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### 1 

# Pulp and Paper Sector Survey Overview 6/8/10 This survey overview document provides instructions for completing the p ulp 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 th e 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. Com

pleting 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 chan ges tab

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

................................ ................................ ................................ ......................... 22 g. By products tab

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

................................ ................................ ................................ ................................ .. 22 i. Kraft condensates tab

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

................................ ................................ ................................ ................................ . 23 k. Bleaching t ab

................................ ................................ ................................ ......................... 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 d ata spreadsheet (P&P CEMS spreadsheet.xls)

................................ ......................... 26 D5. Optional cost data

................................ ................................ ................................ ............................ 28 AT TA CHMENT 1 Emiss ion Units to Include in the Pulp and Paper Survey Response

................................ ............ 30 AT TA CHMENT 2 NSPS and NESHAP Definitions

................................ ................................ ................................ . 32 AT TA CHMENT 3 Sma ll Business Size Standards

................................ ................................ ................................ .... 40 AT TA CHMENT 4 Acronyms and Abbreviations

................................ ................................ ................................ ...... 41 AT TA CHMENT 5 Resources for Estimating Emissions

................................ ................................ ........................... 43 AT TA CHMENT 6 Emissions Test Data Request

................................ ................................ ................................ ...... 44Form A pproved __/__/__ OMB Control No. ____

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### 2 

## A. Survey C overage 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) Per form 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) Man ufacture 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 co nsidering 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 radionuclide s, 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 “m ajor 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). Y ou will receive e

- mail confirmation from EPA that you are not required to complete this survey based upon EPA revie w and agreement with the true are a 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 y ou 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 th is 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 yo u operate). The Facility , Inventory , and Equip detail tab s must be completed for all mills. T able 1 below denotes which survey spreadsheet tabs to com plete depending on mill type . Additional spreadsheets are provided for submittal of continuous emissions monitorin g 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 mo re than one Section 114 letter for multiple facilities, you must create a s eparate survey response for each facility. If you have not already received or downloaded a copy of the survey spreadsheets, they can be dow nloaded 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 docum ent. 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.Form A pproved __/__/__ OMB Control No. ____

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### 3 For reference, Attachment 2 contains the regulatory definit ions 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 p aper 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 abb reviations 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 mil ls 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) By products 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 pap er 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 CEM S 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 cost s Mills that installed selected air pollution controls (see section D5) Equip change costs Mills implementing selected process or equipment changes (see section D5)Form A pproved __/__/__ OMB Control No. ____

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### 4 

## B. Confidential Business I nformation (CBI) The EPA's procedures for handling CBI ar e 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 sp readsheet response by shading the spreadsheet cell containing the “confidential business information (CBI)” information with red highlight and indicat ing in the red block at the top of each spreadsheet tab that the tab contains CBI . Also, please clearly l abel 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 CB I 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 S ubmit Your S urvey R esponse 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 t wo dif ferent mailing addresses

. 

### C 1 . Submitting Your N on - CBI Response Follow these instructions for the non

- CBI portions of your survey response (or for responses that are entirely non

CBI.) After you have completed and reviewed your survey response , remove the CBI components from your survey as instructed in section C2 . Save the Excel spreadsheet (s) containing the non

- CBI portion s of your completed response, non - CBI flow

diagram s, emission test reports, and any other electronic non - CBI attachments on the f lash 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, waste water emissions modeling reports, etc.). Mail the non

- CBI flash dri ve (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. Moral es 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.Form A pproved __/__/__ OMB Control No. ____

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### 5 C 2 . Submitting CBI Follow these instructions for any portion of your survey r esponse that contains CBI. Please create a separate CD or DVD containing a version of your spreadsheet response with only the CBI portion of yo ur data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any flow diagram s 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 C BI 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 27 711 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 ELE CTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E

- mail and facsimile are not secure forms of communication and should never be used to transmit CBI.Form A pproved __/__/__ OMB Control No. ____

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### 6 

## D. How to Complete the S urvey 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 yo u 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 c ontrol measure cost information helpful for EPA’s regulatory analyses. 

### D 1. 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. Respond ents 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 su ffice. 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 liquo r storage tanks or ponds. Pulping process

. Include the equipment in all pulping lines including the digester area, pulp washing lines, evaporator lines, and o xygen delignification systems. Show any brown stock washers, hoods, filtrate tanks, vacuum pump s, 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 stag e of pulp w ashing and/or those located prior to the paper machines. Black liquor gasification . I f 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 diagr am 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 digeste r “block” to the LVHC collection system is informative.Form A pproved __/__/__ OMB Control No. ____

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### 7 D 2. NEI data: Facility and Inventory tabs T he 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) Natio nal Emissions Inventory (NEI) will be used for EPA’s residual ri sk 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 & Pape r 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 w ere compiled based on prior versions of the NEI , updated with data collected by EPA’s Office of Air Quality Planning and Sta ndards

. 1 Many pulp and paper mills have voluntarily updated their NEI data sets for RTR purposes and few additional refinements are needed. How ever, there remain a number of pulp and paper mills for which substantial updates to their NEI data sets are re quested in order for EPA to mo re 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 followi ng the instructions provided below in section D2.a for “ Updating pre

- populated NEI data (in the Facility and Inventory tabs )

. ” The rem aining spreadsheet tabs request information in addition to that included in the NEI, and are to be completed based on the instructions prov ided in section D3 o f this document. If NEI data do no t 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 Inventor y 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 ar e 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 e missions 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/l ongitude 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/2005inve ntory.html. 2 Latitude 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 fugit ive 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 angl e is greater than zero.Form A pproved __/__/__ OMB Control No. ____

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### 8 a. Updating p re - 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 A F in the Facility tab an d column B Z i n 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
“ Pro cess 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. How ever, EPA is sensitive to the time and effort required to update your NEI inventory. Thus, i f 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 mi ll 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. How ever, 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 “ I nstruction ” row appears that the top of each spreadsheet tab to provide a br ief instruction for fields requiring some description. More detailed instructions appear in this document where needed. When updating the NEI data in the Facility and Inventor y tabs, p lease 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 follow s: Gray shaded columns. The gray shaded columns have been lo cked 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 . C opy the entire row

w ith 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 indicat ing your intent with an " X" in the “D elete ” column

. A dding a row . If yo u need to add a new emission unit or pollutant that is not curr ently in the inventory, yo u should scroll to the last row and enter any missing data. Y ou can copy any useful inform ation from other inventory rows and state in the " Process Comment " field "Adding new p rocess." For additions, information does NOT need to be in a revised field. Specify “RTR09” in the “D ata S ource Code” column. Deleting a row

. If you need to delete a row indicate your intent with an " X" in the “D elete ” column and indicate your reason for deletion in the “Delete Comment” column. You may wish to delete row s, for example , because an emission unit wa s decommissioned or is now collec ted as part of the LVHC system; or because yo u cannot identify the source. To revise or replace a whole row . Add your new row and delete the old row

using the i nstructions for adding an d deleting rows above. T o replace the w

hole 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 “D elete ” column and note “complete inventory replacement” in the “Delete Comment” column. A dd your new inventory below the NEI data being replaced.Form A pproved __/__/__ OMB Control No. ____

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### 9 For convenience, the spreadsheet entitled Lookups for P &P survey.xls consolidates and provides the variou s codes associated with the NEI data set y ou are requested to update . This Lookups for P& P survey.xls spreadsheet also contains source classification codes ( SCC )

. These codes w ere 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 paper

related 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) P ulping / Green Liquor Processing and 30700133 Sulfate (Kraft) Pulping / White Liquor Processing. Please use the most app ropriate SCC from the provided lookup table. Similar updates (i.e., both additions and deletions) may have been made to som e of the other NEI code l ookup tables. If a code that you have used in the past no longer appears in the appropriate l ookup table, please select the most appropriate code from those listed. You may clarify yo ur entry by adding text in the “ Comment

– Process ” column

. Codes that are being phased out are shaded green in som e of the lookup tables (along with a note in the lookup table explaining how to treat the green

- shaded codes in yo ur inventory update). Update the single row

of NEI data in th e Facility tab as need ed following the instructions that appear in each column

. The NEI data in the Inventory tab should include all emission units/points that emit ha zardous air pollutants (HAP), criteria air pollutants (CAP) , or total reduced sulfur (TRS ) at the mill, inclu ding every emission point with HAP, CAP , and/or TRS emission limits in your title V operating permit. The Inventory tab contains separate row s 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 eve n 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 yo u operate l isted 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 wi ll 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 conclud e 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 r ecords 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 y ou cannot (successfully) change data by over - writing existing data in a field.

Why do I have to add every em ission unit and /or em ission 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 residua l 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 d etermining the magnitude of emissions for purposes of revi ewing the NSPS.Form A pproved __/__/__ OMB Control No. ____

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### 10 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 p rovide data for each associated emission poin t , 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 sta ck for purposes other than capture and control. In this scenario, apportion the emissions to each process and insert a separate row or row s for each distinct process. Identify and enter the SCC code associated with each emission unit and note the appropr iate stack parameters on each row . N ote 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 Fu rnace 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 ven ts 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 pape r emission units may have multiple emission points (e.g., paper machines, digester blow gases and relief gases , boilers wi th two stacks ) that for various reasons may not be consolidated into a single emission point before release to the atmosphere. In thes e 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

. By pass 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 th e appropriate data in a new row (see previous instructions for “adding a row” ) . If you enter data for bypass stacks, please indicat e these emissions as “bypass” emissions in the
“ REVISED Emission Unit Description ” column

. Please also indicate in the “ REV ISED Emission Unit Description ” column the release point associated with “normal” operations. See also the instructions below for routine and SSM emissions. Backup controls. S om e facilities may have backup control system configurations that provide flex ible 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 shutdow n, the facility has the flexibility to send these same collected LVHC gases to a pow er boiler. For this type of scenario, a facility would indicate in the “ Control M easure ” 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 s tartup, shutdown, and malfunction (SSM) emissions

. Startup, shutdow n, 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 row s 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 sta ck (in order to prevent double counting of the SSM emissions that w ould occur if the SSM emissions are entered in both the routine and bypass rows).Form A pproved __/__/__ OMB Control No. ____

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### 11 Control measures

. For EPA to better understand current control measures that are in operation, w e are r equesting that revie wers 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 unit s are permitted units in your Title V p ermit

. 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 f ugitive emissions are to be included in your NEI update (e.g., fugitive emissions from wastewater handling/treatment units mo deled for permitting purposes ). Fugitive emission parameters are reflected in the “Emission Release Point Ty pe” 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 emi ssions 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 B oilers & 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 pre

populated 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 docum ent. 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 inform ative “ Emission Unit Description ” t hat adequately describes the equipment or type of em ission unit . If no “ Emission Unit Description ” is i n the NEI for a given em ission unit then you will need to add one in the “ REVISED Emission Unit Description ” colum n. If you find that the “ Emission Uni t 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 y our revision entered in the “ REVISED Emission Unit Description ” column relate s your emission unit /process to your permit or process flow

diagram. The SCC s 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 SCC s 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 mo re descriptive co des and to provide some guidance on which codes should be used for certain equipment ty pes. 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 forForm A pproved __/__/__ OMB Control No. ____

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### 12 P&P survey.xls” (and is also available in data base form at http://www.epa.gov/ttn/chief/net/2005inventory.html ). Th e “ Emission Unit Description ” and “REVISED Emission Unit Description ” columns will be used as a check for SCC code assignment. Revised SCC s are available for common collection systems (e.g ., LVHC, HVLC) and for various systems that are commonly comprised of multiple emission points (e.g., 307001 1 4 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 m atches your emission unit then be sure to include an accurate description of your em ission unit in the “ REVISED Emission Unit Description ” column of the Inventory tab. P lease 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 g eneric 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. “E mission Proce ss Group” column

. The P& P Att1 with SCC tab of the “Lookups for P&P survey.xls” spreadsheet contains an “E mission Process Group” column associated with each SCC. You are asked to identify the “E mission Process Group” listed in the P& P Att1 with SCC tab f

or 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 Des cription” 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 Facil ity 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 S tates have not supplied NEI data for major sources. Also, NEI data may be unavailable for non

major 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 synthe tic 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 N EI 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 est imating 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 “ I nstruction ” r ow 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 (in cluding the gray shaded columns ) . If a gray shaded column is superseded by a “REVISED” column, then youForm A pproved __/__/__ OMB Control No. ____

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### 13 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 th e 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 referri ng to the instructions (in this section and section D2.a of this document) for updating the Inventory tab. E nter appropriate identifiers such as the “ F acility R egistry I dentifier ” (text limited to 15 characters) , and the Emission Unit ID , P rocess ID, and E mission R elease P oint 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 SCC s .


### D 3. Process data Complete the Process data portion of the survey only after you have updated your NEI invent ory .

In this portion of the survey you will continue to use the P&P sector survey.xls spreadsheet, where you will : (1) add additiona l information to the right of the orange vertical line in the Facility and Inventory tabs, and (2) add data to mo st of the remaining survey tabs (as applicable). Many of the instructions you need for completing the survey tabs are included in the “ Instruc tion ” row of each tab in the P&

P sector survey.xls spreadsheet . How ever, 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 incl udes fields with pull down menus for common entries. Use these pull

- down m enus whenever possible, or w rite 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 ID s including: Pulping line ID, Bleaching line ID, or paper machine Emission Unit ID
 APCD_ID The NEI Site ID and Emission Unit ID co me from your NEI update in the F acility and Inventory tabs. You will specify the Collection system ID , APCD_ID and the various Line ID s in the Equip detail and other spreadsheet tabs. The Line ID s are described as follows. Pulping line ID . Many mills have only one pulping line. Ho we ver, 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 request ed in addition to the NEI update to inform the technological revie w 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 det ails specific to the processes employed and matches these details to emissions levels that are achieved (e.g., emission concentrations). A pplicability of the NESHAP and NSPS compliance options depend on the specific process equipment.Form A pproved __/__/__ OMB Control No. ____

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### 14 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 betw een multiple pulping lines (e.g., shared c hemical recovery equipment). Indicate multiple pulping line IDs in “ Line ID ” or “pulping line ID” columns for equipment shared betw een 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 P ulping 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 ID s you enter are consistent throughout th e spreadsheet. Bleaching line ID . A b leaching 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

. P aper machine Emission Unit ID . Paper mills may have multiple paper machines (each identified with a paper machine Emission Unit ID ). Emission units located in th e 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 st ock blending and storage tank.

A Note About Identification Numbers ( IDs ) It is im perative 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 functiona l 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 yo ur IDs match throughout the spreadsheet (s). Also, please be sure that no extra spaces or characters are included in th e ID cells

. For example, Emission Unit ID “DIG1” is not read the same as “DIG

- 1” or “DIG

- 1_” by data base software.Form A pproved __/__/__ OMB Control No. ____

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### 15 Follow the instructions below

and in the “Instruction” row s of the spreadsheet to complete the survey tabs. Refer to Table 1 of this document to determine which tabs you must complete dependi ng on the type of mill you operate.

a. Facility tab Com plete 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 d ata. 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 privat e 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 em ploy ees is used for the pulp and paper subsector (322). Note that the “number of employees” is c alculated 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., t em porary) 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 tem porarily idle due to economic conditions in 2009) in the
“ Total number of paper machines ” column. Enter the total paper/paperboard machine capacity as of 2 009 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 tem porarily 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 s urvey base year (2009). In addition, because 2009 w as 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 limi t inform ation) Permit limits for each emission unit/point and pollutant ar e 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 no t include p ermit 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 lin e 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 ” column s to the left of the orange line to determine which pollutant permit limits to enter. I f 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 C FR Part 6 3 subpart s S or M M

. Specif y 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 unit s . You may specify limits for a given pollutant in multiple units/formats (e.g., ppmdv and/or % re duction) if the permit is written to include multiple compliance options. The survey sp readsheet 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 re quested unless this is the only way in which limits are specified in the permit.Form A pproved __/__/__ OMB Control No. ____

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### 16 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 permi t limit units. Include any oxygen correction factors (%O2). Be sure to note if ppm values are on a dry (d) or volume (v) or w eight (w) basis if specified this way in your perm it (ppmdv, ppmdw, ppmv, ppmw). Table 2. Suggested Units of Measure for Per mit Limits Pollutant Suggested units PM 1 Recovery furnaces/chemical recovery com bustion units: gr/dscf @ 8% O2 SDT: lb/ton BLS LK: gr/dscf @10% O2 PM 10 1 Other processes: specify PM 2.5 1 Opacity % (provide averaging time) TRS RF/combustion units: p pmdv @ 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

. Y our permit may simply restate the emission limits contained in Federal rules such as NESHAP subparts S and MM and NSPS subpart s BB or Db . Some permits may list all of the compliance op tions contained in the Federal rules as permit limits. If this is the case, y ou 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 lim i ts ) in C olumn 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 S tate lb/hr or tpy emission limits in addition to the Federal limits

. P articulate 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 f or which you do not have permit limits

.Form A pproved __/__/__ OMB Control No. ____

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### 17 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 row s for opacity. The opacity limits of mo st 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, config uration of controls, pertinent equipment details, and regulatory compliance options used). T he 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 c olumns 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 que stions are included in the Equip detail tab.Form A pproved __/__/__ OMB Control No. ____

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### 18 Equip detail tab columns Description of inform ation requested

A

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

collection system. Com

plete these columns for all emissi on units

. AR

- A T Digesters AJ

- AY Pulp w ashers A Z

- BA Knotters, screens, and deckers BB

- BE Evaporators BF

- B H Oxygen delignification BI

- B R Strippers BS

- B W Pulp storage and liquor storage BX

- CA Liquor storage ponds CB

- CF Causticizing equipment CG Black liquor gasification CH

- C M 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

- D N Sm elt/ash dissolving tanks DD

- D V Lime kilns (including rotary lime kilns and fluidized bed calciners) D W Boilers and thermal oxidizers/incinerators DX

- D Y Identification of emission units incinerating NCG or SOG DZ

- F J 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 shutdow n . 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 app ly 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

. L ist 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 s ystem ID for the different Emission Unit ID s. For example, an LVHC collection system ( Emission Unit ID LVH

C01) may collect emissions from multiple emission points associated with digesters 1, 2, and 3 and an evaporator ( Emission Unit ID s 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 s

ystem ID as the Emission Unit ID

) so you can provide control information and equipment details for the LVHC collection system.Form A pproved __/__/__ OMB Control No. ____

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### 19 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 Emi ssion Unit D escription” column that EU001a and EU001b v ent 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 row s 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. Emissi on 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 emi ssions 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 ). By pass 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 yo u enter into the APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For example, I f you use an ESP (

ESP1) followed by a sc rubber (WSa), you would enter APCD1 type = ESP and APCD2 type = scrubber, and APCD1_ID = ESP1 and APCD2_ID = WSa. I f 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 ID s for each emission unit in the Emission Unit ID column. Use the lime kiln’s Emission Unit ID in the APCD column s. 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 b ackup 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. Com plete the applicable equipment

- specific details requested in columns AR through GB for each ty pe of emission unit in the Equip detail tab by following the directions in the “ Instruction ” row

of the tab. Additional specific instructions ar e provided below for e quipment requiring instructions beyond what could be explained in the
“ Instruction ” row . Leave c olumns that do not apply for a given emission unit blank.Form A pproved __/__/__ OMB Control No. ____

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### 20 All emission units listed in Attachment 1 . Comp le te 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 d igesters , p ulp washers , knotters, screens, deckers , e vaporators , and o xygen 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 understandi ng of the number and characteristics of strippers in use at pulp and paper mills following subpart S compliance. Pulp storage and l iquor storage , and liquor ponds

. HAP emissions may be associated with pulp and cooking liquor storage tanks, and liquor sto rage 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 c an 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 o f impacts analyses. Sm elt 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 anal yses. Wastewater handling/treatment units

. Com plete the generic qu es tions in Columns A through AQ of th e Equip detail tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance. Boilers

. The EPA is requesting limite d 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 s upplemental fuels

. Fuel types are requested fo r fuel

- fired equipment because fuel type can have an effect on emissions . The EPA may consider fuel types and perform calculations based on fuel firi ng rates for various nationwide impact analy ses. 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 fi ring rates for each fuel. The annual fuel amount can be used with the 2009 emission unit operating hour s 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 w

hich information is not readily available. If you do not know an answer and cannot reasonably locate an ans wer, then you may enter “UK” for unknown. How ever, note that survey respondents providing an excessive number of “UKs” will most likely receive follow

- up inquiries related to their survey response.Form A pproved __/__/__ OMB Control No. ____

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### 21 Primary fuel information is requested for fuel

- fi red equipment su ch 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 th e primary fuel for these units. Non

- condensible gases (NCG) and SOG are not considered to b e either primary o r supplemental fuels for purposes of this survey. Supplemental and other fuel information is requested for recovery furnaces and che mical recovery combustion units in addition to other fuel

- fired equipment such as boilers, lime kilns, th erm al oxidizers, and direct

- fired dryers. Information for s econdary and additional fuels used routinely for multi

- fuel fired equipment may be indicated in the supplemental and other fuel columns. Emission unit s tartup and shutdow n . Com plete the startu

p 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 dur ation, 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 c ould apply during startup and shutdow n 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. Th e startup and shutdown questions would also identify pulp and paper emission unit types for which startup and shutdow n are not already addressed with the current emission standards. You are asked to s upply information for routine startup and shutdown events associated with planned process or mi ll downtime. (D o not provide information for unplanned startup/shutdown events associated with equipment malfunctions). The st artup and shutdown data in the Equip detail tab are being sought for regulatory development purposes, and will not be used for enforcement purpo ses. d. Controls tab Com plete 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 c ontrol 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 w et 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, SO 2 , and other HAP. This information will be used in d etermining the capabili ty of different control devices for reducing emissions. If yo u 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 “actua l” 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 effic iency 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 waste water 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 Control s and Equip detail tabs. The Equip detail tab contains questions about heat input capacity, e quipment incinerating NCG or SOG , and primary or supplemental fuels

. Control device s tartup and shutdow n . 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 theForm A pproved __/__/__ OMB Control No. ____

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### 22 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 pr ovide 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 diffe rent 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 ex isting 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 ques tions, y ou are asked to s upply 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 ma lfunctions). 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 emissio ns 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. Com plete the Potential changes tab by following the instructions in the “ Instruction ” row . f. Pulp prod tab T he Pulp prod tab is to be completed by all mills that produce pulp onsite using chem ical, 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)

. Som e data fields apply for specific types of pulp (e.g

. , m echanical 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. Com plete the Pulp prod tab by following the instructions in the “ Instruction ” row . g . Byproducts tab Mills that recover turpentine or t all oil from pulping processes should com plete 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. Com plete 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 t ab. Information regarding the emission units involved, time, controls, and portion of processForm A pproved __/__/__ OMB Control No. ____

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### 23 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. Com plete the P CC tab by following the instructions in the “ Instruction ” row . i . Kraft condensates tab Com plete the Kraft co ndensates tab by following the instructions in the “ Ins truction ” row . The kraft condensate control options are summarized as follows. This table corresponds with the pull down menu options for condensates treated by steam strip pers, biological treatment , or other means

. Control option Applicability Rule ref ere n ce

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 bleac h §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 B alance to the left of the orange vertical lin e (column I) , an d (2) CCA Equipment L ist 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 L ist

. The CCA tab must be completed once for each set of CCA c om pliance calculations used by your mill. Add another CCA tab if you need to provide more than one set of CCA calculation s. As an alternative to c om pleting the CCA tab, you may attach separate documentation of your CCA calculations used for purposes of showing compliance. Sources eli gible for inclusion in the CCA as credit generators include: pulping systems, bleaching systems, causticizing syste ms, and papermaking systems. Debit generating sources can include equipment from the kraft mill HVLC system, including: pulp w ashing systems, knotter systems, screen systems, decker systems, O2 delignification systems, and weak liquor storage tanks. Ref er 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. How ever, EPA reserves the right to request additional detail if needed as a follow

- up to this survey. Com plete the CCA tab by following the instructions in the “ Instruction ” row .Form A pproved __/__/__ OMB Control No. ____

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### 24 k. Bleaching tab All mills that perform bleaching should complete the portion of this tab to the left of the orange vertical li ne (column O ) to describe the bl eaching systems used at your mill. Your response will consist of one row for each ble aching line located at your mill. Most mills will have only one or two ble aching line rows

. If your bleaching system includes any stages that use c hlorine or chlorinated compounds , then you must complete the portion of this tab to the right of the orange vertical line. E xtraction or other bleaching stages that do not use c hlorine or chlorinated compounds are not covered by subpart S and shou ld 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 commo nly used (e.g., to determine if any rem aining 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 chara cterization 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)

. Com plete the Bleaching tab by following the instructions i n 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 ). Com plete the Paper pro d 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 includ e paper machine information on separate rows. Given the numerous specific grades of paper and paper characteristics, EPA reque sts that you distinguish among a relatively short list of generalized paper grades, including:

coated free sheet kraft packagin g 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 unblea ched 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 machi nes. You are asked to s pecify 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.Form A pproved __/__/__ OMB Control No. ____

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### 25 m . HAP additives tab Com plete 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 i t 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 add itives 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). Th e HAP additives information wo uld 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

. Com plete the HAP additives tab by following the instructions in th e “ Instruction ” row .
n . WW tab All m ills 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 mo nitoring, measurement methods (such as ambient measurements) , or modeling methods that apply for measurement or estimation of HAP and TRS (including H 2 S) air emissions asso ciated 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 W WTP 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 e qu ipped with a closed vent collection system and APCD

. If any wastewater treatment units are equipped with a closed vent collection system an d APCD , then you should also include the w astewater treatment unit in the Emission Unit ID column of th e Equip detai l 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 s ystems in destroying HAP. Com plete the WW tab by following the instructions in the “ Instruction ” row . 

### D 4. Test data Attachment 6 of this survey contains a table of emission units and pollutants for which existing emission s data are requested. Emiss ions data are being requested in the form of emissions test reports or continuous emissions mo nitoring, whichever may be available. You are not required to conduct any new emissions testing or continuous emissions monitoring to respond to this survey

. Fo llow 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 valuableForm A pproved __/__/__ OMB Control No. ____

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### 26 information on current emissions levels and will allow EPA to consider variability in emissions from mill to mill (and ov er 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 reques ting existing emission test reports at this time as they may already be available

. Revie w 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 criteri a 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 co ntrol system configuration. For example, if you have installed controls or made significant process changes expected to change emissions , then yo u need no t supply emissions data for the prior configuration. How ever, you may voluntarily supply emission s d ata for prior configurations, as such information would be useful to EPA in characterizing emissions in general (for non

site

- specific uses) , but we request that you identify that such data are no longer representative in the Emissions test data tab. C uto ff dates are provided in Attachment 6 for certain emission unit and pollutant com binations. 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) . Long er 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 d ata prior to the cutoff dates are requested only if necessary to obtain results of at least one representat ive 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, s ubmit full and complete copies of the emission test reports , to include field and lab data sheets and example calculations, meeting the criteria in Attachm ent 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 calculatio ns, etc. EPA will extract the test data from the emission test reports for use in nationwide regulatory analyses. Com plete the Emission test data tab to identify the specific emission units and control systems for which emission te st reports are being su

bm itted, 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 existin g CEMS data an d/or continuous opacity monitoring system (COMS) data from facilities that have installed continuous monitoring systems in or der 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.Form A pproved __/__/__ OMB Control No. ____

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### 27 A separate Microsoft Excel spreadsheet (P&P CEMS Spreadsheet.xls) i s provided for submittal of the re quested CEMS data. The spreadsheet contains individual worksheets (tabs) designed specifically for TRS (12

- hour block average), TRS (hourly), Opacity, NOx, SO 2 , CO, Methanol, Chlorine, and PM. Each wo rksheet 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

- s pecific 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 CEM S concentration data for TRS for the mo st recent 30 days of operation. In addition, respondents are asked to provide the highest s ingle 12

- hour average TRS concentration within the most recent calendar year (CY2009) recorded: (a) under normal operating conditions, (b) under conditions of startup or shutdow n, and (c) under m alfunction 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% O 2 for recovery furnaces and 10% O 2 for lime kilns an d 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 C ollection system ID) , the APCD_ID, and report the 6

- mi nute and 1

- hour averages of opacity for the most recent 30 days of operation. In addition, respon dents are asked to provide the highe st 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 m alfunction 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, SO 2 , and CO . These worksheets are designed for recovery furnaces or lime kilns equipp ed with CEMS for NOx, SO 2 , or CO , but can be used for other emission units equipped with these CEMS . Respondents are requested to specify the Emission_Unit_ID (or C ollection system ID) , the APCD_ID (or type of combustion controls used), and report the 1

- h our 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 m alfunction 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 r ecent 30 days

. ) Total HAP or M ethanol . 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 C ollection 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 m alfunction con ditions

. (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).Form A pproved __/__/__ OMB Control No. ____

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### 28 Total C hlorinated HAP or C hlorine . This worksheet is designed for total chlorinate d 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 C oll ection 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 shutdow n, and (c) under m alfunction 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 de signed for any emissions unit equipped with a PM CEMS. Respondents are requested to specify the Emission_Unit_ID (or C ollection system ID) , the APCD_ID , and report the 1

- hour aver ages 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 start up or shutdown, and (c) under m alfunction 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

- CE MS 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. Opti onal cost dat a 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 a ccompanying 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 perfo rm regulatory analyses. How ever, 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 author ity. 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 OPTI ONAL.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 th is 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 y ears is requested (e .g., costs dating back to 1998). The c ost information could come from vendor quotes for APCD or equipment changes that either have been implemented or w ere explored but not implemented. The EPA is particularly interested in costs of the following air pollution control devices (APCD). Please supply this informati on 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 devicesForm A pproved __/__/__ OMB Control No. ____

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### 29 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 no n - 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

- Install ation 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 gasi fication system Com plete 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 n ot be required for other mills)

.Form A pproved __/__/__ OMB Control No. ____

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### 30 ATTACHMENT 1 Emission Units to Includ e 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 C hemical recovery furnace C hemical recovery com

bustion unit B lack liquor oxidization system S melt or ash dissolving tank L ime kiln or calciner B lack liquor gasification systems Sulfur burner C austicizing E quipment 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 li quor/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 Kno tters Decker S tock chests (including open stock chests ) Pulp storage tanks T hickeners Pulp dryers Evaporators Black liquor storage tank s Evaporator h ot w ells Condensers Boilout tanks Soap storage tanks Soap skimmer tanks Other emission points associated with the evaporators. Oxygen Delignification Equipment Oxyg en delignification reactor Ox ygen delignification blow tank Oxygen de lignif

ication washer Po st
- oxygen washer filtrate tank Pulp storage tanks Other oxygen delignification system emission points. Non

- c ondensable gas (NCG ) Collection LVHC system HVLC system S tripper S ystem Equipment Stripper feed tanks Condensers Heat exchanger s M ethanol Rectification Equipment Rectifiers Condensers Decanters Storage tanks Storage T anks Weak liquor storage tank s Strong liquor storage tank s Liquor storage ponds Acid condensate storage tank s (at sulfite mills)Form A pproved __/__/__ OMB Control No. ____

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### 31 T all Oil Production Equipment T all oil acidulation reactor Storage tank Dehydrator Brine storage tank Screen Centrifuge tank Other tall oil production vents M echanical Pulping Equipment Stone grinder Refiner Chip pre

- steaming vessel Chip cooker Screen Decker Brightening/bleachin g tower Non

- wood Pulping Equipment Secondary Fiber Pulping Equipment Bleaching Equipment T ow er vent s W asher hood s S eal tank vent s C hemical and steam mixers Vacuum p um

ps Paper Making Equipment Paper machines Pulp dryers Machine chest Repulpers Stock b lending 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 waste water handling and treatment units Pow er boilers (including small package boilers) Thermal oxidizers/incinerators Woody ard operationsForm A pproved __/__/__ OMB Control No. ____

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### 32 ATTACHMENT 2 NSPS and NESHAP Definitions NSPS Subpart BB Definitions ( 40 CFR Part 60, § 60.281 ) . (a) Kraft pulp mill means any stat ionary 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 al so considered part of the kraft pulp mill. (b) Neutral sulfite semichemical pulping operation means any operation in which pulp is produced from wo od by cooking (digesting) wood chips in a solution of sodium sulfite and sodium bicarbonate, follow ed by m ec hanical defibrating (grinding). (c) Total reduced sulfur (TRS) means the sum of the sulfur compounds hydrogen sulfide, methyl mercaptan, dim ethyl 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 was hers and associated knotters, vacuum pumps, and filtrate tanks used to w ash the pulp following the digester system. Diffusion washers are excluded from this definition. (f) Multiple

- effect evaporator system means the multiple

- effect evaporators and associ ated 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 chemi cals consisting primarily of sodium and sulfur compounds by burning black liquor which on a quarterly basis contains 7 w eight 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 me ans 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 w eight 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 carbon ate, 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 A pproved __/__/__ OMB Control No. ____

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### 33 NESHAP Subpar t 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 me ans 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 dir ect 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 f urnace 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, w ater, or other fluid is used in the ESP bottom) and a dry particulate matter return system (i.e., no black liquor, w ater, 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, append ix 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 contai ning 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 m ill. Kraft recovery furnace means a recovery furnace that is used to burn black liquor produced by the kraft pulping process, as w ell 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 A pproved __/__/__ OMB Control No. ____

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### 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 o f 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 dete rmined 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 start

up, 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 me ans 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 so da 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 rev ersing 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 st and

- 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 evaporat or, 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 gasificat ion 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 success ful 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 A pproved __/__/__ OMB Control No. ____

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### 35 Sulfite combustion unit means a combustion device, such as a recovery furnace or fluidized

- bed reactor, w here spent liquor from the sulfite pulping process (i.e., red liquor) is burned to recov er 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 consid ered 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 subp art 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 semi

chemical 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 bleachi ng 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 p ulp 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 ste am . 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 i s 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, includ ing 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 l iquid content after the pulp wa shing 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 associate d with batch or continuous digester relief, blow , or flash steam processes.Form A pproved __/__/__ OMB Control No. ____

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### 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, o pen pieces of process equipment, equipment leaks, wa stewater 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. Ev aporator 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 asso ciated 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 mean s 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 w ashing 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 devic e. 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 p ulping 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, therm al 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. F or 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, m egagram of ODP shall be measured to represent the amount of pulp that wa s 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 p rior 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 A pproved __/__/__ OMB Control No. ____

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### 37 Process wastewater treatment system means a collection of equipment, a process, or specific technique that removes or destroys the HAPs in a process waste water stream. Examples include, but are not limited to, a steam stripping unit, wastewater thermal oxidizer, or biological treatment unit. Pulp washing sys tem means all equipment used to w ash 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 th ose 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. Pu lping 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 cond ensate 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 l iquor is burned to recover sodium and sulfur, produce steam, and dispose of unwanted dissolved w ood com ponents 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 w ater 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 an d m echanical 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 liq uor 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 f eed 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 m ethanol rectification process including rectifiers, condensers, decante rs, 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 pro cess. Sulfite pulping means a chemical pulping process that uses a mixture of sulfurous acid and bisulfite ion as the cooking liquor.Form A pproved __/__/__ OMB Control No. ____

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### 38 Temperature monitoring device means a piece of equipment used to monitor temperature and having an accuracy of ±1.0 perc ent 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 equipm ent 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 stream s 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 t ank except washer filtrate tanks containing spent liquor recovered from the pulping process and prior to the evaporator system.Form A pproved __/__/__ OMB Control No. ____

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### 39 Selected definitions from40 CFR Part 60 subpart A (NSPS General Provisions) : Commenced means, with respect to the definitio n 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 reason able 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 exis ting 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 from40 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 comple te, 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 b e 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 mo re 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 radio nuclides, 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) T he 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 compl iance dates, irrespective of any change in emissions of hazardous air pollutants from that source. [§ 63 .2]Form A pproved __/__/__ OMB Control No. ____

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### 40 ATTACHMENT 3 Sm all Business Size Standards

Sm all Business Size Standards for NAICS Subsector 322

– Paper Manufacturing NAICS Codes NAICS U.S. ind ustry title Size standards in number of em ployees 322110 Pulp Mills 750 322121 Paper (except New sprint) Mills 750 322122 Newsprint Mills 750 322130 Paperboard Mills 750 322211 Corrugated and Solid Fiber Box Manufacturing 500 322212 Folding Paper board 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 Man ufacturing 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 5 00 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, 200 8. Accessed June 16, 2009 at: http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdfForm A pproved __/__/__ OMB Control No. ____

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### 41 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 biochemic al 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 dibenzofu ran CEMS continuous emissions monitoring system(s) CERCLA Com

prehensive Environmental Response, Com pensation, & Liability Act cfm cubic feet per minute CFR Code of Federal Regulations Cl2 chlorine ClO2 chlorine dioxide Co cobalt CO carbon monoxide CO2 car

bon 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 E IS 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 perma nganate KOH potassi m 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 megagra m( 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 Sy stem NaOH sodium hydroxide NATA National

- Scale Air Toxics Assessm ent 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 N ational 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 semichemicalForm A pproved __/__/__ OMB Control No. ____

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### 42 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 P OM 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 r egenerative 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 sm elt 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 TM P 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 we t scrubber Wt% weight

- percent WW wa stewater WWT wa stewater treatment WWTP wa stewater treatment plant Y/N yes/no yr year μm micrometer(s) ug microgramsForm A pproved __/__/__ OMB Control No. ____

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### 43 ATTACHMENT 5 Resources for Estimating E mi ssions

Compilation of air pollution emission factors

. V olume I: Stationary point and area sources (5th edition). AP

- 42. Section 1 0.2 , 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, Off ice 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). 200 2. Compilation of speciated reduced sulfur compound and total reduced sulfur emissi ons 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 emi

ssions 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 Im pr ovement, 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.Form A pproved __/__/__ OMB Control No. ____

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### 44 ATTACHMENT 6 E mi ssions 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 A pproved __/__/__ OMB Control No. ____

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### 45 Attachment 6. Pulp and Paper e mission units and pollutants for which existing representative emission test data are requested Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Methanol 1 Total hydroc arbon (THC) as carbon CDD/CDF

and POM/PAH Total

reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide (CO) 1 Test methods M5, M29,

M17 PM CEMS, COMS M29 EPA OTM 27 EPA OTM 28 Chlorine (Cl 2 )

via M26A with modifications desc ribed in subpart S Cl 2 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 fu rnaces (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 Sup ply 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 fo r only the BLO) Not

requested Supply data from 1990 or more recent Not requested Supply mos t

recent data Not requestedForm A pproved __/__/__ OMB Control No. ____

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### 46 Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Methanol 1 Total hydroc arbon (THC) as carbon CDD/CDF

and POM/PAH Total

reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 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 Supp ly

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 mor e 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 dataForm A pproved __/__/__ OMB Control No. ____

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### 47 Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Methanol 1 Total hydroc arbon (THC) as carbon CDD/CDF

and POM/PAH Total

reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide (CO) 1 Digester s, Pulp washers, Evaporators, Turpentine recovery, Strippers, O 2 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 Su pply 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 rec ent 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

requestedForm A pproved __/__/__ OMB Control No. ____

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### 48 Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Methanol 1 Total hydroc arbon (THC) as carbon CDD/CDF

and POM/PAH Total

reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide (CO) 1

Bleac hing 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 r ecent data Not requested
Causticizing area sources Not

requested Supply most recent data Not requested
Stand alone semichemical, m echanical , 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 sy stem (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 (H 2 S), methyl mercaptan, dime thyl 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 i n 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