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Pulp and Paper Sector Survey Overview

6/8/10

This survey overview document provides instructions for completing the pulp and paper survey. This overview is 

organized as follows:

A. Survey Coverage .............................................................................................................................................2

B. Confidential Business Information (CBI)........................................................................................................4

C. How to Submit Your Survey Response...........................................................................................................4

C1. Submitting Your Non-CBI Response................................................................................................4

C2. Submitting CBI.................................................................................................................................5

D. How to Complete the Survey ..........................................................................................................................6

D1. Flow diagrams...................................................................................................................................6

D2. NEI data: Facility and Inventory tabs ..............................................................................................7

a. Updating pre-populated NEI data (in the Facility and Inventory tabs)....................................8

b. Completing Facility and Inventory tabs if not pre-populated by EPA ..................................12

D3. Process data.....................................................................................................................................13

a. Facility tab.............................................................................................................................15

b. Inventory tab (permit limit information) ...............................................................................15

c. Equip detail tab......................................................................................................................17

d. Controls tab ...........................................................................................................................21

e. Potential changes tab .............................................................................................................22

f. Pulp prod tab .........................................................................................................................22

g. Byproducts tab.......................................................................................................................22

h. PCC tab..................................................................................................................................22

i. Kraft condensates tab ............................................................................................................23

j. CCA tab.................................................................................................................................23

k. Bleaching tab.........................................................................................................................24

l. Paper prod tab........................................................................................................................24

m. HAP additives tab..................................................................................................................25

n. WW tab..................................................................................................................................25

D4. Test data..........................................................................................................................................25

a. Emissions test data tab...........................................................................................................26

b. CEMS data spreadsheet (P&P CEMS spreadsheet.xls).........................................................26

D5. Optional cost data............................................................................................................................28

ATTACHMENT 1 Emission Units to Include in the Pulp and Paper Survey Response ............................................30

ATTACHMENT 2 NSPS and NESHAP Definitions.................................................................................................32

ATTACHMENT 3 Small Business Size Standards....................................................................................................40

ATTACHMENT 4 Acronyms and Abbreviations......................................................................................................41

ATTACHMENT 5 Resources for Estimating Emissions...........................................................................................43

ATTACHMENT 6 Emissions Test Data Request ......................................................................................................44
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A. Survey Coverage 

This information request applies for pulp and/or paper/paperboard mills that are a “major source” or “synthetic area 

source” of hazardous air pollutant (HAP) emissions that:

(a) Perform chemical wood pulping (kraft, sulfite, soda, or semi-chemical), or

(b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping 

(RMP)), secondary fiber, and non-wood pulping, or

(c) Perform bleaching, or

(d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“Major source” means any stationary source or group of stationary sources located within a contiguous 

area and under common control that emits or has the potential to emit considering controls, in the 

aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any 

combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the 

case of radionuclides, different criteria from those specified in this sentence.

A “synthetic area source” is a stationary source which is subject to federally-enforceable conditions that limit its 

potential to emit to below major source thresholds.

If your mill is not a “major source” or “synthetic area source” of HAP emissions, then you should send an email to 

Bill Schrock at schrock.bill@epa.gov attaching documentation (such as a valid operating permit) confirming the true 

area source status of your facility and showing that you facility is not subject to either of the pulp and paper 

NESHAP (40 CFR part 63, subpart S or MM). You will receive e-mail confirmation from EPA that you are not 

required to complete this survey based upon EPA review and agreement with the true area source status shown in 

the documentation. 

If your mill is a “major source” or “synthetic area source,” but was not operational in 2009 (and remains closed) or 

does not produce pulp, perform bleaching, or manufacture paper or paperboard products, then you should send an 

email to Bill Schrock at schrock.bill@epa.gov explaining the operational status of your mill. Once EPA has 

reviewed your notification, you will receive e-mail confirmation from EPA regarding whether you should complete 

any portions of this survey.

This survey is to be completed in a Microsoft Excel spreadsheet file that is divided into several worksheets (“tabs” 

within the spreadsheet). You must complete certain tabs of the survey spreadsheet (depending on the type of mill 

you operate). The Facility, Inventory, and Equip detail tabs must be completed for all mills. Table 1 below

denotes which survey spreadsheet tabs to complete depending on mill type. Additional spreadsheets are provided 

for submittal of continuous emissions monitoring system (CEMS) data or control measure cost information.

Please complete the survey for the facility listed in the Section 114 letter you received in the mail. If you received

more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility.

If you have not already received or downloaded a copy of the survey spreadsheets, they can be downloaded here: 

http://icr2010.rti.org.

Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 

2009 equipment configurations, etc), unless another year is specified in the instructions (e.g., for emissions test 

data). 

This survey asks questions about the emission units listed in Attachment 1 to this document. Section D, How to 

Complete the Survey, explains how to treat various configurations of emission units (e.g., multiple emission units 

venting to the same stack, etc.) for each survey tab. 
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For reference, Attachment 2 contains the regulatory definitions from the kraft pulp mill new source performance 

standards (NSPS) (40 CFR Part 60, subpart BB), chemical recovery combustion source national emissions standards 

for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart MM), and from the pulp and paper processing 

NESHAP (40 CFR Part 63, subpart S). Attachment 3 contains a listing of small business size standards for North 

American Industry Classification System (NAICS) code Subsector 322, Paper Manufacturing. Attachment 4 

contains acronyms and abbreviations used throughout this Survey Overview Document and the associated 

spreadsheets. Resources that might be useful for estimating emissions are identified in Attachment 5. Finally, 

Attachment 6 of this survey contains a table of emission units and pollutants for which existing emission test data 

are requested.

Table 1. Survey Spreadsheets and Tabs to Complete

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

P&P sector survey.xls

Facility All mills

Inventory All mills

Equip detail All mills

Controls Mills with add-on air pollution controls on pulping emission units, bleaching 

emission units, papermaking emission units, or boilers. 

Potential changes Chemical pulp mills

Pulp prod Mills that produce any type of pulp (including chemical, mechanical/groundwood, 

secondary fiber, including non-wood pulp)

Byproducts Mills that produce turpentine or tall oil byproducts from pulping processes

PCC Mills that route lime kiln, boiler, or other process exhaust to a precipitated 

calcium carbonate (PCC) plant

Kraft condensates Mills that perform kraft pulping

CCA Mills that perform kraft pulping and use the clean condensate compliance 

alternative (CCA)

Bleaching Mills that perform bleaching

Paper prod Mills the produce paper or paperboard products

HAP additives Mills the produce paper or paperboard products

WW Mills with onsite wastewater treatment plants

Emissions test data Mills operating emission units subject to NESHAP subparts S or MM, or NSPS 

subpart BB

P&P CEMS spreadsheet.xls

CEMS data (separate tabs 

are included for different 

pollutants)

Mills operating emission units subject to NESHAP subparts S or MM, or NSPS 

subpart BB. 

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

APCD costs Mills that installed selected air pollution controls (see section D5)

Equip change costs Mills implementing selected process or equipment changes (see section D5)
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B. Confidential Business Information (CBI) 

The EPA's procedures for handling CBI are described in the letter (and attachments) accompanying the pulp and 

paper information collection request (ICR). If you believe that providing any specific information to us would 

reveal a trade secret, please identify this information clearly in your spreadsheet response by shading the spreadsheet 

cell containing the “confidential business information (CBI)” information with red highlight and indicating in the 

red block at the top of each spreadsheet tab that the tab contains CBI. Also, please clearly label any flow diagrams 

or other attachments submitted with your survey that contain CBI. However, please do not label your entire 

response as CBI if only a portion includes trade secrets. The EPA is likely to follow-up with a request for validation 

of CBI claims for mills claiming large amounts of information as trade secret, especially information that is readily 

reported by other mills without such claims.

C. How to Submit Your Survey Response 

If your response to this information collection request includes data with a claim of CBI, you should follow the 

instructions in this section to ensure the protection of your data. Please note that if you submit CBI, you will be 

separating your data into two portions and sending your data to EPA using two different mailing addresses. 

C1. Submitting Your Non-CBI Response

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely nonCBI.)

After you have completed and reviewed your survey response, remove the CBI components from your survey as 

instructed in section C2. Save the Excel spreadsheet(s) containing the non-CBI portions of your completed 

response, non-CBI flow diagrams, emission test reports, and any other electronic non-CBI attachments on the flash 

drive you were provided with your section 114 letter (or on a CD or DVD). Assemble any non-CBI hard copy 

attachments to your survey (such as hard copy flow diagrams, test data, wastewater emissions modeling reports, 

etc.). Mail the non-CBI flash drive (or disk) and any non-CBI hard copy materials in one envelope to EPA at the 

address specified below by the specified response deadline in the Section 114 letter. (Note: If the 

spreadsheet/diagrams/attachments contain CBI, use the address for Mr. Morales provided in section C2 of this 

document.)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (E143-03)

Attn: Mr. Bill Schrock

109 TW Alexander Drive

Research Triangle Park, NC 27711

EPA recommends sending your non-CBI files via Registered U.S. Mail using return receipt requested, Federal 

Express, or other method for which someone must provide a signature upon receipt.
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C2. Submitting CBI

Follow these instructions for any portion of your survey response that contains CBI. 

Please create a separate CD or DVD containing a version of your spreadsheet response with only the CBI portion of 

your data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any flow diagrams or 

pages of other attachments to your survey response containing CBI, with the CBI portions of the diagrams/pages 

clearly marked (e.g., highlighted or circled). Clearly mark the disk with the words “Confidential Business 

Information.” Send only these CBI files under separate cover to:

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. 

Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature 

upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E-mail 

and facsimile are not secure forms of communication and should never be used to transmit CBI.
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D. How to Complete the Survey 

Your survey response will consist of flow diagrams and completed Microsoft Excel spreadsheets. Separate Excel 

spreadsheets are provided for completion (P&P survey.xls; P&P CEMS Spreadsheet.xls; P&P costs 

OPTIONAL.xls). You must complete certain tabs of the P&P survey.xls spreadsheet (depending on the type of mill 

you operate) as shown in Table 1 above. The P&P CEMS Spreadsheet.xls is to be completed if you have 

continuous emissions monitoring data to supply. The P&P costs OPTIONAL.xls spreadsheet is an optional 

spreadsheet that can be completed to supply control measure cost information helpful for EPA’s regulatory analyses.

D1. Flow diagrams

Please provide a process flow diagram (or diagrams) showing the equipment listed in Attachment 1 as it appears in 

each of the following areas of the mill. Respondents should clearly label the emission unit IDs on each submitted 

flow diagram. The emission unit IDs should match those provided in the survey spreadsheets. Readily available 

block flow diagrams (e.g., such as those used for permit applications) will suffice. Electronic or hard copies are 

acceptable. 

Chemical recovery area. Show each chemical recovery furnace/combustion unit, black liquor oxidizer (if 

used), smelt or ash dissolving tank, causticizing equipment, and lime kiln/calciner. Include liquor storage 

tanks or ponds.

Pulping process. Include the equipment in all pulping lines including the digester area, pulp washing lines, 

evaporator lines, and oxygen delignification systems. Show any brown stock washers, hoods, filtrate 

tanks, vacuum pumps, screens, knotters, deckers, stock chests (including open stock chests, pulp storage 

tanks), thickeners, and weak black liquor storage tanks on the diagram. Include deckers, screens, knotters, 

stock chests, and pulp storage tanks following the last stage of pulp washing and/or those located prior to 

the paper machines. 

Black liquor gasification. If black liquor gasification is used, provide a diagram and description of the 

system including any combustion controls or add-on controls used to reduce air pollutants. 

Wastewater treatment plant (WWTP). Provide a flow diagram of each WWTP showing each wastewater 

handling/treatment unit. 

How detailed must my diagram(s) be? 

The EPA will use the diagram(s) to aid in understanding the general mill flow, and any 

unique characteristics in the mill layout. It is not necessary to show every single vent of 

every emission unit on the diagrams. However, the diagram should provide enough 

information such that it is clear how emissions are collected and controlled. For example, if 

all digester vents are routed to LVHC, then it is not necessary to show each individual 

digester vent when one line drawn from a digester “block” to the LVHC collection system is 

informative.
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D2. NEI data: Facility and Inventory tabs

The U.S. EPA is working to fulfill its obligation under CAA sections 112(f)(2) and 112(d)(6) to review residual risk 

and perform a technology review of the pulp and paper industry NESHAP subparts S and MM. Data sets derived 

from the EPA’s 2005 National Scale Air Toxics Assessment (NATA) National Emissions Inventory (NEI) will be 

used for EPA’s residual risk and technology review (RTR). The RTR data sets have been developed for mills in the 

2005 NATA NEI identified as having emission units with the following NEI MACT codes:

1626-1 Pulp & Paper Production - Pulping and Bleaching Systems at Kraft, Soda, Sulfite, and 

Semichemical Pulping Mills (Subpart S) and Papermaking Systems at all mills.

1626-2 Pulp & Paper Production - Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, 

and Stand-alone Semichemical Pulping Mills (Subpart MM)

1626-3 Pulp and Paper Production - NonMACT Facilities

The 2005 NATA NEI data sets were compiled based on prior versions of the NEI, updated with data collected by 

EPA’s Office of Air Quality Planning and Standards.

1

 Many pulp and paper mills have voluntarily updated their 

NEI data sets for RTR purposes and few additional refinements are needed. However, there remain a number of 

pulp and paper mills for which substantial updates to their NEI data sets are requested in order for EPA to more 

accurately consider RTR for the pulp and paper NESHAP standards. In addition, there may be some mills for which 

no prior pulp and paper MACT category NEI data are available.

If 2005 NATA NEI data exist for your mill, then two of the survey spreadsheet tabs (Facility tab and Inventory tab) 

have been pre-populated with your mill’s NEI data set. You will need to review and revise the NEI data in these 

two tabs as necessary following the instructions provided below in section D2.a for “Updating pre-populated NEI 

data (in the Facility and Inventory tabs).” The remaining spreadsheet tabs request information in addition to that 

included in the NEI, and are to be completed based on the instructions provided in section D3 of this document. 

If NEI data do not already exist for your major or synthetic area source mill, then you will need to provide a full NEI 

update in the Facility and Inventory tabs. See the instructions below in section D2.b for “Completing Facility and 

Inventory tabs if not pre-populated bv EPA” below. The remaining spreadsheet tabs request information in addition 

to that included in the NEI, and are to be completed based on the instructions provided in section D3 of this 

document.

Regardless of whether you are updating a pre-populated data set or providing new inventory information, the 

following items should be noted:

 Unless specifically identified as permitted (i.e., “Allowable”) or startup/shutdown emissions, all emissions 

reported in the survey / inventory format should reflect ACTUAL, routine emissions for the reported

calendar year. 

 Please pay particular attention when entering emission release point stack parameters and locations. EPA 

requires latitude/longitude for each emission point provided in North American Datum (NAD) 83 with 6 

digits to the right of the decimal point. These data are critical inputs to the modeling files that EPA will use 

to determine the risk profile for the residual risk review process.2

 

1

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

2Latitude measure in decimal degrees of the angular distance on a meridian north or south of the equator. Positive 

(+) data point for North America. Example: +78.123456. For point sources, this represents the center of the source; 

for fugitive sources, this is the southwest corner if the fugitive angle is zero or the western most corner if the fugitive 

angle is greater than zero. Longitude measure in decimal degrees of the angular distance on a meridian east or west 

of the prime meridian. Negative (-) data point for North America. Example: -123.234561. For point sources this 

represents the center of the source; for fugitive sources, this is the southwest corner if the fugitive angle is zero, or 

the western most corner if the fugitive angle is greater than zero. 
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a. Updating pre-populated NEI data (in the Facility and Inventory tabs) 

You will need to review and revise the NEI data contained in the “Facility” and “Inventory” tabs as necessary. The 

NEI data appear to the left of the orange vertical line in each tab (column AF in the Facility tab and column BZ in 

the Inventory tab). Pulp and paper survey data fields (in addition to those in the NEI) have been added to the right 

of the orange vertical line in the tab and require completion as described in the instructions in section D3 below for 

“Process data.” The instructions for updating the pre-populated NEI data in the Facility and Inventory tabs are as 

follows.

NEI data are generally requested for the 2009 calendar year. However, EPA is sensitive to the time and effort 

required to update your NEI inventory. Thus, if you have previously reviewed and revised your NEI data within the 

past 3 years and/or you believe the 2005 NATA NEI data in the pre-populated data set provided by EPA is a 

reasonably complete and accurate representation of your mill configuration and emissions, then you do not need to 

update your NEI data for the sole purpose of changing the emission estimates to reflect the 2009 calendar year. 

However, if you must substantially revise or add to your pre-populated NEI data set to make it complete and 

reflective of the current mill configuration, then it is requested that you use the 2009 calendar year for your 

inventory update.

You will update one row of data in the Facility tab, and multiple rows of data in the Inventory tab. An “Instruction”

row appears that the top of each spreadsheet tab to provide a brief instruction for fields requiring some description. 

More detailed instructions appear in this document where needed. When updating the NEI data in the Facility and 

Inventory tabs, please indicate changes only in the unshaded columns. Do not overwrite data in the gray shaded 

columns. Guidance for revising specific blocks of data in the Inventory tab is as follows:

Gray shaded columns. The gray shaded columns have been locked to prevent information in these columns 

from being overwritten. If you wish to change information in these gray columns, then you will need to 

follow the instructions for adding and deleting a row. Copy the entire row with the locked cells and paste it 

below the existing, pre-populated NEI inventory to add and update it. Then mark the old row for deletion

by indicating your intent with an "X" in the “Delete” column.

Adding a row. If you need to add a new emission unit or pollutant that is not currently in the inventory,

you should scroll to the last row and enter any missing data. You can copy any useful information from 

other inventory rows and state in the "Process Comment" field "Adding new process." For additions, 

information does NOT need to be in a revised field. Specify “RTR09” in the “Data Source Code” column.

Deleting a row. If you need to delete a row indicate your intent with an "X" in the “Delete” column and 

indicate your reason for deletion in the “Delete Comment” column. You may wish to delete rows, for 

example, because an emission unit was decommissioned or is now collected as part of the LVHC system; 

or because you cannot identify the source.

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

adding and deleting rows above.

To replace the whole inventory. You may choose to submit a complete NEI replacement. To completely 

replace your NEI data, mark all existing NEI rows for deletion with an "X" in the “Delete” column and note

“complete inventory replacement” in the “Delete Comment” column. Add your new inventory below the 

NEI data being replaced.
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For convenience, the spreadsheet entitled Lookups for P&P survey.xls consolidates and provides the various codes 

associated with the NEI data set you are requested to update. This Lookups for P&P survey.xls spreadsheet also 

contains source classification codes (SCC). These codes were extracted from the NEI data base lookup tables at

http://www.epa.gov/ttn/chief/net/2005inventory.html and contain SCC revisions made in the fall of 2009. Note that 

the process of revising the SCC list in the fall of 2009 involved both the addition and the removal of pulp and paperrelated SCCs. For example, the SCC list previously included the SCC: 30700118 Sulfate (Kraft) Pulping / Liquor 

Clarifiers. This SCC is now obsolete and has been replaced with the more specific SCCs: 30700132 Sulfate (Kraft) 

Pulping / Green Liquor Processing and 30700133 Sulfate (Kraft) Pulping / White Liquor Processing. Please use 

the most appropriate SCC from the provided lookup table. Similar updates (i.e., both additions and deletions) may 

have been made to some of the other NEI code lookup tables. If a code that you have used in the past no longer 

appears in the appropriate lookup table, please select the most appropriate code from those listed. You may clarify 

your entry by adding text in the “Comment – Process” column. Codes that are being phased out are shaded green in 

some of the lookup tables (along with a note in the lookup table explaining how to treat the green-shaded codes in 

your inventory update).

Update the single row of NEI data in the Facility tab as needed following the instructions that appear in each 

column.

The NEI data in the Inventory tab should include all emission units/points that emit hazardous air pollutants (HAP), 

criteria air pollutants (CAP), or total reduced sulfur (TRS) at the mill, including every emission point with HAP, 

CAP, and/or TRS emission limits in your title V operating permit. The Inventory tab contains separate rows of data 

for each emission unit, emission point, and pollutant. The types of emission units listed in Attachment 1 to this 

document (that you operate) must be included in the NEI revision even if these emission units are not already 

included in your title V permit. If emission units/points included in your title V permit (or emission units/points that 

you operate listed in Attachment 1) are not already included in the NEI data, then you will need to add the missing 

emission units/points. There should be an NEI data entry for every emission unit/point and pollutant permit limit 

listed in your title V permit. You will also need to add an accurate description of each emission unit in the 

"REVISED Emission Unit Description" column. In addition, every emission unit will need to be assigned a 

descriptive SCC code. If you review the data in the Inventory tab and conclude that no revisions are needed, then 

mark the “Is Reviewed With No Changes” column in the Inventory tab accordingly. Guidance for different 

emission unit/point configurations and specific data columns are provided as follows.

Why can’t I over-write existing data? 

EPA maintains a record of all changes and "matches" existing NEI entries (i.e., those in 

the attached spreadsheet) to new entries (your revisions). So if a line (record) in the 

spreadsheet/database does not match our existing files, both the old and the new records 

are incorporated into the NEI which can result in double counting. For these reasons, 

any changes must be recorded in one of the unshaded fields and you cannot 

(successfully) change data by over-writing existing data in a field. 

Why do I have to add every emission unit and/or emission point?

The NEI currently includes both HAP and CAP data. Updates to the list of emission units, 

descriptions, and SCC codes would improve the accuracy and completeness of the NEI data for 

use in EPA’s HAP residual risk efforts. Updated information will allow EPA to focus residual 

risk regulatory analyses on the specific types of emission units with questionable risk. The CAP

and TRS data will be used in determining the magnitude of emissions for purposes of reviewing 

the NSPS.
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Multiple emission units ducted to a single release point. It is very common for multiple emission units (or 

for multiple emission points from a single emission unit) to be ducted to a common conveyance for 

purposes of emissions capture and control. The NEI provides parameters associated with releases to the 

atmosphere (e.g., tpy emitted, stack parameters) so it is acceptable to include each common emission 

release point in the NEI (rather that listing each emission unit ducted to the common release point 

separately). For example, an LVHC collection system may collect emissions from multiple emission points 

associated with digesters 1, 2, and 3 and an evaporator. You could either list digesters 1, 2, and 3 and the 

evaporator separately in the NEI (and provide data for each associated emission point, or you could simply 

list the LVHC collection system emission point in the NEI). 

A similar approach can be taken for reporting emissions from two distinct emission units that are vented 

through a common stack for purposes other than capture and control. In this scenario, apportion the 

emissions to each process and insert a separate row or rows for each distinct process. Identify and enter the 

SCC code associated with each emission unit and note the appropriate stack parameters on each row. Note 

the common stack in the "REVISED Emission Unit Description” column. For example, indicate the 

following where 2 recovery furnaces share a common release point: Row 1 – emission unit ID 001 (EU001) 

No. 1 Recovery Furnace vents to emission release point ID 01 (ERP01) and indicate in the “REVISED 

Emission Unit Description” column “No. 1 Recovery Furnace shares common stack with No. 2 Recovery 

Furnace.” On Row 2 – emission unit ID 002 (EU002) No. 2 Recovery Furnace vents to emission release 

point ID 01 (ERP01) and indicate in the “REVISED Emission Unit Description” column “No. 2 Recovery 

Furnace shares common stack with No. 1 Recovery Furnace.”

Single emission unit with multiple emission release points. Pulp and paper emission units may have 

multiple emission points (e.g., paper machines, digester blow gases and relief gases, boilers with two 

stacks) that for various reasons may not be consolidated into a single emission point before release to the 

atmosphere. In these situations, the emission unit should be repeated in the NEI and emissions data and 

stack parameters provided for every emission point. You may use the “REVISED Emission Unit 

Description” column to distinguish among emission points for each emission unit.

Bypass stacks used only during certain times. If your facility operates an emission unit with a bypass stack 

that allows for emissions to bypass the control system, then you can indicate the emissions associated with 

these bypass stacks by entering the appropriate data in a new row (see previous instructions for “adding a 

row”). If you enter data for bypass stacks, please indicate these emissions as “bypass” emissions in the 

“REVISED Emission Unit Description” column. Please also indicate in the “REVISED Emission Unit 

Description” column the release point associated with “normal” operations. See also the instructions below

for routine and SSM emissions.

Backup controls. Some facilities may have backup control system configurations that provide flexible 

operating scenarios. For example, LVHC system gases may normally be collected and burned in a lime 

kiln, but if the lime kiln that controls these emissions is shutdown, the facility has the flexibility to send 

these same collected LVHC gases to a power boiler. For this type of scenario, a facility would indicate in 

the “Control Measure” fields in the Inventory tab that the lime kiln is the primary control device, but would 

also note in the “Control Measure Comment” field that the power boiler serves as a backup control. 

Routine emissions and startup, shutdown, and malfunction (SSM) emissions. Startup, shutdown, and 

malfunction emissions are requested because EPA is modeling both short- and long-term risks. You are 

asked to indicate the SSM annual and maximum hourly emissions in lb/hr and tpy, respectively. If you 

enter separate rows for an emission unit’s routinely used stack and a bypass stack, then you should report 

SSM emissions for the emission unit in the row(s) associated with the bypass stack (in order to prevent 

double counting of the SSM emissions that would occur if the SSM emissions are entered in both the 

routine and bypass rows).
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Control measures. For EPA to better understand current control measures that are in operation, we are 

requesting that reviewers indicate the type of control measure associated with each emission unit. A list of 

control measure codes and control measure descriptions is provided in Lookups for P&P survey.xls. If you 

do not provide control measure information in your update, the emission unit will be considered 

uncontrolled. 

Emission units vented into the building. Do not include emissions units that vent into the building in your

NEI update unless these emission units are permitted units in your Title V permit. For example, if your 

paper machine vents into the building housing the machine and emission limits are contained your permit 

that are applicable to the building vents, then you would included the paper machine in your inventory.

Fugitive emissions. Quantified sources of fugitive emissions are to be included in your NEI update (e.g., 

fugitive emissions from wastewater handling/treatment units modeled for permitting purposes). Fugitive 

emission parameters are reflected in the “Emission Release Point Type” column and other columns related 

to the fugitive length, width, and angle of the fugitive emissions.

Emission units unrelated to the pulp and paper NESHAP and NSPS source categories. Please note that the 

pre-populated NEI data sets contain all emissions data for a facility identified as belonging to a MACT 

category covered under the present RTR. Thus, some of the emissions may be from processes NOT 

associated with the pulp and paper MACT category. The column labeled “MACT Code” indicates if the 

HAP pollutant emissions are associated with the pulp and paper MACT category or another MACT 

category at the facility (e.g., MACT code 0107-2 associated with Industrial/Commercial/Institutional 

Boilers & Process Heaters – gas.). A full list of MACT codes is included in Lookups for P&P survey.xls. 

Data from MACT categories other than the pulp and paper NESHAP categories are shown in the prepopulated spreadsheets to provide a complete dataset for the facility and/or to help you spot additional 

processes which should be assigned to the pulp and paper MACT category.

In this survey we are seeking updates to the equipment used for pulp and paper manufacturing (i.e., pulping 

processes, pulping byproduct recovery, bleaching, papermaking, boilers, etc). A list of the types of 

equipment of interest for pulp and paper production is provided in Attachment 1 to this document. We are 

not seeking updates to collocated operations that are not associated with pulp and paper manufacture (e.g., 

a lumber mill, chemical plant, or wood products mill) at this time, but would accept voluntary updates to 

these data since the data could be considered in determining residual risk for the entire facility. 

“Emission Unit Description,” “REVISED Emission Unit Description” and “REVISED SCC” columns. An 

“Emission Unit Description” column was included in prior drafts of the NEI that mills were asked to 

voluntarily review and update. Every emission unit listed in your NEI inventory should have an 

informative “Emission Unit Description” that adequately describes the equipment or type of 

emission unit. If no “Emission Unit Description” is in the NEI for a given emission unit then you will 

need to add one in the “REVISED Emission Unit Description” column. If you find that the “Emission 

Unit Description” in the NEI is not informative, then you may revise it using the “REVISED Emission Unit 

Description” column. You may find it helpful if the Emission Unit Description or your revision entered in 

the “REVISED Emission Unit Description” column relates your emission unit/process to your permit or 

process flow diagram. 

The SCCs in the NEI will be used by EPA to group similar emission units and draw conclusions regarding 

the emission levels and residual risk associated with each type of emission unit. Proper assignment of 

SCCs will allow EPA to pinpoint emission unit types that need to be examined in more detail for residual 

risk rulemaking. The SCC codes for pulp and paper manufacturing have recently been updated to include 

more descriptive codes and to provide some guidance on which codes should be used for certain equipment 

types. A crosswalk of the available SCC codes with the types of equipment listed in Attachment 1 is 

included in the P&P Att1 with SCC tab of “Lookups for P&P survey.xls”. The full list of SCC codes used 

for EPA’s Emissions Inventory System (EIS)/NEI is included in the All 11575 SCC tab of “Lookups for 
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P&P survey.xls” (and is also available in data base form at

http://www.epa.gov/ttn/chief/net/2005inventory.html). The “Emission Unit Description” and “REVISED

Emission Unit Description” columns will be used as a check for SCC code assignment. 

Revised SCCs are available for common collection systems (e.g., LVHC, HVLC) and for various systems 

that are commonly comprised of multiple emission points (e.g., 30700114 for bleach plants includes 

emissions from the bleaching towers, washer hoods, filtrate tanks, and vacuum pump exhausts). 

Use the SCC that best describes your process, and avoid use of generic not-elsewhere-classified SCCs 

whenever possible. If you do not find an SCC that matches your emission unit then be sure to include 

an accurate description of your emission unit in the “REVISED Emission Unit Description” column 

of the Inventory tab.

Please make every attempt to use SCCs specific to the pulp and paper sector (e.g., use SCC 30700106 for 

pulp and paper lime kilns as opposed to SCC 30501619 for the lime manufacturing sector). 

Please do not use generic not-elsewhere-classified (NEC) SCCs unless you absolutely cannot find a 

specific SCC that resembles your emission unit. If you do choose a NEC SCC, then a description is 

required in the "REVISED Emission Unit Description” column. 

“Emission Process Group” column. The P&P Att1 with SCC tab of the “Lookups for P&P survey.xls”

spreadsheet contains an “Emission Process Group” column associated with each SCC. You are asked to 

identify the “Emission Process Group” listed in the P&P Att1 with SCC tab for any new emission units you 

add to your NEI. These emissions process groupings will be used in modeling risk and identifying general 

areas of the mill for focus of the residual risk rulemaking effort. For existing NEI entries, if the “Emission 

Unit Description” or “REVISED Emission Unit Description” adequately describes your emission unit, it is 

not necessary to include additional or revised text in the “Emission Process Group” column.

b. Completing Facility and Inventory tabs if not pre-populated by EPA 

A 2005 NATA NEI data set does not exist for your mill if the Facility and Inventory tabs of the pulp and paper 

sector survey have not been pre-populated. There are various reasons why the NEI data set may be unavailable. For 

example, some States have not supplied NEI data for major sources. Also, NEI data may be unavailable for nonmajor sources, or there may be no emission units in your NEI data set that correspond with the pulp and paper 

MACT codes. (Note: If your mill is not a major or synthetic area source of HAP emissions, then follow the 

instructions for notifying EPA of your non-major status in section A of this document.) 

If your mill is a major (or synthetic area) source of HAP emissions, then you will need to develop and supply the 

NEI data set requested in the Facility and Inventory tabs of the pulp and paper sector survey. Useful starting points 

for providing the NEI data set may include your air operating permit or permit application, an inventory of emission 

sources for your mill developed for permitting purposes, or the emission calculations developed for the Toxics 

Release Inventory (TRI) for your mill. Additional resources useful for estimating emissions are listed in Attachment 

5.

Populate the NEI information in the Facility and Inventory tabs by adding your data to the left of the orange vertical 

line (column AF in the Facility tab and column BZ in the Inventory tab). Pulp and paper survey data fields (in 

addition to those in the NEI) have been added to the right of the orange vertical line in the tab and require 

completion as described in the instructions for “Process data” in section D3 of this document. 

You will add one row of data in the Facility tab, and multiple rows of data in the Inventory tab. An “Instruction”

row appears that the top of each spreadsheet tab to provide a brief instruction for fields that require some 

description. More detailed instructions appear in this document where needed. You will add data to all columns 

(including the gray shaded columns). If a gray shaded column is superseded by a “REVISED” column, then you 
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may enter your data in either the “REVISED” column or the gray column (but you need not enter the same data into 

both columns).

Add the single row of NEI data in the Facility tab as needed following the instructions that appear in each column. 

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

unique identifier for your mill. Add data to the Inventory tab by referring to the instructions (in this section and 

section D2.a of this document) for updating the Inventory tab. Enter appropriate identifiers such as the “Facility 

Registry Identifier” (text limited to 15 characters), and the Emission Unit ID, Process ID, and Emission Release

Point ID (all text limited to 6 characters). 

The spreadsheet entitled Lookups for P&P survey.xls provides various codes associated with the NEI data. This 

Lookups for P&P survey.xls spreadsheet also contains SCCs.

D3. Process data 

Complete the Process data portion of the survey only after you have updated your NEI inventory. 

In this portion of the survey you will continue to use the P&P sector survey.xls spreadsheet, where you will: (1) add 

additional information to the right of the orange vertical line in the Facility and Inventory tabs, and (2) add data to 

most of the remaining survey tabs (as applicable). Many of the instructions you need for completing the survey tabs 

are included in the “Instruction” row of each tab in the P&P sector survey.xls spreadsheet. However, more detailed 

instructions for selected tabs are provided below to account for common situations and to provide information on 

how the data will be used by EPA. Each survey tab includes fields with pull down menus for common entries. Use 

these pull-down menus whenever possible, or write in information if your selection is not contained in the pull down 

menu. 

Several IDs are requested throughout the pulp and paper survey response spreadsheet(s), including: 

 NEI Site ID

 Emission Unit ID

 Collection system ID

 Various Line IDs including: Pulping line ID, Bleaching line ID, or paper machine Emission Unit ID

 APCD_ID

The NEI Site ID and Emission Unit ID come from your NEI update in the Facility and Inventory tabs. You will 

specify the Collection system ID, APCD_ID and the various Line IDs in the Equip detail and other spreadsheet tabs. 

The Line IDs are described as follows.

Pulping line ID. Many mills have only one pulping line. However, some mills may have multiple pulping 

lines, and/or may have pulping lines of different types (e.g., a kraft pulping line, semichemical line, and a 

Why does EPA need more data than are included in the NEI?

Facility and equipment details are being requested in addition to the NEI update to inform the 

technological review of the pulp and paper NESHAP and NSPS and to provide information on 

means of reducing residual risk. While the NEI provides EPA with data related to emissions release 

points (e.g., mass emission rate and stack exit parameters used for risk analysis and tracking 

nationwide trends), the technological review of the NESHAP and NSPS standards considers 

emission unit and control equipment details specific to the processes employed and matches these 

details to emissions levels that are achieved (e.g., emission concentrations). Applicability of the 

NESHAP and NSPS compliance options depend on the specific process equipment. 
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secondary fiber pulping line). In general, a pulping line begins with digesters (or chip steaming for TMP; 

repulping for secondary fiber pulping; etc.) and ends with high density storage of pulp (prior to bleaching 

and/or papermaking). You may find it easier to specify the Pulping line ID in the Pulp prod tab first before 

completing the Equip detail tab or other spreadsheet tabs that use the Pulping line ID.

You will identify the different pulping lines in the Equip detail tab, Pulp prod tab, and several other 

spreadsheet tabs. There may be shared equipment between multiple pulping lines (e.g., shared chemical 

recovery equipment). Indicate multiple pulping line IDs in “Line ID” or “pulping line ID” columns for 

equipment shared between multiple pulping lines.

Example 1: Consider a kraft mill with two pulping lines (PULP2A AND PULP3) that share 

equipment in the chemical recovery loop. The Pulping line ID column would contain 

“PULP2A_PULP3” in the for the shared emission units in the chemical recovery loop.

Example 2: Consider a kraft mill with semichemical pulping collocated, having pulping lines 

KRAFT1 and SEMICHEM1 that share an evaporator and a recovery furnace. The pulping 

line ID assigned for the evaporator and recovery furnace could be KRAFT1_SEMICHEM1. 

If the Emission Unit ID or the Process ID identifier in the Inventory tab uniquely describes your pulping 

line, then you may use this alpha-numeric code as the Pulping line ID. If the Inventory tab does not contain 

a unique identifier for your pulping line, you can independently assign this unique identifier.

If in doubt as to what ID to use, enter Pulping line IDs that make sense for your mill. The purpose of the 

Pulping line ID is to distinguish among emission units used in the pulping area and on different pulping 

lines. Just make sure that the Line IDs you enter are consistent throughout the spreadsheet.

Bleaching line ID. A bleaching line is a group of bleaching stages arranged in series such that bleaching of 

the pulp progresses as the pulp moves from one stage to the next. The Bleaching line ID is used to identify 

which emission units appear in each bleaching line located at the mill. Most mills would have only one 

bleaching line (if any), but there may be some mills with multiple bleaching lines (with each bleaching line 

assigned a different Bleaching line ID). The Bleaching line ID entered in the Equip detail tab must match 

the Bleaching line ID used in the Bleaching tab.

Paper machine Emission Unit ID. Paper mills may have multiple paper machines (each identified with a 

paper machine Emission Unit ID). Emission units located in the paper mill should be assigned a Line ID

based on the paper machine the emission unit serves (as identified with the paper machine Emission Unit 

ID). For example, stock blending and storage tanks serving paper machine PM1 would be assigned a Line 

ID of “PM1” (where PM1 is the paper machine Emission Unit ID) would be assigned for each stock 

blending and storage tank. If stock blending and storage tanks were shared among paper machines PM2 

and PM3, then “PM2_PM3” would be entered as the Line ID for each stock blending and storage tank.

A Note About Identification Numbers (IDs)

It is imperative that you use the same IDs to describe the same facility, process line, 

equipment/emission unit, and emission release point throughout the survey. These ID codes will be 

used to link the various pulp and paper data base tables together into a functional and informative 

data base to be used for regulatory analyses. You may choose your own IDs (e.g., based on IDs 

already included in the NEI, IDs from existing process flow diagrams, IDs in your air permit, etc.), 

but the IDs you choose must be consistent throughout your survey response. If you wish to avoid 

follow-up calls regarding your survey data, please make every effort to ensure that your IDs match 

throughout the spreadsheet(s).

Also, please be sure that no extra spaces or characters are included in the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software.
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Follow the instructions below and in the “Instruction” rows of the spreadsheet to complete the survey tabs. Refer to 

Table 1 of this document to determine which tabs you must complete depending on the type of mill you operate.

a. Facility tab 

Complete the columns to the right of the orange line in the Facility tab, following the instructions provided in the 

“Instruction” row. Your response in the Facility tab will consist of one row of data. These data will be used by 

EPA to characterize your facility and identify applicable regulations. 

Size of entity. Attachment 3 to this document contains a listing of NAICS codes and small business size 

standards or NAICS subsector 322. For private businesses, small entity is defined for each NAICS of the 

owning entity based on number of employees and/or company revenue. The parent company number of 

employees is used for the pulp and paper subsector (322). Note that the “number of employees” is 

calculated according to the Small Business Size Regulations codified at 12 CFR §121.06 where all 

individuals employed on a full-time, part-time, or other (e.g., temporary) basis are counted equally. 

Paper or paperboard processes/products. Enter the total number of operable paper machines located at the 

mill in 2009 (including any machines that were temporarily idle due to economic conditions in 2009) in the 

“Total number of paper machines” column. Enter the total paper/paperboard machine capacity as of 2009 

in the "2009 total paper/paperboard capacity, st/yr” column. Note that capacity represents the 

paper/paperboard production capability of the operable machines and may be greater than 2009 actual 

production. Next enter the total 2009 capacity to produce each paper grade across all paper machines 

(again, including machines temporarily idle in 2009).

Paper/paperboard capacity utilization. You are asked to provide the decimal percentage utilization for 

paper/paperboard production at your mill for the survey base year (2009). In addition, because 2009 was 

characterized by short-term production curtailments at many mills due to the U.S. economic situation, you 

are asked to provide a 5-year average capacity utilization. 

b. Inventory tab (permit limit information)

Permit limits for each emission unit/point and pollutant are requested to the right of the orange line in the Inventory 

tab (column BZ). You should include a row of data for every emission unit/point and pollutant combination with a 

permit limit. Do not include permit limits in rows you marked for deletion of the NEI data. If a pollutant appears 

in the NEI, but is not listed in your permit with a specific permit limit, then leave the permit limit information to the 

right of the orange line blank since no permit limit applies. 

For each emission unit, refer to the NEI data “Pollutant Code,” “REVISED Pollutant Code,” and/or 

“Pollutant_Code_Desc” columns to the left of the orange line to determine which pollutant permit limits to enter.

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 below. 

These suggested units were taken from existing Federal limits codified in 40 CFR part 60 subpart BB or 40 CFR 

Part 63 subparts S or MM. Specify permit limits as written in the permit if the suggested limit units are not included 

in the permit. You do not need to convert limits to the suggested units. You may specify limits for a given pollutant 

in multiple units/formats (e.g., ppmdv and/or % reduction) if the permit is written to include multiple compliance 

options. The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit 

limits of most interest to EPA are concentration limits (ppmdv, gr/dscf, etc.), percent reduction, mass per unit 

production (lb/ton of material throughput, etc) because these limits can be compared from facility to facility 

independent of emission unit or mill capacity. Mass emission rate limits (lb/hr or tpy) are not being requested unless 

this is the only way in which limits are specified in the permit.
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EPA will use the permit limit information you supply in comparing permit limits across similar emission units 

nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction 

factors (%O2). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way 

in your permit (ppmdv, ppmdw, ppmv, ppmw). 

Table 2. Suggested Units of Measure for Permit Limits

Pollutant Suggested units

PM1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O2

SDT: lb/ton BLS

LK: gr/dscf @10% O2

PM10

1 Other processes: specify

PM2.5

1

Opacity % (provide averaging time)

TRS RF/combustion units: ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S)

LK: ppmdv @ 10% O2

Other processes: lb/ADT pulp and/or ppmdv

SO2 lb/MMBtu and/or ppmdv or limits on fuel S content

NOx lb/MMBtu (as NO2) or ppmdv

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

VOC lb/{production}, specify if as propane, etc. or ppmdv

THC Report as carbon. 

RF/combustion units: Lb/ton BLS

HCl ppmdv and/or % reduction

Methanol and gaseous organic 

HAP

chemical recovery combustion sources: lb/ton BLS

process sources: ppmv @ 10% O2, lb/ton ODP, and/or percent reduction

Chlorine and chlorinated HAP ppmv, lb/ton ODP, and/or percent reduction 

Other speciated HAP (specify...) Specify units

1

Specify filterable and/or condensable if your permit limits distinguish between the filterable and condensable PM 

fractions.

Permits restating NESHAP and NSPS limits. Your permit may simply restate the emission limits contained 

in Federal rules such as NESHAP subparts S and MM and NSPS subparts BB or Db. Some permits may 

list all of the compliance options contained in the Federal rules as permit limits. If this is the case, you do 

not need to enter permit limits that are exactly the same as Federal NESHAP or NSPS. Instead, specify the 

applicable Federal rule (not the specific numeric Federal limits) in Column CF and skip the remaining 

permit questions/columns in the table. If your permit contains additional State limits in terms other than 

the Federal limit, please indicate these limits in the appropriate column (e.g., Column CG for permit limit 

1, Column CJ for permit limit 2, etc.) Please do not enter State lb/hr or tpy emission limits in addition to 

the Federal limits.

Particulate Matter (PM) fractions. The NEI contains many variations and fractions of PM (e.g., Primary 

PM10, Filterable Portion Only; Primary PM10 (Includes Filterables + Condensibles), Primary PM2.5, 

Filterable Portion Only, etc). Enter your permit limit information for the relevant fraction(s). Leave the 

permit limit columns blank for any PM fractions listed in the NEI data for which you do not have permit 

limits. 
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Opacity. The NEI does not include opacity as a pollutant, but Federal rules limit opacity for certain 

equipment, and states may have different limits for opacity. Please enter permit limits for opacity for the 

emission units/points you included in the NEI with PM data. Enter the opacity data as an alternative permit 

limit format on the same row where you specify your PM permit limit(s). Your do not need to add separate 

rows for opacity. The opacity limits of most interest to EPA are those for fuel fired equipment such as 

recovery furnaces, chemical recovery combustion units, lime kilns, boilers, and thermal oxidizers.

VOC, HAP, and other pollutant groupings. There may be instances where specific pollutants are listed in 

the NEI, but your permit limits emissions of the specific pollutant through a limit on a larger grouping of 

pollutants such as VOC, HAP, PAH, etc. To reflect these types of permit limits, enter the relevant numeric 

permit limit and note the pollutant grouping limit in the “units for permit limit” column (e.g., 50 ppmdv 

VOC). [Note: The converse of this situation – where your permit contains limits for specific pollutants 

that are not listed in the NEI – should not be an issue if you have followed the NEI update instructions in 

section D2 above. You should have an NEI data row for every emission unit/point and pollutant permit 

limit listed in your title V permit.] 

c. Equip detail tab 

All mills are asked to complete the Equip detail tab. This tab asks for information for each individual emission 

unit. The purpose of this tab is to provide EPA with equipment-specific details needed for the Agency to review the 

technology-based standards (i.e., nationwide numbers of equipment, configuration of controls, pertinent equipment 

details, and regulatory compliance options used).

The types of emission units listed in Attachment 1 that you operate should be included in the Equip detail tab.

Columns A through AQ ask generic questions for all emission units. The columns to the right of column AQ

request design and operating details for specific types of emission units (e.g., recovery furnaces, digesters, etc.).

The table below summarizes the different types of equipment for which specific questions are included in the Equip 

detail tab.
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Equip detail tab 

columns

Description of information requested

A-AQ Equipment, controls, and Federal rule applicability for each emission unit and 

collection system. Complete these columns for all emission units. 

AR-AT Digesters

AJ-AY Pulp washers

AZ-BA Knotters, screens, and deckers

BB-BE Evaporators

BF-BH Oxygen delignification

BI-BR Strippers

BS-BW Pulp storage and liquor storage

BX-CA Liquor storage ponds

CB-CF Causticizing equipment

CG Black liquor gasification

CH-CM Black liquor oxidation systems

CN-DA Recovery furnaces and recovery furnace ESPs

DB-DH Semi-chemical combustion units (at stand-alone semichemical pulp mills)

DI-DN Smelt/ash dissolving tanks

DD-DV Lime kilns (including rotary lime kilns and fluidized bed calciners)

DW Boilers and thermal oxidizers/incinerators

DX-DY Identification of emission units incinerating NCG or SOG

DZ-FJ Fuel types and amounts for fuel-fired equipment (e.g., for lime kilns, recovery 

furnaces, boilers, thermal oxidizers, etc.)

FV-GB Emission unit startup and shutdown.

Data are requested for each emission unit (and need not be broken out by individual emission points for a given 

emission unit unless different collection or control measures apply for the different emission points from an 

emissions unit). Specify the Line ID, Emission Unit ID and Collection system ID (if applicable), and APCD_ID(s) 

by following the directions in the “Instruction” row of the Equip detail tab. Some common configurations of 

emission units are addressed below.

Multiple emission units ducted to a single release point. List each emission unit separately in the Equip 

detail tab even if the exhaust from the emission unit is ducted to a common conveyance. For multiple

emission units ducted through a common conveyance to the same release point, list each Emission Unit ID

separately and provide the same Collection system ID for the different Emission Unit IDs.

For example, an LVHC collection system (Emission Unit ID LVHC01) may collect emissions from 

multiple emission points associated with digesters 1, 2, and 3 and an evaporator (Emission Unit 

IDs D1, D2, D3 and EVAP1). You should list digesters 1, 2, and 3 and the evaporator on four

separate rows in the Equip detail tab (with 4 separate Emission Unit IDs, as shown above) and 

provide the data requested for each emission unit, indicating for each entry that the emissions are 

collected by the LVHC collection system (Emission Unit ID LVHC01). You should also list the 

LVHC collection system in the in the Emission Unit ID column (using the Collection system ID as 

the Emission Unit ID) so you can provide control information and equipment details for the LVHC 

collection system.
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Single emission unit with multiple release points. Repeat the Emission Unit ID on separate rows and 

distinguish the release points using the “Emission unit description” column in as many rows as needed to 

reflect all of the release points associated with the emission unit in the Equip detail tab. For example, 

Emission Unit ID 001 (EU001) is vented to two stacks with different controls. Split EU001 to EU001a and 

EU001b on separate rows of the Equip detail tab, and then indicate in the “REVISED Emission Unit 

Description” column that EU001a and EU001b vent through separate stacks. Enter details associated with 

emission release (APCD information and compliance options for subparts S, MM, or BB) in each row. 

Enter equipment details (year installed, hr/yr, combustion controls, fuel data, equipment design and other 

operating parameters) in only 1 row, leaving all other rows associated with the Emission Unit ID blank.

Emission units vented into the building. Include emissions units that vent into a building in the Equip 

detail tab, and enter “BLDG” in the “Configuration if not emitted through a conveyance” column.

Emission units that are not vented. Include emissions units that are not vented in the Equip detail tab, and 

enter “NV” in the “Configuration if not emitted through a conveyance” column.

Emission units with fugitive emissions. Include emissions units with fugitive emissions in the Equip detail

tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveyance” column.

If an emission unit produces both fugitive emissions and emissions that are emitted though a conveyance 

then you need to specify the fugitive emissions on a separate row in the Equip detail tab (e.g., as a “Single 

emission unit with multiple release points” as described in the instructions immediately above for the Equip 

detail tab).

Bypass stacks used only during certain times. Do not include data for bypass stacks or control system 

bypasses in the Equip detail tab, except as specified for backup controls below.

Air pollution control devices (APCD). In the APCD columns, enter primary air pollution control devices 

(i.e., the pollution control used most frequently) in the sequence in which they are used to control emissions 

from each emission unit (or collection system) identified in the Emission Unit ID column. Enter a 

description of the APCD in the APCD “type” column and an ID code in the APCD_ID column. The ID 

you enter into the APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For 

example,

If you use an ESP (ESP1) followed by a scrubber (WSa), you would enter APCD1 type = ESP and 

APCD2 type = scrubber, and APCD1_ID = ESP1 and APCD2_ID = WSa. 

If a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG prior to burning of the 

SOG in a lime kiln (Emission Unit ID = LK2), then APCD1_ID = WLIQSBR and APCD2_ID 

= LK2.

Emission units routed to a boiler or lime kiln for emissions control. Enter the Emission Unit IDs for each 

emission unit in the Emission Unit ID column. Use the lime kiln’s Emission Unit ID in the APCD 

columns.

Backup controls. Backup controls include alternative controls used when flow from an emission source 

(e.g., LVHC or HVLC collection system) is diverted from the primary control device to a less frequently 

used control device. For example, the primary LVHC control may be lime kiln 1 and the backup control 

may be a boiler when lime kiln 1 is not operating. Enter backup controls in the “Back-up method of 

control” column of the Equip detail tab. Do not include backup controls in the columns for APCD1 

through APCD4.

Complete the applicable equipment-specific details requested in columns AR through GB for each type of emission 

unit in the Equip detail tab by following the directions in the “Instruction” row of the tab. Additional specific 

instructions are provided below for equipment requiring instructions beyond what could be explained in the 

“Instruction” row. Leave columns that do not apply for a given emission unit blank.
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All emission units listed in Attachment 1. Complete columns A through AQ. These columns ask generic questions 

for all emission units related to how the emission units are vented and controlled, and related to Federal rule 

applicability. Additional questions in columns AR through GB may also apply for selected emission unit types.

Pulp processing equipment. Information pertaining to pulp processing equipment such as digesters, pulp washers, 

knotters, screens, deckers, evaporators, and oxygen delignification is requested so EPA can determine the population 

and characteristics of these emission units following subpart S MACT compliance. Capacities are requested so EPA 

can estimate emissions and perform impacts analyses.

Strippers. Information related to strippers is requested to provide an understanding of the number and characteristics 

of strippers in use at pulp and paper mills following subpart S compliance.

Pulp storage and liquor storage, and liquor ponds. HAP emissions may be associated with pulp and cooking liquor 

storage tanks, and liquor storage ponds. Questions pertaining to pulp and liquor storage are asked to provide an 

inventory of storage equipment and to characterize any storage processes that may require further analysis for 

subpart S residual risk purposes.

Causticizing equipment. Limited questions are asked for equipment in the causticizing loop of mills that perform 

kraft, soda, or semichemical pulping. Information on causticizing operations provides inventory detail and process 

rates for purposes of emission calculations, and can inform EPA of practices that could be used to reduce emissions 

from the lime kiln or from other causticizing equipment. 

Recovery furnaces and chemical recovery combustion units. Questions pertaining to recovery furnaces have been 

combined for kraft, kraft with co-located semichemical, soda, and sulfite pulps. The equipment-specific details will 

provide post-MACT recovery furnace and chemical recovery combustion unit configurations. Capacities and other 

design parameters are requested for purposes of impacts analyses.

Smelt tanks and lime kilns. These questions will characterize the population of smelt dissolving tanks and lime kilns 

following subpart MM compliance. Capacities and other design parameters are requested for purposes of impacts 

analyses.

Wastewater handling/treatment units. Complete the generic questions in Columns A through AQ of the Equip detail

tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance.

Boilers. The EPA is requesting limited information on boilers in the Equip detail tab because many pulp and paper 

mills use boilers for primary or backup control of organics from pulping process and because boilers currently 

contribute to the facility-wide risk levels at pulp and paper mills.

Primary and supplemental fuels. Fuel types are requested for fuel-fired equipment because fuel type can have an 

effect on emissions. The EPA may consider fuel types and perform calculations based on fuel firing rates for 

various nationwide impact analyses. Because the types and amounts of fuels fired can vary seasonally, EPA is 

requesting the amount of each fuel type used in 2009 instead of hourly firing rates for each fuel. The annual fuel 

amount can be used with the 2009 emission unit operating hours to derive an annual average fuel firing rate for 

purposes of regulatory analyses.

What if I do not know the answer to a survey question? 

There may be survey questions that you do not know the answer to, or for which information is not 

readily available. If you do not know an answer and cannot reasonably locate an answer, then you 

may enter “UK” for unknown. However, note that survey respondents providing an excessive 

number of “UKs” will most likely receive follow-up inquiries related to their survey response. 
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Primary fuel information is requested for fuel-fired equipment such as boilers, lime kilns, thermal oxidizers, and 

direct-fired dryers (e.g., pulp dryers or paper machine dryers). Primary fuels are not requested for recovery furnaces 

or other chemical recovery combustion units because black liquor (or red liquor) is assumed to be the primary fuel 

for these units. Non-condensible gases (NCG) and SOG are not considered to be either primary or supplemental 

fuels for purposes of this survey. Supplemental and other fuel information is requested for recovery furnaces and

chemical recovery combustion units in addition to other fuel-fired equipment such as boilers, lime kilns, thermal 

oxidizers, and direct-fired dryers. Information for secondary and additional fuels used routinely for multi-fuel fired 

equipment may be indicated in the supplemental and other fuel columns.

Emission unit startup and shutdown. Complete the startup and shutdown questions for all emission units currently 

subject to Federal or State emission limits or monitoring requirements. Questions pertaining to emission unit startup 

and shutdown are asked in order to provide EPA with an understanding of the duration, emissions potential, work 

practices, and control mechanisms of startup and shutdown events for the wide variety of equipment used at pulp 

and paper mills. The EPA is considering standards that could apply during startup and shutdown events (or whether 

the current standards developed for normal operation should apply) in light of the December 2008 vacatur of the 

NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart A. The startup and shutdown 

questions would also identify pulp and paper emission unit types for which startup and shutdown are not already 

addressed with the current emission standards. You are asked to supply information for routine startup and 

shutdown events associated with planned process or mill downtime. (Do not provide information for unplanned 

startup/shutdown events associated with equipment malfunctions). The startup and shutdown data in the Equip 

detail tab are being sought for regulatory development purposes, and will not be used for enforcement purposes. 

d. Controls tab

Complete the Controls tab by following the instructions in the “Instruction” row for add-on air pollution control 

devices used to control pulp and paper emission units. The data requested in the Controls tab include pertinent 

control device design parameters that will be used by EPA to distinguish among control devices (e.g., pressure drop 

and L/G ratio can be used to identify high vs. low efficiency wet scrubbers) and to understand the non-air 

environmental impacts associated with the control devices (e.g., amount of wastewater or solid waste generated and 

methods for handling).

Boilers. You do not need to include air pollution control device details for boilers in the Controls tab since NCGs 

combusted by boilers are presumed to be destroyed in the boiler and are subsequently unaffected by the boiler’s 

APCD. 

Control efficiency. Actual and design control efficiencies are requested for PM, TRS, HCl, SO2, and other HAP. 

This information will be used in determining the capability of different control devices for reducing emissions. If 

you have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant 

across the control device, that you would enter this test result as the “actual” control efficiency. If you do not have 

test data specifying the actual control efficiency, then the control device manufacturer’s “design” control efficiency 

is requested for applicable pollutants. Please enter both the actual and design control efficiency if available. Leave

the control efficiency columns blank if actual or design control efficiency is not known (or not applicable for a given 

pollutant). 

Strippers. Specific information for strippers used to reduce air emissions from process liquid or wastewater streams 

is requested in the Equip detail tab rather than in the Controls tab.

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

tabs. The Equip detail tab contains questions about heat input capacity, equipment incinerating NCG or SOG, and 

primary or supplemental fuels.

Control device startup and shutdown. The EPA is considering standards that could apply during startup and 

shutdown events (or whether the current standards developed for normal operation should apply) in light of the 
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December 2008 vacatur of the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart 

A. Questions pertaining to control device startup and shutdown are asked in order to provide EPA with an 

understanding of the duration and definition of startup and shutdown events for the types of control devices used at 

pulp and paper mills. The EPA is seeking information on the integral nature of startup and shutdown events for the 

different combinations of emission units and control devices used in the pulp and paper industry. In addition, 

because Federal NSPS and NESHAP require continuous monitoring of emissions or control device operating 

parameters, information is requested to inform EPA of particular pulp and paper NSPS or NESHAP control device 

parameter limits that cannot feasibly be met during startup and shutdown events. Certain parameters may be 

"instant on" while others are more transient in nature (i.e., changing as startup or shutdown progresses). Examples 

could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved 

due to low exhaust gas flow from the emission unit. The EPA will use this information to evaluate which existing 

control device parameter limits may remain in effect during startup and shutdown events, and which parameter 

limits may need to be replaced with another requirement during startup and shutdown. In all of the control device 

startup and shutdown questions, you are asked to supply information for routine startup and shutdown events

associated with planned equipment or mill downtime. (Do not provide information for unplanned startup/shutdown 

events associated with equipment malfunctions). The startup and shutdown data in the Controls tab are being 

sought for regulatory development purposes, and will not be used for enforcement purposes. 

e. Potential changes tab

The Potential changes tab lists several types of mill changes that could affect emissions or rule applicability. This 

information will be used by EPA in projecting the number of new emission units likely to be installed for purposes 

of new source impacts analyses. Most of the questions in the Potential changes tab have yes/no answers, with

additional description requested for any planned changes.

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

f. Pulp prod tab

The Pulp prod tab is to be completed by all mills that produce pulp onsite using chemical, semichemical, 

mechanical, non-wood, and secondary fiber pulping processes. This tab is arranged in a way to accommodate 

multiple pulping lines and each pulping line should occupy only one row (e.g. co-produces kraft and mechanical 

pulps use two rows). Some data fields apply for specific types of pulp (e.g., mechanical pulp, non-wood pulp). If a

data field does not apply to a particular type of pulping line, simply leave the field blank. Provide data for the 2009 

operating year. The pulp production data will be used by EPA to understand the general mill flow and in estimation 

of impacts and economic analyses. 

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

g. Byproducts tab 

Mills that recover turpentine or tall oil from pulping processes should complete the Byproducts tab. Basic turpentine 

and tall oil production information are requested (hr/yr, gal/day and digesters supplying byproduct production). 

Turpentine recovery systems are covered under subpart S. Tall oil production may be considered in the review of 

pulp and paper regulations. The information requested may be used to estimate emissions and in economic 

calculations.

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

h. PCC tab

Mills that route lime kiln, boiler, or other process exhaust to a precipitated calcium carbonate (PCC) plant should 

complete the PCC tab. Information regarding the emission units involved, time, controls, and portion of process 
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exhaust routed to the PCC plant are requested. Questions regarding land ownership and permitting are also asked. 

This information would help regulation writers understand the nature of this process should routing of exhaust to an 

onsite PCC plant need to be mentioned (e.g., with a special provision, exemption, etc.) in a regulation.

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

i. Kraft condensates tab

Complete the Kraft condensates tab by following the instructions in the “Instruction” row. The kraft condensate 

control options are summarized as follows. This table corresponds with the pull down menu options for condensates 

treated by steam strippers, biological treatment, or other means. 

Control option Applicability Rule reference

92% total HAP reduction (by weight) §63.446(e)(3)

Remove 6.6 pounds/ton ODP Mills that do not bleach §63.446(e)(4)

210 ppmw at the outlet of the control 

device Mills that do not bleach §63.446(e)(4)

Remove 10.2 pounds/ton ODP Mills that bleach §63.446(e)(5)

330 ppmw at the outlet of the control 

device Mills that bleach §63.446(e)(5)

Remove prorated mass of ___ pounds/ton 

ODP. {Respondent should specify limit in 

blank}

Mills producing a 

mixture of bleached and 

unbleached pulp §63.446(i)

j. CCA tab

The CCA tab is divided into two portions: (1) Emission Balance to the left of the orange vertical line (column I), and 

(2) CCA Equipment List on the right of the orange vertical line. You will enter one row of data for the Emissions 

Balance and multiple rows of data for the CCA Equipment List.

The CCA tab must be completed once for each set of CCA compliance calculations used by your mill. Add another 

CCA tab if you need to provide more than one set of CCA calculations. As an alternative to completing the CCA 

tab, you may attach separate documentation of your CCA calculations used for purposes of showing compliance. 

Sources eligible for inclusion in the CCA as credit generators include: pulping systems, bleaching systems, 

causticizing systems, and papermaking systems. Debit generating sources can include equipment from the kraft 

mill HVLC system, including: pulp washing systems, knotter systems, screen systems, decker systems, O2 

delignification systems, and weak liquor storage tanks. Refer to the system definitions in subpart S at §§63.441 and 

63.447(a). EPA is not requesting detailed calculations used to show compliance with the CCA at this time. 

However, EPA reserves the right to request additional detail if needed as a follow-up to this survey. 

Complete the CCA tab by following the instructions in the “Instruction” row.
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k. Bleaching tab

All mills that perform bleaching should complete the portion of this tab to the left of the orange vertical line (column 

O) to describe the bleaching systems used at your mill. Your response will consist of one row for each bleaching 

line located at your mill. Most mills will have only one or two bleaching line rows.

If your bleaching system includes any stages that use chlorine or chlorinated compounds, then you must complete

the portion of this tab to the right of the orange vertical line. Extraction or other bleaching stages that do not use 

chlorine or chlorinated compounds are not covered by subpart S and should be reported with “NA (no chlorine or 

chlorinated compounds used in this stage)” indicated.

Responses to these bleaching questions will be used to characterize mills according to bleaching processes used, 

estimate nationwide emissions, and identify subpart S compliance options commonly used (e.g., to determine if any

remaining residual risk is associated only with bleaching at mills meeting certain compliance options). Information 

on how the mill uses the pulp exiting the bleach plant may be used for economic modeling and in characterization of 

potential emissions from paper machines (e.g., use of bleached/unbleached pulp produced onsite, use of purchased 

pulp, effects of bleaching process on paper machine emissions, etc).

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

l. Paper prod tab

All mills that produce paper should complete the Paper prod tab. Report information for all operable paper 

machines (including idle machines that are capable of operating in the future). Complete the Paper prod tab by 

following the instructions in the “Instruction” row.

If multiple paper grades are produced on the same paper machine (e.g., coated free sheet produced some of the time, 

and uncoated freesheet produced at other times), then you will need to include paper machine information on 

separate rows. Given the numerous specific grades of paper and paper characteristics, EPA requests that you 

distinguish among a relatively short list of generalized paper grades, including: 

coated free sheet kraft packaging

uncoated free sheet linerboard

coated groundwood corrugating medium

uncoated groundwood solid bleached board

tissue & sanitary recycled board

specialty packaging & industrial construction paper and board

other *

*Respondents are asked to specify a general paper grade in the event that one of the 

 general grades listed above is not representative.

Information on pulp type is requested because it is possible that pulp type may have an effect on emissions 

(particularly for bleached versus unbleached pulps). Should EPA consider paper machines for residual risk 

rulemaking, information such as pulp type, whether the pulp is bleached or unbleached, paper grade, and liquid HAP 

concentration may be useful for purposes of subcategorizing of paper machines. 

You are asked to specify the approximate makeup of each paper machine furnish - specifically the approximate 

percentage of each pulp type. We recognize that the percentage can vary throughout the operating year, and 

therefore, a specific percentage is not being requested. It will be sufficient to round to the nearest 5 or 10 percent.
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m. HAP additives tab

Complete the HAP additives tab for any stock preparation and paper machine additives that contain measurable 

concentrations of one or more of the following HAP: formaldehyde, acetaldehyde, napthalene, methylene chloride, 

acrylamide, or benzene. Only include in this tab additives with measurable quantities of HAP as reported on the 

material safety data sheet (MSDS) for the additive. Although it is unclear whether paper machine additives 

contribute significantly to paper machine emissions (e.g., because additives may partition to the paper product or 

white water, and not necessarily to the air) EPA is requesting information for paper machine additives that contain 

HAP of significance for purposes of residual risk. EPA is not requesting information for other paper machine 

additives (many of which contain no HAP). The HAP additives information would be used (e.g., along with 

emissions data for paper machines) to identify HAP-containing additives that may contribute significantly to paper 

machine HAP emissions or residual risk, and to evaluate work practices related to additives. 

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

n. WW tab

All mills with onsite wastewater treatment plants (WWTP) should complete the WW tab columns to the left of the 

orange vertical line (column W). The purpose of the WW tab is to provide EPA with information regarding the

status of permitting requirements and emissions measurement for pulp and paper mill wastewater treatment plants. 

This information will be used by EPA for purposes of reviewing the pulp and paper regulations (e.g., NSPS and/or 

NESHAP subpart S). Use the WW tab to specify any Federal/State/local requirements, permit limits, fence-line 

monitoring, measurement methods (such as ambient measurements), or modeling methods that apply for 

measurement or estimation of HAP and TRS (including H2S) air emissions associated with the wastewater treatment 

system.

In addition to questions about measurement and permitting status, mills are requested to submit a flow diagram of 

the WWTP (see section D1 of these instructions) and to complete some basic questions regarding WWTP capacity, 

the sequence of wastewater treatment units, and upstream controls/practices that reduce air emissions from the 

WWTP. Mills are also asked to identify any wastewater treatment units that are closed to limit emissions to the 

atmosphere, or equipped with a closed vent collection system and APCD. If any wastewater treatment units are 

equipped with a closed vent collection system and APCD, then you should also include the wastewater treatment 

unit in the Emission Unit ID column of the Equip detail and Control tabs and indicate the APCD information in 

those tabs. 

Mills with wastewater treatment plants that serve as the biological treatment system for the subpart S kraft 

condensate standards must complete the questions to the right of the orange vertical line in the WW tab. These 

questions request the subpart S quarterly biological treatment system compliance testing results for the four quarters 

of calendar year 2009. This information will inform EPA of the performance of biological treatment systems in 

destroying HAP.

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

D4. Test data

Attachment 6 of this survey contains a table of emission units and pollutants for which existing emissions

data are requested. Emissions data are being requested in the form of emissions test reports or continuous emissions 

monitoring, whichever may be available. You are not required to conduct any new emissions testing or continuous 

emissions monitoring to respond to this survey. Follow the instructions below for the “Emissions test data tab” for 

emissions test reports. Follow the instructions for completing the “CEMS data spreadsheet (P&P CEMS 

spreadsheet.xls)” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports 

for a given emission unit and pollutant combination. The emissions test data collected will provide valuable 
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information on current emissions levels and will allow EPA to consider variability in emissions from mill to mill 

(and over time for a given emission unit and pollutant) in reviewing and setting emission standards. When 

submitting test data, EPA is requesting full test reports with field and lab data sheets and example calculations, not 

just summary reports.

a. Emissions test data tab

Attachment 6 of this survey contains a table of emission units and pollutants for which existing emission test data

are requested. You are not required to conduct any new emissions testing to respond to this survey. The EPA is 

only requesting existing emission test reports at this time as they may already be available. 

Review the test data request table in Attachment 6 of this survey. Locate any existing emissions test reports in your 

files that match the test method and other criteria for each emission unit and pollutant combination requested. 

Emissions test data representative of your current operations are requested. You are not required to supply 

emissions data that are no longer representative of the current emission unit and control system configuration. For 

example, if you have installed controls or made significant process changes expected to change emissions, then you 

need not supply emissions data for the prior configuration. However, you may voluntarily supply emissions data for 

prior configurations, as such information would be useful to EPA in characterizing emissions in general (for nonsite-specific uses), but we request that you identify that such data are no longer representative in the Emissions test 

data tab.

Cutoff dates are provided in Attachment 6 for certain emission unit and pollutant combinations. More recent cutoff 

dates are specified for emission unit and pollutant combinations expected to be widely available (e.g., 2001 or date 

of MACT compliance). Longer cutoff dates are included for emission unit and pollutant combinations for which 

data are likely to be sparse (e.g., dating back to 1990). Test data prior to the cutoff dates are requested only if 

necessary to obtain results of at least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff date. Multiple years of test data will allow 

EPA to examine and account for variability in emissions in setting emissions standards. 

Supply both air pollution control device inlet and outlet data if available. 

As noted above, submit full and complete copies of the emission test reports, to include field and lab data sheets and 

example calculations, meeting the criteria in Attachment 6 with your survey response.

Electronic (pdf) or hard copies are acceptable. Include the summary portion of the report and any appendices 

showing run-by-run test parameters, method detection limits, laboratory data, production data, example calculations, 

etc. EPA will extract the test data from the emission test reports for use in nationwide regulatory analyses.

Complete the Emission test data tab to identify the specific emission units and control systems for which emission 

test reports are being submitted, the pollutant tested, and the test method. The Emission test data tab will be used by 

EPA as the starting point for development of the emissions test data base that EPA intends to construct based on the 

emission test data received through this survey.

b. CEMS data spreadsheet (P&P CEMS spreadsheet.xls)

The EPA is requesting the most recent 30 days of existing CEMS data and/or continuous opacity monitoring system 

(COMS) data from facilities that have installed continuous monitoring systems in order to comply with regulatory 

requirements or permit conditions. You are not required to install or operate any new CEMS or COMS to respond 

to this survey.

CEMS data that are representative of your current operations are requested. You are not required to supply CEMS 

data that are no longer representative of the current emission unit and control system configuration. 
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A separate Microsoft Excel spreadsheet (P&P CEMS Spreadsheet.xls) is provided for submittal of the requested 

CEMS data. The spreadsheet contains individual worksheets (tabs) designed specifically for TRS (12-hour block 

average), TRS (hourly), Opacity, NOx, SO2, CO, Methanol, Chlorine, and PM. Each worksheet is designed to 

accommodate data from one CEMS (including oxygen data). If you have multiple CEMS of the same type (e.g., 

two TRS CEMS on different emission units), then you must copy the relevant worksheet in order to enter data for 

the additional CEMS.

A brief introduction to each of the CEMS worksheets follows. Additional, field-specific instructions are included on 

each worksheet. An “EXAMPLE” completed worksheet is also provided as a separate tab within the P&P CEMS 

Spreadsheet.xls.

TRS (12-Hour Average). This worksheet is designed for recovery furnaces, smelt dissolving tanks, lime 

kilns, digester systems, brown stock washer systems, multiple effect evaporator systems, and condensate 

stripper systems subject to the TRS monitoring requirements in NSPS subpart BB, but can be used for any 

emission units with TRS CEMS. Respondents are requested to specify the Emission_Unit_ID (or collection 

system ID), the APCD_ID, and report the 12-hour averages of CEMS concentration data for TRS for the 

most recent 30 days of operation. In addition, respondents are asked to provide the highest single 12-hour 

average TRS concentration within the most recent calendar year (CY2009) recorded: (a) under normal 

operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions. 

(The data for startup, shutdown, and malfunction may be included in the most recent 30 days of CEMS data, 

or may be for a 12-hour period outside the most recent 30 days). [Note: The reported concentrations of TRS 

should be corrected to 8% O2 for recovery furnaces and 10% O2 for lime kilns and other equipment.]

TRS (1-Hour Average). Same as above, except that this worksheet is designed to accept the 1-hour average 

TRS data for the same 30-day period as provided for the 12-hour averages.

Opacity. This worksheet is designed for recovery furnaces or lime kilns equipped with COMS. 

Respondents are requested to specify the Emission_Unit_ID (or Collection system ID), the APCD_ID, and 

report the 6-minute and 1-hour averages of opacity for the most recent 30 days of operation. In addition, 

respondents are asked to provide the highest single 6-minute average opacity recorded within the most recent 

calendar year (CY2009) recorded: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions. (The data for startup, shutdown, and malfunction may be 

included in the most recent 30 days of COMS data, or may be for an hour outside the most recent 30 days.)

NOx, SO2, and CO. These worksheets are designed for recovery furnaces or lime kilns equipped with CEMS 

for NOx, SO2, or CO, but can be used for other emission units equipped with these CEMS. Respondents are 

requested to specify the Emission_Unit_ID (or Collection system ID), the APCD_ID (or type of combustion 

controls used), and report the 1-hour averages of the CEMS data for these compounds for the most recent 30 

days of operation. In addition, respondents are asked to provide the highest single 1-hour average 

concentration within the most recent calendar year (CY2009) recorded: (a) under normal operating 

conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions. (The data for 

startup, shutdown, and malfunction may be included in the most recent 30 days of CEMS data, or may be for 

an hour outside the most recent 30 days.)

Total HAP or Methanol. This worksheet is designed for total HAP or methanol CEMS installed to 

demonstrate compliance with the NESHAP subpart S limits for LVHC systems, HVLC systems, or steam 

strippers (but can be used for other emission units equipped with these CEMS). Respondents are requested 

to identify the source of NCGs/SOGs being controlled by Emission_Unit_ID (or Collection system ID), the 

APCD_ID, and report the 1-hour averages of the CEMS data for the most recent 30 days of operation. In 

addition, respondents are asked to provide the highest single 1-hour average within the most recent calendar 

year (CY2009) recorded: (a) under normal operating conditions, (b) under conditions of startup or shutdown, 

and (c) under malfunction conditions. (The data for startup, shutdown, and malfunction may be included in 

the most recent 30 days of CEMS data, or may be for an hour outside the most recent 30 days).
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Total Chlorinated HAP or Chlorine. This worksheet is designed for total chlorinated HAP or chlorine CEMS 

installed to show compliance with the NESHAP subpart S limits for bleaching systems (but can be used for 

other emission units equipped with these CEMS or HCl CEMS). Respondents are requested to indicate the 

Emission_Unit_ID (or Collection system ID) being controlled, the APCD_ID, and report the 1-hour averages 

of the CEMS data for the most recent 30 days of operation. In addition, respondents are asked to provide the 

highest single 1-hour average within the most recent calendar year (CY2009) recorded: (a) under normal 

operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions. 

(The data for startup, shutdown, and malfunction may be included in the most recent 30 days of CEMS data, 

or may be for an hour outside the most recent 30 days).

PM. This worksheet is designed for any emissions unit equipped with a PM CEMS. Respondents are 

requested to specify the Emission_Unit_ID (or Collection system ID), the APCD_ID, and report the 1-hour 

averages of the CEMS data for the most recent 30 days of operation. In addition, respondents are asked to 

provide the highest single 1-hour average concentration within the most recent calendar year (CY2009)

recorded: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under 

malfunction conditions. (The data for startup, shutdown, and malfunction may be included in the most recent 

30 days of CEMS data, or may be for an hour outside the most recent 30 days).

OPTIONAL-CEMS cost. Completion of this worksheet is OPTIONAL. This worksheet requests equipment 

cost data for CEMS or COMS installed within the past 10 years. EPA can use these data to estimate costs of 

CEMS or COMS when evaluating monitoring options.

D5. Optional cost data

The EPA requests information related to the capital and operating costs of selected air pollution controls or 

process/equipment changes. Providing this cost information to EPA is optional at this time. As noted in the Section 

114 letter accompanying this survey, an additional 60 days beyond the due date for the other portions of your survey 

response is allowed for submittal of the optional cost information. The Agency wishes to receive enough cost 

information on a voluntary basis to perform regulatory analyses. However, should additional cost information be 

needed, EPA reserves the right to follow up with mills that have installed equipment or implemented process 

changes of interest to request cost information under CAA section 114 authority. 

The spreadsheet entitled “P&P costs OPTIONAL.xls” can be completed to provide cost information. This 

spreadsheet contains two tabs (APCD costs and Equip change costs). The EPA recognizes that cost information can 

be sensitive. The “P&P costs OPTIONAL.xls” spreadsheet contains a red block at the top of each tab where you 

can indicate if the tab contains CBI, or if the entire tab should be treated as CBI. Responses containing CBI should 

be submitted according to the instructions in section C1 of this document.

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs of control 

measures that may be considered as regulatory options. These cost data will be used by EPA to estimate the 

nationwide costs of any regulatory options based on the control measure indicated. Cost information from within

the last 10-12 years is requested (e.g., costs dating back to 1998). The cost information could come from vendor 

quotes for APCD or equipment changes that either have been implemented or were explored but not implemented.

The EPA is particularly interested in costs of the following air pollution control devices (APCD). Please supply this 

information using the APCD costs tab:

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

selective non-catalytic reduction (SNCR)

 - Black liquor oxidizer incinerators or thermal oxidizers

 - Lime kiln electrostatic precipitators (ESP)

 - Bleach plant CO control devices
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The EPA is particularly interested in costs of the following process changes or equipment changes/upgrades. Please 

supply this information using the Equip change costs tab.

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

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

 - Changing from a dry bottom/wet PM return ESP to a dry bottom/dry PM return ESP

 - Adding chambers/fields to an existing ESP 

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

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

 - Replacing a recovery furnace with a black liquor gasification system

Complete the APCD costs and Equip change costs tabs by following the instructions in the “Instruction” rows of 

those tabs. You may also submit information in an alternative format (e.g., as an attachment to your response) if 

needed. Because the cost data will be used by EPA to estimate the nationwide costs, please note if you believe that 

any portion of the cost information that you supply would be completely unrepresentative of costs that other mills 

may face for similar control projects (e.g., if your project capital cost included installation extra buildings, land 

purchases, etc. that may not be required for other mills). 

 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

30

ATTACHMENT 1

Emission Units to Include in the Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your survey response (Inventory and Equip detail tabs). 

You may not operate all of the emission units listed below. Only include equipment operated at your mill. 

The “Lookups for P&P survey.xls” file contains a crosswalk of the equipment listed in this attachment with the 

available SCCs.

Chemical Recovery Combustion Equipment

Chemical recovery furnace

Chemical recovery combustion unit 

Black liquor oxidization system

Smelt or ash dissolving tank

Lime kiln or calciner 

Black liquor gasification systems

Sulfur burner

Causticizing Equipment

Green liquor clarifier

Green liquor storage tank

Green liquor surge tank

Slaker

Causticizers

White liquor clarifier

White liquor storage tank

White liquor pressure filter tank

White liquor/weak wash pressure filter

Weak wash storage tank

Dregs washer

Dregs filter exhaust

Salt cake mix tank

Lime mud washer

Lime mud filter system

Digester Area Equipment

Digester

Chip bin

Chip steaming vessel

Flash tank

Blow tank

Condenser

Turpentine decanter

Pulp Washing, Thickening, and Storage Equipment

Brown stock washers

Hoods

Filtrate tanks

Vacuum pumps

Screens

Knotters

Decker

Stock chests (including open stock chests)

Pulp storage tanks

Thickeners

Pulp dryers

Evaporators

Black liquor storage tanks

Evaporator hot wells

Condensers

Boilout tanks

Soap storage tanks

Soap skimmer tanks

Other emission points associated with the 

evaporators. 

Oxygen Delignification Equipment

Oxygen delignification reactor

Oxygen delignification blow tank

Oxygen delignification washer

Post-oxygen washer filtrate tank

Pulp storage tanks 

Other oxygen delignification system emission points.

Non-condensable gas (NCG) Collection

LVHC system

HVLC system

Stripper System Equipment

Stripper feed tanks

Condensers

Heat exchangers

Methanol Rectification Equipment

Rectifiers

Condensers

Decanters

Storage tanks 

Storage Tanks

Weak liquor storage tanks

Strong liquor storage tanks

Liquor storage ponds

Acid condensate storage tanks (at sulfite mills)
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

31

Tall Oil Production Equipment

Tall oil acidulation reactor

Storage tank

Dehydrator

Brine storage tank

Screen

Centrifuge tank

Other tall oil production vents 

Mechanical Pulping Equipment

Stone grinder

Refiner

Chip pre-steaming vessel

Chip cooker 

Screen 

Decker

Brightening/bleaching tower 

Non-wood Pulping Equipment

Secondary Fiber Pulping Equipment

Bleaching Equipment

Tower vents

Washer hoods

Seal tank vents

Chemical and steam mixers

Vacuum pumps

Paper Making Equipment

Paper machines

Pulp dryers

Machine chest

Repulpers

Stock blending and storage tanks

Broke tanks

Savealls

White water storage tanks

Wastewater treatment system units

Clarifiers

Settling ponds

Aerated stabilization basins

UNOX systems

Wastewater tanks

Other wastewater handling and treatment units 

Power boilers (including small package boilers)

Thermal oxidizers/incinerators

Woodyard operations
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

32

ATTACHMENT 2

NSPS and NESHAP Definitions

NSPS Subpart BB Definitions (40 CFR Part 60, § 60.281). 

(a) Kraft pulp mill means any stationary source which produces pulp from wood by cooking (digesting) wood chips 

in a water solution of sodium hydroxide and sodium sulfide (white liquor) at high temperature and pressure. 

Regeneration of the cooking chemicals through a recovery process is also considered part of the kraft pulp mill. 

(b) Neutral sulfite semichemical pulping operation means any operation in which pulp is produced from wood by

cooking (digesting) wood chips in a solution of sodium sulfite and sodium bicarbonate, followed by mechanical 

defibrating (grinding). 

(c) Total reduced sulfur (TRS) means the sum of the sulfur compounds hydrogen sulfide, methyl mercaptan, 

dimethyl sulfide, and dimethyl disulfide, that are released during the kraft pulping operation and measured by 

Method 16. 

(d) Digester system means each continuous digester or each batch digester used for the cooking of wood in white 

liquor, and associated flash tank(s), blow tank(s), chip steamer(s), and condenser(s). 

(e) Brown stock washer system means brown stock washers and associated knotters, vacuum pumps, and filtrate 

tanks used to wash the pulp following the digester system. Diffusion washers are excluded from this definition. 

(f) Multiple-effect evaporator system means the multiple-effect evaporators and associated condenser(s) and 

hotwell(s) used to concentrate the spent cooking liquid that is separated from the pulp (black liquor). 

(g) Black liquor oxidation system means the vessels used to oxidize, with air or oxygen, the black liquor, and 

associated storage tank(s). 

(h) Recovery furnace means either a straight kraft recovery furnace or a cross recovery furnace, and includes the 

direct-contact evaporator for a direct- contact furnace. 

(i) Straight kraft recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and 

sulfur compounds by burning black liquor which on a quarterly basis contains 7 weight percent or less of the total 

pulp solids from the neutral sulfite semichemical process or has green liquor sulfidity of 28 percent or less. 

(j) Cross recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and sulfur 

compounds by burning black liquor which on a quarterly basis contains more than 7 weight percent of the total 

pulp solids from the neutral sulfite semichemical process and has a green liquor sulfidity of more than 28 percent. 

(k) Black liquor solids means the dry weight of the solids which enter the recovery furnace in the black liquor. 

(l) Green liquor sulfidity means the sulfidity of the liquor which leaves the smelt dissolving tank.

(m) Smelt dissolving tank means a vessel used for dissolving the smelt collected from the recovery furnace. 

(n) Lime kiln means a unit used to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, 

which is calcium oxide. 

(o) Condensate stripper system means a column, and associated condensers, used to strip, with air or steam, TRS 

compounds from condensate streams from various processes within a kraft pulp mill. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

33

NESHAP Subpart MM Definitions (40 CFR Part 63, § 63.861)

Bag leak detection system means an instrument that is capable of monitoring PM loadings in the exhaust of a fabric 

filter in order to detect bag failures. A bag leak detection system includes, but is not limited to, an instrument that 

operates on triboelectric, light scattering, light transmittance, or other principle to monitor relative PM loadings. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or 

semichemical pulping process. 

Black liquor gasification means the thermochemical conversion of black liquor into a combustible gaseous product. 

Black liquor oxidation (BLO) system means the vessels used to oxidize the black liquor, with air or oxygen, and the 

associated storage tank(s). 

Black liquor solids (BLS) means the dry weight of the solids in the black liquor that enters the recovery furnace or 

semichemical combustion unit. 

Black liquor solids firing rate means the rate at which black liquor solids are fed to the recovery furnace or the 

semichemical combustion unit. 

Chemical recovery combustion source means any source in the chemical recovery area of a kraft, soda, sulfite or 

stand-alone semichemical pulp mill that is an NDCE recovery furnace, a DCE recovery furnace system, a smelt 

dissolving tank, a lime kiln, a sulfite combustion unit, or a semichemical combustion unit. 

Chemical recovery system means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, and lime 

kilns at a kraft or soda pulp mill. Each existing recovery furnace, smelt dissolving tank, or lime kiln is considered 

a process unit within a chemical recovery system. 

Direct contact evaporator (DCE) recovery furnace means a kraft or soda recovery furnace equipped with a direct 

contact evaporator that concentrates strong black liquor by direct contact between the hot recovery furnace 

exhaust gases and the strong black liquor. 

Direct contact evaporator (DCE) recovery furnace system means a direct contact evaporator recovery furnace and 

any black liquor oxidation system, if present, at the pulp mill. 

Dry electrostatic precipitator (ESP) system means an electrostatic precipitator with a dry bottom (i.e., no black 

liquor, water, or other fluid is used in the ESP bottom) and a dry particulate matter return system (i.e., no black 

liquor, water, or other fluid is used to transport the collected PM to the mix tank). 

Fabric filter means an air pollution control device used to capture PM by filtering a gas stream through filter media;

also known as a baghouse. 

Hazardous air pollutants (HAP) metals means the sum of all emissions of antimony, arsenic, beryllium, cadmium, 

chromium, cobalt, lead, manganese, mercury, nickel, and selenium as measured by EPA Method 29 (40 CFR part 

60, appendix A) and with all nondetect data treated as one-half of the method detection limit. 

Hog fuel dryer means the equipment that combusts fine particles of wood waste (hog fuel) in a fluidized bed and 

directs the heated exhaust stream to a rotary dryer containing wet hog fuel to be dried prior to combustion in the 

hog fuel boiler at Weyerhaeuser Paper Company’s Cosmopolis, Washington facility. The hog fuel dryer at 

Weyerhaeuser Paper Company’s Cosmopolis, Washington facility is Emission Unit no. HD–14. 

Kraft pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sodium hydroxide and sodium sulfide. The recovery process used to regenerate cooking chemicals is 

also considered part of the kraft pulp mill. 

Kraft recovery furnace means a recovery furnace that is used to burn black liquor produced by the kraft pulping 

process, as well as any recovery furnace that burns black liquor produced from both the kraft and semichemical 

pulping processes, and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

34

Lime kiln means the combustion unit (e.g., rotary lime kiln or fluidized-bed calciner) used at a kraft or soda pulp 

mill to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, which is calcium oxide 

(CaO). 

Lime production rate means the rate at which dry lime, measured as CaO, is produced in the lime kiln. 

Method detection limit means the minimum concentration of an analyte that can be determined with 99 percent 

confidence that the true value is greater than zero. 

Modification means, for the purposes of § 63.862(a)(1)(ii)(E)(1), any physical change (excluding any routine part 

replacement or maintenance) or operational change (excluding any operational change that occurs during a startup, shutdown, or malfunction) that is made to the air pollution control device that could result in an increase in 

PM emissions. 

Nondetect data means, for the purposes of this subpart, any value that is below the method detection limit. 

Nondirect contact evaporator (NDCE) recovery furnace means a kraft or soda recovery furnace that burns black 

liquor that has been concentrated by indirect contact with steam. 

Particulate matter (PM) means total particulate matter as measured by EPA Method 5, EPA Method 17 (§ 

63.865(b)(1)), or EPA Method 29 (40 CFR part 60, appendix A). 

Process unit means an existing DCE or NDCE recovery furnace, smelt dissolving tank, or lime kiln in a chemical 

recovery system at a kraft or soda mill. 

Recovery furnace means an enclosed combustion device where concentrated black liquor produced by the kraft or 

soda pulping process is burned to recover pulping chemicals and produce steam. Includes black liquor 

gasification. 

Regenerative thermal oxidizer (RTO) means a thermal oxidizer that transfers heat from the exhaust gas stream to the 

inlet gas stream by passing the exhaust stream through a bed of ceramic stoneware or other heat-absorbing 

medium before releasing it to the atmosphere, then reversing the gas flow so the inlet gas stream passes through 

the heated bed, raising the temperature of the inlet stream close to or at its ignition temperature. 

Semichemical combustion unit means any equipment used to combust or pyrolyze black liquor at stand-alone 

semichemical pulp mills for the purpose of chemical recovery. Includes black liquor gasification. 

Similar process units means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, or lime kilns at 

a kraft or soda pulp mill. 

Smelt dissolving tanks (SDT) means vessels used for dissolving the smelt collected from a kraft or soda recovery 

furnace. 

Soda pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

sodium hydroxide solution. The recovery process used to regenerate cooking chemicals is also considered part of 

the soda pulp mill. 

Soda recovery furnace means a recovery furnace used to burn black liquor produced by the soda pulping process 

and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 

Stand-alone semichemical pulp mill means any stationary source that produces pulp from wood by partially 

digesting wood chips in a chemical solution followed by mechanical defibrating (grinding), and has an onsite 

chemical recovery process that is not integrated with a kraft pulp mill. 

Startup means, for the chemical recovery system employing black liquor gasification at Georgia-Pacific’s facility in 

Big Island, Virginia only, the end of the gasification system commissioning phase. Commissioning is that period 

of time in which each part of the new gasification system will be checked and operated on its own to make sure it 

is installed and functions properly. Commissioning will conclude with the successful completion of the 

gasification technology supplier’s performance warranty demonstration, which proves the technology and 

equipment are performing to warranted levels and the system is ready to be placed in active service. For all other 

affected sources under this subpart, startup has the meaning given in § 63.2. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

35

Sulfite combustion unit means a combustion device, such as a recovery furnace or fluidized-bed reactor, where spent 

liquor from the sulfite pulping process (i.e., red liquor) is burned to recover pulping chemicals. 

Sulfite pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sulfurous acid and bisulfite ions. The recovery process used to regenerate cooking chemicals is also 

considered part of the sulfite pulp mill. 

Total hydrocarbons (THC) means the sum of organic compounds measured as carbon using EPA Method 25A (40 

CFR part 60, appendix A). 

NESHAP Subpart S Definitions (40 CFR Part 63, § 63.441): 

All terms used in this subpart shall have the meaning given them in the CAA, in subpart A of this part, and in this 

section as follows: 

Acid condensate storage tank means any storage tank containing cooking acid following the sulfur dioxide gas 

fortification process. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or semichemical pulping process. 

Bleaching means brightening of pulp by the addition of oxidizing chemicals or reducing chemicals. 

Bleaching line means a group of bleaching stages arranged in series such that bleaching of the pulp progresses as the 

pulp moves from one stage to the next. 

Bleaching stage means all process equipment associated with a discrete step of chemical application and removal in 

the bleaching process including chemical and steam mixers, bleaching towers, washers, seal (filtrate) tanks, 

vacuum pumps, and any other equipment serving the same function as those previously listed. 

Bleaching system means all process equipment after high-density pulp storage prior to the first application of 

oxidizing chemicals or reducing chemicals following the pulping system, up to and including the final bleaching 

stage. 

Boiler means any enclosed combustion device that extracts useful energy in the form of steam. A boiler is not 

considered a thermal oxidizer. 

Chip steamer means a vessel used for the purpose of preheating or pretreating wood chips prior to the digester, using 

flash steam from the digester or live steam. 

Closed-vent system means a system that is not open to the atmosphere and is composed of piping, ductwork, 

connections, and, if necessary, flow-inducing devices that transport gas or vapor from an emission point to a 

control device. 

Combustion device means an individual unit of equipment, including but not limited to, a thermal oxidizer, lime 

kiln, recovery furnace, process heater, or boiler, used for the thermal oxidation of organic hazardous air pollutant 

vapors. 

Decker system means all equipment used to thicken the pulp slurry or reduce its liquid content after the pulp 

washing system and prior to high-density pulp storage. The decker system includes decker vents, filtrate tanks, 

associated vacuum pumps, and any other equipment serving the same function as those previously listed. 

Digester system means each continuous digester or each batch digester used for the chemical treatment of wood or 

non-wood fibers. The digester system equipment includes associated flash tank(s), blow tank(s), chip steamer( s) 

not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding 

the pulp washing system, and any other equipment serving the same function as those previously listed. The 

digester system includes any of the liquid streams or condensates associated with batch or continuous digester 

relief, blow, or flash steam processes. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

36

Emission point means any part of a stationary source that emits hazardous air pollutants regulated under this subpart, 

including emissions from individual process vents, stacks, open pieces of process equipment, equipment leaks, 

wastewater and condensate collection and treatment system units, and those emissions that could reasonably be 

conveyed through a stack, chimney, or duct where such emissions first reach the environment. 

Evaporator system means all equipment associated with increasing the solids content and/or concentrating spent 

cooking liquor from the pulp washing system including pre-evaporators, multi-effect evaporators, concentrators, 

and vacuum systems, as well as associated condensers, hotwells, and condensate streams, and any other 

equipment serving the same function as those previously listed. 

Flow indicator means any device that indicates gas or liquid flow in an enclosed system. 

HAP means a hazardous air pollutant as defined in § 63.2 of subpart A of this part. 

High volume, low concentration or HVLC collection system means the gas collection and transport system used to 

convey gases from the HVLC system to a control device. 

High volume, low concentration or HVLC system means the collection of equipment including the pulp washing, 

knotter, screen, decker, and oxygen delignification systems, weak liquor storage tanks, and any other equipment 

serving the same function as those previously listed. 

Knotter system means equipment where knots, oversized material, or pieces of uncooked wood are removed from 

the pulp slurry after the digester system and prior to the pulp washing system. The knotter system equipment 

includes the knotter, knot drainer tanks, ancillary tanks, and any other equipment serving the same function as 

those previously listed. 

Kraft pulping means a chemical pulping process that uses a mixture of sodium hydroxide and sodium sulfide as the 

cooking liquor. 

Lime kiln means an enclosed combustion device used to calcine lime mud, which consists primarily of calcium 

carbonate, into calcium oxide.

Low volume, high concentration or LVHC collection system means the gas collection and transport system used to 

convey gases from the LVHC system to a control device. 

Low volume, high concentration or LVHC system means the collection of equipment including the digester, 

turpentine recovery, evaporator, steam stripper systems, and any other equipment serving the same function as 

those previously listed. 

Mechanical pulping means a pulping process that only uses mechanical and thermo-mechanical processes to reduce 

wood to a fibrous mass. The mechanical pulping processes include, but are not limited to, stone groundwood, 

pressurized groundwood, refiner mechanical, thermal refiner mechanical, thermo-mechanical, and tandem 

thermomechanical. 

Non-wood pulping means the production of pulp from fiber sources other than trees. The non-wood fiber sources 

include, but are not limited to, bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf fibers. 

Oven-dried pulp or ODP means a pulp sample at zero percent moisture content by weight. Pulp samples for 

applicability or compliance determinations for both the pulping and bleaching systems shall be unbleached pulp. 

For purposes of complying with mass emission limits in this subpart, megagram of ODP shall be measured to 

represent the amount of pulp entering and processed by the equipment system under the specified mass limit. For 

equipment that does not process pulp, megagram of ODP shall be measured to represent the amount of pulp that 

was processed to produce the gas and liquid streams. 

Oxygen delignification system means the equipment that uses oxygen to remove lignin from pulp after high-density 

stock storage and prior to the bleaching system. The oxygen delignification system equipment includes the blow

tank, washers, filtrate tanks, any interstage pulp storage tanks, and any other equipment serving the same function 

as those previously listed. 

Primary fuel means the fuel that provides the principal heat input to the combustion device. To be considered 

primary, the fuel must be able to sustain operation of the combustion de without the addition of other fuels. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

37

Process wastewater treatment system means a collection of equipment, a process, or specific technique that removes 

or destroys the HAPs in a process wastewater stream. Examples include, but are not limited to, a steam stripping 

unit, wastewater thermal oxidizer, or biological treatment unit. 

Pulp washing system means all equipment used to wash pulp and separate spent cooking chemicals following the 

digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at 

unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, 

rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, 

filtrate tanks, foam breakers or tanks, and any other equipment serving the same function as those previously 

listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks 

following the last stage of pulp washing. 

Pulping line means a group of equipment arranged in series such that the wood chips are digested and the resulting 

pulp progresses through a sequence of steps that may include knotting, refining, washing, thickening, blending, 

storing, oxygen delignification, and any other equipment serving the same function as those previously listed. 

Pulping process condensates means any HAP-containing liquid that results from contact of water with organic 

compounds in the pulping process. Examples of process condensates include digester system condensates, 

turpentine recovery system condensates, evaporator system condensates, LVHC system condensates, HVLC 

system condensates, and any other condensates from equipment serving the same function as those previously 

listed. Liquid streams that are intended for byproduct recovery are not considered process condensate streams. 

Pulping system means all process equipment, beginning with the digester system, and up to and including the last 

piece of pulp conditioning equipment prior to the bleaching system, including treatment with ozone, oxygen, or 

peroxide before the first application of a chemical bleaching agent intended to brighten pulp. The pulping system 

includes pulping process condensates and can include multiple pulping lines. 

Recovery furnace means an enclosed combustion device where concentrated spent liquor is burned to recover 

sodium and sulfur, produce steam, and dispose of unwanted dissolved wood components in the liquor. 

Screen system means equipment in which oversized particles are removed from the pulp slurry prior to the bleaching 

or papermaking system washed stock storage. 

Secondary fiber pulping means a pulping process that converts a fibrous material, that has previously undergone a 

manufacturing process, into pulp stock through the addition of water and mechanical energy. The mill then uses 

that pulp as the raw material in another manufactured product. These mills may also utilize chemical, heat, and 

mechanical processes to remove ink particles from the fiber stock. 

Semi-chemical pulping means a pulping process that combines both chemical and mechanical pulping processes. 

The semi-chemical pulping process produces intermediate yields ranging from 55 to 90 percent. 

Soda pulping means a chemical pulping process that uses sodium hydroxide as the active chemical in the cooking 

liquor. 

Spent liquor means process liquid generated from the separation of cooking liquor from pulp by the pulp washing 

system containing dissolved organic wood materials and residual cooking compounds. 

Steam stripper system means a column (including associated stripper feed tanks, condensers, or heat exchangers) 

used to remove compounds from wastewater or condensates using steam. The steam stripper system also contains 

all equipment associated with a methanol rectification process including rectifiers, condensers, decanters, storage 

tanks, and any other equipment serving the same function as those previously listed.

Strong liquor storage tanks means all storage tanks containing liquor that has been concentrated in preparation for 

combustion or oxidation in the recovery process. 

Sulfite pulping means a chemical pulping process that uses a mixture of sulfurous acid and bisulfite ion as the 

cooking liquor. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

38

Temperature monitoring device means a piece of equipment used to monitor temperature and having an accuracy of 

±1.0 percent of the temperature being monitored expressed in degrees Celsius or ±0.5 degrees Celsius (C), 

whichever is greater. 

Thermal oxidizer means an enclosed device that destroys organic compounds by thermal oxidation. 

Turpentine recovery system means all equipment associated with recovering turpentine from digester system gases 

including condensers, decanters, storage tanks, and any other equipment serving the same function as those 

previously listed. The turpentine recovery system includes any liquid streams associated with the turpentine 

recovery process such as turpentine decanter underflow. Liquid streams that are intended for byproduct recovery 

are not considered turpentine recovery system condensate streams. 

Weak liquor storage tank means any storage tank except washer filtrate tanks containing spent liquor recovered 

from the pulping process and prior to the evaporator system. 
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

39

Selected definitions from 40 CFR Part 60 subpart A (NSPS General Provisions):

Commenced means, with respect to the definition of new source in section 111(a)(2) of the Act, that an owner or 

operator has undertaken a continuous program of construction or modification or that an owner or operator has 

entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program 

of construction or modification. [§60.2]

Construction means fabrication, erection, or installation of an affected facility. [§60.2]

Modification means any physical change in, or change in the method of operation of, an existing facility which 

increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility 

or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not 

previously emitted. [§60.2]

Reconstruction means the replacement of components of an existing facility to such an extent that: (1) The fixed 

capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to 

construct a comparable entirely new facility, and (2) It is technologically and economically feasible to meet the 

applicable standards set forth in this part. [§60.15(b)]

Selected definitions from 40 CFR Part 63 subpart A (NESHAP General Provisions):

Commenced means, with respect to construction or reconstruction of an affected source, that an owner or operator 

has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered 

into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of 

construction or reconstruction. [§63.2]

Construction means the on-site fabrication, erection, or installation of an affected source. Construction does not 

include the removal of all equipment comprising an affected source from an existing location and reinstallation of 

such equipment at a new location. The owner or operator of an existing affected source that is relocated may elect 

not to reinstall minor ancillary equipment including, but not limited to, piping, ductwork, and valves. However, 

removal and reinstallation of an affected source will be construed as reconstruction if it satisfies the criteria for 

reconstruction as defined in this section. The costs of replacing minor ancillary equipment must be considered in 

determining whether the existing affected source is reconstructed. [§63.2]

Major source means any stationary source or group of stationary sources located within a contiguous area and under 

common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or 

more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, 

unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those 

specified in this sentence. [§63.2]

Reconstruction, unless otherwise defined in a relevant standard, means the replacement of components of an 

affected or a previously nonaffected source to such an extent that: (1) The fixed capital cost of the new 

components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new 

source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant 

standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, 

an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new 

sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that 

source. [§63.2]
Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

40

ATTACHMENT 3

Small Business Size Standards

Small Business Size Standards for NAICS Subsector 322 – Paper Manufacturing

NAICS

Codes

NAICS U.S. industry title Size

standards in

number of

employees

322110 Pulp Mills 750

322121 Paper (except Newsprint) Mills 750

322122 Newsprint Mills 750

322130 Paperboard Mills 750

322211 Corrugated and Solid Fiber Box Manufacturing 500

322212 Folding Paperboard Box Manufacturing 750

322213 Setup Paperboard Box Manufacturing 500

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing 500

322215 Non-Folding Sanitary Food Container Manufacturing 750

322221 Coated and Laminated Packaging Paper Manufacturing 500

322222 Coated and Laminated Paper Manufacturing 500

322223 Coated Paper Bag and Pouch Manufacturing 500

322224 Uncoated Paper and Multiwall Bag Manufacturing 500

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 500

322226 Surface-Coated Paperboard Manufacturing 500

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 500

322232 Envelope Manufacturing 500

322233 Stationery, Tablet, and Related Product Manufacturing 500

322291 Sanitary Paper Product Manufacturing 500

322299 All Other Converted Paper Product Manufacturing 500

Source: U. S. Small Business Administration Table of Small Business Size Standards Matched to North American 

Industry Classification System Codes, Effective August 22, 2008. Accessed June 16, 2009 at: 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf
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ATTACHMENT 4

Acronyms and Abbreviations

acfm actual cubic foot (feet) per minute 

ADTBP air-dried ton(s) of bleached pulp

ADTFP air-dried ton(s) of finished paper

ADTP air-dried ton(s) of pulp

APCD air pollution control device(s)

As arsenic

AS activated sludge

ASB aerated stabilization basin(s)

atm atmosphere(s)

Be beryllium

BLO black liquor oxidation

BLS black liquor solids

BOD biochemical oxygen demand

BOD5 5-day BOD

Btu British thermal unit(s)

°C degrees Celsius

Ca calcium

CaO calcium oxide (lime)

CBI confidential business information

CCA Clean Condensate Alternative

Cd cadmium

CDD chlorinated dibenzo-p-dioxin

CDF chlorinated dibenzofuran

CEMS continuous emissions monitoring system(s)

CERCLA Comprehensive Environmental Response, 

Compensation, & Liability Act

cfm cubic feet per minute

CFR Code of Federal Regulations

Cl2 chlorine

ClO2 chlorine dioxide

Co cobalt

CO carbon monoxide

CO2 carbon dioxide

COMS continuous opacity monitoring system(s)

Cr chromium

cu ft cubic foot (feet)

CY calendar year

d day(s)

DCE direct contact evaporator 

dscf dry standard cubic foot (feet)

dscfm dry standard cubic feet per minute

ECF elemental chlorine free

EIS Emissions Inventory System

EPA U.S. Environmental Protection Agency

ESP electrostatic precipitator(s)

°F degrees Fahrenheit

ft foot (feet)

ft2 square foot (feet)

g gram(s)

gal gallon(s)

gpm gallon(s) per minute

gr grain(s)

GW groundwood

H2O water

H2S hydrogen sulfide

HAP hazardous air pollutant(s)

HCl hydrochloric acid

Hg mercury

HHV higher heating value

hr hour(s)

HVLC high volume low concentration

HW hardwood 

in. inch(es)

ISIS Industrial Sector Integrated Solutions

kg kilogram(s)

KMNO4 potassium permanganate

KOH potassim hydroxide

kWh kilowatt-hour(s)

l liter(s)

lb pound(s)

LK lime kiln(s)

LVHC low volume high concentration

MACT maximum achievable control technology

MDL method detection limit

MEE multiple-effect evaporator(s)

mg milligram(s)

Mg megagram(s); magnesium

MLVSS mixed liquor volatile suspended solids

MMBtu million Btu

mmscf million standard cubic feet

Mn manganese

NA not applicable

NAICS North American Industry Classification 

System

NaOH sodium hydroxide

NATA National-Scale Air Toxics Assessment

NCASI National Council of the Paper Industry for 

Air and Stream Improvement

NCG noncondensable gas(es)

NDCE nondirect contact evaporator

NEC Not Elsewhere Classified

NEI National Emissions Inventory

NESHAP National emissions standard(s) for 

hazardous air pollutants

NH3 ammonia

Ni nickel

No. number

NOx nitrogen oxides

NSPS new source performance standard(s)

NSSC neutral sulfite semichemical
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O2 oxygen

O3 ozone 

OCC Old Corrugated Container

ODP oven-dried pulp 

ODT oven dried ton(s)

ONP Old News Print

OTM Other Test Method

PAH polycyclic aromatic hydrocarbons

Pb lead

PCC precipitated calcium carbonate

PCF processed chlorine free

PM particulate matter

PM10 PM with an aerodynamic diameter of up to 

10 μm

PM2.5 PM with an aerodynamic diameter of up to 

2.5 μm

POM polycyclic organic matter

ppm part(s) per million

ppmdv part(s) per million dry volume

ppmdw part(s) per million dry weight

ppmv part(s) per million by volume

ppmw part(s) per million by weight

RF recovery furnace(s)

RMP refiner mechanical pulping

RTO regenerative thermal oxidizer(s)

RTR residual risk and technology review

Sb antimony

SCA specific collecting area

SCC Source Classification Code

scf standard cubic foot (feet)

scfm standard cubic feet per minute

SDT smelt dissolving tank(s)

Se selenium

sec second(s)

SIC Standard Industrial Classification

SO2 sulfur dioxide

SOG stripper offgas(es)

SSM startup, shutdown, and malfunction

st short ton(s)

SW softwood

TBD To Be Determined

TCF totally chlorine free

TCDD tetrachlorodibenzo-p-dioxin

TEQ 2,3,7,8-TCDD toxic equivalent

THC total hydrocarbon

TMP thermomechanical pulping

ton ton(s)

tph ton(s) per hour

tpy ton(s) per year

TRI Toxics Release Inventory 

TRS total reduced sulfur

UK Unknown

U.S. United States

VOC volatile organic compound

WESP wet ESP

WS wet scrubber

Wt% weight-percent 

WW wastewater

WWT wastewater treatment 

WWTP wastewater treatment plant

Y/N yes/no

yr year

μm micrometer(s)

ug micrograms
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ATTACHMENT 5

Resources for Estimating Emissions

Compilation of air pollution emission factors. Volume I: Stationary point and area sources (5th edition). AP-42. 

Section 10.2, Chemical Wood Pulping, September 1990. Research Triangle Park, NC: U. S. Environmental 

Protection Agency, Office of Air Quality Planning and Standards. Available at 

http://www.epa.gov/ttn/chief/ap42/ch10/index.html

Compilation of air pollutant emission factors. Volume I: stationary point and area sources (Chapter 1, External 

Combustion Source). AP-42. 2001. Research Triangle Park, NC. U.S. Environmental Protection Agency, Office of 

Air Quality Planning and Standards. Available at http://www.epa.gov/ttn/chief/ap42/ch01/index.html

National Council for Air and Stream Improvement, Inc. (NCASI). 2002. Compilation of speciated reduced sulfur 

compound and total reduced sulfur emissions data for kraft mill sources. Technical Bulletin No. 849. Research 

Triangle Park, NC. Available to NCASI members at www.ncasi.org.

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

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

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

National Council for Air and Stream Improvement, Inc. (NCASI). 2004. Compilation of criteria air pollutant 

emissions data for sources at pulp and paper mills including boilers. Technical Bulletin No. 884. Research 

Triangle Park, N.C. Available to NCASI members at www.ncasi.org.

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

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

Bulletin No. 973. Research Triangle Park, N.C. Available to NCASI members at www.ncasi.org.
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ATTACHMENT 6

Emissions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the emission test reports, to include field and 

lab data sheets and example calculations.)
Form Approved __/__/__

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Attachment 6. Pulp and Paper emission units and pollutants for which existing representative emission test data are requested

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Methanol1 Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Test methods M5, M29, 

M17

PM CEMS, 

COMS

M29 EPA 

OTM 

27

EPA

OTM 28

Chlorine (Cl2) 

via M26A with 

modifications 

described in 

subpart S

Cl2 CEMS

M26 or 26A Method 308 

(part 63)

Methanol 

CEMS

M25 or 

M25A

M23 M16 or

TRS CEMS

Provide total 

TRS data. 

Also provide 

speciated 

TRS data, if 

available.

M7

CEMS

M6

CEMS

M10

CEMS

Recovery 

furnaces (NDCE 

and DCE)

Supply data

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Supply any

CDD or 

POM data 

and note if 

equipment 

config. has 

changed

Supply most 

recent data

Black liquor 

oxidizer (BLO)

Note: The BLO 

vent is included 

in definition of 

DCE, but listed 

separately in case 

data are available 

for only the BLO)

Not 

requested

Supply data 

from 1990 or 

more recent

Not 

requested

Supply most 

recent data Not 

requested
Form Approved __/__/__

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Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Methanol1 Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Chemical 

recovery 

combustion units 

- sulfite

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Not 

requested

Supply 

most 

recent 

data

Chemical 

recovery 

combustion units 

- stand alone 

semichemical

Supply data 

from 1990 

or more 

recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or

more recent

Not 

requested

Supply 

most 

recent 

data

Smelt dissolving 

tanks (SDT) or 

ash dissolving 

tanks

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Supply most 

recent data

Not 

requested

Lime 

kilns/fluidized 

bed calciners

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Supply most 

recent data

Black liquor 

gasification 

systems

Supply most 

recent data Not requested Supply most recent data

Thermal 

oxidizers

Supply most 

recent data Not requested

Supply 

most 

recent 

data
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47

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Methanol1 Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Digesters, Pulp 

washers, 

Evaporators, 

Turpentine 

recovery, 

Strippers, O2

delignification, 

Knotters and 

screens, Deckers 

(high density 

storage), and 

Weak and strong 

liquor storage 

tanks (or their 

associated LVHC 

and/or HVLC 

collection 

systems)

Not 

requested

Supply most 

recent data 

following 

MACT 

compliance

Not 

requested

Supply most 

recent data 

following 

MACT 

compliance

Not 

requested

Sulfite pulping 

sources

Not 

requested

Supply most 

recent data 

following 

MACT 

compliance

Not 

requested

Supply 

most 

recent 

data

Not 

requested

Wastewater 

Treatment 

Systems

Not 

requested

Supply most 

recent 

modeling or 

measurement 

data (as 

requested in 

WW tab)

Not 

requested

Supply most 

recent 

modeling or 

measurement 

data (as 

requested in 

WW tab)

Not 

requested
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48

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Methanol1 Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Bleaching 

systems subject to

subpart S Not 

requested

Supply most 

recent data 

following 

MACT 

compliance

Not requested Not 

requested

Supply 

most 

recent data 

following 

MACT 

compliance

Paper machine

emission points Not 

requested

Supply most 

recent data Not 

requested

Causticizing area 

sources

Not 

requested

Supply 

most 

recent 

data

Not 

requested

Stand alone 

semichemical, 

mechanical, 

nonwood, and 

secondary fiber

pulping

Not 

requested

Supply 

most 

recent 

data

Not 

requested

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

CEMS spreadsheet.xls)

2. The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) and speciated mercury (Hg) test data if 

available.

3. Speciated TRS would include: hydrogen sulfide (H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.

Emissions test data representative of your current operations are requested as described in the survey instructions.

M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. 

The “OTM” test methods can be found at http://www.epa.gov/ttn/emc/prelim.html