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

March 19, 2012

MEMORANDUM

SUBJECT: Meeting notes for the March 16

, 2012 meeting with AF&PA

FROM: John Bradfield

TO: Docket EPA

- HQ

- OAR

- 2007

- 0544

This memorandum summarizes the meeting between The American Forest and Paper Association (AF&PA) and the EPA on March 16

, 2012. This meeting was requested in response
to the R isk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the pulp and paper industry.

Meeting Attendees:

John Bradfield , EPA Paul Noe, AF&PA
John Pinkerton, NCASI Jeff Shumaker, International Paper Mike Curtis, Georgia

- Pacific Corey Brandt, Rock

- Tenn, Inc. Robin Dunkins, EPA Bill Schrock, EPA Rich Garber, Boise Inc. (via phone) Tom Holloway, RTI Katie Hanks, RTI Corey Gooden, RTI Timothy Hunt, AF&PA Jim Taylor, MWV Vipin Varma, NCASI Scott Jordan, EPA (via phone)
Jim Hirtz , EPA (via phone) Kelly Rimer, EPA Rob Kaufmann, KCPS Brittany Robinson, URS
Dave Heinhold

, AECOM (via phone)

Discussion Points :

• Discussions followed the attached agenda (Attachment 1) and slides (Attachment 2)

• Further Questions. If EPA has additional technical clarifications, tentative plans were made for a follow up meeting on March 28 th

.2 Attachment 1

Pulp and Paper RTR Meetin g with EPA & AF&PA

March 16, 2012; 1 to 4 PM

Classroom C114 at EPA Offices

RTP, NC

Agenda

• Introductions

• Risk Assessment

o Risk assessment methods

o Updates provided by companies

• Discuss Condensate Treatment Standard (94% efficiency)

o Review ICR data and analysis from comments

o Review cost and cost effectiveness analysis

• Wrap

- up/Next steps3 Attachment 2

# Pulp & Paper Residual Risk and Technology Review Proposal

Industry Meeting with OAQPS

Research Triangle Park, NC



## March 16, 2012

# Agenda

Risk Assessment

Condensate Control Efficiency

Cost analyses



## Excess Emission Allowances

Start

- up & Shutdown

Other issues

– if time

Next Steps/Wrap

- up

2

# Risk Assessment

# Risk Assessment Conclusions

AF&PA agrees with EPA’s conclusion that “ample margin of safety” exists

Reflects 3 years worth of work updating NEI data



### MACT clearly worked!

Conservative assumptions inappropriate

Must use “actuals”

– not allowables

Total facility risk can’t be considered

– only source category



### EJ consideration not allowed



### Acrolein

– hard to measure, reactive and short lived

National emission inventory (NEI) comprehensive

4

# Risk Assessment: Conservative

EPA using outdated science

Formaldehyde : CIIT study; biologically based
Acrolein: Hamner study and CA REL (lower risk by order of magnitude) 

## Corrections to NEI provided by companies

66 of 171 mills provided including 20 of top 25
Vast majority will lessen risk

Hexachloroethane over

- estimated 

## Rerun HEM risk analysis?

Will not change the conclusion of acceptable risk
May be prudent given mill effort and focus on risk

5

# Condensate Collection and Treatment

1. 

### There are multiple sources of variability in Condensate Collection and Treatment

2. 

### ICR data does not indicate over

- performance in complying with MACT I Phase 1

3. 

### Proposed change in treatment efficiency from 92%
to 94% is unsupported by performance data and is more than a marginal improvement

## Demonstrating Compliance with Condensate 

## Collection and Treatment

– The Three Components

Condensate Collection

Data variability



### Over

- collection and Averaging Times to achieve 99%+ Compliance Probability


## Treatment Efficiency

Performance variability

Technical Limitations of achieving the proposed increase from 92% to 94%



## Condensate Treatment

Flexible compliance options (lb/ODTP or percent removal)

7

### Three components to demonstrating ongoing compliance

Ongoing compliance

High (99%+) compliance probability essential to avoid exceedances

Need to consider the following

Variability in collection (1) Treatment system performance variability (2)
C umulative effect of variability in (1) and (2) on Condensate Treatment (3) 

# Condensate Collection and Treatment

8 1. Condensate HAP/Methanol Collection 2. Percent Removal 3. Condensate HAP/Methanol
Treatment

Bleached

– 11.1 lb/ODTP

Unbleached

– 7.2 lb/ODTP SS: 92% removal of Methanol

Bio: (a) F bio, Adj = 92% || F bio, methanol ~ 94%
OR (b) Measure prevailing F bio, Adj Bleached

– 10.2 lb/ODTP

Unbleached

– 6.6 lb/ODTP

OR (1) X F bio, Adj ≥ (3)

# Condensate Collection 

# Variability

There is significant Variability in Condensate Methanol Collected on a daily basis

Four variables in statistical treatment of collection data

1. 

### Level of over

- collection (above 11.1 and 7.2 lb/ODTP requirement)

2. 

### Relative Standard Deviation (RSD) of site

- specific collection data

3. 

### Compliance probability

4. 

### Averaging time



### NCASI statistical methodology illustrates impact of variability for a facility collecting 10% additional methanol in condensates and targeting a 95% compliance probability

Required a veraging time = (0.181 x RSD) 2



### Analysis can be extended to include other over

- collection OR compliance probability scenarios

9

## Basis: A 15

- day averaging period



## Key Takeaways

Facility with 25 to 35% RSD in condensate methanol collection needs between 18 and 27% over

- collection to demonstrate ongoing compliance

Collection levels above 11.1 and 7.2 lb/ODTP primarily serve to increase compliance probability

Should not be interpreted as performance at levels exceeding the current standard 

# Condensate Collection 

# Variability

% Compliance Probability

RSD 95% 96% 97% 98% 99%

20 9 10 11 12 14

25 12 13 14 15 18

30 15 16 17 19 22

35 17 19 20 23 27



### 10

## These 4 mills have a 15

- day averaging period

25 to 35% RSD in site

- specific condensate methanol collection data typically observed at bleached and unbleached mills

While daily collection levels could be above 11.1 and 7.2 lb/ODTP, variability can work against ability to demonstrate ongoing compliance

Averaging period and over

- collection improves compliance probabilities 

# Condensate Collection 

# Variability Data from 4 mills

11 Condensate Collection Characteristics

Source Avg. Daily Collection, lb/ODTP Standard Deviation (SD) RSD

Mill A ( Bleached) 12.7 3.2 25.1

Mill B (Unbleached) 9.5 3.1 32.5

Mill C ( Bleached) 15.1 3.4 22.4

Mill D (Bleached) 17.7 4.4 25.0

# Biotreatment System 

# Variability

– from ICR Data

12

# Biotreatment System 

# Variability

Biotreatment Systems

Average annual “intra

- facility” variability in F bio,methanol 

### for ASBs reflected in ICR data was 5%

Average F bio,methanol 

### of 94% could therefore be accompanied by swings between 91% and 96%

High rate systems like UNOX also exhibit operational variability



### NEI 13363

– Performance varied between 91.6% and 98.3 %



### Key Takeaways

Numerical performance > 92% not indicative of “ease of compliance” OR ability to achieve higher levels of treatment

Operational variability is inherent and unavoidable

13

# Condensate Treatment

– 

# Behind the numbers

Variabilities associated with (1) and (2) are compounded while calculating and demonstrating lb/ODTP treatment

Flexibility to use either lb/ODTP or percent removal incorporated into original rule to

Ensure compliance during unanticipated process upsets or operational variability that result in treatment devices performing below the 92 % control level

Ensure ongoing compliance using over

- collection and the ability to use the lb/ODTP option 

### Prevailing higher levels of collection and treatment indicates compliance margins and is driven by the need to increase compliance probability

Increasing the treatment requirement would dramatically reduce this compliance probability

14

## ICR Data and MACT I Phase 1 Compliance

– 

## Other Considerations

ICR Data

– Behind the Numbers

For CCA Mills, condensate treatment data reflect both Phase 1 and 

### CCA compliance

High Rate Biotreatment Systems cannot be grouped with ASBs

IPT data from Steam Strippers reflect best performance scenarios

Mills reporting Percent Removal Data in Biotreatment Systems

ICR data from limited number of mills does not support

over

- performance towards MACT I Phase 1 Mills reporting lb/ODTP treatment



### ICR data from limited number of mills does not support

over

- performance towards MACT I Phase 1

15

## Compliance Approaches used by CCA Mills

Facilities with cleaner condensates on Brownstock Washer showers either

Over

- collect condensates for treatment in Steam Strippers OR

Route additional condensates to the ASB for treatment



### Emission reductions are

Incremental reductions achieved from a “baseline” that reflects MACT I Phase 1 compliance

From the use of cleaner condensates on HVLC sources

Due to improved treatment in wastewater treatment systems realized through voluntary upgrades


### For CCA mills, collection and treatment levels reported in the 2011 ICR reflect ongoing compliance with MACT I Phase 1 and CCA

16

# CCA strategies as grouped by EPA in their 

# October 21, 2011 memo

17 CCA Technology Number of Units Affected Upgrade Assumptions

Steam Stripper, Biological Treatment, & Collect Additional Condensates 21 • These mills collect additional condensates and send to the steam stripper or biological treatment systems for treatment

Clean Shower Water, Clean Condensates, & Substitution 7 • These mills collect additional condensates and send to the steam stripper or biological treatment systems for treatment

Wastewater Treatment System Upgrades Only 6 • Assumed these facilities would need the upgrades to achieve the 94% treatment efficiency and could not use credits for CCA.

Other Alternatives 4 • Assumed these facilities could still utilize the CCA option as we do not have information for these
sites.

## Compliance Approaches used by CCA Mills using over



## collection and additional treatment

Over

- collect and over

- treat condensates in Steam Strippers to clean up HVLC source condensates for emission reductions

Eight unbleached mills

Three bleached mills



### WWTP area emission reductions

Eleven mills

– over

- collection and additional treatment in ASB through voluntary upgrades | sewer diversion credits

Three mills

- no over

- collection but voluntary upgrades that result in additional treatment | sewer diversion credits

Three mills

– additional treatment not significant



### Six mills confirmed as adopting other “equivalency” projects



### Four mills

– more detailed info being sought (non

- member companies)

18

### 19 HVLC
Sources Contaminated
Condensate

Clean
Condensate HVLC CCA

HVLC B ase



## F bio
MACT 1 Phase 1 Wastewater (WW1) Baseline Emissions = (WW1 + P1) x (1

– F bio )

Phase 1 Condensates (P1)

Phase 1 Compliance: P1 ≥ 11.1 and (P1 x F bio ) ≥ 10.2

Additional Condensates in Hard Pipe (P2) Additional

Treatment Higher F bio Wastewater (WW CCA )

Phase 1 Condensates (P1) CCA Emissions = (WW CCA + P1 + P2) x (1

– F bio, CCA )

= baseline = CCA

Facility hardpiping additional condensates and operating biotreatment system at Higher F bio in order to use the CCA option

Higher Fbio achieved through voluntary treatment system upgrades 

## Example Bleached Mill with CCA



## – Compliance ApproachHVLC Source emissions = 1.4 lb/ODTP

Wastewater Treatment system loadings

Baseline: WW 1 = 10 lb/ODTP; P1 = 12.2 lb/ODTP

CCA: WW CCA = 7 lb/ODTP; P1 = 12.2 lb/ODTP; P2 = 3 lb/ODTP

MACT I Phase 1 Fbio = 92 % (baseline)

Fbio , CCA = 95%



### 20 Baseline HAP, lb/ton CCA Emissions, lb/ton

HVLC Sources 1.40 0.50

Wastewater Treatment System (10 + 12.2) x 0.08 =

1.78 (7 + 12.2 + 3) x 0.05 =

1.11

Total 3.18 1.66

Required Control from HVLC Sources = 0.98 x 1.4 = 1.37

Emission Reductions from CCA = 3.18

– 1.66 = 1.52 || 1.52 > 1.37 

## Example Bleached Mill with CCA



## – Compliance Calculations

### PHASE 1

Demonstrate that P1 is ≥ 11.1 lb/ODTP

Over

- collection is sometimes built into the permit language as a requirement for Phase 1

Demonstrate that P1 x MACT I Phase 1 Fbio (baseline) ≥ 10.2 lb/ODTP



### PHASE 2 through CCA

Demonstrate that (P1+P2) is ≥ (11.1+3) = 14.1 lb/ODTP

O ver

- collection and averaging times also needed here to increase compliance probability

Measure Fbio, CCA

Demonstrate that Emission Reductions at Fbio, CCA ≥ (0.98 x 1.4) lb/ODTP



### 21 

## Example Bleached Mill with CCA



## – Compliance Elements

## Example Bleached Mill with CCA



## – Biotreatment Performance is a Requirement under CCA

Takeaways

Higher F bio 

### under CCA required for Phase 2 compliance

For CCA mills, the ICR data on biotreatment performance reflects the Higher F bio


### The calculated lb/ODTP treated also cannot be compared 

### against Phase 1 requirements

Performance data from CCA mills therefore cannot be compared against Phase 1 requirements

22

## Biotreatment Systems

– High Rate Systems cannot 

## be grouped with ASBs

High rate systems like AST and UNOX operate at higher treatment efficiencies than Aerated Stabilization Basins 

## (ASB )

Percent removal data from high rate systems cannot be grouped with those of ASBs

The “combined average” would be biased high

Would erroneously conclude that ASBs are performing at levels significantly above the current standard

Replacing ASB with AST or UNOX would be cost

- prohibitive

23

## Steam Strippers

– Does the data reflect sustained 

## performance above the requirements of the standard?

ICR data on percent removal reflect equipment performance during Initial Performance Tests ( IPT)


## Snapshot of performance immediately following commissioning or scheduled maintenance

Reflects built

- in design factors in equipment design

Essential to ensure ongoing compliance at the level of the current standard (i.e., 92 %)
Compensates for gradual degradation of performance over normal maintenance cycles due to fouling or scaling
Compensates for operational variability in steam supply and condensate flows 

## IPT data provided in the ICR does not reflect ability to

over

- control on a sustainable basis

24

## ICR Data

– Mills Reporting Percent Removal Data 

## from Biotreatment Systems (Table 1)

Fbio,adj = 92% is equivalent to Fbio,methanol = 94%

Impact of r

- factor approach to establish treatment 

### equivalency for non

- methanol HAPs


## Only limited number of mills with data reflecting MACT I Phase 1 compliance

ICR data from mills reporting percent removals average F bio,methanol 

### of 95.7%

Considering F bio 

### variability, this data is within compliance margins associated with MACT 1 Phase 1 requirements

Does not reflect over performance

Inappropriate to be used as basis for new percent removal limits

25

## ICR Data

– Mills Reporting lb/ODTP Treatment 

## (Tables 2 and 3)

For CCA Mills, lb/ODTP treated reflects both Phase 1 and Phase 2 compliance

Inappropriate to attribute this as over

- performance towards MACT I Phase 1



## Data from only 3 or 4 facilities are reflective of true 

## MACT I Phase 1 compliance

Some facilities have unique operational scenarios

Data from such a limited number of mills should not be the basis for revising numerical condensate treatment standards

26

# Proposed Increase in Treatment Efficiency

from 92% to 94%

1. 

### Historical compliance data does not support sustained over

- performance

2. 

### The proposed increase is more than a marginal improvement and presents achievability and 

### compliance issues

## Historical Compliance Data does not reflect


## sustained over

- performance

Only a limited number of mills with performance data reflective of MACT I Phase 1 compliance

Cannot be the basis for concluding over

- performance and revising standards


### Higher levels of collection and treatment are for compliance margins and driven by the need to maximize compliance probability

Not indicative of over

- performance

Increasing the treatment requirement would dramatically reduce this compliance probability


### Current treatment device performance needed to ensure compliance at the current 92% standard

Design factors are integral in Steam strippers

Actual Fbio, methanol in ASBs already at 94%

- when considering operational variability, current data is not indicative of over

- performance



### 28

## Biotreatment Systems

– 92% to 94% is more than a 

## marginal improvement

Proposed increase in biotreatment efficiency (F bio,adj 

## ) from 92% to 94% would mean

An increase in actual F bio, methanol 

### to 96%

Facilities would need major treatment system upgrades to achieve sustainable and ongoing treatment of 96%

Upgrades would be prohibitively expensive in many cases



### Given 

## F bio 

## variability, sustained operation at 96% would be infeasible

Would result in additional compliance demonstration issues

29

## Steam Strippers

– 92% to 94% is more than a 

## marginal improvement

The need to preserve compliance margins and compensate for fouling etc. would mean upgrades 

## and (in some cases) rebuilds

M ore energy, trays, and steam contact area

All units operating @ < 96 % expected to need upgrades

30

# Cost Estimates for Proposed Increased

Treatment Standards

# Facility Treatment Options & 

# Upgrade Assumptions

32 Treatment Option Number of Units Upgrade Assumptions

Stripper Only 43 • Mills under 96% treatment efficiency will need to upgrade their units.

• All mills will need to increase O&M Cost
Biological Treatment Only 39 • All mills will need to increase aeration and have nutrient addition
Biological
Treatment & Stripping 9 • 1/2 the mills that have treatment efficiency under 96% will need to upgrade their units (assume upgrade is to the stripper). All strippers will need to increase O&M costs.
Recycle 5 • Assume no upgrades required

Thermal Oxidizer 1 • Assume no upgrades required

TOTAL 97 • Assume that 91 mills are affected (less recycle & thermal oxidizer)

NOTE: Assumed that mills can still utilize the CCA option, but will need to upgrade their control systems and redemonstrate compliance with CCA via an IPT.

## Cost Estimate to treat to 94% : Assumptions 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)

Stripper Assumptions

More energy , trays, and steam contact area



### N eed compliance margin

– units with < 96%

20% are integrated with evaporators

Assume 10% downtime remains

- no backup


## Wastewater Treatment System Assumptions

I ncrease in aeration and nutrient addition would be sufficient

Added nutrients may impact water quality standards

All systems impacted

33

## Cost Estimate to treat to 94% : Strippers 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)

EPA Estimate

8 stripper upgrades

$2.7 M/each 

## AF&PA Estimate

27 strippers (96% and 

## below)

23 Strippers (only treatment device)

4 Strippers for facilities with dual treatment (1/2 of these units)



## $2.9 M/each for non



## integrated units

$5.8 M/each for integrated units

34

## Cost Estimate to treat to 94% : Biological Treatment 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)



# EPA Estimate

7 systems (at or below 94%)

Capital costs range 

## from $1

– 4 M/each 

# AF&PA Estimate

39 systems (all with biological treatment)

Capital cost of 

## $6M/each

35

## Cost Estimate to treat to 94% : O&M Costs 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)

Strippers

Increased energy : 12 MMBtu/hr x 8390 hr/yr x $3/MMBtu

I ncreased maintenance to maintain efficiency: one additional outage per year at $100K


## Biological Treatment Systems

– all affected

Increased energy: $2.3 M/year/facility
Maintenance costs for aerators: $220K/year/facility



### C ost for chemicals only (nutrient): $60K/year/facility

36

## Cost Estimate to treat to 94% : Biological Treatment 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)

37 

### Cost Range 

### ($M) Average Cost



### ($M)
Aeration Installation Costs (Capital) $1.5

– $12.5 $6

Annual Power Cost Increase $0.6

– $5 $2.3

Annual Maintenance Cost Increase $0.06

- $0.5 $0.22

# Cost Estimate to treat to 94% 

# (AF&PA Methodology: 10.4/6.8 lb/ODTP)

38



### Number 

### of Units Affected Capital



### Costs ($M) Annual



### Energy Costs ($M) Annual



### O&M Costs ($M)
Stripper Upgrade 27 $94 $8 $3

Current Strippers 25

-- $8 $3

Aeration 39 $230 $90 $9

Nutrient Addition 39

-- -- $2

TOTAL

-- $324 $106 $17

## Cost Estimate to treat to 94% : Comparison 

## (AF&PA Methodology: 10.4/6.8 lb/ODTP)

39 

## EPA Estimate AF&PA

Estimate



## Number of Facilities Affected 15 91

Capital Cost ($M) $36 $324

Annualized Capital Cost ($M) $4.1 $30.4

Annual O&M Costs ($M) $0.15 $123

Annualized Cost ($M) $4.25 154

Cost /Ton (Using 4092 tons/yr) $1,000 $38,000

# Excess Emission Allowances

# Excess Emission Allowances

Necessary due to Inherent Process Variability, 

## Design, and Technology Reasons

– Not SSM

Generally not due to equipment breakdown/repair

P rocess variability and safety interlocks cause release



## Part of the “MACT Floor”

- best performing units could not meet the standards at all times
Technology and operations have not changed to allow for safe operations without these provisions

41

## Excess Emission Allowances: 

## LVHC & HVLC Systems

Gases are potentially explosive and cannot be burned 

## safely without supplemental fuel

Flame safety system will not permit the gases to be admitted until the burner is operating on supplemental fuel and ignition is proven (criteria for safe operation, known as “permissives,” must be met) Generally 9

– 15 interlocks Safety interlocks are required by both Factory Mutual Insurance and the National Fire Protection Association for burning of these non

- condensable gases. When these gases are burned in a recovery furnace, there are safety guidelines issued by the Black Liquor Recovery Advisory Committee.

42

## Excess Emission Provisions: 

## LVHC & HVLC Systems

Example Events

Loss of Flame or Burner Permissive

Typically short in duration and quickly resolved

Example: Temporarily loss of permissive due to cleaning oil gun(s)



### Process Variation

Variation causes a “domino effect” in the mill

Example: Paper Machine Trip causes a swing in steam header pressure and vent at digester system



### Loss of Permissive and Back

- up Control Device Not Readily Available (LVHC systems)

Backup control device undergoing maintenance or not a “hot” backup 

### Note: Emergency Shutdowns can actually result in increased emissions rather than allowing the permissive to resolve

43

## Excess Emission Allowance: Emission Estimates 

## LVHC & HVLC Systems

Not possible to quantify emissions on a site

- or event

- specific basis

Not aware of any successful measurements of releases from vents during these circumstances

Limited data available from collection systems prior to control devices during normal operations 

### Emissions will vary based on the cause, location, and source

Vary between facilities and within facility at similar source

Vary based on the circumstances of the release 

### Sampling these events is not feasible

Events cannot be anticipated

Generally short duration so difficult to respond to sample

Generally unsafe to sample these events

Some vents are not accessible



### 44

## Excess Emission Allowances: Vent

- less Transfer 

## LVHC & HVLC Systems

Some units cannot be designed for vent

- less transfer Systems with recovery furnaces 

## Systems that have different types of boilers as the Primary and Back

- up Control Devices (i.e., one boiler is under positive pressure and the other boiler is under negative pressure) 

## Systems such as oxidizers that were installed as Back

- up Control Only ( these units are typically not maintained in a “hot” state)

45

# Excess Emission Allowances: 

# Steam Strippers

Almost all facilities do not have backup strippers

Downtime needed for 

## Stripper tray damage or plugging Efficiency losses in the stripper due to contamination of condensate with fiber or black liquor Steam supply downtime

Combustion control device downtime Stripper maintenance

46

# Excess Emission Allowances: 

# HVLC/LVHC Cost Estimate Assumptions

HVLC Control Devices

Assume all facilities have one control device and elimination of excess emission allowance will require routing gases to a back



### up control device. Assumes that the facility has an available back

- up option This is not the cost in previous estimates for CCA mills to install the piping for collection and treatment of HVLC gases to a single control device. 

## LVHC Control Devices
All systems have a primary and backup control device

– no routing to an additional control device necessary 

## LVHC/HVLC Collection Systems
Systems collect gases from equipment in the pulping process 

### areas. Assume a backup collection system (piping) will be necessary to collect any “vents” from equipment

47

# Excess Emission Allowances: 

# Stripper Cost Estimate Assumptions

Back

- up Stripper will be required to accommodate stripper downtime due to maintenance

Without back

- up systems, mills will need to shutdown the pulping 

### process equipment during stripper downtime Based on the proposed regulations, EPA wants to require higher treatment standards which will require additional maintenance on control systems and increased downtime 

## Installation of a Collection Tank for Long

- Term Storage is Not 

## a Solution

Tanks are suitable for short

- term downtime periods (trips, etc.)

– not maintenance outages Volume generated by strippers is such that long

- term storage is not realistic Systems are maxed out on volume (flow) 

### Storage of condensates during long

- term downtime events would require an increase in flow (throughput) to compensate for the condensates being generated and treatment of stored condensates

48

# Excess Emission Allowances: 

# Capital Cost Estimates

• Assumes all 97 Mills subject to the collection requirements will need to install ductwork to route HVLC to a backup control device (and a backup control device is available) and ductwork for redundant LVHC/HVLC collection systems.

• Assumes all 52 mills with strippers will need to install a backup stripper.

NOTE: Even with these systems, facilities cannot guarantee 100% compliance due to process variability and safety considerations.



### 49 

### AF&PA Estimate ($M)

HVLC Redundant Control Costs $500
Redundant LVHC/HVLC Collection Systems $700
Backup Strippers $400

TOTAL $1,600

# Targeted Excess Emissions and SSM 

# Survey is being Planned

Survey will attempt to provide more details on the following

Circumstances for excess emissions

Whether they qualify as SSM events AND if not, why not

General categorization of excess emissions events (and causes)

Differentiating between excess emissions events and SSM events



### Frequency and duration of occurrences to reflect an overall industry snapshot (would be difficult to estimate or quantify emissions, given the challenges described earlier)

Compilation of prevalent monitoring procedures and work practices


## Lastly, why excess emission periods are needed for technology or operational reasons AND how all events cannot be avoided (e.g., permissive and interlock events)

50

# Startup & Shutdown

# Startup & Shutdown

EPA assumed operations (and emissions) are not different during startup & shutdown vs. normal operation

Nothing in the record to support
No known data available for emissions during SS events
Regulations prohibit using data for compliance purposes collected during SS events

52

# Startup & Shutdown

Examples where emissions could be different:

Control device may be less efficient:



### Until it reaches operating temperature

W hen the pollutant concentrations are lower than during steady

- state operation
Until a process reaches steady

- state operation, that process may generate substantially higher emissions, either on a total mass basis or on a mass per unit of production basis
Venting of LVHC/HVLC systems due to system “permissives” not being met 

## Legal issues covered in comments

53

# Other Topics of Concern

# Other Topics of Concern

Concentration limit for Bleached Mills should be 258 ppmv

Proposed rule states 210 ppmv which is inconsistent with the docket 

## Electronic Reporting is unreasonable

Subpart S Performance Tests are unlike Stack Tests 

## Compliance Deadline should be 3 years for all changes to the rules

Including electronic reporting and affirmative defense 

## EPA’s proposed requirement that the Administrator specify test conditions is unreasonable

Test under normal conditions

55

# Cost Estimates IF Over

- collection with

Pound per Ton Option

## Cost Estimate to treat to 94%: Assumptions 

## ( EPA Methodology : 12.8/8.3 lb/ODTP)



# Assumptions

The lb/ODTP treatment option not viable

The Clean Condensate Alternative not viable

Need to treat additional condensates will negate current compliance demonstrations
Install collection system at $15M/facility

Assumes that 4% HVLC allowance remains in 

## place

57

## Cost Estimate to treat to 94% 

## ( EPA Methodology : 12.8/8.3 lb/ODTP)

58



### Number of Units Affected Capital

Costs ($M) Annual

Energy Costs ($M) Annual

O&M Costs 

### ($M)
Stripper Upgrade 27 $94 $8 $3

Current Strippers 25

-- $8 $3

Aeration 39 $230 $90 $9

Nutrient Addition 39

-- -- $2

HVLC to Single
Treatment Device 34 $510

-- --

TOTAL

-- $834 $106 $17

## Cost Estimate to treat to 94% : Comparison 

## (AF&PA vs. EPA Methodology)

59 

## EPA Estimate AF&PA

Estimate

Number of Facilities Affected 15 91

Capital Cost ($M) $36 $834

Annualized Capital Cost ($M) $4.1 $48 + 30 = 78

Annual O&M Costs ($M) $0.15 $123

Annualized Cost ($M) $4.25 $202

# Supplemental Information

# Supplemental Materials

Equivalency Calculation

– Steps and Alternative 

## Approaches

Additional Details Pertaining to the CCA Option

61

# Equivalency Calculation used by EPA

Percent Standard Improvement when treatment is increased from 92% to 94%

2% of the maximum possible 8% in improvement is achieved: OR 2/8 = 25%

i.e., 25% of the remaining possible treatment is achieved

Percent Standard Improvement for each 1% increase in treatment efficiency (from 93% to 98%) is calculated

At 93%

- 1% of max possible 8% = 1/8 = 12.5%

At 94%

- 2% of max possible 8%: 2/8 = 25%

At 95%

- 3/8 = 37.5%

92% 100% % Treatment Scale

98% 94% 96% Max Improvement Possible = 8% Improve to 94% = 2% 8%

2%



### 62

# Equivalency Calculation used by EPA

Percentage Standard Improvements are directly applied as FACTORS to scale up the lb/ODTP treatment limit from the current as follows:

This approach of converting to the lb/ODTP scale is inconsistent with the logic behind the equivalency calculation 

### Resulting lb/ODTP standards greater than current collection levels

63

### Directly compute new limits from Current Collection numbers

7.2 lb/ODTP x 0.94 = 6.8 lb/ODTP for unbleached mills

11.1 lb/ODTP x 0.94 = 10.4 lb/ODTP for bleached mills 

# Recalculating numerical standards

92% 100% % Treatment Scale 98%

6.6 7.2 lb/ODTP (Unbleached)

10.2 11.1 lb/ODTP (Bleached) 94% 96%

New limits at 94% Eff. 6.8 lb/ODTP 10.4 lb/ODTP Current
Collection Current
Treatment



### 64

## Applying the percent standard improvement to 

## recalculate numerical standards

The percent standard improvement metric can also be used to recalculate numerical standards as follows

At 100%

- Collection levels are 7.2 lb/ODTP and 11.1 lb/ODTP (unbleached and bleached respectively)

At 92%

- Treatment levels are 6.6 lb/ODTP and 10.2 lb/ODTP

For instance, 25% of the remaining possible treatment is achieved by changing the standard from 92% to 94%

6.6 + 25% of (7.2

– 6.6) = 6.8 lb/ODTP

- unbleached mills
10.2 + 25% of (11.1

– 10.2) = 10.4 lb/ODTP

- bleached mills

92% 100% % Treatment Scale 98%

6.6 7.2 lb/ODTP (Unbleached)

10.2 11.1 lb/ODTP (Bleached) 94% 96%

New limits at 94% Eff. 6.8 lb/ODTP 10.4 lb/ODTP Current
Collection Current
Treatment



### 65

## Impact of the current RTR Proposal on CCA compliance

94% treatment level AND/OR revised lb/ODTP standards



## Facilities over

- collecting and over

- treating condensates in Steam Strippers or ASBs would lose a portion of the resulting emission credits

Insufficient emission credits to demonstrate compliance 

### under CCA 

## Compliance option would involve the installation of HVLC collection systems

Capital costs of up to $15

– 20 million / installation

66Table 1. Mills Reporting Percent Removal Data

NEISiteID Predominant

Treatment Method Fbio, MeOH Compliance

Measure Fbio, methanol in Compliance

Demonstration UNOX / CCA / Activated Sludge Q1 Q2 Q3 Q4 CCA Comments

NEI13340 Biotreatment 94 93.0 95.4% 92.1% 91.5% 91.6%

NEI12411 Biotreatment 94 97.0

NEI13363 Biotreatment 94 98.2

NEI18652 Biotreatment 94 93.3

NEI18658 Biotreatment 94 96.4

NEI26506 Biotreatment 94 95.3 94.0% 97.0% 96.0% 94.0%

NEI26581 Biotreatment 94 99.1 O2 Delig collected | Addtl. treatment in ASB | 92% for Phase 1

NEI33103 Biotreatment 94 96.7

NEI33104 Biotreatment 94 98.3

NEI40554 Biotreatment 94 99.2

NEI40600 Biotreatment 94 98.4 Over-collection and addtl ASB treatment | Sewer Diversion credits

NEI42254 Biotreatment 94 94.7

NEI42317 Biotreatment 94 99.0

NEI6450 Biotreatment 94 94.9 No detailed info. Mill taken to be using HVLC source credits

NEI7104 Biotreatment 94 99.0

NEI8261 Biotreatment 94 98.3 Legend
Average 95.7 97.5

97.3 CCA Mills

98.3 UNOX

AST

Notes Q1, Q2, ... Quarterly ASB performance Tests 1. 92% removal includes non-methanol HAP removal. Corresponding Fbio, MeOH actually has to be ~ 94% in order to achieve Fbio, adj of 92% 2. UNOX and Activated Sludge mills are high rate systems | Not appropriate for evaluating the Phase 1 removal standard 3. At CCA mills, % removal also reflects compliance with CCA requirements | Performance cannot be compared against Phase 1 standard 4. Only 4 mills with ASBs remain on this list - This limited list should not be the basis for revising the standard

5. The remaining 4 mills have an average performance level of 95.7% (as compared to the required 94%) 6. "Intra-mill" Variability in Fbio, Methanol (in quarterly performance tests) can be as high as 4 to 5% Example variability in Fbio, MethanolTable 2. Unbleached Mills Kraft Condensate Compliance Data

NEISiteID Predominant Treatment

Method Compliance

Measure Phase 1 Compliance

Demonstration CCA Mills Phase 1 + CCA Compliance UNOX / AST /

Anaerobic Comments Q1 Q2 Q3 Q4

NEI11251 Stripping 6.6 CCA 7.3

NEI12492 Biotreatment 6.6 CCA 8.5 Addtl treatment in ASB w aerator addition

NEI18338 Biotreatment - Prorate UB/B 6.6 CCA 9.2 Over-collection and additional treatment in ASB

NEI18657 Biotreatment 6.6 8.9 Fbio of 84.6% | Relies on over-collection to demonstrate compliance

NEI26471 Stripping 6.6 CCA 19.5 All named streams to SS for treatment - clean up HVLC cond.

NEI26491 Stripping 6.6 CCA 11.0 Addtl treatment in SS to clean up HVLC showers

NEI33025 Stripping 6.6 CCA 9.8 Addtl treatment in SS to clean up HVLC showers

NEI34070 Biotreatment 6.6 7.8 Variability in Quarterly Fbios 97.6% 89.3% 89.6% 98.6%

NEI41252 Stripping 6.6 CCA 9.5 Addtl treatment in SS to clean up HVLC showers

NEI41552 Biotreatment 6.6 CCA 11.6 Over-collection of condensates | Sewer diversion credits

NEI42338 Biotreatment 6.6 CCA 11.7 Over-collection of condensates | Sewer diversion credits

NEI42357 Biotreatment 6.6 CCA 6.6

NEI42689 Biotreatment 6.6 13.7

NEI42710 Biotreatment 6.6 CCA 9.6 Hardpipe addtl 2 -3 lb/ODTP condensates to UNOX

NEI45182 Stripping 6.6 CCA 10.6 Addtl treatment in SS to clean up HVLC showers

NEI46931 Stripping 6.6 8.2 2001 Initial Performance Test

NEI47104 Stripping and biotreatment 6.6 14.9 Subset of condensates to SS (50% removal). SS outlet to Hardpipe | Unique scenario

NEI6057 Biotreatment 6.6 11.3 Fbio Variability | Overcollection to demonstrate compliance 86.4% 98.3% 94.2% 97.3%

NEI8186 Stripping 6.6 8.8 8.8 lb/ODTP is by SS | Bio is backup option

NEI8619 Stripping and biotreatment 6.6 CCA 8.8 Over-collection and additional treatment in ASB

NEI26495 Stripping and biotreatment 6.6 8.7 Utilizes BOTH options. Total = SS + Bio | Unique scenario

NEI7933 Stripping 6.6 CCA 12.0 Addtl treatment in SS to clean up HVLC showers

Average 8.2 10.5

Notes 1.Redline comments reflect unique scenarios at UB mills reporting lb/ODTP treatment numbers 2. UNOX and Activated Sludge mills are high rate systems | Not appropriate for evaluating the Phase 1 removal standard 3. At CCA mills, % removal also reflects compliance with CCA requirements | Performance cannot be compared against Phase 1 standard 4. Only 3 mills with ASBs remain on this list - This limited list should not be the basis for revising the standard 5. "Intra-mill" Variability in Fbio, Methanol (in quarterly performance tests) is highTable 3. Bleached Mills Kraft Condensate Compliance Data

NEISiteID Predominant Treatment

Method Compliance

Measure Phase 1 Compliance_

ASB Phase 1 Compliance_

SS CCA Mills Phase 1 + CCA Compliance UNOX / AST /

Anaerobic Comments Q1 Q2 Q3 Q4

NEI11338 Biotreatment 10.2 12.0

NEI12368 Stripping/Recycle 10.2 18.895 Utilizes partial recycling option

NEI18334 Biotreatment 10.2 CCA 16.3 No Additional Info

NEI18335 Biotreatment 10.2 CCA 10.7

NEI18373 Biotreatment 10.2 12.3

NEI18390 Stripping 10.2 13.7

NEI18660 Biotreatment 10.2 CCA 16.6 Addtl 5 lb/odtp over-collected in HP | Sewer divert | Addtl treatment

NEI26476 Stripping 10.2 15.9

NEI26514 Biotreatment 10.2 16.5

NEI26526 Biotreatment 10.2 CCA 14.2 Misc. source elimination | Additional treatment in ASB

NEI33883 Stripping 10.2 13.5

NEI34064 Stripping 10.2 CCA 12.9

NEI34066 Stripping 10.2 CCA 16.4 Addtl 6 lb/ODTP to SS | sewer diversion credits | cleaner showers in HVLC

NEI40282 Stripping 10.2 20.4

NEI41314 Stripping and biotreatment 10.2 15.5 2 - 3 lb/ODTP over-collection | sewer diversion | higher ASB treatment

NEI41628 Biotreatment 10.2 14.9 UNIQUE SCENARIO | 70% Fbio | All Batch Blow Heat condensates collected|Highly variable collection

NEI42410 Biotreatment 10.2 CCA 13.3 Over-collection | ASB upgrade

NEI42695 Stripping 10.2 17.1 2001 IPT data

NEI45474 Biotreatment 10.2 16.7 ALL NAMED STREAMS option | 5% variability in Fbio 92.9% 98.0% 98.9% 94.1%

NEI46599 Stripping 10.2 15.7 2007 and 2010 performance test data

NEI46739 Stripping/Recycle 10.2 11.9

NEI46760 Stripping 10.2 14.4 Redundant SS. Multiple units for separate streams

NEI46835 Stripping 10.2 11.7

NEI47074 Stripping 10.2 16.7

NEI47077 Stripping 10.2 17.4 2004 IPT

NEI47091 Biotreatment 10.2 CCA 18.1 All condensates to ASB | Voluntary ASB upgrade

NEI6261 Biotreatment 10.2 CCA 15.0 Addtl condensates in HP | Sewer diversion credits

NEI6273 Stripping/Recycle 10.2 12.4

NEI7181 Biotreatment 10.2 15.0

NEI7559 Stripping 10.2 CCA 13.5 Addtl condensates to SS | Sewer diversion and ASB upgrade credits

NEI759 Stripping 10.2 14.6

NEI8177 Stripping 10.2 CCA 20.8 No detailed Info

NEI8278 Stripping 10.2 CCA 17.8 Addtl condensates to SS | cleaner showers in HVLC

NEI8601 Biotreatment 10.2 18.1 Anaerobic _ High Rate Treatment System_All streams

NEI33887 Stripping/Recycle 10.2 18.4 Includes SS and Recycle | Verify Numbers
Average 15.5

Notes 1. UNOX and Activated Sludge mills are high rate systems | Not appropriate for evaluating the Phase 1 removal standard 2. At CCA mills, lb/ODTP treatment reflects compliance with CCA requirements | Performance cannot be compared against Phase 1 standard 3. Only THREE mills (TWO with unique, facility-specific characteristics) remain - This limited # cannot be the basis for revising the standard

4. Treatment levels at facilities using Steam Strippers are calculated using limited (1 OR 2 sets) of Performance Data | Reflects best operating scenario

IPT data from Steam Strippers reflect performance immediately following commissioning or scheduled maintenance. Numerical % removal data from these periods reflect safety factors inherent in equipment design. These design factors are essential to ensure ongoing compliance at the level of the current standard (i.e., 92%).