
                      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          SECTOR POLICIES AND PROGRAMS DIVISION
                       OFFICE OF AIR QUALITY PLANNING AND STANDARDS
                               OFFICE OF AIR AND RADIATION


October 20, 2011

MEMORANDUM

SUBJECT:	Summary of Clean Condensate Alternative Technology Review
	
FROM:	John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)
		Kelley Spence	(EPA/OAR/OAQPS/SPPD/NRG)
	
TO:		Docket EPA-HQ-OAR-2007-0544


This memorandum summarizes the technology review of the Clean Condensate Alternative (CCA) in pulp mills subject to 40 CFR 63, subpart S analyzed for the Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the pulp and paper industry. 
                                       
Background[1]:

   The clean condensate alternative (CCA) is a pollution prevention alternative emission limit for pulping vents that is available only to kraft HVLC systems (which includes washers, knitters, screens, deckers, and oxygen delignification).  The CCA allows mills to meet the HVLC emission requirements by reducing the HAP emissions elsewhere, usually process water.  This approach allows mills to control HAP emissions by reducing the amount of HAPs that are volatilized from selected process equipment instead of using combustion devices to control HVLC system vent streams. In a classic example, HAP condensates in paper machine process water are removed.  By reducing the HAP concentration in process water, the amounts of volatilized HAPs are also reduced.
   
   To achieve compliance, the facility must demonstrate that the HAP emission reductions using the CCA technology are equal to or greater than those emission reductions that would have been achieved through compliance with the HVLC system requirements. Mathematically, the mass of emissions required for control on HVLC sources creates a debit.  The sum of the debits must be offset by an equal or greater number of credits achieved by control of the selected alternative emission source. The baseline emission value against which emission credits are measured must be determined after compliance has been achieved with the kraft pulping process condensate standards, and the revised effluent limitations guidelines and standards in 40 CFR 430 subpart BB.  
   
   The CCA allows mills to take credit for emission reductions achieved in several systems through the use of CCA technologies.  The sources from which emission reductions can be debited or credited are limited to the following: pulping systems (HVLC), bleaching systems, causticizing systems, and papermaking systems.  The CCA emission reductions are generated either by control of condensates that are not regulated under the kraft pulping condensate standard or control beyond the levels required by the condensate standard. 

Developments in Practices, Processes, and Control Technologies

   The Information Collection Request (ICR)[2] requested that facilities utilizing CCA provide their baseline emissions (debits), their CCA emission reductions (credits) and a process description.  The CCA emission reduction value requested was defined as: HAP emission reductions from baseline. 

   Out of 175 survey responses from major sources, 38 facilities responded as CCA facilities. Compliance approaches ranged significantly between the facilities, but included steam strippers, clean washer showers, hard-piping, stand-alone biological treatment, whitewater temperature and HAP content monitoring, and over-collection and over-treatment of condensates, as shown in Table 1. Of the predominant compliance methods, 6 utilized steam stripping, 15 utilized wastewater treatment (1 facility utilizing dredging and 5 utilizing hard-piping), and 5 utilized cleaner water practices on paper machines.
   
   Using the survey data, EPA compared the baseline HAP reduction required by subpart S with the reductions achieved using the CCA approach.  Baseline control at the 38 CCA mills would have resulted in base emissions of approximately 31 kg HAP per ODTP (oven-dried ton pulp). The nationwide HAP emissions achieved through use of CCA at these 38 mills was approximately 16 kg HAP per ODTP. Thus, the CCA achieved a 50% reduction in HAPs on a kg HAP per ODTP basis beyond what would have been required through HVLC vent gas incineration under subpart S. Based on available production values, the CCA compliance option resulted in approximately 40% lower total emissions on a tons per year basis than compliance with subpart S utilizing HVLC vent gas incineration. 
   
   Due to the broad scope of practices, processes, and controls that were used to generate credits, our technology review did not elucidate any developments or advances in HAP control at CCA sources.
                                         
                                         
                                         
                                         
                                         
                                         
                                         
                                         
                                         
                                         
                                         
           Table 1: Summary of CCA technologies from ICR part 1 review
                                         
                                Facility NEI ID
                               Facility Location
CCA Technology
                                   NEI11172
                                Monticello, MS
Steam stripper
                                   NEI11251
                                 Valliant, OK
Clean shower water
                                   NEI13340
                                  Halsey, OR
Captured Brownstock washers and decker exit gases.  Installed low flow hoods on brownstock washers.  The decker is not required to be collected but it is a large source of methanol.  Gases sent to a methanol scrubber and then sent to the wastewater treatment
                                   NEI12492
                                  Orange, TX
Reduction of methanol stripped to air at the ASB by installing and operating additional aerators
                                   NEI18334
                                Pennington, AL
Stand-alone biological treatment unit
                                   NEI18335
                                   Selma, AL
Stand-alone biological treatment unit
                                   NEI18338
                                  Brewton, AL
Maintain a minimum of 60% control efficiency in the ASB
                                   NEI18652
                               Arkansas City, AR
Collection and hard-piping of additional pulping process condensates from the evaporator and pre-evaporator areas of the mill
                                   NEI18658
                                Pine Bluff, AR
Closed collection system, hard-piping to WWT and discharged below liquid surface for biological treatment
                                   NEI18660
                                  Ashdown, AR
Hard-piping additional methanol to ASB treatment system
                                   NEI26309
                                Cantonment, FL
Install 2 primary clarifiers
                                   NEI26471
                                   Macon, GA
Maintain paper machine white water temperature to equal to or less than 185 degrees F to ensure volatilization of methanol is minimized.
                                   NEI26491
                               Cedar Springs, GA
Installation of foam tank fog nozzles and barometric condenser to minimize methanol losses
                                   NEI26526
                                  Jessup, GA
Rerouted hard-piped Subpart S regulated condensates to subsurface injection in the Mill's No. 1 Aeration Stabilization Basin and installed additional curtains, aerators, and mixers to further segment the basin's treatment stages and increase overall methanol
                                   NEI26581
                                 Lewiston, ID
Stand-alone biological treatment unit
                                   NEI33023
                                   Hodge, LA
Collection and treatment of flash evaporator condensates with addition to turpentine decanter underflow before routing the stropped condensates to the pulp washing system
                                   NEI33025
                                  Campti, LA
Clean water - shower water flow monitoring, periodic sampling and testing for methanol concentration.
                                   NEI34064
                                 Columbus, MS
Clean condensate to recaust
                                   NEI34066
                                New Augusta, MS
Stand-alone biological treatment unit
                                   NEI40247
                                Riegelwood, NC
Close recovery boiler and transfer weak black liquor from lagoon to storage tank
                                   NEI40600
                                  Toledo, OR
Offset HVLC emissions through over-collection and over-treatment of foul condensate.
                                   NEI41252
                             North Charleston, SC
Steam stripper
                                   NEI41552
                                  Counce, TN
Use fresh water only on last stage of each brown stock washer, maintain paper machine white water MeOH concentration of 15 mg/L or less (28-day average), and collect pulp mill condensates totaling 7.2 ln/ODTP MeOH and treating to remove at least 6
                                   NEI42317
                                 Hopewell, VA
Traded use of digester condensate for wash water on brown stock washers with freshwater and digester condensate is collected and hard-piped to POTW UNOX basin and treated to 92 % control efficiency
                                   NEI42338
                                 Longview, WA
Additional collection of ~1,500 additional pounds per day (1.0 lb/ODTP), total of >8.2 lb/ODTP of HAPS on 30 day rolling average as measured at hard pipe outlet; destroy additional 1.0 lb/ODTP (>7.6 lb/ODTP)at WW outlet
                                   NEI42357
                               Port Townsend, WA
Upgrade ASB
                                   NEI42410
                                  Wallula, WA
Stand-alone biological treatment unit
                                   NEI42710
                                 Kaukauna, WI
Increase condensate treatment
                                   NEI45182
                                Springfield, OR
Lock out NCG scrubber underflow from causticizer and condensate from dissolving tank scrubber
                                   NEI47091
                                   Perry, FL
Stand-alone biological treatment unit
                                    NEI6261
                                    Jay, ME
Over collection of foul condensate through the hard-pipe which bypasses the primary clarifier (reduces emissions from the primary clarifier).
                                    NEI7559
                                 Deridder, LA
Steam stripper
                                    NEI8177
                                 Riceboro, GA
Steam stripper
                                    NEI8261
                             Fernandina Beach, FL
Replacing the wastewater treatment (WWT) cooling tower with non-contact heat exchangers, thereby eliminating HAP emissions from HVLC
                                    NEI8278
                                Panama City, FL
Steam stripper
                                    NEI8619
                                 Pine Hill, AL
Mill water, clean condensates of Kraft Multi-Effect Evaporator (4th Effect), and stripped condensates are used in pulp washers to reduced methanol carryover to Paper Machine No. 1.
                                    NEI9201
                                 Plymouth, NC
ASB dredging
                                    NEI7933
                                 Florence, SC
New steam stripper
                                         
                                         
   
   
   
   

References:

1. Pulp and Paper NESHAP: A Plain English Description. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.  EPA-456/R-98-008. November 1998.

2. Pulp and Paper ICR
