Pulp and Paper Sector Survey 

Instructions for Part III: 

Chemical Recovery Combustion Sources

11/16/10

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

  TOC \o "1-3" \h \z \t "Head - special,1"    HYPERLINK \l
"_Toc276033259"  A.	Part III Introduction	  PAGEREF _Toc276033259 \h  2 


  HYPERLINK \l "_Toc276033260"  B.	Confidential Business Information
(CBI)	  PAGEREF _Toc276033260 \h  4  

  HYPERLINK \l "_Toc276033261"  C.	How to Submit Your Part III Survey
Response	  PAGEREF _Toc276033261 \h  4  

  HYPERLINK \l "_Toc276033262"  C1. 	Submitting Your Non-CBI Response	 
PAGEREF _Toc276033262 \h  4  

  HYPERLINK \l "_Toc276033263"  C2. 	Submitting CBI	  PAGEREF
_Toc276033263 \h  5  

  HYPERLINK \l "_Toc276033264"  D.	How to Complete the Part III Survey	 
PAGEREF _Toc276033264 \h  5  

  HYPERLINK \l "_Toc276033265"  D1.  	Process data (P&P survey_PIII.xls)
  PAGEREF _Toc276033265 \h  5  

  HYPERLINK \l "_Toc276033266"  a. 	PIII Equip detail tab	  PAGEREF
_Toc276033266 \h  7  

  HYPERLINK \l "_Toc276033267"  b.  	PIII Permit limits tab	  PAGEREF
_Toc276033267 \h  10  

  HYPERLINK \l "_Toc276033268"  c.  	PIII Controls tab	  PAGEREF
_Toc276033268 \h  11  

  HYPERLINK \l "_Toc276033269"  d. 	PCC tab	  PAGEREF _Toc276033269 \h 
12  

  HYPERLINK \l "_Toc276033270"  D2.  	Test data	  PAGEREF _Toc276033270
\h  12  

  HYPERLINK \l "_Toc276033271"  a. 	PIII Emissions test data tab	 
PAGEREF _Toc276033271 \h  12  

  HYPERLINK \l "_Toc276033272"  b. 	CEMS data spreadsheet (P&P
CEMS_PIII.xls)	  PAGEREF _Toc276033272 \h  13  

  HYPERLINK \l "_Toc276033273"  D3.  	Optional cost data	  PAGEREF
_Toc276033273 \h  16  

  HYPERLINK \l "_Toc276033275"  PART III - ATTACHMENT 1     HYPERLINK \l
"_Toc276033276"  Emission Units to Include in the Part III Pulp and
Paper Survey Response	  PAGEREF _Toc276033276 \h  17  

  HYPERLINK \l "_Toc276033277"  PART III - ATTACHMENT 2     HYPERLINK \l
"_Toc276033278"  Part III Emissions Test Data Request	  PAGEREF
_Toc276033278 \h  18  

 

A.	Part III 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
semichemical), 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 have completed the form in Attachment 1 of the Survey Overview
document and submitted it to Bill Schrock (  HYPERLINK
"mailto:schrock.bill@epa.gov"  EPA ) before beginning Part I of the
survey.  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.

Part III of this information request applies for pulp mills that are a
“major source” or “synthetic area source” of hazardous air
pollutant (HAP) emissions that perform chemical wood pulping (for
example, with the kraft, sulfite, soda, semichemical or other pulping
process).

This survey is to be completed in a Microsoft Excel spreadsheet file
that is divided into several worksheets (“tabs” within the
spreadsheet file).  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 III of this survey asks questions about the chemical recovery
combustion sources listed in Attachment 1 to this document.  Section D,
How to Complete the Part III 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 of this
document contains a table of emission units and pollutants for which
existing emission test data are requested under Part III.

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 production 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 III Survey Spreadsheets and Tabs to Complete

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

P&P survey_PIII.xls

	PIII Equip detail	All mills subject to Part III

PIII Permit limits	All mills subject to Part III (unless permit limit
information for Part III emission units was provided in Part I)

PIII Controls	Mills with add-on air pollution controls on chemical
recovery combustion sources. 

PIII Emissions test data	Mills operating emission units for which test
data are requested in Attachment 2 to this document.

P&P CEMS_PIII.xls

CEMS data (separate tabs are included for different pollutants)	Mills
operating CEMS on chemical recovery combustion sources.

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

APCD costs	Mills that installed selected air pollution controls (see
section D3)

Equip change costs	Mills implementing selected process or equipment
changes (see section D3)



B.	Confidential Business Information (CBI)  

The 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
attachments submitted with your survey that contain CBI.  However,
please do not label your entire response as CBI if only a portion
includes trade secrets.  The EPA is likely to follow-up with a request
for validation of CBI claims for mills claiming large amounts of
information as trade secret, especially information that is readily
reported by other mills without such claims.

C.	How to Submit Your Part III 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, 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 or test data).  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/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 pages of attachments to your survey response containing CBI,
with the CBI portions of the 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 III Survey  

Your survey response will consist of emission test reports and completed
Microsoft Excel spreadsheets.  Separate Excel spreadsheet files are
provided for completion (P&P survey_PIII.xls; P&P CEMS_PII.xls; P&P
costs OPTIONAL_PIII.xls). You must complete certain tabs of the P&P
survey_PIII.xls spreadsheet file (depending on the type of mill you
operate) as shown in Table 1 above.   The P&P CEMS_PIII.xls spreadsheet
file is to be completed if you have continuous emissions monitoring data
to supply.  The P&P costs OPTIONAL_PIII.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.  	Process data (P&P survey_PIII.xls)

In this portion of the survey you are asked to add data to the various
tabs in the P&P survey_PIII.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_PIII.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 Part III of the the pulp and paper
survey response spreadsheet(s), including:   

NEI Site ID

Emission Unit ID

Collection system ID

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 PIII Equip detail and other spreadsheet tabs.  

 

 

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. 	PIII Equip detail tab  

All mills covered by Part III are asked to complete the PIII 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 PIII Equip detail tab.  Columns A through AM
ask generic questions for all emission units.  The columns to the right
of column AM request design and operating details for specific types of
emission units (e.g., recovery furnaces, etc.).  The table below
summarizes the different types of equipment for which specific questions
are included in the PIII Equip detail tab.

PIII Equip detail tab columns  	Description of information requested



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



	AN	Black liquor gasification

AO-AT	Black liquor oxidation systems

AU-BH	Recovery furnaces and recovery furnace ESPs

BI-BN	Semichemical combustion units (at stand-alone semichemical pulp
mills)

BO-BT	Smelt/ash dissolving tanks

BU-CB	Lime kilns (including rotary lime kilns and fluidized bed
calciners)

CC	Fuel-fired equipment

CD-CJ	Equipment incinerating NCG or SOG

CK-DN	Primary and supplemental fuels

DO-DU	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 PIII 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 PIII 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. 

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 PIII 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 PIII 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 PIII 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 PIII 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 PIII 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 PIII Equip detail tab (e.g., as a
“Single emission unit with multiple release points” as described in
the instructions immediately above for the PIII Equip detail tab).

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

Air pollution control devices (APCDs).  In the APCD columns, enter
primary air pollution control devices (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 another emission unit for emissions control. 
Enter the Emission Unit IDs for each emission unit being controlled in
the Emission Unit ID column.  Use the controlling emission unit’s
Emission Unit ID  as the APCD_ID in the APCD columns.

Complete the applicable equipment-specific details requested in columns
AN through DN for each type of emission unit in the PIII 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
AM.  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 AN through
DU may also apply for selected emission unit types.

Recovery furnaces and semichemical combustion units.  Questions
pertaining to recovery furnaces have been combined for kraft, kraft with
co-located semichemical, soda, and sulfite pulps.  The
equipment-specific details will provide post-MACT recovery furnace and
semichemical combustion unit configurations.  Capacities and other
design parameters are requested for purposes of impacts analyses. 
Conversion years (e.g., year DCE converted to NDCE, or year of wet- to
dry-bottom ESP conversion) allow EPA to identify mills that might have
relatively recent cost and other information related to equipment
conversions.  The combustion unit hottest temperature is requested for
semichemical combustion units in order to characterize the different
types of semichemical combustion units.

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

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 fuel information is requested for fuel-fired equipment such as
lime kilns and thermal oxidizers.  Primary fuels are not requested for
recovery furnaces or semichemical combustion units because black liquor
(or red liquor) is assumed to be the primary fuel for these units. 
Non-condensable gases (NCG) and stripper off gases (SOG) are not
considered to be either primary or supplemental fuels for purposes of
this survey.  Supplemental and other fuel information is requested for
recovery furnaces and semichemical combustion units in addition to other
fuel-fired equipment such as lime kilns and thermal oxidizers. 
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 PIII Equip detail
tab are being sought for regulatory development purposes and will not be
used for enforcement purposes.  

b.  	PIII Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of
this document are requested.  You do not need to complete this section
if you provided the Part III emission unit permit limits in your
response to Part I (simply mark the box that appears in cell F3 of the
PIII Permit limits tab to indicate permit limits were submitted under
Part I).

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 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 PIII Permit limits tab, we
will accept a copy of your operating permit (e.g., title V operating
permit) instead of the completed PIII 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

Other processes:  lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or
specify

PM101

	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.

c.  	PIII 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.).

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).      

Thermal oxidizers.  Questions pertaining to thermal oxidizers are
included in both the Controls and PIII Equip detail tabs.  The PIII
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.  

d. 	PCC tab

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

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

D2.  	Test data

Attachment 2 of this Part III 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_PIII.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. 	PIII Emissions test data tab 

Attachment 2 of this survey contains a table of emission units and
pollutants for which existing emission test data are requested.  You are
not required to conduct any new emissions testing to respond to this
survey.  The EPA is only requesting existing emission test reports at
this time as they may already be available.   

Review the test data request table in Attachment 2 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 PIII Emissions test data tab.

Cutoff dates are provided in Attachment 2 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 2 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 PIII 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 PIII
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_PIII.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_PIII.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_PIII.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 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 1hour 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.

 

D3.  	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_PIII.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_PIII.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 III, the EPA is particularly interested in costs of the
following APCDs.  Please supply this information using the APCD costs
tab:

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

     - Black liquor oxidizer incinerators or thermal oxidizers

     - Lime kiln ESP

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

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

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

    - Changing from a wet PM return system to a dry PM return system for
your ESP

    - Adding chambers/fields to an existing ESP 

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

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

    - Replacing a recovery furnace with a black liquor gasification
system

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

  PART III - ATTACHMENT 1

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

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

Chemical Recovery Combustion Equipment

Recovery furnace

Semichemical combustion unit 

Black liquor oxidation system

Smelt or ash dissolving tank

Lime kiln or calciner  

Black liquor gasification system

Sulfur burner





PART III - ATTACHMENT 2

Part III 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 III - Attachment 2.  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	Hydrochloric acid (HCl)	Acetaldehyde,
Formaldehyde, Methanol1	Total hydrocarbon (THC) as carbon	CDD/CDF

and

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

Test 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	M26 or 26A	Methanol:  Method 308 (part 63); Methanol CEMS; or
Other applicable methods	M25 or M25A

	M23	M16 or

TRS CEMS

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

CEMS	M6

CEMS	M10

CEMS

Recovery furnaces (NDCE and DCE)

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

Not requested

	Supply data from 1990 or  more recent

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



	Black liquor oxidizer (BLO)

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





Supply data from 1990 or more recent

Not requested	Supply most recent data

Not requested

	Chemical recovery combustion units  - sulfite	Supply data from 2001 and
more recent following subpart MM MACT compliance	Supply data from 1990
or more recent	Supply most recent data

Not requested	Supply data from 1990 or  more recent



Not requested	Supply most recent data



Chemical recovery combustion units  - stand alone semichemical	Supply
data from 1990 or more recent

Supply most recent data

Not requested	Supply data from 1990 or more recent



Not requested	Supply most recent data



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

Not requested

Supply data from 1990 or more recent

	Supply most recent data	Not requested



Lime kilns/fluidized bed calciners

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

Not requested

Supply data from 1990 or more recent

	Supply most recent data



	Black liquor gasification systems	Supply most recent data

	Not requested	Supply most recent data







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

	OMB Control No. ____-____

	Approval Expires __/__/__

Part III						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), percent solids,
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
technological 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 technological review of the NESHAP and NSPS standards considers
emission unit and control equipment details specific to the processes
employed and matches these details to emissions levels that are achieved
(e.g., emission concentrations).  Applicability of the NESHAP and NSPS
compliance options depends on the specific process equipment. 

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

It is very helpful for EPA’s data analysis purposes if data are
entered into the P&P CEMS_PIII.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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