1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY PLANNING AND STANDARDS

OFFICE 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 Risk 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 28th.
2

Attachment 1

Pulp and Paper RTR Meeting 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 steps
3

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)

Cumulative 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) Fbio, Adj = 92% || Fbio, methanol ~ 94%

OR (b) Measure prevailing Fbio, Adj

Bleached – 10.2 lb/ODTP

Unbleached – 6.6 lb/ODTP

OR (1) X Fbio, 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 averaging 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

Site ID Average Max-Min

NEI11338 0.860 0.890 0.950 0.57 0.900 9%

NEI12492 0.932 0.939 0.924 0.932 1%

NEI13340 0.954 0.921 0.915 0.916 0.927 4%

NEI18334 0.974 0.975 0.987 0.979 0.979 1%

NEI18335 0.964 0.910 0.936 0.951 0.940 5%

NEI18338 0.985 0.978 0.917 0.933 0.953 7%

NEI18652 0.975 0.976 0.963 0.944 0.965 3%

NEI18658 0.996 0.997 0.991 0.998 0.995 1%

NEI18660 0.860 0.970 0.910 0.890 0.908 11%

NEI26506 0.940 0.970 0.960 0.940 0.953 3%

NEI26514 0.999 0.999 0.999 0.998 0.999 0%

NEI26526 0.970 0.970 0.970 0.970 0.970 0%

NEI26581 0.994 0.992 0.995 0.990 0.993 1%

NEI34070 0.977 0.893 0.897 0.987 0.938 9%

NEI40600 0.996 0.997 0.993 0.996 0.995 0%

NEI41314 0.970 0.990 1.000 1.000 0.990 3%

NEI41552 0.950 0.950 0.930 0.920 0.938 3%

NEI41628 0.704 0.690 0.740 0.750 0.721 6%

NEI42357 0.920 0.986 0.989 0.995 0.973 8%

NEI42410 0.786 0.736 0.843 0.898 0.816 16%

NEI47091 0.986 0.961 0.974 0.980 0.975 3%

NEI47104 0.727 0.975 0.981 0.960 0.972 2%

NEI6057 0.864 0.983 0.942 0.973 0.941 12%

NEI6450 0.991 0.991 0.991 0.991 0.991 0%

Average 5%

Quarterly PTs, Fbio, Methanol
Biotreatment System 

Variability

Biotreatment Systems

Average annual “intra-facility” variability in Fbio,methanol for ASBs 

reflected in ICR data was 5%

Average Fbio,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 overcollection 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

HVLCCCA

HVLCBase

Fbio

MACT 1 Phase 1

Wastewater (WW1)

Baseline Emissions = (WW1 + P1) x (1 – Fbio)

Phase 1 Condensates (P1)

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

Additional Condensates

in Hard Pipe (P2)

Additional 

Treatment

Wastewater (WWCCA Higher Fbio )

Phase 1 Condensates (P1)

CCA Emissions = (WWCCA + P1 + P2) x (1 – Fbio, CCA)

 = baseline

 = CCA

Facility hardpiping additional condensates and operating biotreatment system at Higher Fbio in 

order to use the CCA option

Higher Fbio achieved through voluntary treatment system upgrades

Example Bleached Mill with CCA 

– Compliance Approach
HVLC Source emissions = 1.4 lb/ODTP

Wastewater Treatment system loadings

Baseline: WW1 = 10 lb/ODTP; P1 = 12.2 lb/ODTP

CCA: WWCCA = 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

Over-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 Fbio under CCA required for Phase 2 compliance

For CCA mills, the ICR data on biotreatment performance 

reflects the Higher Fbio

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 

Fbio,methanol of 95.7%

Considering Fbio 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 (Fbio,adj) 

from 92% to 94% would mean

An increase in actual Fbio, 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 Fbio 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

More 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

Need compliance margin – units with < 96%

20% are integrated with evaporators

Assume 10% downtime remains - no backup

Wastewater Treatment System Assumptions

Increase 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 nonintegrated 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

Increased 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

Cost 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

Process 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 backup 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

When 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

94% 96% 98%

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:

Recalculated Numerical Limits (lb/ODTP)

% Treatment

(% control 

improvement)

Multiplication 

Factor Used Bleached Mills Unbleached Mills

92% 10.2 6.6

93% (12.5%) 1.125 11.5 (= 10.2 x 1.125) 7.4 (= 6.6 x 1.125)

 94% (25%) 1.250 12.8 (= 10.2 x 1.25) 8.3 (= 6.6 x 1.25)

95% (37.5%) 1.375 14.0 9.1

 96% (50%) 1.500 15.3 9.9

 97% (62.5%) 1.625 16.6 10.7

 98% (75%) 1.750 17.9 11.6

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

% Treatment Scale 92% 98% 100%

lb/ODTP (Unbleached) 6.6 7.2 

lb/ODTP (Bleached) 10.2 11.1

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

% Treatment Scale 92% 98% 100%

lb/ODTP (Unbleached) 6.6 7.2 

lb/ODTP (Bleached) 10.2 11.1

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

66
Table 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, Methanol
Table 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 high
Table 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%).