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

October 20, 2011



### MEMORANDUM

SUBJECT: Summary of Clean Condensate Alternative Technology Review

FROM: John Bradfield (EPA/OAR/OAQPS/SPPD/NRG) Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA

- HQ

- OAR

- 2007

- 0544

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

Background 1 

### :

The clean condensate alternative (CCA) is a pollution prevention alternative emission limit for pulping vents that is available only to kraft HVLC systems (which includes washers, knitters, screens, deck ers, and oxygen delignification) . The CCA allows mills to meet the HVLC
emission requirements by reducing the HAP emissions elsewhere, usually process water . This approach allows mills to control HAP emissions by reducing the amount of HAPs that are
vola tilized from selected process equipment instead of using combustion devices to control HVLC system vent streams. In a classic example, HAP condensates in paper machine process
water are removed. By reducing the HAP concentration in process water, the amounts of
volatilized HAPs are also reduced.

To achieve compliance, the facility must demonstrate that the HAP emission reductions using the CCA technology are equal to or greater than those emissi on reductions that would have been achieved through compliance with the HVLC system requirements. Mathematically, the mass of emissions required for control on HVLC sources creates a debit. The sum of the debits must be offset by an equal or greater numbe r of credits achieved by control of the selected
alternative emission source. The baseline emission value against which emission credits are
measured must be determined after compliance has been achieved with the kraft pulping process condensate standards, and the revised effluent limitations guidelines and standards in 40 CFR 430 subpart BB.

### The CCA allows mills to take credit for emission reductions achieved in several systems through the use of CCA technologies. The sources from which emission reduct ions can be
debited or credited are limited to the following: pulping systems (HVLC), bleaching systems, causticizing systems, and papermaking systems. The CCA emission reductions are generated
either by control of condensates that are not regulated under the kraft pulping condensate standard or control beyond the levels required by the condensate standard.

Developments in Practices, Processes, and Control Technologies

The Information Collection Request (ICR) 2 

### requested that facilities utilizing CCA provide their baseline emissions (debits), their CCA emission reductions (credits) and a process description. The CCA emission reduction value requested was defined as: HAP emission
reductions from baseline.

Out of 175 survey responses from major sources, 38 facilities responded as CCA facilities. Compliance approaches ranged significantly between the facilities, but included steam strippers, clean washer showers, hard

- piping, stand

- alone biological treatment, whi tewater temperature and HAP content monitoring, and over

- collection and over

- treatment of condensates

, as shown in
Table 1

. Of the predominant compliance methods, 6 utilized steam stripping, 15 utilized wastewater treatment (1 facility utilizing dredging a nd 5 utilizing hard

- piping), and 5 utilized

c leaner water practices on paper machines.

Using the survey data, EPA compared the baseline HAP reduction required by subpart S with the reductions achieved using the CCA approach. Baseline control at the 38 CCA mills would
have resulted in base emissions of approximately 31 kg HAP per ODTP (oven

- dried ton pulp).
The nationwide HAP emissions achieved through use of CCA at these 38 mills was approximately 16 kg HAP per ODTP . Thus, the CCA achieved a 50% reduction in HAPs on a kg HAP per ODTP basis beyond what would have been required through HVLC vent gas incineration under subpart S. Based on available production values, the CCA compliance option resulted in approximately 40% lower total emissions on a t ons per year basis than compliance with subpart S utilizing HVLC vent gas incineration.

Due to the broad scope of practices, processes, and controls that were used to generate credits, our technology review did not elucidate any developments or advances in HAP control at
CCA sources.

### Table 1: Summary of CCA technologies from ICR part 1 review

Facility
NEI ID Facility Location CCA Technology

NEI11172 Monticello, MS S team stripper

NEI11251 Valliant, OK Clean shower water

NEI13340 Halsey, OR C aptured Brownstock washers and decker exit gases. Installed low flow hoods on brownstock washers. The decker is not required to be collected but it is a large source of methanol. Gases sent to a methanol scrubber and
then sent to the wastewater treatm en t

NEI12492 Orange

, TX R eduction of methanol stripped to air at the ASB by installing and operating additional aerators

NEI18334 Pennington, AL S tand

- alone biological treatment unit

NEI18335 S elma, AL S tand

- alone biological treatment unit

NEI18338 Brewton, AL Maintain a minimum of 60% control efficiency in the ASB

NEI18652 Arkansas City, AR C ollection and hard

- piping of additional pulping process condensates from the evaporator and pre

- evaporator areas of the mill

NEI18658 Pine Bluff, AR Closed collection system, hard

- piping to WWT and discharged below liquid surface for biological treatment

NEI18660 Ashdown, AR H ard

- piping additional methanol to ASB treatment system

NEI26309 Cantonment, FL I nstall 2 primary clarifiers

NEI26471 Macon, GA M aintain paper machine white water temperature to equal to or less than 185 degrees F to ensure volatilization of methanol is minimized.

NEI26491 Cedar Springs, GA I nstallation of foam tank fog nozzles and barometric condenser to
minimize methanol losses

NEI26526 Jessup , GA Rerouted hard

- piped Subpart S regulated condensates to subsurface injection in the Mill's No. 1 Aeration Stabilization Basin and installed additional curtains, aerators, and mixers to further segment the basin's treatment stages and inc rease overall methan ol

NEI26581 Lewiston, ID S tand

- alone biological treatment unit

NEI33023 Hodge, LA C ollection and treatment of flash evaporator condensates with addition to turpentine decanter underflow before routing the stropped condensates to
the pulp washing system

NEI33025 Campti, LA C lean water

- shower water flow monitoring, periodic sampling and testing
for methanol concentration.

NEI34064 Columbus, MS C lean condensate to recaust

NEI34066 New Augusta, MS S tand

- alone biological treatment unit

NEI40247 Riegelwood, NC C lose recov e ry boiler and transfer weak black liquor from lagoon to storage tank

NEI40600 Toledo, OR O ffset HVLC emissions through over

- collection and over

- treatment of foul
condensate.

NEI41252 North Charleston, SC S team stripper

NEI41552 Counce, TN Use fresh water only on last stage of each brown stock washer, maintain paper machine white water MeOH concentration of 15 mg/L or less (28

- day average), and collect pulp mill condensates totaling 7.2 ln/ODTP MeOH and treating to remove at least 6Facility
NEI ID Facility Location CCA Technology

NEI42317 Hopewell, VA T raded use of digester condensate for wash water on brown stock washers with freshwater and digester condensate is collected and hard

- piped to POTW UNOX basin and treated to 92 % control efficiency

NEI42338 Longview, WA Additional collection of ~1,500 additional pounds per day (1.0 lb/ODTP), total of >8.2 lb/ODTP of HAPS on 30 day rolling average as measured at hard pipe outlet; destroy additional 1.0 lb/ODTP (>7.6 lb/ODTP)at WW
outlet

NEI42357 Port Townsend , WA U pgrade ASB

NEI42410 Wallula, WA S tand

- alone biological treatment unit

NEI42710 Kaukauna, WI I ncrease condensate treatment

NEI45182 Springfield, OR Lock out NCG scrubber underflow from causticizer and condensate from dissolving tank scrubber

NEI47091 Perry, FL S tand

- alone biological treatment unit

NEI6261 Jay, ME O ver collection of foul condensate through the hard

- pipe which bypasses the primary clarifier (reduces emissions from the primary clarifier).

NEI7559 Deridder , LA S team stripper

NEI8177 Riceboro, GA S team stripper

NEI8261 Fernandina Beach,
FL Replacing the wastewater treatment (WWT) cooling tower with non

contact heat exchangers, thereby eliminating HAP emissions from HVLC

NEI8278 Panama City, FL S team stripper

NEI8619 Pine Hill, AL Mill water, clean condensates of Kraft Mult i

- Effect Evaporator (4th Effect), and stripped condensates are used in pulp washers to reduced methanol carryover to Paper Machine No. 1.

NEI9201 Plymouth, NC ASB dredging

NEI7933 Florence, SC New steam stripper



### References:

1. Pulp and Paper NESHAP: A Plain English Description. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. EPA

- 456/R

- 98

- 008. November
1998.

2. Pulp and Paper ICR