this will (in all likelihood) provide a
unique identifier for your mill. 

STEP 2.  Populate the NEI information in the New Inventory tab of the
P&P NEI blank.xls spreadsheet following the instructions in Section C
above and that appear in each column of the spreadsheet. You will add
multiple rows of data in the New Inventory tab (one row for each
pollutant emitted from each emission unit emission release point).  

“Start Date” and “End Date” columns.  You are asked to provide
emissions data for the 2009 operating year.  The “Start Date” and
“End Date” columns indicate the dates for which NEI data are
provided.  For example, Start Date = 20090101 and End Date = 20091231
indicate that the NEI data cover emissions for the 2009 operating year
(e.g., from 1-1-2009 until 12-31-2009). 

STEP 3.  Submit your revised inventory following the instructions in
Section B of this document.

  PART II - ATTACHMENT 1

Emission Units to Include in the NEI Update

Include the following types of equipment (emission units) in your NEI
Update.  You may not operate all of the emission units listed below. 
Only include equipment operated at your mill.  

The Lookups for P&P survey.xls file (P&P Att 1 with SCC tab) contains a
crosswalk of the equipment listed in this attachment with the available
source classification codes (SCCs).  The relevant pulp and paper MACT
codes are indicated in parentheses below.  Other MACT codes can be found
in the Lookups for P&P survey.xls file (MACT Code tab).

Chemical Recovery Combustion Equipment (1626-2)

Chemical recovery furnace

Chemical recovery combustion unit 

Black liquor oxidation system

Smelt or ash dissolving tank

Lime kiln or calciner  

Black liquor gasification system

Sulfur burner

Causticizing Equipment (1626-1)

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 (1626-1)

Digester

Chip bin

Chip steaming vessel

Flash tank

Blow tank

Condenser

Turpentine decanter

Pulp Washing, Thickening, and Storage Equipment (1626-1)

Brown stock washers

Hoods

Filtrate tanks

Vacuum pumps

Screens

Knotters

Decker

Stock chests (including open stock chests)

Pulp storage tanks

Thickeners

Pulp dryers

Evaporators (1626-1) 

Black liquor storage tanks

Evaporator hot wells

Condensers

Boilout tanks

Soap storage tanks

Soap skimmer tanks

Other emission points associated with the evaporators.  

Oxygen Delignification Equipment (1626-1)

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 (1626-1)

LVHC system

HVLC system

Stripper System Equipment (1626-1) 

Stripper feed tanks

Condensers

Heat exchangers

Methanol Rectification Equipment (1626-1)

Rectifiers

Condensers

Decanters

Storage tanks  

Storage Tanks (1626-1)

Weak liquor storage tanks

Strong liquor storage tanks

Liquor storage ponds

Acid condensate storage tanks (at sulfite mills)

Tall Oil Production Equipment (1626-1)

Tall oil acidulation reactor

Storage tank

Dehydrator

Brine storage tank

Screen

Centrifuge tank

Other tall oil production vents    

Mechanical Pulping Equipment (1626-1)

Stone grinder

Refiner

Chip pre-steaming vessel

Chip cooker 

Screen  

Decker

Brightening/bleaching tower    

Non-wood Pulping Equipment (1626-1)

Secondary Fiber Pulping Equipment (1626-1)

Bleaching Equipment (1626-1)

Tower vents

Washer hoods

Seal tank vents

Chemical and steam mixers

Paper Making Equipment (1626-1)

Paper machines

Pulp dryers

Machine chest

Repulpers

Stock blending and storage tanks

Broke tanks

Savealls

White water storage tanks

Wastewater Treatment System Units (1626-1)

Clarifiers

Settling ponds

Aerated stabilization basins

UNOX systems

Wastewater tanks

Other wastewater handling and treatment units 

Power Boilers (Including Small Package Boilers)

Thermal Oxidizers/Incinerators (1626-1 or 1626-3)

Woodyard Operations (1626-3)

PART II - ATTACHMENT 2

Resources for Estimating Emissions

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

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

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

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

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

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

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

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

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

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

Part II - Attachment 3

Instructions for Accessing the Pulp and Paper NEI Update FTP Site

In Internet Explorer go to:    HYPERLINK "ftp://ftp.rti.org" 
ftp.rti.org 

 

Once you are there, to log into the FTP space:

Click “Page” (circled in red below) and then “Open FTP Site in
Windows Explorer.”

 

Once it is open in Windows Explorer, Click on 'File' and then 'Login
As...'

 

You should get this login request:

 

Enter:

username: pulppaper

password: part2NEI

Once you're logged in, you'll be automatically redirected to the
“Pulp_Paper_NEI_Update” folder.

Although you may be able to view files directly in your browser, you may
find it easier to right click and save the documents locally, especially
for large documents.

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

 For pre-populated NEI inventories, you would use the "REVISED Emission
Unit Description” column for updates.

 The Emission Release Point Type codes are:  1 – Fugitive; 2 –
Vertical; 3 – Horizontal; 4 - Goose Neck; 5 - Vertical with Rain Cap;
6 - Downward-facing Vent; 99 - Unknown

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

 

Part II	Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

	Form Approved __/__/__

	OMB Control No. ____-____

	Approval Expires __/__/__

Why can’t I over-write existing data? 

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

Latitude/longitude specified at western most corner (when fugitive angle
> 0)

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.

L=10 ft

W=4 ft

Angle = 45 degrees

L=10 ft

W=4 ft

Angle = 0

Latitude/longitude specified at SW corner (when fugitive angle = 0)

A Note About Emission Release Parameters

Please pay particular attention when entering emission release point
stack parameters and locations (latitude/longitude).  These data are
critical inputs to the modeling files that EPA will use to determine the
risk profile for the residual risk review process.

	 page \* arabic 1 

	 page \* arabic 20 

