May 4, 2012 

Thomas Holloway 

RTI International 

3040 Cornwallis Road 

Research Triangle Park, NC 27709 

Re: Packaging Corporation of America – Counce, TN 

Part II Information Collection Request (ICR) Revision 

RTI Mill #142, NEI Site ID 41552 

Dear Mr. Holloway: 

On behalf of the Packaging Corporation of America (PCA), All4 Inc. (ALL4) is providing a 

revised Part II response to U.S. Environmental Protection Agency’s (U.S. EPA’s) February 22, 

2011 Information Collection Request (ICR) for PCA’s Counce, Tennessee Pulp and Paper Mill 

(Mill). The Mill submitted its original response to the Part II ICR on June 6, 2011 and has 

revised its submittal in order to reflect the following: 

• Updated acetaldehyde emission rates associated with the Mill’s two (2) paper machines 

(Emission Unit IDs G301 and G302). The revised emission rates are based upon the 

results of recent whitewater sampling performed by the Mill and Mill-specific emission 

factors developed by National Council for Air and Stream Improvement (NCASI). 

• Updated acetaldehyde emission rates associated with the Mill’s wastewater treatment 

plant sources (Emission Unit IDs P10370 and P10371). Acetaldehyde emissions from 

the Mill’s primary settling basin have been deleted based upon clarification from NCASI 

that acetaldehyde would not be present in the Mill’s primary wastewater treatment stage 

since all acetaldehyde is present in the hard-piped condensate which is sent to the aerated 

stabilization basin. Acetaldehyde emissions associated with the aerated stabilization 

basin have been updated based upon the results of more representative sampling 

performed during 2012. 

• Updated physical exhaust characteristics of multiple emission release points in order to 

be consistent with the Mill’s original submittal and/or actual configuration during 

Calendar Year 2009. 

• Updated latitude and longitude of the wastewater treatment plant. 

• A revised Source Classification Code (SCC) for the No. 4 White Liquor/Green Liquor 

storage tank (Emission Unit ID T6061) which restores the Mill’s originally-reported 

value. 

• Deleted rows corresponding to incorrect Emission Unit ID and Emission Release Point 

ID pairings for the #2 Heavy Black Liquor Storage Tank (Emission Unit ID T7223) and 

the 63% Black Liquor Storage Tank (Emission Unit ID T7227). 
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5/3/2012 Document1 

• Added rows corresponding to corrected Emission Unit ID and Emission Release Point ID 

pairings for the #2 Heavy Black Liquor Storage Tank (Emission Unit ID T7223) and the 

63% Black Liquor Storage Tank (Emission Unit ID T7227). 

As ALL4’s Eric Swisher indicated to you during a telephone conversation on April 25, 2012, 

numerous major equipment changes occurred at the Counce Mill during the 2011 calendar year. 

These changes, and the associated impact on the emission rates of various compounds, will be 

addressed in future NEI updates. Therefore, the Counce Mill’s revised response continues to 

include information representative of operations and emissions during Calendar Year 2009. 

Along with the revised Part II response, we are also providing a plot plan for the Mill in order to 

ensure that on-site receptors are not modeled by U.S. EPA. 

PCA is submitting the enclosed detailed information with the expectation that it is to be used only 

for the purposes stated in the ICR and reserves the right to object to any other use of the 

information by U.S. EPA or any other governmental entity, and the right to contest the use of the 

submitted information by any non-governmental entity for any purpose including, but not limited 

to, in any court of law. 

If you have any questions or require additional information regarding this submittal, please 

contact me at 610-933-5246, extension 14, (jegan@all4inc.com) or Mr. Robin Ashe, Counce Mill 

Environmental Manager, at 731-689-1290 (rashe@packagingcorp.com). 

Sincerely, 

All4 Inc. 

John P. Egan 

Principal Consultant 

Cc: Robin Ashe, PCA 

 Richard Holland, PCA 

 Eric Swisher, ALL4 

 Megan Uhler, ALL4