United States Office of Air Quality EPA-456/R-98-008

Environmental Protection Planning and Standards November 1998

Agency Research Triangle Park, NC 27711 www.epa.gov/ttn/uatw/pulp/pulppg.html

Pulp and Paper NESHAP: 

A Plain English Description
ii

Disclaimer

This document was furnished to the U.S. Environmental Protection Agency by Eastern Research

Group, Inc. This document is final and has been reviewed and approved for publication. The

opinions, findings, and conclusions are those of the authors and not necessarily those of the

U.S. Environmental Protection Agency.

When using this document, remember that it is not legally binding and does not replace the

National Emission Standard for Hazardous Air Pollutants (NESHAP) for Source Category: 

Pulp and Paper Production (April 15, 1998, 63 FR 18504) for purposes of application of the rule

to any specific mill.

This document is not intended, nor can it be relied upon, to create any rights enforceable by any

party in litigation with the United States. The EPA may change this document at any time

without public notice.

Amendments to the Cluster Rule are being drafted and will be posted on the Technology Transfer

Network (TTN) at www.epa.gov/ttn/uatw/pulp/pulppg.html. You should periodically check

this website for amendments and/or other relevant information.
iii

Chapter 1 - 

Introduction

Chapter 2 - 

Description of

the Pulping and

Bleaching

Processes

Contents

Page

1.1 What does this document do? ...................................... 1

1.2 Why do I need this document? ..................................... 2

1.3 How should I use this document? ................................... 3

1.4 What are the Pulp and Paper “Cluster Rules”? ........................ 4

Figure 1. Types of Mills Covered Under the Cluster

Rules ................................... 4

Figure 2. Comparison of the Revised Final

Subcategories with Previous Subcategories ..... 7

1.5 What is the purpose of the Pulp and Paper NESHAP? .................. 8

Figure 3. Highest Emitted Hazardous Air Pollutants

from Pulp and Paper Mills .................. 8

1.6 How many sources does the NESHAP affect? ........................ 10

Figure 4. Location of Pulp and Paper Mills .............. 10

1.7 What if I have questions? ........................................ 11

1.8 How do I get additional copies of this document? ..................... 11

1.9 Where can I find additional information about this NESHAP? ........... 12

1.10 Where can I find additional information on the pulp and paper industry? ... 14

2.1 What distinguishes the types of mills that manufacture pulp and paper? ... 15

Figure 5. Chemical Pulping Process Differences .......... 16

2.2 What is the kraft pulping process? ................................. 17

Kraft digesting process .................................... 17

Figure 6. Example Overview of a Kraft Pulping Mill with

a Papermaking System .................... 18
Contents (Continued)

Page

iv

Kraft pulp processing steps ................................. 19

Figure 7. Brown Stock Washing System (Rotary Vacuum) . . 20

Evaporator system ........................................ 21

Oxygen delignification system ............................... 21

Gas collection systems ..................................... 22

Figure 8. Typical Oxygen Delignification System

(Medium Consistency) .................... 23

Condensate stripping ...................................... 24

2.3 What is bleaching? ............................................. 25

Figure 9. Example Bleaching Line ..................... 26

Bleaching chemicals ....................................... 27

Bleaching mixers ......................................... 28

Bleaching retention towers .................................. 28

Bleached pulp washers ..................................... 28

What is pulp preparation and papermaking? .................... 29

2.4 Soda mills .................................................... 30

2.5 Sulfite mills ................................................... 31

Figure 10. Example Sulfite Pulping System .............. 32

2.6 Semi-chemical mills ............................................ 33

Figure 11. Example Semi-chemical Pulping System ....... 34

2.7 Mechanical, secondary fiber, and non-wood fiber pulp mills ............ 35

Mechanical pulping ....................................... 35

Secondary fiber pulping .................................... 35

Non-wood fiber pulping .................................... 36

2.8 References for Chapter 2 ........................................ 37
Contents (Continued)

Page

v

Chapter 3 - 

Overview of the

Pulp and Paper

NESHAP

Chapter 4 - 

NESHAP

Requirements

for Kraft Mills

3.1 Which mills are subject to the NESHAP? ........................... 38

3.2 What processes and equipment systems must be controlled? ............ 39

Figure 12. Equipment Systems Covered by the

Pulping Vent Standards .................... 40

3.3 What are the emission control requirements? ......................... 41

Figure 13. Alternative Emission Limits ................. 42

3.4 What control systems will mills typically use to meet the emission

limits? .................................................. 43

3.5 How do mills demonstrate initial and continuous compliance? ........... 44

Figure 14. What Pollutants or Surrogates Must

Be Measured? ........................... 46

3.6 When must mills comply? ....................................... 47

3.7 What additional requirements apply to new sources? .................. 48

3.8 What is a new source? .......................................... 49

4.1 Standards for kraft pulping system vents ............................ 52

What kraft pulping system vents must be controlled? ............ 52

What are the emission limits for kraft pulping system vents? ...... 53

What does the NESHAP require for enclosures and closed-vent

systems? .......................................... 54

When must mills comply with the kraft pulping vent standards? .... 55

How does a mill demonstrate initial compliance with the kraft

pulping system vent standards? ........................ 56

Figure 15. How Does a Mill Demonstrate Initial

Compliance with the Kraft Pulping

System Vent Emission Limits? .............. 56

How does a mill demonstrate continuous compliance with the

kraft pulping system vent standards? .................... 57
Contents (Continued)

Page

vi

Figure 16. How Does a Mill Demonstrate Initial and

Continuous Compliance with the

Closed-Vent Systems Standard? ............. 57

Figure 17. How Does a Mill Demonstrate Continuous

Compliance with the Kraft Pulping

System Vent Emission Limits? .............. 58

Must a mill comply at all times? ............................. 59

4.2 Standards for kraft pulping process condensates ...................... 60

What is a condensate and why control it? ...................... 60

What kraft pulping condensates must be controlled? ............. 60

Does the mill have to collect all those streams? ................. 61

What are the control requirements? ........................... 61

What does the NESHAP require for condensate closed

collection systems? .................................. 62

When must a mill be in compliance? .......................... 63

How does a mill demonstrate initial compliance for kraft pulping

process condensate standards? ......................... 64

Figure 18. How Does a Mill Demonstrate Initial

Compliance with Kraft Pulping Condensate

Emission Limits? ......................... 65

How does a mill demonstrate continuous compliance with

pulping process condensate standards? .................. 65

Figure 19. How Does a Mill Demonstrate Continuous

Compliance with Kraft Pulping Process Condensate

Emission Limits? ......................... 66

Must a mill comply at all times? ............................. 67

4.3 Standards for the kraft bleaching system vents ....................... 68

What bleaching emission points must be controlled? ............. 68

Are there any exemptions to the bleaching requirements? ......... 68

What are the control requirements for chlorinated HAPs? ......... 69

What are the control requirements for chloroform? .............. 69

When must bleaching systems comply? ....................... 70

How does a mill demonstrate initial compliance with the

bleaching standards? ................................. 71
Contents (Continued)

Page

vii

Chapter 5 - 

NESHAP

Requirements

for SemiChemical and

Soda Mills

How does a kraft mill demonstrate continuous compliance with

the bleaching standards? .............................. 72

Figure 20. How Does a Kraft Mill Demonstrate

Continuous Compliance with Emission

Limits for Chlorinated HAPs? .............. 73

4.4 Clean condensate alternative for HVLC vents ........................ 75

Which equipment systems can be used to generate the emission

reductions? ........................................ 76

What emission reductions are creditable? ...................... 76

Can a mill use the CCA for only part of the emission reduction

requirement for the HVLC system? ..................... 76

How does a mill use the CCA? .............................. 77

How does a mill demonstrate initial compliance? ................ 78

How does a mill demonstrate continuous compliance? ............ 78

What approvals are required to use the CCA? .................. 78

4.5 How do the requirements for the NSPS and the NESHAP compare? ...... 79

Figure 21. Comparison of NESHAP and NSPS Alternative

Emission Limit(s) Requirements ............ 80

5.1 Standards for semi-chemical and soda pulping system vent standards ..... 82

What pulping system vents must be controlled? ................. 82

What are the emission limits for semi-chemical and soda pulping 

system vents? ...................................... 83

What does the NESHAP require for enclosures and closed-vent systems

at semi-chemical and soda mills? ....................... 84

When must mills comply with the semi-chemical and soda

pulping process standards? ............................ 85

How does a mill demonstrate initial and continuous compliance with the

pulping system vent standards? ........................ 85

Must a mill comply at all times? ............................. 85

5.2 Standards for bleaching system vents at semi-chemical and soda mills .... 86

Semi-chemical mills ....................................... 86

Soda mills ............................................... 86
Contents (Continued)

Page

viii

Chapter 6 - 

NESHAP

Requirements

for Sulfite Mills

Chapter 7 - 

NESHAP

Requirements

for Mechanical,

Secondary Fiber,

and Non-wood

Fiber Pulp Mills

6.1 Standards for sulfite pulping system vents ........................... 88

What sulfite pulping system vents must be controlled? ........... 88

What are the emission limits for sulfite pulping system vents? ..... 89

What does the NESHAP require for enclosures and closed-vent

systems? .......................................... 90

When must mills comply with the sulfite pulping process requirements?91

How does a mill demonstrate initial compliance with the sulfite pulping

system vent standards? ............................... 91

How does a mill demonstrate continuous compliance with the

sulfite pulping system vent standards? ................... 92

Figure 23. How Does a Mill Demonstrate Initial and

Continuous Compliance with

the Closed-Vent Systems Standard? .......... 92

Figure 24. How Does a Mill Demonstrate Continuous

Compliance with the Sulfite Pulping System

Vent Standards? ......................... 93

6.2 Standards for sulfite bleaching system vents ......................... 94

When must sulfite bleaching systems comply? .................. 94

7.1 Standards for bleaching system vents ............................... 95

What mechanical, secondary fiber, and non-wood fiber bleaching system

emission points must be controlled? ..................... 95

Are there any exemptions to the bleaching requirements? ......... 96

What are the control requirements for chlorinated HAPs? ......... 96

When must mechanical, secondary fiber, and non-wood fiber bleaching

systems comply? .................................... 96

How does a mill demonstrate initial compliance with the

bleaching standards? ................................. 97

How does a mill demonstrate continuous compliance with the bleaching

standards? ......................................... 98

Figure 25. How Does a Kraft Mill Demonstrate

Continuous Compliance with Emission

Limits for Chlorinated HAPs? .............. 99
Contents (Continued)

Page

ix

Chapter 8 - 

Other Federal

Regulations

Affecting Pulp

and Paper Mills

Appendices

8.1 What other Federal air regulations affect the pulp and paper industry? ... 101

8.2 What other Federal water regulations affect the pulp and paper industry? . 103

Figure 26. A Guide to the Acronyms for

Technology-Based Water Standards ......... 105

Figure 27. Applicability of Technology-Based

Standards .............................. 106

8.3 What Federal hazardous wastes regulations affect the pulp and paper

industry? ............................................... 107

8.4 What upcoming regulations will affect pulp and paper mills? ........... 109

A: List of U.S. Pulp and Paper Mills

B: NESHAP for Source Category: Pulp and Paper Production

C: Flowchart Summary of the NESHAP

D: List of EPA Region Office Contacts

E: Equipment Diagrams for Pulp and Paper Mills

F: List of Equipment Affected by the NESHAP

G: Pulp and Paper NESHAP Control Requirements

H: Compliance Milestones Timeline for Existing Sources

I: Summary of Effluent Limitations Guidelines for Bleached Papergrade

Kraft Mills
1

This document does

NOT replace the

NESHAP for purposes

of making legal

interpretations!

Chapter 1 - Introduction

The U.S. Environmental Protection Agency (EPA) published the National

Emission Standards for Hazardous Air Pollutants (NESHAP) for the Pulp

and Paper Industry (40 CFR 63, Subpart S) on April 15, 1998 as part of the

Pulp and Paper Cluster Rules. The NESHAP affects existing and new major

sources that chemically and nonchemically pulp wood and non-wood fibers

for pulp and paper production. The NESHAP requires these sources to

control hazardous air pollutant (HAP) emissions using the maximum

achievable control technology (MACT). The Cluster Rules also revised the

effluent limitations guidelines and standards under the Clean Water Act for

pulp mills that make bleached papergrade products.

1.1 What does this document do?

This document focuses on the NESHAP and describes:

C the pulping and bleaching processes

C the requirements of the NESHAP

C the scope of effluent limitations guidelines and standards

revisions

C additional references and sources of information about pulp

and paper mills
Chapter 1 - Introduction

2

1.2 Why do I need this document?

You need this document because it will help you understand the NESHAP.

Implementation of the pulp and paper NESHAP is complex for both affected

mills and regulators because:

C There is a tremendous amount of variability in the pulp and

paper industry with respect to processes, equipment, and

products. For example, the task of turning wood into pulp is

performed by different processes using different equipment

and different chemicals at kraft mills, sulfite mills, and

mechanical pulping mills. As a result, different emission

points must be controlled at each type of mill.

C The NESHAP allows for a significant amount of flexibility in

the control strategies used to reach compliance.

C The timelines for compliance vary for different parts of the

mill.

C More stringent control requirements apply to some new

sources.

C Technical requirements for some of the available control

strategies will be specified on a mill-by-mill basis by the

implementing agency.
Chapter 1 - Introduction

3

1.3 How should I use this document?

If you are familiar with the pulping and bleaching processes, there is no need

to read Chapter 2. You should skip ahead to Chapter 3. Everyone should

read Chapter 3 as it provides the overview of the NESHAP. After reading

Chapter 3, you should decide what other sections of the document you need.

If You Need the Following Information... Then Read...

A description of the Cluster Rules Chapter 1

A description of pulping and bleaching processes Chapter 2

An overview of the NESHAP Chapter 3

A description of how new source requirements apply Chapter 3

NESHAP requirements for kraft mills Chapter 4

NESHAP requirements for soda and semi-chemical Chapter 5

mills

NESHAP requirements for sulfite mills Chapter 6

NESHAP requirements for mechanical, secondary Chapter 7

fiber, and non-wood fiber pulp mills

A description of other existing and upcoming Chapter 8

Federal regulations affecting pulp and paper mills

A list of pulp and paper mills Appendix A

A copy of the NESHAP Appendix B

Flowchart summary of the NESHAP Appendix C

A list of EPA Regional Office contacts Appendix D

Equipment diagrams Appendix E

A list of equipment affected by the NESHAP Appendix F

A summary of the NESHAP control requirements Appendix G

A timeline of compliance milestones Appendix H

Summary of effluent limitations guidelines and Appendix I

standards for bleached papergrade kraft mills
Chapter 1 - Introduction

4

Stay informed about

new or revised

requirements by

visiting "What’s New"

pages of the OECA

and Unified Air

Toxics Websites:

http://es.epa.gov/

oeca/wn2.html

and

http://www.epa.gov/

ttn/uatw/

uatwnew.html

1.4 What are the Pulp and Paper “Cluster Rules”?

The Cluster Rules are a simultaneous publication of Federal air and water

pollution control regulations. They are an example of the EPA’s efforts to

simplify compliance by coordinating the regulation of multimedia industrial

pollution and will reduce both air and water pollutant discharges. You can

get an electronic copy of the Cluster Rules from the Federal Register website

at http://www.access.gpo.gov/su_docs/aces/aces140.html or the EPA

Unified Air Toxics website at http://www.epa.gov/ttn/uatw on the Rules

and Implementation Page.

The goals of this coordinated regulatory approach are to:

C provide greater protection of human health and the

environment

C reduce the overall cost of complying with wastewater

regulations and air emissions controls

C promote and facilitate coordinated compliance planning by

the industry

C promote and facilitate pollution prevention

C emphasize the multimedia nature of pollution control

Figure 1 identifies the mill types covered under the Cluster Rules. 

Appendix A lists the mills potentially affected by the Cluster Rules by facility

name and location.

Figure 1.

Types of Mills Covered Under the Cluster Rules

Then it is Subject to These Parts of the Cluster Rules...

If the Mill is this Type... NESHAP Guidelines and Standards

Revised Effluent Limitations

Kraft X Bleached Papergrade only

Soda X Bleached Papergrade only

Sulfite X Papergrade only

Semi-Chemical X

Mechanical X

Non-Wood Fiber X

Secondary Fiber X
Chapter 1 - Introduction

5

The features of the

NESHAP are:

C Alternative emission

 limits

C Varying compliance

 periods (3-8 years)

C New and existing

 source controls

C Flexibility for

 evolving

 technologies

C Compliance dates

 coordinated with

 effluent limitations

 guidelines and

 standards

The Cluster Rules consist of the following two components:

(1) National Emission Standards for Hazardous Air Pollutants

(NESHAP) from the Pulp and Paper Industry

(40 CFR 63, Subpart S). The pulp and paper NESHAP specifies

emission standards for pulping and bleaching systems at all chemical

pulping mills and bleaching systems at mechanical pulping, non-wood

fiber, and secondary fiber mills.

The air emissions control standards require mills to reduce hazardous

air pollutant emissions through the use of thermal oxidizers, boilers,

lime kilns, recovery furnaces, caustic scrubbers, or other control

devices, or process modifications. In general, the NESHAP requires

mills to:

C collect and incinerate pulping process vent emissions

C collect and control bleaching process vent emissions

with a caustic scrubber

C eliminate the use of certain bleaching chemicals

C collect and treat process condensate streams to

remove HAPs through biological treatment or

stripping (kraft mills only)

The NESHAP is written to encourage pollution prevention

techniques. See Appendix B for a copy of the NESHAP and

Appendix C for a flowchart summary of the NESHAP.

This NESHAP does NOT address emissions from chemical recovery

process combustion sources. Emissions from these sources will be

covered by another NESHAP (Subpart MM) proposed on

April 15, 1998 (63 FR 18754).
Chapter 1 - Introduction

6

Stay informed

about new or

revised

requirements by

visiting the EPA

Office of Water’s

Pulp and Paper

Website:

http://www.epa.

gov/ost/pulppaper/

(2) Effluent Limitations Guidelines and Standards, Pretreatment

Standards, and New Source Performance Standards for the Pulp,

Paper, and Paperboard Category (40 CFR 430, Subparts A-L). 

These regulations control discharge of pollutants in wastewaters

generated at pulp and paper mills. The pretreatment standards apply

to mills that discharge wastewater to a municipal wastewater

treatment facility (i.e., Publicly Owned Treatment Works or POTW). 

The effluent limitations guidelines and standards are applied to the

mills that directly discharge into receiving water via the National

Pollution Discharge Elimination System (NPDES) permit program. 

In addition, the effluent limitations guidelines and standards portion

of the Cluster Rules:

C Includes best management practices (BMP)

regulations for a portion of the pulp, paper, and

paperboard industry. The BMP rules are designed to

prevent or contain leaks and spills of pulping liquor,

soap, and turpentine, and to control any intentional

diversions of these substances.

C Specifies new analytical methods for twelve

chlorinated phenolic pollutants and for adsorbable

organic halides (AOX).

C Revises the subcategorization scheme for existing

effluent limitations guidelines and standards for the

pulp and paper industry (shown in Figure 2) and

revises the effluent limitations guidelines and

standards for Bleached Papergrade Kraft and Soda

subcategory (Subpart B) and the Papergrade Sulfite

subcategory (Subpart E). The EPA revised the

subcategorization scheme to better define the

processes typically found in U.S. mills.

C Includes the Voluntary Advanced Technology

Incentives Program which is designed to encourage

direct discharging bleached papergrade kraft mills to

install more pollution prevention technology than

required by the regulations.
Chapter 1 - Introduction

7

Figure 2.

Comparison of the Revised Final

Subcategories with Previous Subcategories

Final Final Previous Subcategorization

Codified Subcategorization Scheme with Previous 

Subpart Scheme 40 CFR 430 Subparts Noted in Parentheses

A Dissolving Kraft Dissolving Kraft (F)

B Bleached Papergrade Kraft and Soda Market Bleached Kraft (G) a

BCT Bleached Kraft (H)

Fine Bleached Kraft (I)

Soda (P)

C Unbleached Kraft Unbleached Kraft (A)

- Linerboard

- Bag and Other Products

Unbleached Kraft and Semi-Chemical (D, V)

D Dissolving Sulfite Dissolving Sulfite (K)

- Nitration

- Viscose

- Cellophane

- Acetate

E Papergrade Sulfite Papergrade Sulfite (J,U) a

- Blow Pit Wash

- Drum Wash

F Semi-Chemical Semi-Chemical (B)

- Ammonia

- Sodium

G Mechanical Pulp GW-Thermo-Mechanical (M)

GW-Coarse, Molded, News (N)

GW-Fine Papers (O)

GW-Chemical-Mechanical (L)

H Non-Wood Chemical Pulp Miscellaneous mills not covered by a specific subpart

I Secondary Fiber Deink Deink Secondary Fiber (Q)

- Fine Papers

- Tissue Papers

- Newsprint

J Secondary Fiber Non-Deink Tissue from Wastepaper (T)

Paperboard from Wastepaper (E)

- Corrugating Medium

- Non-Corrugating Medium

Wastepaper-Molded Products (W)

Builders’ Paper and Roofing Felt

(40 CFR Part 431 Subpart A)

K Fine and Lightweight Papers from Purchased Pulp Non-Integrated Fine Papers (R)

- Wood Fiber Furnish

- Cotton Fiber Furnish

Lightweight Papers (X)

- Lightweight Papers

- Lightweight Electrical Papers

L Tissue, Filter, Non-Woven, and Paperboard from Non-Integrated

Purchased Pulp - Tissue Paper (S)

- Filter and Non-Woven (Y)

- Paperboard (Z)

 Revised under the Cluster Rules. a
Chapter 1 - Introduction

8

A major source is a

stationary source that

has the potential to

emit 10 tons per year

of any one HAP or

25 tons per year of

total HAPs.

1.5 What is the purpose of the Pulp and Paper

NESHAP?

The purpose of this NESHAP is to reduce HAP emissions from the pulp and

paper industry, thus reducing public health hazards. The EPA regulated this

industry because pulp and paper mills are major sources of HAP emissions

listed in Section 112 of the Clean Air Act (CAA). Section 112(d) of the

CAA directs EPA to set maximum achievable control technology (MACT)

standards for major stationary sources. MACT standards are technologybased emission limitations that require the maximum degree of emission

limitations that is achievable considering cost, human health, environmental,

and energy impacts.

Pulp and paper mills emit 240,000 tons of HAPs annually that impact both

air quality and public health. The pulp and paper NESHAP will reduce 1996

emissions of HAPs from pulp and paper facilities by 153,000 tons per year

(a 64 percent reduction). Figure 3 lists the HAPs emitted in the largest

quantities from pulp and paper mills. 

Figure 3.

Highest Emitted Hazardous Air Pollutants

from Pulp and Paper Mills

Hazardous Air Pollutants

Acrolein Methanol

Acetaldehyde Methylene chloride

o-Cresol Methyl ethyl ketone

Carbon tetrachloride Phenol

Chloroform Propionaldehyde

Cumene 1,2,4-Trichlorobenzene

Formaldehyde o-Xylene
Chapter 1 - Introduction

9

The control techniques used to reduce HAP emissions will also reduce

emissions of other pollutants. For example, the NESHAP will reduce

volatile organic compound (VOC) emissions by 450,000 tons per year. 

Volatile organic compounds cause a variety of adverse health effects and are

precursors to the formation of tropospheric (ground level) ozone.

Emissions of total reduced sulfur (TRS) compounds cause the odors

commonly associated with pulp and paper production. Exposure to TRS

emissions has been linked to symptoms including headaches, watery eyes,

nasal problems, and breathing difficulties. Total reduced sulfur emissions are

regulated by new source performance standards (NSPS) under Section 111

of the CAA. Although not specifically regulated by the NESHAP, the

NESHAP will result in a reduction of TRS emissions by 87,000 tons per

year. 
Chapter 1 - Introduction

10

The list of mills in

Appendix A is

provided for

information only. 

The list is not

necessarily

complete, nor does

it represent an EPA

determination that

any specific mill is

subject to the rules.

1.6 How many sources does the NESHAP affect?

Figure 4 shows the location of the pulp and paper facilities in the United

States that are potentially affected by the pulp and paper NESHAP. 

Appendix A lists the pulp and paper mills (including facility name, and

location by city and state) that were identified as potentially affected sources

at the time the NESHAP was published.

Figure 4.

Location of Pulp and Paper Mills

State Mills State Mills State Mills

Alabama 19 Kansas 2 New Mexico 1

Arkansas 8 Kentucky 5 New York 49

Arizona 2 Louisiana 13 Ohio 30

California 34 Massachusetts 38 Oklahoma 6

Colorado 1 Maryland 3 Oregon 12

Connecticut 10 Maine 18 Pennsylvania 31

Delaware 2 Michigan 33 South 9

Carolina

Florida 11 Minnesota 9 Tennessee 13

Georgia 24 Missouri 3 Texas 11

Iowa 2 Mississippi 10 Virginia 12

Idaho 1 Montana 1 Vermont 6

Illinois 10 North 17 Washington 22

Carolina

Indiana 12 New 12 Wisconsin 46

Hampshire

New Jersey 14 West Virginia 2

Total 564

Source: Lockwood-Post Directory, 1996.
Chapter 1 - Introduction

11

Identify your State

and local contacts

using the Membership

Directory at the

STAPPA/ALAPCO

website at

http://www.4cleanair.

org

STAPPA/ALAPCO =

State and Territorial

Air Pollution Program

Administrators/

Association of Local

Air Pollution Control

Officials

Copies are

available free of

charge from the

EPA library.

1.7 What if I have questions?

If you are the owner or operator of a pulp and paper mill, you can get

additional information from:

C your State or local air pollution control agency

C trade associations, such as Technical Association of the Pulp

& Paper Industry (TAPPI) at http://www.tappi.org or

American Forest and Paper Association (AF&PA) at

http://www.afandpa.org

If you work for a State or local regulatory agency and have questions

regarding the implementation of this NESHAP, you should contact your

EPA Regional Office. A list of EPA Regional Office contacts is included in

Appendix D. 

1.8 How do I get additional copies of this document?

You can get copies of this document from:

C EPA’s Technology Transfer Network (TTN) on the world

wide web at

http://www.epa.gov/ttn/uatw/pulp/pulppg.html

C Library Services Office (MD-35)

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Telephone: (919) 541-2777

C National Technical Information Services (NTIS)

Technology Administrations

5285 Port Royal Road

Springfield, Virginia 22161

Telephone: (703) 605-6000

Fax: (703) 321-8547

Note: NTIS will charge a fee for each document

requested.
Chapter 1 - Introduction

12

An overview of this

NESHAP is

available on a

40 minute video

tape. You can view

this tape at your

State or local air

pollution control

office.

Check the UATW

for correction

notices and

amendments.

1.9 Where can I find additional information about this

NESHAP?

You can find information about the basis and purpose of this NESHAP in

the Federal Register notices and background information documents. The

background information documents are:

C Pulp, Paper, Paperboard Industry - Background Information

for Proposed Air Emissions Standards for Manufacturing

Processes at Kraft, Sulfite, Soda, and Semi-chemical Mills. 

Publication No. EPA-453/R-93-050a. October 1993

C Pulp, Paper, Paperboard Industry - Background Information

for Promulgated Air Emissions Standards for Manufacturing

Processes at Kraft, Sulfite, Soda, and Semi-Chemical,

Mechanical, and Secondary and Non-wood Fiber Mills. 

Publication No. EPA-453/R-93-050b. October 1997

Federal Register notices pertaining to the NESHAP are:

C Proposed NESHAP: published December 17, 1993

(58 FR 66078)

C Correction notice to the proposed NESHAP: published

March 17, 1994 (59 FR 12567)

C Notice of Data Availability (NODA): published February 22,

1995 (60 FR 9813)

C Supplemental Notice: published March 8, 1996

(61 FR 9383)

C Promulgated NESHAP: published April 15, 1998

(63 FR 18504)

C Correction of minor errors on the April 15, 1998 Notice: 

published August 7, 1998 (63 FR 42238)
Chapter 1 - Introduction

13

C Interpretation and Technical Amendment regarding

applicability to excess emission allowance for condensate

treatment systems: published September 16, 1998

(63 FR 49455)

You can get these documents and other relevant documents from:

C EPA’s Unified Air Toxics website (UATW) at

http://www.epa.gov/ttn/uatw or

http://www.epa.gov/ttn/uatw/pulp/pulppg.html. These

sites contain background documents, preambles, regulations,

guidance documents, and policy memos

C “What’s New” page of the UATW at

http://www.epa.gov/ttn/uatw/uatwnew for the most

current information

C The Air Dockets (A-92-40 and A-95-31) which are available

for public inspection between 8 a.m. and 4 p.m., Monday

through Friday, except for Federal holidays, at:

Air and Radiation Docket and Information Center

(MD-6102)

U.S. Environmental Protection Agency

401 M Street SW

Room M-1500

Waterside Mall

Washington, DC 20460

Telephone: (202) 260-7548
Chapter 1 - Introduction

14

The Kraft Pulp Mill

Compliance

Assessment Guide

covers the Cluster

Rules as well as

NSPS and other

rules affecting kraft

mills.

1.10 Where can I find additional information on the

pulp and paper industry?

You can get additional information from:

C Biermann, C.J. 1993. Essentials of Pulping and

Papermaking. San Diego, CA: Academic Press, Inc.

C Burgess, T. 1995. The Basics of Foul Condensate Stripping. 

1995 Kraft Recovery Short Course. Atlanta, GA: 

TAPPI PRESS.

C EPA. 1998. Permit Guidance Document for Pulp, Paper and

Paperboard Manufacturing Point Source Category, 40 CFR

Part 430, draft. Office of Water, Washington, DC.

C EPA. 1995. Office of Compliance Sector Notebook Project: 

Profile of the Pulp and Paper Industry. 

Publication No. EPA/310-R-95-015. 

http://es.epa.gov/oeca/sector/index.html#pulp Office of

Enforcement and Compliance Assurance, Washington, DC.

C EPA. 1999. Kraft Pulp Mill Compliance Assessment Guide. 

Publication No. EPA/310-B-99-001. Office of Enforcement

and Compliance Assurance, Washington, DC.

C How Paper is Made: An Overview of Pulping and

Papermaking from Woodyard to Finished Product. 1997. 

Available on CD-ROM, Atlanta, GA: TAPPI PRESS.

C Kocurek, M.J. and Stevens, C.F.B., eds. 1983. Pulp and

Paper Manufacture. Third Edition. Joint Textbook

Committee of the Paper Industry.

C Mimms, A., Kocurek, M., Pyatte, J. and Wright, E. eds. 

1993. Kraft Pulping. Atlanta, GA: TAPPI PRESS.

C Smook, G.A. 1992. Handbook for Pulp and Paper

Technologists. Second Edition. Bellingham, WA: Angus

Wilde Publications.
15

If you are already

familiar with

pulping and

bleaching

processes, you can

move ahead to

Chapter 3.

The types of pulp

mills are:

C kraft

C soda

C sulfite

C semi-chemical

C mechanical

C secondary fiber

C non-wood fibers

Chapter 2 - Description of the Pulping and

Bleaching Processes

Three major types of fibers are used to make pulp and paper products: 

wood; secondary fibers (recycled fibers); and non-wood fibers (e.g., cotton,

flax, hemp). However, the majority of pulp and paper products are made

from wood, and most wood mills use the kraft pulping process.

Because kraft mills represent the majority of the industry, this chapter

describes the processes at kraft mills using wood. A general process

overview for each of the other types of mills is also provided. This chapter

does not explain each individual process, but rather focuses on the main

activities affected by the NESHAP. For further information about the pulp

and paper industry and process operations, please refer to the list of

materials provided in Chapter 1.

2.1 What distinguishes the types of mills that

manufacture pulp and paper?

Kraft, soda, and sulfite mills all use chemicals in their pulping processes.

These processes differ primarily in the chemicals used for digesting wood

chips. Mechanical pulping involves shredding or grinding wood chips

without the use of chemicals and semi-chemical pulping combines chemical

and mechanical methods. Secondary fiber mills mechanically separate pulp

from waste paper products. Non-wood fiber mills can use mechanical and

chemical pulping processes. Figure 5 summarizes the characteristics of the

different types of chemical pulping processes.
Chapter 2 - Pulping and

Bleaching Processes

16

Figure 5.

Chemical Pulping Process Differences

Pulping Pulp Chemicals Pulp Yield Type of Wood Typical Pulp

Process Type Produced Used Percent Used Uses

Typical Typical

Kraft Kraft NaOH, Na S 40-50 Softwood and Writing paper; 2

hardwood paper bags;

cardboard;

specialty

products such as

rayon, acetate,

and cellophane

Soda Soda NaOH 45-55 Hardwood Writing paper;

specialty

products such as

rayon, acetate,

and cellophane

Sulfite Acid sulfite H SO , 45-55 Softwood and Writing paper; 2 3

M(HSO3) hardwood specialty

(M=Ca, Mg, products such as

Na, NH ) rayon, acetate, 4

and cellophane

Semi-chemical Neutral Na SO 65-80 Hardwood Corrugated

Sulfite Semi- Na CO containers

chemical

2 3

2 3

 Source: Smook, 1992.
Chapter 2 - Pulping and

Bleaching Processes

17

The NESHAP has

the same emission

limits for

papergrade and

dissolving grade

pulp production.

2.2 What is the kraft pulping process?

The pulping process converts raw materials into a fibrous mass that can be

formed into paper or cardboard. Wood contains both cellulose fibers and

lignin; the objective of the kraft pulping process is to dissolve the lignin and

leave most of the cellulose fibers intact.

The main operations performed in the kraft pulping process are: 

C digestion of wood to form pulp

C pulp processing to recover spent cooking chemicals and to

remove impurities and uncooked wood chips (deknotting,

pulp washing, pulp screening)

C concentration of used pulping liquor for chemical recovery

Figure 6 depicts a typical overview of a kraft pulp and paper mill. More

detailed diagrams for each equipment system in the pulping process are

provided in Appendix E.

Kraft digesting process

Kraft pulping entails cooking, or digesting, wood chips at elevated

temperature and pressure in an alkaline pulping liquor that contains sodium

sulfide (Na2S) and sodium hydroxide (NaOH). Cooking may be performed

in either batch digester or continuous digester systems. For mills that use

softwood feedstock (e.g., pine), the digester system generally will include a

turpentine recovery system. The turpentine is recovered from digester relief

vent gases. 

The pulping liquor and elevated temperature and pressure promote

breakdown of the bonds in the lignin compounds. Depending on pulping

conditions, as much as 90-95 percent of the lignin can be removed from

wood in kraft pulping.

Two types of pulp are produced:

C papergrade (for making paper, paperboard, tissue)

C dissolving grade (for making rayon, cellophane, acetate, food

additives)
18

Figure 6.

Example Overview of a Kraft Pulping Mill with a Papermaking System
Pulp

from

Digester

Pulp

to 

Washer

Knots

Chapter 2 - Pulping and

Bleaching Processes

19

Weak black liquor

consists of

dissolved wood

compounds and

spent cooking

chemicals. 

Kraft pulp processing steps

Kraft mills remove impurities from the raw pulp prior to bleaching or

papermaking. The primary pulp cleaning operations include deknotting (in

the knotter), brown stock washing (in the pulp washing system), and pulp

screening (in the screening system).

Deknotting removes

knots and other

portions of uncooked

wood from the pulp

slurry. Kraft mills

burn the knots and

uncooked wood for

energy recovery,

dispose of them as

waste, or recycle them

for repulping. The diagram to the right shows a typical knotter.

Brown stock washing recovers spent cooking liquor (weak black liquor) for

reuse in the pulping process. Efficient washing is critical to maximize the

return of cooking liquor to chemical recovery and to minimize carryover of

cooking liquor (known as brown stock washing loss) into the bleach plant. 

A variety of brown stock washing technologies are used; the most common

technology is a series of two to four rotary vacuum washers. In each

washer, wash water is applied to displace cooking liquor in the pulp;

countercurrent washing is generally used to reduce fresh water requirements. 

Other common washer types are diffusion washers, rotary pressure washers,

horizontal belt filters, wash presses, and dilution/extraction washers. 

Figure 7 shows a typical rotary vacuum washer system.
Washer Washer Washer

Water

Pulp from

Knotter

System

Seal

tank

Seal

tank

Seal

tank

Foam

tank

Spent liquor

to Weak Black 

Liquor 

Storage Tank

Pulp

storage

tank Pulp to

Screen and Decker

Systems

Hood vent gases

20

Figure 7.

Brown Stock Washing System (Rotary Vacuum)
Chapter 2 - Pulping and

Bleaching Processes

21

A screen system

removes oversized

particles from the

pulp slurry prior to

the bleaching or

papermaking

system.

A decker is used to

thicken the pulp for

storage after

screening or

subsequent

delignification

steps.

Pulp screening removes the remaining oversized particles (fiber bundles and

contaminants) from washed pulp. The pulp is diluted to low percent solids,

then passed through a perforated screen, and rejects are continuously

removed from the screen. Methods for removing rejects are shaking and

vibration, hydraulic sweeping action, back-flushing, or pulsing the flow

through the openings with various moving foils, paddles, and bumps. Mills

may operate open, partially closed, or closed screen rooms. In open screen

rooms, wastewater from the screening process is discharged to wastewater

treatment. In closed screen rooms, wastewater is reused in brown stock

washing or other pulping operations and ultimately enters the chemical

recovery system. 

A decker system is all of the equipment used to thicken the pulp slurry after

the pulp washing system. It includes decker vents, filtrate tanks, and

vacuum pumps.

Evaporator system

Weak black liquor collected from the pulp washers goes into a weak black

liquor storage tank. The weak black liquor is sent to the multiple effect

evaporator (MEE) to evaporate water and concentrate the weak black liquor

in order to increase solids content. Typically, weak black liquor recovered

from the brown stock washers contains between 13 and 17 percent solids. 

The weak black liquor is then concentrated to 60-80 percent solids, which is

required for efficient combustion in the recovery boiler. An MEE will

include four to seven effects, or bodies, arranged in series. At pulp mills

using soft wood, a tall oil recovery system is generally incorporated into the

evaporator system to recover tall oil from the black liquor. Tall oil is sold

for use in manufacturing cosmetics.

Oxygen delignification system

Some mills that produce bleached pulp may also have an oxygen

delignification stage either in the pulping area or as a prebleaching stage. 

The oxygen delignification process reduces the lignin content without

reducing pulp strength or yield. High efficiency oxygen delignification

minimizes the amount of bleaching chemicals needed to achieve adequate

pulp brightness.
Chapter 2 - Pulping and

Bleaching Processes

22

There are currently two types of oxygen delignification systems available: 

high consistency and medium consistency. Medium consistency systems are

more popular due to safer operation and lower capital costs. Design and

placement of these systems vary from mill to mill. Oxygen delignification

systems of the two-stage design are most often employed in the U.S. for new

installations. Figure 8 shows a typical oxygen delignification system.

Gas collection systems

Gas collection systems, or noncondensible gas (NCG) systems, are used to 

collect gases from the various pulping processes and transport them to an

appropriate air pollution control device. There are two basic categories of

NCGs: low volume, high concentration (LVHC); and high volume, low

concentration (HVLC).

Low volume, high concentration (LVHC) systems typically collect gases

from the following systems:

C digester system

C turpentine recovery system

C evaporator system

C steam stripper system

C any other system serving one of these functions

High volume, low concentration (HVLC) systems typically collect gases

from the following systems:

C knotter system

C pulp washing system

C screen system

C oxygen delignification system

C weak liquor storage tanks

C any other equipment serving one of these functions
Mixer

Oxygen

Tower

Hood vent gases 

Washer

Filtrate

tank

Weak Black

Liquor

Pulp to

Bleaching System

Pulp from

Screen and 

Decker System 23

Figure 8.

Typical Oxygen Delignification System (Medium Consistency)
Chapter 2 - Pulping and

Bleaching Processes

24

Historically, most

LVHC gases have

been controlled,

while a smaller

portion of the

HVLC gases have

been controlled.

Steam stripper

systems were

historically

installed to control

TRS odor.

A number of mills use a dedicated incinerator to control NCG emissions, but

most mills use process combustion sources such as the lime kiln, power

boilers, or a recovery boiler.

Condensate stripping

The pulping process equipment may include a steam stripper system to

remove organics and total reduced sulfur (TRS) compounds from various

liquid process condensate streams. Steam stripping is a multistage

distillation separation process that uses direct steam as the heat source. The

pulping process condensate streams most often stripped are the turpentine

decanter underflow, blow steam condensates, and certain evaporator

condensates. The stripped condensates may then be used as hot process

water.

Kraft pulping process condensates originate from the following systems:

C digester system

C turpentine recovery system

C evaporator system
Chapter 2 - Pulping and

Bleaching Processes

25

Each bleaching

stage performs

three functions:

C mixing of pulp

 and bleaching

 chemicals

C reaction of

 bleaching

 chemicals with

 the pulp

C washing the

 chemicals out of

 the pulp

2.3 What is bleaching?

Bleaching brightens the pulp in a series of chemical operations that are

together called a bleaching line. A bleaching line typically consists of a

sequence of three to six bleaching stages. The number of stages varies

depending on the brightness requirements of the pulp and the specific design

of the mill. Typically, the stages are sequenced as an alternating series of

bleaching and extraction stages. In a bleaching stage, the pulp is treated

with chemical bleaching agents. In an extraction stage, chemicals (usually

sodium hydroxide) are added to neutralize the chemical reactions and the

acidity of the pulp prior to the next bleaching stage. An extraction stage is

not required in all cases.

Each bleaching stage consists of three steps: mixing of pulp and bleaching

chemical (and in some cases steam); reaction of the chemical with the pulp in

a retention tower; and washing the chemical out of the pulp. Thus, the

equipment considered part of a stage includes chemical and steam mixers,

retention (bleaching or extraction) towers, and the washers and their

associated seal (filtrate) tanks and/or vacuum pumps.

Figure 9 depicts the major equipment found in a typical three-stage bleaching

plant. The function of these equipment systems and a brief description

follow. 
Chlorinated bleaching stage vent gases

to scrubber

Pulp flow

Water/filtrate flow

Gas stream

M Mixer

Bleach plant filtrates

sent to 

wastewater treatment

Bleached

Pulp

Pulp from

Pulping 

System

Bleaching

Tower

Washer

Extraction

Tower

Washer

Seal

tank

Seal

tank

Washer

Seal

tank

Bleaching

Tower

M

M M

Extraction

chemicals

Bleaching

chemicals

Bleaching

chemicals 26

Figure 9.

Example Bleaching Line
Chapter 2 - Pulping and

Bleaching Processes

27

Bleaching stage

means all process

equipment

associated with a

discrete step of a

chemical

application and

removal in the

bleaching process.

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 chemicals

Almost any oxidant could be used as a bleaching agent. However, for

bleaching pulp, the chemical must be both powerful and inexpensive to

produce or purchase. There are a variety of chemicals that meet these

criteria. Both chlorinated and non-chlorinated chemicals are used for

bleaching. The chemicals and their common bleaching stage abbreviations

are shown below. These bleaching chemicals are grouped into two

categories: chlorinated and non-chlorinated. 

Chemicals Abbreviation

Chlorinated Bleach Chemicals

Elemental chlorine C

Hypochlorite H

Chlorine dioxide D

Chlorine with chlorine dioxide (CD), (C+D)

substitution

Non-chlorinated Bleach Chemicals

Oxygen O

Peroxide P

Ozone Z

Chlorinated bleaching chemicals. There are three chlorinated chemicals

commonly used for bleaching pulp: elemental chlorine (C), chlorine dioxide

(D), and hypochlorite (H). Since elemental chlorine is a good delignifying

agent, it performs best when used in the first bleaching stage. 

Non-chlorinated bleach chemicals. Common examples of non-chlorinated

bleaching chemicals include: oxygen (O); peroxide (P); and ozone (Z). 

Bleach stages that use various combinations of alkali, oxygen, and peroxide

are common in many bleach plants.
Chapter 2 - Pulping and

Bleaching Processes

28

The NESHAP

requires collection

and control of HAP

emissions from the

chlorinated

bleaching stages

only!

Bleaching mixers

Bleaching chemicals must be thoroughly mixed with the pulp to ensure pulp

quality, to minimize chemical waste, and to minimize the generation of

bleaching contaminants such as chlorinated dioxins and furans. Enclosed

rotary high-shear mixers or static in-the-pipe mixers are used to mix the pulp

and bleaching chemicals.

Bleaching retention towers

Retention towers are used to maintain bleaching conditions for the pulp as it

passes through each bleaching stage. For complete bleaching chemical

reaction, it is necessary to maintain a certain temperature, time, consistency,

pressure, and pH for each bleach stage. Conditions vary with the bleaching

chemical used (e.g., chlorine, chlorine dioxide, hydrogen peroxide). In many

bleaching systems, the retention towers are named by the bleach chemical

used or the function of that particular bleaching stage (e.g., chlorination

tower).

There are two primary types of retention towers: the upflow tower; and the

downflow tower. The choice of tower design depends on the particular

conditions desired for the bleach stage. As a general rule, chlorinated

bleaching stages use an upflow tower design or a similar design. See

diagram number 29 in Appendix E.

Bleached pulp washers

To minimize chemical usage and equipment corrosion, it is important to

remove as much bleaching chemical as possible from the pulp before it enters

the next bleaching stage. Bleached pulp washing is performed in the same

type of equipment that washes the brown stock. See discussion on brown

stock washers on page 19. 

More detailed diagrams on the air and water discharges of each system are

provided in Appendix E.
Chapter 2 - Pulping and

Bleaching Processes

29

What is pulp preparation and papermaking?

The final stages at a pulp and paper mill include the preparation of pulp for

papermaking and the actual papermaking process. In the pulp preparation

area, the pulp fibers are cleaned to remove unwanted particles (such as dirt

and sand) from the pulp stock. The cleaned fibers will then undergo some

level of refining. In the refining process, the pulp fibers are subjected to

mechanical action to develop their optimal papermaking properties with

respect to the product being made.

In the papermaking process, the pulp stock is converted into paper. This

process begins when the pulp stock is distributed across the forming table. 

On the forming table, the paper sheet formation starts as the excess water

contained in the pulp stock drains from the pulp fibers. The newly formed

paper sheet is removed from the forming table and is conveyed through a

series of presses to remove additional water and to continue the sheet

forming process. The remaining water contained in the paper sheet is

removed as the sheet travels around a series of steam-heated cylinders. 

After the paper sheet leaves the dryers, it may undergo several other

processes, depending on the final paper product. These additional processes

include; calendering (where the sheet is pressed to reduce thickness and

smooth the surface), winding (where the sheet is wound onto a reel), and

coating (where various chemical or dyes are applied to the paper sheet).
Chapter 2 - Pulping and

Bleaching Processes

30

The soda pulping

process was the first

chemical pulping

method and was the

precursor to the kraft

pulping process.

2.4 Soda mills

The soda pulping process utilizes an alkaline liquor with sodium hydroxide

as the only active chemical. Except for the difference in chemicals used, this

process is the same as that described for the kraft mill.
Chapter 2 - Pulping and

Bleaching Processes

31

The sulfite pulping

process uses acid

solutions of sulfurous

acid (H2SO3) and

bisulfite ions (HSO ). 3

-

2.5 Sulfite mills

The sulfite pulping process uses an acid solution of sulfurous acid (H SO ) 2 3

and bisulfite ion (HSO ) to break the lignin bonds between wood fibers, 3

-

while kraft mills use an alkaline solution. Because the sulfite cooking

process is an oxidizing reaction, sulfur dioxide is generated instead of the

reduced sulfur compounds generated by the kraft process (a reducing

reaction). Thus, the chemical recovery processes at sulfite mills are different

than at kraft mills. Otherwise, the process is similar to the kraft process.

Sulfite pulp has less color than kraft pulp and can be more easily bleached,

although the sulfite pulp is not as strong as kraft pulp. Figure 10 depicts an

overview of a typical sulfite pulping system. 
32

Figure 10.

Example Sulfite Pulping System
Chapter 2 - Pulping and

Bleaching Processes

33

Semi-chemical pulp is

generally not

bleached.

2.6 Semi-chemical mills

Semi-chemical pulping involves partial digestion of wood chips in a weak

chemical solution such as sodium sulfite (Na SO ) and sodium carbonate 2 3

(Na CO ) followed by mechanical refining for fiber separation. Semi- 2 3

chemical pulp is very stiff, making this process common in corrugated

container manufacture. Figure 11 shows an overview of a typical semichemical pulping system.
34

Figure 11.

Example Semi-chemical Pulping System
Chapter 2 - Pulping and

Bleaching Processes

35

Bleaching systems

that use chlorine or

chlorine dioxide are

the only emission

sources at

mechanical,

secondary fiber, and

non-wood fiber mills

affected by the pulp

and paper NESHAP.

Secondary fiber

mills make pulp

from recycled

paper and other

products.

2.7 Mechanical, secondary fiber, and non-wood fiber

pulp mills

Mechanical pulping

Mechanical pulping uses physical pressure instead of chemicals to separate

wood fibers. Mechanical pulping processes have the advantage of

converting up to 95 percent of the dry weight of the fiber source into pulp,

but require an enormous amount of energy relative to chemical pulping. 

Mechanically produced pulp is of lower strength than chemically produced

pulp and is used principally for newsprint and other non-permanent paper

goods.

Mechanical pulps are brightened with hydrogen peroxide (H O ) and/or 2 2

sodium sulfite (Na2SO3). The brightening chemicals are applied during the

pulp processing stage (e.g., in-line brightening), or in chemical application

towers. These chemicals only brighten the pulp and do not permanently

bleach the pulp. Typically, bleaching of mechanical pulps using chlorine or

chlorine dioxide is not practiced because of the high cost of bleaching

chemicals and negative impact on pulp yield.

Secondary fiber pulping

Secondary fibers include any fibrous material that has undergone a

manufacturing process and is being recycled as the raw material for another

manufactured product. Secondary fibers have less strength and bonding

potential than virgin fibers. The fibrous material is dropped into a large tank,

or pulper, and mixed by a rotor. The pulper may contain either hot water or

pulping chemicals to promote dissolution of the paper matrix. Debris and

impurities are removed by “raggers”(wires that are circulated in the

secondary fiber slurry so that debris accumulates on the wire) and “junkers”

(bucket elevators that collect heavy debris pulled to the side of the pulper by

centrifugal force).
Chapter 2 - Pulping and

Bleaching Processes

36

The NESHAP does

not apply to mills

that rewater

purchased pulp

(e.g., dried bales or

sheets of pulp

being made into a

slurry).

Non-wood fiber pulping

Non-wood pulping is the production of pulp from fiber sources other than

trees. Non-wood fibers used for papermaking include straws and grasses

(e.g., flax, rice), bagasse (sugar cane), hemp, linen, ramie, kenaf, cotton, and

leaf fibers. Pulping of these fibers may be performed by mechanical means at

high temperatures or using a modified kraft or soda process. Non-wood

fiber pulp production is not common in the U.S.
Chapter 2 - Pulping and

Bleaching Processes

37

2.8 References for Chapter 2

Biermann, C.J. 1993. Essentials of Pulping and Papermaking. San Diego,

CA: Academic Press, Inc.

Burgess, T. 1995. The Basics of Foul Condensate Stripping. 1995 Kraft

Recovery Short Course. Atlanta, GA: TAPPI PRESS.

EPA. 1995. Office of Compliance Sector Notebook Project: Profile of the

Pulp and Paper Industry. EPA/310-R-95-015. Office of Enforcement and

Compliance Assurance, Washington, DC. 

EPA. 1993. Pulp, Paper, Paperboard Industry - Background Information

for Proposed Air Emissions Standards for Manufacturing Processes at Kraft,

Sulfite, Soda, and Semi-chemical Mills. EPA-453/R-93-050a. Office of Air

Quality Planning and Standards, Research Triangle Park, NC.

Mimms, A., Kocurek, M., Pyatte, J., and Wright, E., eds. 1993. Kraft

Pulping. Atlanta, GA: TAPPI PRESS. 

Smook, G.A. 1992. Handbook for Pulp and Paper Technologists. Second

Edition. Bellingham, WA: Angus Wilde Publications.
38

A copy of the

April 15, 1998

NESHAP is in

Appendix B. Refer

to the UATW for

correction notices

and amendments.

The NESHAP does

NOT apply to

paper mills unless

they also produce

pulp.

Find a list of HAPs

at http://www.epa.

gov/ttn/uatw/

pollsour.html

Chapter 3 - Overview of the Pulp and Paper

NESHAP

3.1 Which mills are subject to the NESHAP?

The pulp and paper NESHAP applies to existing and new major sources that

produce pulp, paper, or paperboard, and use any of these pulping processes:

C kraft using wood

C soda using wood

C sulfite using wood

C semi-chemical using wood

C mechanical using wood

C processes using secondary fibers or non-wood fibers

A major source is any mill that emits or has the potential to emit (considering

Federally enforceable controls) 10 tons per year (tpy) or more of any HAP

or 25 tpy or more of any combination of HAPs.
Chapter 3 - Overview of

NESHAP

39

General Requirements

of the NESHAP:

C vent control on

 pulping systems

C treatment of

 condensates from

 kraft pulping

 systems only

C vent control on

 bleaching systems

C elimination of

 certain bleaching

 chemicals

C no control of

 papermaking

 systems

3.2 What processes and equipment systems must be

controlled?

The NESHAP has separate emission limits for pulping system vents, pulping

process condensate streams, and bleaching systems. The applicability of

these standards varies depending on the type of mill.

If the Mill is Pulping Pulping Following

This Type... System Vents Condensates Compounds

Then the NESHAP Covers These Processes...

Bleaching Systems

That Use the

Kraft X X Chlorine or any

chlorinated compound

Sulfite X Chlorine or any

chlorinated compound

Semi-chemical X Chlorine or any

chlorinated compound

Soda X Chlorine or any

chlorinated compound

Mechanical Chlorine or chlorine

dioxide

Secondary Fiber Chlorine or chlorine

dioxide

Non-Wood Fiber Chlorine or chlorine

dioxide
Chapter 3 - Overview of

NESHAP

40

For purposes of

this NESHAP,

LVHC systems are:

C digester

 system

C turpentine

 recovery system

C evaporator

 system

C steam stripper

 system

C any other

 system serving

 one of these

 functions

Systems that are

not regulated:

C wood yards

C pulping systems

 at mechanical,

 non-wood, and

 secondary fiber

 pulp mills

C tall oil recovery

 systems

C causticizing

 systems

C papermaking

 systems

In addition, the specific pulping process vents covered by the standards vary

depending on the type of mill and the classification of the pulping system as a

new or existing source. See Figure 12. The applicability and control

requirements of each type of mill are explained in detail in Chapters 4

through 7.

Figure 12.

Equipment Systems Covered by the

Pulping Vent Standards

If the

Mill is And These Equipment

This Then These Equipment Systems are Systems are Covered at

Type... Covered at Existing Sources... New Sources ...

a

b

Kraft C LVHC systems Same as existing sources

C Pulp washing system plus all...

C Oxygen delignification system C Decker systems

C Decker systems that use any process water C Screen systems

 other than fresh water or paper machine C Knotter systems

 white water or any process water with C Weak liquor storage

 total HAPs concentration > 400 ppmw tanks

C Knotter systems with HAP emissions

 greater than 0.05 kg/Mg oven-dried pulp

C Screen systems with HAP emissions

 greater than 0.1 kg/Mg oven-dried pulp

C Combined knotter and screen systems with

 HAP emissions greater than 0.15 kg/Mg

 oven-dried pulp

Soda LVHC systems Same as existing sources

plus all...

 Pulp washing systems

Sulfite C Digester system Same as existing sources

C Evaporator system plus all...

C Pulp washing systems C Weak liquor storage

 tanks

 C Strong liquor storage

 tanks

 C Acid condensate storage

 tanks

Semi- LVHC systems Same as existing sources

chemical plus all...

 Pulp washing systems

 See Appendix F for a list of specific equipment within each system. a

 See page 49 for the definition of a new source. b
Chapter 3 - Overview of

NESHAP

41

The NESHAP has

one alternative

emission limit for

pulping system

vents, pulping

condensates, and

bleaching systems

that does not

require testing and

monitoring.

3.3 What are the emission control requirements?

The NESHAP provides several alternative emission limits for the pulping

vent standard, pulping condensates standard, and bleaching system standard. 

For each regulated emission point, a mill can choose the emission limit with

which to comply and can use any emission control technology to achieve

compliance.

The format (e.g., percent reduction or outlet concentration) of the

alternative emission limits varies depending on the type of mill (Figure 13). 

For ease of explanation, Figure 13 provides only the formats of the

alternative limits, since the actual emission limits vary depending on the type

of mill. The emission limits for each type of mill are presented in Chapters 4

through 7 and are summarized in Appendix G.

Where two or more pulping processes share a piece of equipment, that piece

of equipment is considered a part of the pulping process type with the more

stringent NESHAP requirements for that piece of equipment.
Chapter 3 - Overview of

NESHAP

42

Figure 13.

Alternative Emission Limits

For the Following The Regulated And a Mill Can Choose One of the

Standards... Pollutant is... Following Emission Limits ...

a

Pulping system vents Total HAPs C Percent reduction

 C Kraft million by volume) for thermal

 C Soda oxidizer

 C Semi-chemical C Design specification for thermal

C Outlet concentration (parts per

oxidizer

C Duct vents to a boiler, recovery

furnace, or lime kiln

Pulping system vents Total HAPs C Percent reduction 

 C Sulfite C Mass emission limit (lb/ton ovenb

dried pulp)b

Pulping system condensates Total HAPs C Recycling to equipment subject to

 C Kraft pulping standards

C Biological treatment

C Percent reduction (HAP mass in the

condensates)

C Mass removal (lb/ton oven-dried

pulp)

C Outlet concentration (parts per

million by weight)

Bleaching system Chlorinated HAPs C Percent reduction

 C Kraft (other than C Outlet concentration (ppmv) from

 C Soda chloroform) the treatment device

 C Sulfite C Mass emission limit (lb/ton ovendried pulp)c

C Eliminate use of chlorinated

compounds

Chloroform C Eliminate use of hypochlorite and

chlorine

C Effluent (water) limitations

Emission limits vary for different types of pulping systems and control devices. A mill will likely use several closed- a

vent systems and each one can comply with any of these alternative emission limits.

Percent reduction and mass emission limits apply to sulfite pulping system vents, and any emissions from vents, b

wastewater, and condensate streams from the control device.

Mass emission limit applies to total emission from all regulated bleaching stages in the bleaching system. c
Chapter 3 - Overview of

NESHAP

43

3.4 What control systems will mills typically use to

meet the emission limits?

The control systems that most mills are likely to use to meet the emission

limits shown in Figure 13 are listed below:

C Pulping system vents

- thermal oxidizers

- power boilers, lime kilns, recovery furnaces

C Pulping process condensates

- steam strippers

- biological treatment

- recycling to pulping equipment that is controlled by

the NESHAP

C Bleaching system vents

- caustic scrubbers (for chlorinated HAPs, other than

chloroform)

- process modifications to eliminate the use of chlorine

and hypochlorite
Chapter 3 - Overview of

NESHAP

44

Figure 14 explains

in general how

mills must

demonstrate

compliance with

the NESHAP.

Administrator

means an

authorized

representative of

the EPA (e.g., a

State that has been

delegated the

authority to

implement and

enforce this

NESHAP).

3.5 How do mills demonstrate initial and continuous

compliance?

In general, mills must conduct an initial performance test and then

continuously monitor a set of control device or process operating

parameters. Exceeding a monitoring parameter will constitute a violation of

the standard.

Initial performance test. A performance test is required for most sources

regulated by this NESHAP. The performance test serves two purposes:

(1) To demonstrate that the control device complies with the

emission limit (Figure 14 explains the pollutants that must be

measured and the allowable surrogates that a mill may choose

to measure as an alternative)

(2) To establish the process operating parameter values (e.g., fire

box temperature for thermal oxidizers) that must be

monitored to demonstrate continuous compliance with the

standard

The NESHAP specifies the required monitoring parameters for most control

devices. If a mill uses a control device for which the monitoring parameters

are not specified, then the mill must propose and demonstrate, to the

satisfaction of the Administrator, a set of monitoring parameters that can

prove continuous compliance with the NESHAP. During the performance

test, mills must test simultaneously for emissions and monitor the

appropriate operating parameters to establish the parameter values (e.g., the

specific fire box temperature) that constitute continuous compliance.
Chapter 3 - Overview of

NESHAP

45

The NESHAP

generally requires

continuous

monitoring of

operating

parameters (not

emissions) to

demonstrate

compliance.

Continuous monitoring. Continuous monitoring is used to demonstrate

that a mill is in compliance with the NESHAP at all times. Mills must

continuously monitor operating parameters and report all instances where

the values deviate from the maximum or minimum values established during

the initial performance test. As an alternative, mills may install a continuous

emissions monitor.

Recordkeeping and reporting requirements. Mills must comply with the

recordkeeping and reporting requirements of the NESHAP General

Provisions (40 CFR 63) and those of the pulp and paper NESHAP. These

requirements include initial notifications, retaining records of performance

tests and monitoring data, and periodic reporting of periods of excess

emissions. Table 1 of Appendix B identifies which sections of the General

Provision requirements apply and which are overridden by this NESHAP.

In addition, the pulp and paper NESHAP requires some mills to submit a

control strategy report. The control strategy report must be submitted with

the initial notification (by April 15, 1999) and updated every 2 years until

compliance is achieved. The report must include the following:

C description of emission controls or process modifications

selected for compliance

C compliance schedule

C a report on the progress of installing the emission controls or

process modifications during the past 2-year period.

The control strategy report is required only if a mill uses one of the

following strategies that provide either additional compliance time or

compliance flexibility:

C Bleaching systems that comply with the Voluntary

Technology Advanced Incentives Program (see page 70)

C HVLC system vents that comply after April 16, 2001

C HVLC system vents that comply with the Clean Condensate

Alternative (see page 75)
Chapter 3 - Overview of

NESHAP

46

Figure 14.

What Pollutants or Surrogates Must Be Measured?

If These Systems are Then the Test is Required for this Must be

Covered by the Regulated at this Surrogate Continuously

NESHAP... Pollutant is... Frequency ... Pollutant... Monitored

And a And a Mill May And These

Performance Choose to Test Parameters

a

b

Pulping Total HAPs Initially Methanol Operating

parameters or

methanol outlet

concentration

Bleaching Chlorinated Initially Chlorine Operating

HAPs (excluding parameters or

chloroform) chlorine outlet

concentration

Chloroform None -- None c c

Condensates

Biological treatment Total HAPs Quarterly Methanol Operating

(in condensates) parameters

d

(daily)

Steam stripping Total HAPs Initially Methanol Operating

(in condensates) parameters or

methanol outlet

concentration

The U.S. EPA or the delegated authority may require an owner or operator to conduct performance tests at the a

affected facility at any other time when the action is authorized under Section 114 of the CAA (40 CFR subsection

63.7(a)(3)).

Compliance tests are conducted using the following methods: b

Compound(s) Test method

Total HAPs; methanol M308

Chlorinated HAPs Any method approved by the Administrator

Chlorine M26A

Total HAPs; methanol in

 condensates M305

Methanol in condensates NCASI GC/FIDe

A mill can comply by eliminating the use of chlorine and hypochlorite or by complying with the numerical limits of c

the effluent limitations guidelines and standards for water in 40 CFR 430.

The initial performance test and 1st quarter percent reduction tests must be performed for total HAPs. However, if a d

relationship between total HAPs and methanol destruction is established in the 1st quarter percent reduction tests,

methanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and 4th quarter tests.

e The National Council of the Paper Industry for Air and Stream Improvement (NCASI) direct injection gas

chromatography/flame ionization (GC/FID) method may be used as an alternative to EPA Method 305.
Chapter 3 - Overview of

NESHAP

47

For purposes of

this NESHAP,

HVLC systems are:

C knotter system

C pulp washing

 system

C screen system

C oxygen

 delignification

 system

C weak liquor

 storage tanks

3.6 When must mills comply?

The major compliance milestones for affected sources are shown below. 

This information presents only a portion of the requirements faced by owners

and operators of pulp and paper mills. Appendix H provides the detailed

milestone compliance timeline for existing sources.

Affected Sources Must Comply by April 16, 2001...

Except for the Following... Which Must Comply...

New sources At startup or by June 15, 1998,

whichever is later

HVLC system vents at kraft mills Within 8 years (April 17, 2006) a

Dissolving grade bleaching systems Within 3 years of publication of the

at kraft or sulfite pulping mills revised effluent limitations b

guidelines and standards

Bleaching system at any mill Within 6 years (April 15, 2004)

choosing to implement the

Voluntary Advanced Technology

Incentives Program for effluent c

limitations guidelines and standards

 LVHC systems must still meet the April 16, 2001 compliance date (see page 55). a

 Dissolving grade bleaching systems are similar to bleaching systems at bleached kraft b

 or sulfite mills, but usually contain six to eight bleach stages for maximum delignification

 and pulp cleanliness. The April 15, 1998 Cluster Rules did not publish effluent

 limitations guidelines and standards for these subcategories. Development of these

 revised rules is underway.

 Refer to page 70. c

Also, by April 15, 1999, the following is due:

C Initial notification

C Initial control strategy report
Chapter 3 - Overview of

NESHAP

48

For new sources,

the emission limits

are the same as

existing sources.

See page 49 for the

definition of a new

source.

3.7 What additional requirements apply to new

sources?

New sources at pulp and paper mills have more stringent compliance

requirements than existing sources. These include:

C More emission points must be controlled. For pulping

systems, the emission limits (see Figure 12) for new and

existing processes are the same, but more emission points

must be controlled at new sources. For bleaching systems

and pulping condensates, the emission limits and emission

points that must be controlled for new and existing sources

are identical.

C Earlier compliance dates. New sources must comply at the

date of startup or on June 15, 1998, whichever is later.

C Preconstruction approval. The owner or operator of mills

subject to the pulp and paper NESHAP must submit an

application to EPA for approval to construct any new source

that is subject to this rule. The preconstruction approval

process applies only if two conditions are met: 

- if the construction or reconstruction involves pulping

and/or bleaching system equipment as defined in

Section 3.8 

- the new or reconstructed source in and of itself is a

major source 

Construction must not commence until the EPA Administrator

approves the application. The EPA Administrator will approve the

application after determining that the source, if properly constructed,

will not cause a violation of the NESHAP. The requirements for the

submission and approval of construction applications are contained in

40 CFR 63.5 (e) and (f).
Chapter 3 - Overview of

NESHAP

49

The definition of a

new source is

different under the

Clean Water Act. 

See 40 CFR 122.2

and

40 CFR 430.01(j)

for the definition of

a new source for

effluent limitations

guidelines and

standards, and

pretreatment

standards.

Upon

reconstruction, an

existing source

immediately

becomes subject to

the new source

requirements!

3.8 What is a new source?

What constitutes a new or reconstructed source for each mill type that is

subject to this NESHAP is defined below.

A New Is the Construction of Any Any One of the Commences

Source at a ... Using... One of the Following... Following... After...

Or the

Reconstruction of That a

Kraft mill, Wood C A new mill C Pulping system 12/17/93

Soda mill, C New pulping system C Bleaching system

Semi-chemical C New bleaching system

mill, or C Additional pulping line

Sulfite mill. C Additional bleaching line

Mechanical Wood C Bleaching system Bleaching system 03/08/96

pulping mill C Bleaching line

Other mills Secondary C Bleaching system Bleaching system 03/08/96

or non- C Bleaching line

wood fibers

 Reconstruction means replacement of components to the extent that the fixed capital cost of the new a

 components exceeds 50 percent of the fixed capital cost that would be required to construct a

 comparable new source. (40 CFR 63.2 Subpart A).

What is an “Additional Line?” An additional line means a line that adds

capacity to an existing pulping or bleaching system. For example, consider a

mill with two existing pulping lines. The construction of a third line would

constitute an additional line and would be subject to new source controls. On

the other hand, a like-kind replacement of one of the lines would not be

considered an additional line. However, the replacement of one of the lines

with a new line that increases the capacity of the pulping system would be

considered an additional line that is subject to the new source requirements.

What Does “Reconstruction” Mean? Reconstruction means the replacement

of components to the extent that the fixed capital cost of the new components

exceeds 50 percent of the fixed capital cost that would be required to construct

a comparable new source. If this condition is met, upon construction, an

existing source immediately becomes subject to the MACT standards for new

sources irrespective of any change in emissions of HAPs. See 40 CFR 63.2 and

63.5.
Chapter 3 - Overview of

NESHAP

50

The pulp and paper NESHAP defines either the entire pulping system or

bleaching system as the equipment to which the 50 percent criterion is applied. 

For example, consider a mill that is refurbishing one of its two pulping lines by

replacing worn out equipment or components. To determine if reconstruction

occurs, the replacement costs would be compared to the construction costs for

replacing the entire pulping system (e.g., both lines). If the replacement cost is

less than 50 percent, the line is treated as an existing source. However, if the

cost exceeds 50 percent, then the replacement/construction project would be

deemed as a reconstruction of the pulping system, and both lines would

become subject to the new source provisions, even if emissions after the

reconstruction are the same or decrease.
51

Systems that are

not regulated:

C wood yards

C tall oil recovery

 systems

C causticizing

 systems

C papermaking

 systems

The CCA focuses

on reducing HAP

emissions

throughout the mill

by reducing the

HAP mass in

process water

streams that are

recycled to various

process areas in

the mill.

Chapter 4 - NESHAP Requirements for Kraft Mills

For kraft mills, the NESHAP contains emission standards for pulping system

vents, pulping process condensates, and bleaching system vents.

There are several alternative emission limits for each process covered. 

Compliance times will vary based on the process and emission limit selected,

even within the same mill. This designed flexibility promotes and encourages

new technologies, particularly joint air/water controls and pollution prevention

technologies.

The NESHAP also includes an option called the Clean Condensate Alternative

(CCA). The CCA applies only to kraft pulping system vent standards for the

HVLC system and features both pollution prevention and emission averaging. 

The CCA is described on page 75.

If You Need the Following Information... Then Read...

Standards for kraft pulping system vents Section 4.1

Standards for kraft pulping process condensates Section 4.2

Standards for kraft bleaching system vents Section 4.3

Description of the clean condensate alternative Section 4.4

Comparison of requirements for the NESHAP Section 4.5

and the NSPS
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

52

For purposes of this

NESHAP, the LVHC

system includes all

vents from:

C digester system

C turpentine recovery

 system

C evaporator system

C steam stripper

 system

and

The HVLC system

includes all vents

from:

C pulp washing

 system

C knotter system

C screen system

C decker system

C oxygen

 delignification

 system

C weak liquor storage

 tanks

The combined

knotter and screen

system limit applies

if the mill is unable

to differentiate

emissions between

the two systems.

4.1 Standards for kraft pulping system vents

The NESHAP requires the pulping system emission points to be enclosed,

collected in a closed-vent system, and then vented to a control device. This

section describes the emission points that must be controlled, the four

alternative emission limits, and the compliance requirements.

What kraft pulping system vents must be controlled?

The NESHAP specifies that vents from the mill systems must be controlled. All

the vents from the LVHC system must be controlled. The HVLC vents

requiring control vary based on the quantity of emissions and whether the

source is new or existing. 

The Following Pulping Systems Must be Controlled ...

a

Existing Sources

C LVHC system

C Pulp washing system

C Oxygen delignification system

C Decker systems that use any process water other than fresh water or paper machine

white water, or process water with a concentration of HAPs greater than 400 parts

per million by weight (ppmw)

C Knotter systems with HAP emissions equal to or greater than 0.1 pounds per ton

oven-dried pulp

C Screen systems with HAP emissions equal to or greater than 0.2 pounds per ton ovendried pulp

C Combined knotter and screen systems with HAP emissions equal to or greater than

0.3 pounds per ton oven-dried pulp

New Sources

C Same as existing sources plus...

C All decker systems

C All screen systems

C All knotter systems

C All weak liquor storage tank vents

Each equipment system has multiple emission points. For example, the evaporator system a

comprises pre-evaporators, multi-effect evaporators, concentrators, vacuum systems, associated

condensers, hot wells, and condensate streams. A complete list of the emission points in each

equipment system is provided in Appendix F.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

53

These emission

limits apply to each

control device.

A fifth alternative

is available for

kraft HVLC system

vents only. See

Section 4.4 for an

explanation of the

Clean Condensate

Alternative.

What are the emission limits for kraft pulping system vents?

The emissions from kraft pulping system vents must meet one of four

alternative emission limits, as shown below. These emission limits apply to

each control device used to control HAP emissions. A mill will likely use

several closed-vent systems and control devices (including both add-on control

devices and existing combustion devices) and each can comply with any of

these four alternative emission limits. These emission limits apply to both new

and existing sources.

Pulping System Vent Gases Must be Collected in a Closed-vent System

and Routed to One of These Four Control Devices...

1. A boiler, lime kiln, or recovery furnace in which the HAP gas stream

is introduced with the primary fuel or into the flame zone

2. A thermal oxidizer operated at a minimum temperature of 1,600°F

and a minimum residence time of 0.75 seconds

3. A thermal oxidizer that reduces the total HAP concentration at the

outlet to 20 ppmv corrected to 10% O on a dry basis, measured as 2

total HAPs or methanol

4. Any control device that reduces total HAP emissions by 98% by

weight, measured as total HAPs or methanol
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

54

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems?

All regulated equipment system vents must be enclosed and routed through a

closed-vent system to the control device that is selected for compliance. The

requirements for enclosures and closed-vent systems are presented below. The

requirements are intended to prevent leaks and ensure that process openings

(e.g., sampling ports on a brown stock washer enclosure) are closed while the

mill is in operation.

This Equipment.... Must Meet These Requirements....

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance, or

repairs

Components operated at positive Operate with no detectable leaks

pressure (500 parts per million by volume

[ppmv] VOC above background)

Bypass lines that could divert vent Seal and secure the opening so that

stream containing HAPs to the the valve or closure mechanism

atmosphere cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

55

Compliance Dates:

LVHC system:

 April 16, 2001

HVLC system:

 April 17, 2006

HVLC systems that

comply before

April 16, 2001 are

not required to

submit a

compliance

strategy report.

When must mills comply with the kraft pulping vent standards?

The LVHC system sources at kraft mills must comply with the NESHAP by

April 16, 2001, while the HVLC system sources must comply by

April 17, 2006.

For HVLC system vents complying after April 16, 2001, a non-binding

compliance strategy report must be submitted initially and updated every

2 years until compliance is achieved. The compliance strategy report must

contain, among other information, a description of the emission controls or

process modifications selected for compliance and a compliance schedule

indicating when each step toward compliance will be reached.

For safety purposes, kraft mills typically separate pulping vent streams into two

groups: low volume, high concentration (LVHC) vent streams and high

volume, low concentration (HVLC) vent streams. The NESHAP does not

specify which vents must be routed to the LVHC and HVLC collection

systems. Each mill makes this decision. However, compliance dates are based

on EPA’s definition of LVHC and HVLC system equipment, and these

compliance dates do not change based on how a mill chooses to collect their

system vents. For example, a mill could control an evaporator vent (LVHC

source) along with a group of HVLC vents. In such cases, the emissions from

this closed-vent system would have to comply by April 2001, because 2001 is

the compliance date specified for the LVHC system source.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

56

The test method

specified is used to

determine pollutant

concentration. 

Additional

calculations or

formulas are

specified in the

NESHAP to convert

the concentration

values into the

appropriate format

to demonstrate

compliance with a

particular emission

limit.

How does a mill demonstrate initial compliance with the kraft

pulping system vent standards?

A mill must demonstrate compliance through an initial performance test for

each closed-vent system and control device. However, the rule contains two

alternative emissions limits for which an initial performance test of the control

device is not required. If a mill complies with the pulping system vents

standards by venting the gases to a boiler, lime kiln, or recovery furnace, the

mill must demonstrate only that the gases are being introduced with the primary

fuel or into the flame zone. Also, if a mill complies with the pulping system

vents standards by venting the gases to a thermal oxidizer operating at the

minimum design specifications, the mill must demonstrate only that the gases

are being properly introduced into the thermal oxidizer.

The initial performance test has three objectives:

(1) To demonstrate that each control device complies with the emission

limit. Refer to Figure 15.

(2) To demonstrate that the closed-vent system captures and contains

all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that must be

monitored to demonstrate continuous compliance. For example, the

test would establish the minimum fire box temperature of the thermal

oxidizer that indicates 98 percent by weight reduction of total HAPs.

Figure 15.

How Does a Mill Demonstrate Initial Compliance with

the Kraft Pulping System Vent Emission Limits?

To Demonstrate Initial Conduct an Initial

Compliance With This Performance Test To Measure These

Emission Limit... Following This Method... Parameters...

Introduce HAP emission None required. None required

stream with the primary fuel Demonstrate that gases are

or into the flame zone properly introduced.

Operate at a minimum None required None required

temperature of 1,600 F and

a minimum residence time

of 0.75 seconds

Reduce the total HAP Method 308 Total HAP or methanol

concentration at the outlet to concentration at the outlet of

 20 ppmv corrected to the thermal oxidizer

10% O on a dry basis 2

Reduce total HAP Method 308 Total HAP or methanol

emissions by 98% by mass at the control device

weight inlet and outlet
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

57

Continuous

monitors are

required except for

vent streams that

are combusted in a

lime kiln, recovery

furnace, or boiler.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

kraft pulping system vent standards?

Mills must install a continuous monitoring system to measure either HAP

concentration or control device operating parameters. Figure 17 presents

the monitoring, reporting, and recordkeeping requirements for each

alternative emission limit.

In addition, a mill must periodically inspect and maintain all enclosures and

closed-vent systems. These requirements are explained in Figure 16. The

mill must maintain a site-specific inspection plan for the enclosures and

closed-vent system. Records of all inspection results and repairs must also

be kept according to the specifications of 40 CFR 63.454.

Figure 16.

How Does a Mill Demonstrate Initial and Continuous Compliance with

the Closed-Vent Systems Standard?

If the System has... Then Inspect... And Report... Records of...

And Keep

Enclosure opening Visually inspect every 30 Any exceedences of the closed- All visual checks and

days to ensure closed and vent standard in quarterly any repairs

sealed reports. If no exceedences

occur, submit semi-annual

reports.

Annually demonstrate Same as above All pressure tests

negative pressure

Closed-vent system Visually inspect every 30 Same as above All visual checks and

days for visible defects repairs

Positive pressure Annually demonstrate no Same as above All leak tests

closed-vent system detectable leaks (less than

500 ppmv)

Bypass line valve Inspect every 30 days to Same as above All visual checks and

ensure valve is in a closed repairs

position and vent stream is

not diverted through bypass

line
58

Figure 17.

How Does a Mill Demonstrate Continuous Compliance with the Kraft Pulping

System Vent Emission Limits?

If a Mill Chooses This

Alternative Emission Then Continuously Monitor These

Limit... Parameters... And Report This Information... And Keep These Records for 5 Years...

Introduce HAP emission None required None required None required

stream with the primary

fuel or into the flame

zone

Operate at a minimum Fire box temperature C Certify in the performance test report that Fire box temperature

temperature of 1,600°F the minimum residence time is achieved

and a minimum residence C Semi-annual emissions and continuous

time of 0.75 seconds monitoring performance report

C If exceedences occur, then quarterly reports

are required (40 CFR 63.10(e))

Reduce the total HAP Fire box temperature C Semi-annual emissions and continuous Fire box temperature a

concentration at the outlet monitoring performance report

to 20 ppmv corrected C If exceedences occur, then quarterly reports

to 10% O on a dry basis are required (40 CFR 63.10(e)) 2

 or

Total HAP concentration Same as above Total HAP concentration a a

Reduce total HAP When using a thermal oxidizer, monitor Same as above Fire box temperature a

emissions by 98% by fire box temperature

weight

When using a control device other than a Same as above Parameters approved by the Administrator

thermal oxidizer or incineration,

operating parameters must be established

during the initial performance test and

approved by the Administratorb

 Methanol may be used as a surrogate for total HAPs. a

Administrator means an authorized representative of the EPA (e.g., a State that has been delegated the authority to implement and enforce this b

 NESHAP).
Control device down time

Total process operating time

× 100%

25 hours

4,250 hours

× 100% ' 0.59%

Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

59

The NESHAP does

not specify rigid

averaging times,

but rather allows

State permitting

authorities

flexibility in

establishing millspecific times. 

Check the UATW

periodically for 

additional

information

concerning

averaging times.

Must a mill comply at all times?

For pulping system vents, the NESHAP establishes an allowable percent of

operating time during which HAP emission levels in excess of the established

limit shall not be considered to be a violation of the standard. Periods of

excess emissions include when the control device is inoperable and when the

operating parameter values established during the initial performance test

cannot be maintained at the appropriate level. The allowance is in addition

to excused periods under the startup, shutdown or malfunction provisions,

and is calculated by dividing the time of excess emissions by the total process

operating time in a semi-annual reporting period.

The excess emissions allowances are:

C 1 percent of operating time for control devices used for

LVHC system vents

C 4 percent of operating time for control devices used for

HVLC system vents

C 4 percent of operating time for control devices used for

combined LVHC and HVLC system vents (i.e., controlled by

the same device)

Even though periods of excess HAP emissions may be exempt under the

MACT requirements, these periods of excess emissions must still comply

with NSPS total reduced sulfur (TRS) requirements, and any applicable

State requirements.

To calculate the percent of periods of excess emissions in a semi-annual

period, divide the number of hours in the reporting period during which the

control device was not operating or parameter deviations occurred by the

total number of process operating hours and multiply by 100 percent. For

example, to calculate the semi-annual excess emissions for an LVHC system

control device where the device down time was 25 hours and the total

process operating time was 4,250 hours:
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

60

The condensate

streams subject to

control and the

alternative emission

limits are the same for

new and existing

sources.

Liquid streams

intended for

byproduct recovery,

such as the combined

turpentine/water

streams prior to the

turpentine decanter or

concentrated black

liquor, are not

considered process

condensate streams

subject to the control

requirements of this

regulation.

4.2 Standards for kraft pulping process condensates

The NESHAP requires condensate streams from the pulping system to be

collected in a closed collection system and treated. The NESHAP provides

five alternative emission limits (shown on page 61). This section describes

the condensates that must be controlled and the alternative emission limits.

What is a condensate and why control it?

Kraft pulping condensates are HAP-containing liquids that are condensed

from pulping system vent streams. These HAP-containing liquids result

from the contact of water with organic compounds in the pulping process. 

In absence of these Cluster Rules, most condensates would be discharged

into open collection systems and transported to either the wastewater

treatment plant or a publicly owned wastewater treatment plant. The

emissions of concern are the HAPs that volatilize as the condensates travel

through these open systems.

What kraft pulping condensates must be controlled?

The NESHAP requires control of condensates from all of the equipment in

the following systems:

C digester system

C turpentine recovery system

C evaporator system (condensates from weak liquor feed stage

vapors and vacuum systems only).

C LVHC collection system

C HVLC collection system

The LVHC and HVLC collection system condensates means those

condensates generated by the condensation of moisture in the closed-vent

collection systems that convey the LVHC and HVLC system vent gases to a

control device.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

61

By segregating

condensate streams

containing the

greatest amount of

HAP and treating only

these streams, an

equivalent emission

reduction can be

achieved at a lower

cost.

Most mills are

expected to use

steam stripping for

alternative

emission limits 4

and 5.

Does the mill have to collect all those streams?

No. A mill may choose to collect and control all the condensate streams

from the equipment systems listed on page 60. Alternatively, the NESHAP

contains two options for minimizing the volume of condensate that must be

treated (referred to as volume reduction options). These options are

summarized below.

A Mill Must Collect and Control One of the Following

Combinations of Streams...

C All condensate streams

C Volume reduction option 1: Treat all LVHC and HVLC collection system

streams plus streams that contain 65% of the total HAP mass from the digester

system, turpentine recovery system, and evaporator system (only condensates

from weak liquor feed stage vapors and vacuum systems)

C Volume reduction option 2: Treat any subset of the regulated streams that contain

in total 7.2 lbs HAP per ton of oven-dried pulp at mills that do not perform

bleaching or 11.1 lbs HAP per ton of oven-dried pulp at mills that perform

bleaching

What are the control requirements?

The NESHAP provides five alternative emission limits for condensate

streams as shown below. The three strategies expected to be used by most

mills are: recycling, biological treatment, and steam stripping.

Kraft Pulping Process Condensates Must be Collected in a Closed-collection System

and Treated to Meet One of These Five Alternative Emission Limits...

1. Recycle the condensate to a piece of equipment that meets the control standards

for pulping system vents (see page 53)

2. Use a biological treatment system to reduce or destroy the total HAPs by 92% a

by weight 

3. Treat the condensates to reduce or destroy the total HAPs by 92% by weight b

4. Treat the condensates to remove 10.2 pounds HAPs per ton of oven-dried pulp at b

mills performing bleaching or 3.3 pounds HAPs per ton of oven-dried pulp at b

mills that do not perform bleaching

5. Treat the condensates to achieve a total HAP concentration of 330 ppmw at the b

outlet of the control device at mills that perform bleaching or 210 ppmw at the

outlet of the control device at mills that do not perform bleaching

 Measured as total HAPs only. a

 Measured as total HAPs or methanol. b
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

62

The condensate

tank requirement

applies only to

tanks used to store

or handle the

regulated

condensates, not

tanks used to store

weak liquor.

What does the NESHAP require for condensate closed

collection systems?

Regardless of the emission limit selected, the condensates subject to control

must be transported in a closed collection system such that no emissions

occur. The NESHAP requirements for closed collection systems are

presented below.

This Equipment.... Requirements....

Must Meet ALL of These

Closed collection systems used to All of the individual drain system

transport pulping process condensates requirements specified in §63.960,

containing HAPs 63.961, and 63.962 of Subpart RRa

except that any air vents in the

collection system must meet standards

of §63.443 (c) and (d) for the closedvent systems and HAP reductions for

kraft pulping system vent emissions

Condensate tanks used in the closed Operate with no detectable leaks

collection system (500 ppmv VOC above background)

and

Vent emissions to a closed-vent system

(see page 54) and route to a control

device (see page 53)

and

When the tank contains pulping process

condensates or any HAP removed from

the pulping condensate stream, all

openings must be kept in a closed,

sealed position - except during

sampling, inspection, maintenance, or

repair operations

 Subpart RR of 40 CFR 63 (National Emission Standards for Individual Drain Systems) a

 establishes design, operating, inspection, and monitoring requirement standards for

 controlling air emissions from individual drain systems. The standards control

 emissions from individual drain systems using covers or seals, or hard-piping.

 Subpart RR also requires inspections of water seals and closure devices for defects or

 damage initially and establishes repair requirements for individual drain systems. The

 NESHAP requires inspection every 30 days.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

63

The mill can meet the closed collection system requirements in two ways:

• Hardpiping

• Use existing drains, but cover all openings and route all open

vents through a closed-vent collection system to a control

device meeting the NESHAP requirements for pulping system

vents.

If there are air vents off the closed collection system, these vents must be

routed to a closed-vent system. These air vents must comply with the kraft

pulping system standards for closed-vent systems and HAP emissions (see

pages 53 and 54).

When must a mill be in compliance?

Mills must achieve compliance with the pulping process condensate

requirements by April 16, 2001.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

64

How does a mill demonstrate initial compliance for kraft

pulping process condensate standards?

Mills must conduct a performance test to demonstrate initial compliance. A

performance test is required for each closed collection system and treatment

option. 

With respect to pulping condensates, the performance test serves four

purposes:

(1) To demonstrate that the appropriate condensate streams are

being collected and treated. The options for determining the

streams to be collected and controlled are presented on page 61. If a

mill uses one of the volume reduction options, the NESHAP requires

documentation to support the choice. For example, if a mill opts to

control condensate streams based on mass of total HAPs, the mill

must present test results to support that a complying mass of the

total HAPs is collected. Even in the case where a mill chooses to

collect and treat all pulping condensate streams, the mill must

demonstrate that all of the condensate streams have been identified

and collected. 

(2) To demonstrate that the closed collection system does not allow

any emissions to occur. Refer to page 62.

(3) To demonstrate that the control device complies with the

emission limit. For all alternative emission limits except biological

treatment, the mill can measure either total HAPs or methanol

concentration to document compliance with the emission limits. For

biological treatment, total HAPs concentration must be measured. 

See Figure 18.

(4) To establish the process operating parameter values that must

be continuously monitored. During the performance test, the mill

must measure the parameter values that the mill will monitor to

indicate continuous compliance. For example, the values of steam

feed rate, condensate feed rate, and temperature are specified as the

monitoring parameters for steam strippers.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

65

For the recycle

treatment option,

the performance

test would consist

only of verifying

that no leaks were

present in the

closed collection

system and

confirming closedvent system and

control device

requirements.

The test method

specified is used to

determine liquid

stream pollutant

concentration. 

Additional

calculations or

formulas are

specified in the

NESHAP to convert

the concentration

values into the

format appropriate

to demonstrate

compliance with a

particular emission

limit.

Figure 18.

How Does a Mill Demonstrate Initial

Compliance with Kraft Pulping Condensate Emission Limits?

To Demonstrate Initial Conduct an Initial

Compliance With This Performance Test To Measure These

Emission Limit... Following This Method... Parameters...

Recycle the condensate to None required None required

controlled equipment

Use a biological treatment Method 305 Total HAP concentration

system to meet 92%

reduction and and

Part 63, Appendix C Fraction of total HAPs

(e.g., WATER8) removed (f ) bio

Treat condensates to meet Method 305 Total HAP or methanol

92% reduction mass at the control device

inlet and outlet

Treat the condensates to Method 305 Total HAP or methanol

meet mass limits mass at the control device

inlet and outlet

Treat the condensates to Method 305 Total HAP or methanol

meet concentration limits concentration at the control

device outlet

How does a mill demonstrate continuous compliance with

pulping process condensate standards?

Mills must install continuous monitors to measure control device operating

parameters, except when recycling condensates to controlled process

equipment. In addition, quarterly percent reduction testing is required if a

mill chooses to comply using biological treatment. The monitoring

requirements depend on the alternative emission limit selected. Figure 19

summarizes the monitoring, reporting, and recordkeeping requirements for

each alternative emission limit.

The closed collection system must be visually inspected every 30 days

according to the following requirements:

C National Emission Standards for Individual Drain Systems

(63.964 subpart RR) requires inspection and monitoring

C Subpart S requires reporting and recordkeeping of all visual

inspection results. Semi-annual reports must be submitted. If

exceedences occur, then quarterly reports are required.
66

Figure 19.

How Does a Mill Demonstrate Continuous Compliance with Kraft Pulping Process Condensate Emission Limits?

If a Mill Chooses to

Comply With

Alternative Emission

Limits Using This Then Continuously Monitor All of

Technique... These Parameters... And Report This Information... And Keep These Records for 5 Years...

Recycle the condensate None required None required None required

to controlled equipment 

Steam stripper (percent Process wastewater feed rate C Semi-annual emissions and continuous Process wastewater feed rate

reduction, concentration, monitoring performance report

or mass limits) C If exceedences occur, then quarterly

reports are required (40 CFR 63.10(e))

Steam feed rate Same as above Steam feed rate

Process wastewater column feed Same as above Process wastewater column feed

temperature temperature

Steam stripper Steam stripper outlet concentration Same as above Steam stripper outlet concentration

(concentration)

Use a biological Quarterly test of percent HAP Same as above Percent HAP reduction

treatment system reductiona

Outlet soluble BOD5Same as above Outlet soluble BOD5

Mixed liquor volatile suspended solids Same as above Mixed liquor volatile suspended solids

Horsepower of aerator units Same as above Horsepower of aerator units

Inlet liquid flow Same as above Inlet liquid flow

Liquid temperature Same as above Liquid temperature

Other device Operating parameters demonstrated to Same as above Parameters approved by the Administrator

the Administrator’s satisfaction

Volume reduction Same as above Same as above Same as above

options

The initial performance test and 1st quarter percent reduction tests must be performed for total HAPs. However, if a relationship between total HAPs and methanol a

destruction is established in the 1st quarter percent reduction tests, methanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and 4th quarter tests.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

67

Although there are

no explicit back-up

control

requirements as

part of the

NESHAP, back-up

controls may be

necessary for mills

that are concerned

that the excess

emission allowance

is inconsistent with

expected control

device operating

experience.

Must a mill comply at all times?

The NESHAP provides a 10 percent excess emissions allowance for all

control devices other than biological treatment systems (63 FR 49455). For

example, the allowance accounts for steam stripper tray damage or plugging,

efficiency losses in the stripper due to contamination of condensate with

fiber or black liquor, steam supply downtime, and combustion control device

downtime.

Unlike the pulping standard, the 10 percent allowance for condensates

includes excused periods of excess emissions associated with the startup,

shutdown, and malfunction.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

68

Bleaching is the

brightening of pulp by

the addition of

oxidizing or reducing

chemicals.

A bleaching line is

a group of

bleaching stages

arranged in a

series such that

bleaching of the

pulp progresses as

the pulp moves

from one stage to

the next. Typically

a bleaching line

contains

3-5 stages.

4.3 Standards for the kraft bleaching system vents

At kraft mills, the emission limits apply to bleaching systems that use

chlorine or chlorinated compounds. The rules have emission limits for both

chloroform and chlorinated HAP. Kraft mills must comply with both of

these requirements. This section describes the emission points that must be

controlled, the alternative emission limits, and compliance requirements.

What bleaching emission points must be controlled?

The NESHAP applies only to bleaching lines that use chlorinated

compounds and only to the bleaching stages where chlorine or chlorinated

compounds are introduced. Extraction stages are not covered. All vents in

a regulated stage must be controlled. A stage consists of the following

equipment:

• retention towers

• washers

• seal tanks

• chemical and steam mixers (if vented to the atmosphere)

• vacuum pumps (if present)

Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or any chlorinated

HAP is exempt from all NESHAP requirements for bleaching.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

69

The requirements for

enclosures and

closed-vent systems

are the same as for

the pulping system

vent standards

(page 54).

What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are

introduced must be enclosed and routed via a closed-vent collection system

to a control device. The rules provide three alternative emission limits for

demonstrating compliance, as shown below. Most mills are expected to use

caustic scrubbers to comply.

Bleaching System Gases Must be Collected in a Closed-vent System and Meet One

of These Three Alternative Emission Limits ...

a

1. Reduce chlorinated HAP emissions by 99% by weight b

2. Achieve a total outlet mass emission rate 0.002 pounds chlorinated HAPs per

b

ton oven-dried pulp for all subject stages

3. Achieve an outlet concentration of chlorinated HAPs 10 ppmv b

Some mills may be able to meet the outlet concentration or mass limits through use of a

process modifications (i.e., 100 percent chlorine dioxide substitution). In these cases,

enclosures and closed-vent systems are not required.

Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or b

 as chlorine.

What are the control requirements for chloroform?

The rules provide two alternative emission limits for chloroform control. 

Both of these options (shown below) require process modifications. A mill

can comply by eliminating the use of chlorine and hypochlorite or by

complying with the numerical limits of the effluent limitations guidelines and

standards for water. If the compliance date for the effluent limitations

guidelines and standards is different than for the NESHAP, the NESHAP

compliance dates must be met.

To Reduce Chloroform Emissions From the Bleaching Process,

Use One of These Two Options...

1. Eliminate the use of chlorine and hypochlorite

2. Comply with applicable Effluent Limitations Guidelines and Standards

(40 CFR 430)a

 Refer to Appendix I for a summary of the wastewater regulations for bleached papergrade a

 kraft mills.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

70

Bleaching Systems

Compliance Dates:

Most mills: 

April 16, 2001

Mills enrolled in

VATIP: April 15,

2004

VATIP is available

only to papergrade

kraft and

papergrade soda

mills that discharge

directly to

receiving waters.

When must bleaching systems comply?

 Bleaching systems must comply by April 16, 2001 with two exceptions.

C Mills enrolled in the Voluntary Advanced Technology

Incentives Program (VATIP)

C Dissolving grade kraft mills

Voluntary Advanced Technology Incentives Program (VATIP). Under the

Effluent Limitations Guidelines and Standards (40 CFR Part 430.24), a mill

may choose to enroll one or more of its bleach lines in the Voluntary

Advanced Technology Incentives Program. The program provides extended

compliance with the water pollution control requirements for bleached

papergrade kraft and soda mills in exchange for achieving greater water

pollutant reductions than the regulatory baseline. Mills electing this program

receive a 3-year extension for complying with the NESHAP bleaching

standards (i.e., must comply by April 15, 2004). Three conditions must be

met to qualify for the extension.

C No increase in the application rates of either chlorine or

hypochlorite (in kg per Mg oven-dried pulp) in the bleaching

system beyond current levels. The current application rate is

defined as the average daily rates used over the three months

prior to June 15, 1998. The application rate limitation is

provided to prevent a bleaching system from “backsliding”

(i.e., increasing chlorinated bleaching chemical use during the

extended compliance period). EPA is considering guidance

and rule changes pertaining to “backsliding.” Check the

TTN at www.epa.gov/ttn/uatw/uatwnew.html for

updates.

C Submit a control strategy report by April 1999.

C Submit an updated control strategy report every two years

under 63.455(b) until compliance is achieved. The report

must contain milestones and status reports for achieving

compliance.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

71

The compliance

date for dissolving

grade kraft mills is

not specified in the

NESHAP, but is

anticipated

between

2003-2005.

Dissolving grade kraft mills must comply within 3 years after publication of

revised effluent limitations guidelines and standards under 40 CFR 430.14

through 430.17 and 40 CFR 430.44 through 430.47. These rules are

scheduled to be revised sometime between 2000 and 2002.

How does a mill demonstrate initial compliance with the

bleaching standards?

Chlorinated HAPs. Mills must demonstrate initial compliance with

chlorinated HAP standards by conducting an initial performance test for each

bleaching stage where chlorine or chlorinated compounds are introduced.

The initial performance test has two objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that

must be monitored to demonstrate continuous

compliance.

At the option of the mill, compliance may be demonstrated by measuring

either total chlorinated HAPs (including chloroform) or chlorine

concentration. The following methods must be used:

Chlorinated HAPs - Any method that has been

demonstrated to the Administrator’s

satisfaction.

Chlorine - Method 26A, as modified by

63.457(b)(5) of the rules.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

72

Continuous

monitoring is

required unless a

mill complies by

eliminating all use

of chlorine or

chlorinated

compounds as

bleaching agents.

These same tests

are required as

part of the initial

performance test.

Chloroform. No initial performance test is required if the mill chooses to

eliminate use of chlorine and chlorinated HAPs. The mill must demonstrate

in the initial notification that is not using these chemicals. Alternatively, if a

mill chooses to comply with the Effluent Limitations Guidelines and

Standards, then all compliance demonstration requirements of 40 CFR 430

apply.

How does a kraft mill demonstrate continuous compliance with

the bleaching standards?

For chlorinated HAPs, a continuous monitoring system must measure either

emissions, or control device or process operating parameters. The

monitoring, reporting, and recordkeeping requirements are summarized in

Figure 20.

In addition, the mill must conduct periodic inspection and maintenance of all

enclosures and closed-vent systems. These requirements are explained

below. The mill must maintain a site-specific inspection plan for the

enclosures and closed-vent system. Records of repairs based on the

inspections must also be kept.

If the System has... Then Inspect... And Report... Records of...

And Keep

Enclosure opening Visually inspect every 30 Any exceedences of the closed- All visual checks and

days to ensure closed and vent standard in quarterly any repairs

sealed reports. If no exceedences

occur, submit semi-annual

reports.

Annually demonstrate Same as above All pressure tests

negative pressure

Closed-vent system Visually inspect every 30 Same as above All visual checks and

days for visible defects repairs

Positive pressure Annually demonstrate no Same as above All leak tests

closed-vent system detectable leaks (less than

500 ppmv)

Bypass line valve Inspect every 30 days to Same as above All visual checks and

ensure valve is in a closed repairs

position and vent stream is

not diverted through bypass

line

Note: This is the same table as the one presented on page 57.

For chloroform, if the mill chooses to eliminate the use of hypochlorite and

chlorine, then no parametric monitoring is required to show continuous

compliance. If the mill chooses not to eliminate the use of hypochlorite and

chlorine, then the mill must comply with the effluent limitations guidelines

and standards.
73

Figure 20.

How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlorinated HAPs?

If a Mill Chooses This

Technique to Comply

With This Alternative Continuously Monitor These

Emission Limit... Parameters... Report This Information... And Keep These Records for 5 Years...

Gas scrubber to reduce pH or oxidation/reduction potential of C Semi-annual emissions and continuous pH or oxidation/reduction potential of

chlorinated HAP effluent monitoring performance report effluent

emissions by 99% by C If exceedences occur, then quarterly

weight or to achieve an reports are required (40 CFR 63.10(e))

outlet mass emission

rate 0.002 pounds

chlorinated HAPs per

ton oven-dried pulp

Vent gas inlet flow rate Same as above Vent gas inlet flow rate

Scrubber liquid influent flow rate Same as above Scrubber liquid influent flow rate

Gas scrubber to achieve Same as above

an outlet concentration

of chlorinated HAPs

10 ppmv

Chlorine concentration at the outlet or Chlorine concentration or all of the

measure all three of the following

parameters

following

pH or oxidation/reduction potential of Same as above pH or oxidation/reduction potential of

effluent effluent

Vent gas inlet flow rate Same as above Vent gas inlet flow

Scrubber liquid influent flow rate Same as above Scrubber liquid influent flow rate

Any control device other Determine appropriate monitoring Same as above Parameters approved by the Administrator

than a gas scrubber or parameter values during the initial

process modifications performance testa

 As specified in 40 CFR Part 63.453(n) a
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

74

Check the UATW at

www.epa.gov/ttn/

uatw/uatwnew.html

for updates.

Mills in the voluntary advanced technology incentives program must

monitor compliance in the interim!

The figure below summarizes the monitoring, reporting, and recordkeeping

requirements for mills enrolled in the VATIP that receive the 3-year

compliance date extension. These requirements apply from June 1998 up to

the time that the mill demonstrates compliance with all the applicable

bleaching system emission limits.

If a Mill

Chooses This

Alternative Then Continuously And Keep These

Emission Monitor These And Report This Records for

Limit... Parameters... Information... 5 Years...

No increase in Chlorine and An initial control Daily application

the use of hypochlorite strategy report by rates

hypochlorite and application rates in April 1999 meets the

chlorine lb/ton oven-dried pulp requirements of

(daily average) 63.455. Updated

control strategy

report every 2 years,

 and

Daily application

rates of chlorine and

hypochlorite must be

reported every six

months

EPA is considering guidance and rule changes pertaining to

“backsliding” from existing controls during the initial period when a

mill is working toward meeting its voluntary advanced technology best

available technology (BAT). The change would make the restriction on

the daily application rates apply from April 2001 up to the time that

the mill demonstrates compliance with all the applicable bleaching

system emission limits.
Chapter 4 - NESHAP Requirements -

Kraft Mills

Clean Condensate Alternative

75

The CCA applies

only to the kraft

HVLC system:

C washers

C knotters and

 screens

C deckers

C oxygen

 delignification

4.4 Clean condensate alternative for HVLC vents

The clean condensate alternative (CCA) is a pollution prevention alternative

emission limit for pulping vents that is available only to kraft HVLC systems. 

The CCA allows mills to meet the HVLC emission limits by reducing the

HAP concentration in the process waters that are recycled to other pieces of

process equipment. This approach allows mills to control HAP emissions by

reducing the amount of HAPs that are volatilized from selected process

equipment instead of using combustion devices to control HVLC system

vent streams. 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

emission reductions that would have been achieved through compliance with

the HVLC system requirements.

For example, a mill could use a stand-alone biological treatment device to

reduce the total HAP concentration in pulping process condensates. The

effluent from the stand-alone biological treatment device could be used as

process water in the pulping washing system and causticizing system. In this

scenario, initial compliance using the CCA would be demonstrated by

showing that the reduction of emissions from both the pulping washing

system and causticizing system is equal to or greater than the reductions that

would have been achieved by applying the pulping vent standards to the pulp

washing system vent emissions.
Chapter 4 - NESHAP Requirements -

Kraft Mills

Clean Condensate Alternative

76

The CCA is similar

to emission

averaging.

The concept of the

CCA is the reduction

of HAP emissions

through reduction of

HAP concentration in

process water.

The CCA can be

used by both new

and existing

sources.

Which equipment systems can be used to generate the

emission reductions?

Process condensates are recycled throughout the mill. The CCA allows mills

to take credit for emission reductions achieved in several systems through

the use of CCA technologies.

Sources From Which Emission Reductions Can be Credited...

C Pulping systems (HVLC)

C Bleaching systems

C Causticizing systems

C Papermaking systems

What emission reductions are creditable?

A CCA technology must achieve the emission reductions by removing HAPs

from condensate streams. The CCA emission reductions are generated by:

C control of condensates that are not regulated under the kraft

pulping condensate standard

C control beyond the levels required by the condensate standard

Emission reductions from add-on controls on vent streams do not count.

Can a mill use the CCA for only part of the emission reduction

requirement for the HVLC system?

Yes. The HAP emission reductions resulting from the CCA can be used as

partial or complete fulfilment of the emission reductions required for the

HVLC pulping standard. For example, a mill may elect to use the CCA in

lieu of vent controls for the washer system, but comply by using vent

controls for the rest of the HVLC system.
Emission reductions

achieved by the CCA '

Baseline

emissions &

Emission levels after

the CCA has been

implemented

Chapter 4 - NESHAP Requirements -

Kraft Mills

Clean Condensate Alternative

77

All CCA emission

reductions must be

based on actual

test data.

How does a mill use the CCA?

A mill must follow these steps to implement the CCA:

(1) Determine baseline emissions. Baseline emissions are to be

measured after compliance has been achieved with all of the

following:

C Kraft pulping process condensate standards

C All effluent limitations guidelines and standards in

40 CFR subpart B

C Emission reductions attributable to control technology

required by local, State, or Federal agencies

Furthermore, baseline emissions must include any control

equipment installed and operated before December 17, 1993.

(2) Calculate emission reductions that would have been achieved

through compliance with the kraft pulping HVLC system

standards.

(3) Measure emissions reductions achieved by the CCA.

(4) Demonstrate compliance through the CCA by documenting

that emission reductions achieved through the CCA are

greater than or equal to emission reductions that would have

been achieved through compliance with the kraft pulping

HVLC system standards.
Chapter 4 - NESHAP Requirements -

Kraft Mills

Clean Condensate Alternative

78

The compliance

date for existing

CCA sources is

April 17, 2006.

How does a mill demonstrate initial compliance?

A mill must conduct a performance test before and after CCA

implementation. Baseline emission levels and all CCA emission reductions

must be based on actual test data. 

How does a mill demonstrate continuous compliance?

The control strategy using the CCA will vary between mills, depending on

mill configuration and emission points selected. Thus, the monitoring and

reporting requirements for the CCA are not specified in the rules. Each mill

must propose monitoring, reporting, and recordkeeping requirements for the

Administrator’s approval.

What approvals are required to use the CCA?

Mills that opt to use the CCA must submit a CCA control strategy report

along with the initial notification. Updates are required every 2 years. The

requirements of the control strategy report are specified at

40 CFR 63.455(b) and 40 CFR 63.447(g).

The mill must report to the Administrator by the final compliance date the

rationale, calculations, test procedures, and data used to demonstrate

compliance. The Administrator will make the final compliance

determination.
Chapter 4 - NESHAP Requirements -

Kraft Mills - NSPS vs. NESHAP

79

4.5 How do the requirements for the NSPS and the

NESHAP compare?

Figure 21 compares NSPS and NESHAP for kraft pulping emission sources. 

Note that demonstrating compliance with a NESHAP alternative emission

limit(s) does not necessarily mean that NSPS requirements are automatically

met. In fact, the only alternative emission limit(s) of the NESHAP that also

satisfies the NSPS requirement is the thermal oxidizer design requirement 

(1600 F for 0.75 seconds).
Chapter 4 - NESHAP Requirements -

Kraft Mills - NSPS vs. NESHAP

80

The MACT control

technologies can be

used to comply with

the NSPS, but mills

still must

demonstrate that

the NSPS emission

limits for TRS are

being met.

A thermal oxidizer

is the only option

where meeting the

NESHAP

automatically

meets the NSPS. 

Figure 21.

Comparison of NESHAP and NSPS Alternative Emission

Limit(s) Requirements

If a Mill

Uses This Does NESHAP

Control The NSPS And the NESHAP Compliance Ensure

Option... Requires... Requires... NSPS Compliance?

Lime Kiln less than 8 ppmv Introduce vent stream No

TRS at 10% with primary fuel into

oxygen flame zone.

Recovery Straight recovery: Introduce vent stream No

Furnace 5 ppmv TRS at 8% with primary fuel into

oxygen flame zone.

Cross recovery: Same as above No

25 ppmv TRS at

8% oxygen

Power 1200 F for Introduce vent stream No

Boiler 0.5 second with primary fuel into

flame zone.

Thermal 1200 F for 1600 F for 0.75 Yes

Oxidizer 0.5 second second

 or

20 ppmv total HAPs No

or methanol at 10%

oxygen

 or

98% reduction by No

weight of total HAPs

or methanol

Other means 5 ppmv TRS at 98% reduction by No

actual oxygen weight of total HAPs

content of or methanol

untreated stream

Uncontrolled 0.005 g TRS/kg Vent gases must be No

digester air-dried pulp routed to a closed-vent

system (ADP) collection system.
81

The NESHAP

requirements for

semi-chemical and

soda mills are similar

to the requirements

for kraft mills except

that pulping process

condensates are not

regulated at semichemical and soda

mills.

Chapter 5 - NESHAP Requirements for

Semi-Chemical and Soda Mills

For semi-chemical and soda mills, the NESHAP contains emission standards

for pulping system vents and bleaching system vents. There are several

alternative emission limits for both processes, and mills can choose the

emission limits with which to comply.

The requirements in the NESHAP for semi-chemical and soda mills are

described in this chapter.

If You Need the Following Information... Then Read...

Standards for semi-chemical and soda pulping Section 5.1

system vents

Standards for semi-chemical and soda Section 5.2

bleaching system vents
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

82

For purposes of

this NESHAP, the

LVHC system

includes all vents

from:

C digester system

C turpentine

 recovery

 system

C evaporator

system

For semi-chemical

and soda mills, the

NESHAP does not

apply to existing

HVLC systems.

5.1 Standards for semi-chemical and soda pulping

system vent standards

What pulping system vents must be controlled?

The NESHAP requires certain equipment in the pulping systems at semichemical and soda mills to be enclosed, collected in a closed-vent system,

and then vented to a control device. 

The Following Pulping System Vents Must be Controlled...

Existing Sources

C LVHC system

New Sources

C LVHC system

C Pulp washing system

Each equipment system has multiple emission points. For example, the pulp

washing system can include vacuum drum washers, diffusion washers, rotary

pressure washers, horizontal belt filters, intermediate stock chests, associated

vacuum pumps, filtrate tanks, and foam breakers. A complete list of the

emission points in each equipment system is provided in Appendix F.
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

83

The NESHAP does

not provide the

Clean Condensate

Alternative to semichemical and soda

pulping systems

because the Clean

Condensate

Alternative was

provided to kraft

mills as an option

for meeting the

HVLC system

emission limits.

HVLC systems at

existing semichemical and soda

mills are not

regulated by the

NESHAP.

What are the emission limits for semi-chemical and soda

pulping system vents?

The emissions from semi-chemical and soda pulping system vents must meet

one of four alternative emission limits, as shown below. These emission

limits apply to each control device used to control HAP emissions. A mill

will likely use several closed-vent systems and control devices (including

both add-on control devices and existing combustion devices) and each can

comply with any of these four alternative emission limits. These emission

limits apply to both new and existing sources.

Pulping System Vent Gases Must be Collected in a Closed-vent

System and Routed to One of These Four Control Devices...

1. Any control device that reduces total HAP emissions by 98% by

weight, measured as total HAPs or methanol

2. A boiler, lime kiln, or recovery furnace in which the HAP gas

stream is introduced with the primary fuel or into the flame zone

3. A thermal oxidizer operated at a minimum temperature of 1,600°F

and a minimum residence time of 0.75 seconds

4. A thermal oxidizer that reduces the total HAP concentration at the

outlet to 20 ppmv corrected to 10% O2 on a dry basis, measured

as total HAPs or methanol

Note: These emission limits are the same as for kraft mills (presented on

page 53).
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

84

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems at semi-chemical and soda mills?

All regulated equipment system vents must be enclosed and routed through a

closed-vent system to the control device that is selected for compliance. The

requirements for enclosures and closed-vent systems are presented below. 

The requirements are intended to prevent leaks and ensure that process

openings (e.g., sampling ports on a brown stock washer enclosure) are

closed while the mill is in operation.

This Equipment.... Requirements....

Must Meet These

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance,

or repairs

Components operated at positive Operate with no detectable leaks

pressure (500 ppmv VOC above

background)

Bypass lines that could divert vent Seal and secure the opening so that

stream containing HAPs to the the valve or closure mechanism

atmosphere cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes

Note: These requirements are the same as for kraft mills (presented on

page 54).

When must mills comply with the semi-chemical and soda

pulping process standards?
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

85

Because semichemical and soda

mills are not

affected by the

Effluent

Limitations

Guidelines and

Standards, the

NESHAP does not

allow these mills

any extended

compliance times.

Pulping systems at semi-chemical and soda mills must comply with the

MACT standards by April 16, 2001. 

How does a mill demonstrate initial and continuous compliance

with the pulping system vent standards?

A mill must demonstrate compliance through an initial performance test and

then continuously monitor a set of control device operating parameters for

each closed-vent system and control device. When complying by venting

gases to a boiler, lime kiln, or recovery furnace, the initial performance test

must demonstrate that the gases are being introduced with the primary fuel

or into the flame zone.

The initial and continuous compliance requirements for semi-chemical and

soda mills are identical to those for kraft mills. Please read pages 56 through

59 of this document.

Must a mill comply at all times?

For pulping system vents, the NESHAP establishes an allowable percent of

operating time during which HAP emission levels in excess of the established

limit shall not be considered to be a violation of the standard.

For soda and semi-chemical mills, the excess emission allowances are:

C 1 percent of operating time for control devices used for

LVHC system vents

C 4 percent of operating time for control devices used for pulp

washing systems (HVLC)

C 4 percent of operating time for control devices used for

combined LVHC and pulp washing system vents

(i.e., controlled by the same device)

The excess emission allowances are the same for kraft, semi-chemical, and

soda mills. Refer to page 59 for additional details.
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Bleaching System Vents

86

Currently, there is

only one soda mill

operating in the

U.S.

5.2 Standards for bleaching system vents at

semi-chemical and soda mills

Semi-chemical mills

Generally, semi-chemical mills in the United States do not have bleaching

systems and therefore are not subject to bleaching standards. Technically,

the rule would apply if a semi-chemical mill installed a bleaching system

using chlorine. While this is not expected to occur, such a mill would have

to comply with the emission standards for chlorinated HAPs (excluding

chloroform) from bleaching vents. The rule would not apply to bleaching

systems using chlorinated compounds other than chlorine. Refer to

Section 4.3 for information about bleaching standards, excluding the

chloroform standard.

Soda mills

At soda mills, emission limits apply to bleaching systems that use chlorine or

chlorinated compounds. The emission standards and compliance

demonstration requirements for soda mills are the same as for kraft mills

(presented in Section 4.3) and are not repeated in this chapter. Refer to the

following pages for specific information.

C Emission points to be controlled—page 68

C Control requirements for chlorinated HAPs and

chloroform—page 69

C How to demonstrate initial compliance—page 71

C How to demonstrate continuous compliance—page 72.
87

Chapter 6 - NESHAP Requirements for

Sulfite Mills

For sulfite mills, the NESHAP contains emission standards for pulping

system vents and bleaching system vents.

The NESHAP contains two alternative emission limits for pulping system

vents. Each mill can choose to comply with either limit. Different numerical

emission limits are specified for calcium- and sodium-based pulping systems

than for magnesium- and ammonium-based pulping systems.

The NESHAP also contains several alternative emission limits for bleaching

process system vents. The NESHAP does not regulate pulping process

condensates at sulfite mills.

If You Need the Following Information... Then Read...

Standards for sulfite pulping system vents Section 6.1

Standards for sulfite bleaching system vents Section 6.2
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

88

The emission limits

are the same for

existing and new

sources. 

Appendix C

contains a

flowchart summary

of the NESHAP.

6.1 Standards for sulfite pulping system vents

The NESHAP requires the pulping systems to be enclosed, collected in a

closed-vent system, and then vented to a control device. This section

describes the emission points that must be controlled, the two alternative

emission limits, and the compliance requirements.

What sulfite pulping system vents must be controlled?

The NESHAP specifies that all the vents from the digester system,

evaporator system, and pulp washing systems must be controlled. 

Additional equipment must be controlled at new sources. These pulping

system vents are identified below.

The Following Pulping System Vents Must be Controlled...

Existing Sources

C Digester system

C Evaporator system

C Pulp washing system

New Sources

C Same as existing sources plus...

C All weak liquor storage tanks

C All strong liquor storage tanks

C All acid condensate storage tanks

Each equipment system has multiple emission points. For example, the

evaporator system comprises pre-evaporators, multi-effect evaporators,

concentrators, vacuum systems, associated condensers, hot wells, and

condensate streams. A complete list of the emission points in each

equipment system is provided in Appendix F.
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

89

These emission

limits apply to the

entire source, not

to individual pieces

of equipment as do

the emission limits

for pulping system

vents at other mills.

Outlet emission

level and percent

reduction

requirements must

account for HAP

releases from vents,

condensates, and

wastewater from

control devices

used to reduce HAP

emissions.

What are the emission limits for sulfite pulping system vents?

The sulfite pulping system vents must meet either a percent reduction or

mass emission limit identified for the specific type of sulfite pulping process

(i.e., calcium- and sodium-based or magnesium- and ammonium-based

pulping processes). The emission limits apply to the combined emissions

from both the regulated equipment and any vents, wastewater, and

condensate streams generated from any control device used to reduce the

HAP emissions. Therefore, a mill must choose either the percent reduction

or the mass emission format and demonstrate compliance with the emission

limit using the combined emissions from the entire pool of regulated

equipment. Compliance may not be demonstrated at individual pieces of

equipment or individual closed-vent systems.

If the Sulfite Pulping System Then Choose One of the

is This Type... Following Emission Limits...

Calcium-based and Reduce total HAP concentration to

Sodium-based 0.89 lb/ton oven-dried pulp,

measured as total HAPs or

methanol

or

Reduce total HAP emissions by

92% by weight, measured as total

HAPs or methanol

Ammonium-based and Reduce total HAP concentration to

Magnesium-based 2.2 lb/ton oven-dried pulp,

measured as total HAPs or

methanol

or

Reduce total HAP emissions by

87% by weight, measured as total

HAPs or methanol
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

90

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems?

All regulated equipment systems must be enclosed and routed through a

closed-vent system to the control device that is selected for compliance. The

requirements for enclosures and closed-vent systems are presented below. 

The requirements are intended to prevent leaks and ensure that process

openings (e.g., sampling ports on a brown stock washer enclosure) are

closed while the mill is in operation.

This Equipment.... Requirements....

Must Meet These

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance,

or repairs

Components operated at positive Operate with no detectable leaks

pressure (500 ppmv VOC above

background)

Bypass lines that could divert vent Seal and secure the opening so that

stream containing HAPs to the the valve or closure mechanism

atmosphere cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes

Note: These requirements are the same as for kraft mills (presented on

page 54).
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

91

When must mills comply with the sulfite pulping process

requirements?

Affected sources at sulfite mills must comply with the NESHAP by April 16,

2001.

How does a mill demonstrate initial compliance with the sulfite

pulping system vent standards?

A mill must demonstrate compliance through an initial performance test. 

Total HAP may be measured as methanol using Method 308.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 23.

(3) To establish the process operating parameter values that must

be monitored to demonstrate continuous compliance. For

example, at a calcium-based and sodium-based sulfite mill, the vent

gas flow rate, scrubbing media flow rate, and pH of the scrubber

effluent that indicate 92 percent reduction by weight of total HAPs

or methanol using Method 308.
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

92

The excess

emissions

allowance (for

kraft, semichemical, and soda

mills) does NOT

apply to sulfite

mills.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

sulfite pulping system vent standards?

Mills must install a continuous monitoring system to measure either control

device or process operating parameters. Control device (other than gas

scrubbers) or process parameters to be monitored are determined by the

facility (i.e., site-specific). Continuous monitors for the selected parameters

are required to demonstrate continuous compliance. Figure 24 presents the

continuous compliance monitoring requirements.

In addition, the mill must comply with the requirements for periodic

inspection and maintenance of all enclosures and closed-vent systems. These

requirements are explained in Figure 23. The mill must maintain a sitespecific inspection plan for the enclosures and closed-vent system. Records

of repairs based on the inspections must also be kept.

Figure 23.

How Does a Mill Demonstrate Initial and Continuous Compliance with

the Closed-Vent Systems Standard?

If the System has... Then Inspect... And Report... Records of...

And Keep

Enclosure opening Visually inspect every 30 Any exceedences of the closed- All visual checks and

days to ensure closed and vent standard in quarterly any repairs

sealed reports. If no exceedences

occur, submit semi-annual

reports.

Annually demonstrate Same as above All pressure tests

negative pressure

Closed-vent system Visually inspect every 30 Same as above All visual checks and

days for visible defects repairs

Positive pressure Annually demonstrate no Same as above All leak tests

closed-vent system detectable leaks (less than

500 ppmv)

Bypass line valve Inspect every 30 days to Same as above All visual checks and

ensure valve is in a closed repairs

position and vent stream is

not diverted through bypass

line

Note: These are the same requirements as for kraft mills (presented on

page 57).
93

Figure 24.

How Does a Mill Demonstrate Continuous Compliance with the

Sulfite Pulping System Vent Standards?

If the Sulfite Pulping This Alternative And the Mill Chooses Continuously Monitor And Report This Records for

System is This Type... Emission Limit... This Technique... These Parameters... Information... 5 Years...

And the Mill Chooses And Keep These

Calcium-based and Reduce total HAP Gas scrubber pH or oxidation/reduction C Semi-annual pH or oxidation/

Sodium-based concentration at the outlet potential of effluent emissions and reduction potential of

a

to 0.89 lb/ton or reduce continuous effluent

total HAP emissions by Vent gas inlet flow rate monitoring a

92% by weight performance Vent gas inlet flow

Scrubber liquid influent report rate

flow rate C If exceedences

occur, then Scrubber liquid

quarterly reports influent flow rate

are required

(40 CFR

63.10(e))

Site-specific parameters Determine appropriate Same as above Parameters approved

monitoring parameter by the Administrator

values during the initial

performance testb

Ammonium-based and Reduce total HAP Same as above Same as above Same as above Same as above

Magnesium-based concentration at the outlet

a

to 2.2 lb/ton or reduce

total HAP emissions by a

87% by weight

Methanol may be used as a surrogate for total HAPs. a

As specified in 40 CFR Part 63.453(a). b
Chapter 6 - NESHAP Requirements

Sulfite Mills

Bleaching System Vents

94

The compliance

date for dissolving

grade sulfite mills

is not specified in

the NESHAP, but is

anticipated

between

2003-2005.

6.2 Standards for sulfite bleaching system vents

At sulfite mills the emission limits apply to bleaching systems that use

chlorine or chlorinated compounds. The NESHAP has emission limits for

both chloroform and chlorinated HAP. Sulfite mills must comply with both

of these requirements. The emission standards and compliance

demonstration requirements for sulfite mills are the same as for kraft mills

(presented in Section 4.3) and are not repeated in this chapter. Refer to the

following pages for specific information.

C Emission points to be controlled—page 68

C Control requirements for chlorinated HAPs and

chloroform—page 69

C How to demonstrate initial compliance—page 71

C How to demonstrate continuous compliance—page 72.

When must sulfite bleaching systems comply?

Bleaching systems must comply by April 16, 2001 with one exception.

C Dissolving grade sulfite mills must comply within 3 years after

publication of revised effluent limitations guidelines and standards

under 40 CFR 430.14 through 430.17 and 40 CFR 430.44 through

430.47. These rules are scheduled to be revised sometime between

2000 and 2002.
95

Secondary fiber

means recycled fiber.

The chloroform

control requirements

of the NESHAP do not

apply to bleaching

systems at these types

of mills.

Typically, a bleaching

line contains

3-5 stages.

Chapter 7 - NESHAP Requirements for

Mechanical, Secondary Fiber,

and Non-wood Fiber Pulp Mills

The NESHAP regulates bleaching system vents for mechanical pulping,

secondary fiber, and non-wood fiber pulp mills. The NESHAP applies to

bleaching systems that use chlorine or chlorine dioxide, and has identical

requirements for mechanical, secondary fiber, and non-wood fiber processes.

The pulping process system vents and condensates are not regulated at these

mills. 

7.1 Standards for bleaching system vents

At mechanical, secondary fiber, and non-wood fiber pulp mills the NESHAP

regulates chlorinated HAPs (excluding chloroform). The emission limits

apply to bleaching systems that use chlorine or chlorine dioxide. However, if

a bleaching system for one of these processes also accepts pulp from

processes at a kraft, semi-chemical, soda, or sulfite mill, then the more

stringent bleaching system requirements will apply (i.e., the bleaching system

also must meet the chloroform control requirements).

What mechanical, secondary fiber, and non-wood fiber

bleaching system emission points must be controlled?

The NESHAP applies only to bleaching stages that use chlorine or chlorine

dioxide. Extraction stages are not covered. All vents in a regulated stage

must be controlled. A stage consists of the following equipment:

C retention towers

C washers

C seal tanks

C chemical and steam mixers (if vented to the atmosphere)

C vacuum pumps (if present)
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

96

There are no control

requirements for

chloroform at these

other types of mills.

The requirements for

enclosures and

closed-vent systems

are the same as for

the pulping system

vent standards

(page 54).

Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or chlorine dioxide is

exempt from all NESHAP requirements for bleaching.

What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are

introduced must be enclosed and routed via a closed-vent collection system

to a control device. The rule provides three alternative emission limits for

demonstrating compliance, as shown below. Most mills are expected to use

caustic scrubbers to comply.

Bleaching System Gases Must be Collected in a Closed-vent System

and Meet One of These Three Alternative Emission Limits ...

a

1. Reduce chlorinated HAP emissions by 99% by weight b

2. Achieve a total outlet mass emission rate 0.002 pounds

chlorinated HAPs per ton oven-dried pulp for all subject stages b

3. Achieve an outlet concentration of chlorinated HAPs 10 ppmv b

Some mills may be able to meet the outlet concentration or mass limits through use of a

process modifications (i.e., 100 percent chlorine dioxide substitution). In these cases,

enclosures and closed-vent systems are not required.

Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or b

 as chlorine.

Note: These emission limits are the same for kraft mills (presented on

page 69).

When must mechanical, secondary fiber, and non-wood fiber

bleaching systems comply?

All mechanical, secondary fiber, and non-wood fiber processes must comply

with the chlorinated HAP control requirements by April 16, 2001.
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

97

How does a mill demonstrate initial compliance with the

bleaching standards?

Chlorinated HAPs. The mill must demonstrate initial compliance with

chlorinated HAP standards by conducting an initial performance test for each

bleaching stage where chlorine or chlorinated compounds are introduced.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameters that must

be monitored to demonstrate continuous compliance.

At the option of the mill, compliance may be demonstrated by measuring

either total chlorinated HAPs or chlorine concentration. The following

methods must be used:

Chlorinated HAPs - Any method that has been

demonstrated to the Administrator’s

satisfaction.

Chlorine - Method 26A, as modified by

63.457(b)(5) of the rule.
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

98

Continuous

monitoring is

required unless a

mill complies by

eliminating all use

of chlorine or

chlorinated

compounds as

bleaching agents.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

bleaching standards?

For chlorinated HAPs, a continuous monitoring system must measure either

emissions, or control device or process operating parameters. The

monitoring, reporting, and recordkeeping requirements are summarized in

Figure 25.

In addition, the mill must conduct periodic inspection and maintenance of all

enclosures and closed-vent systems. These requirements are explained

below. The mill must maintain a site-specific inspection plan for the

enclosures and closed-vent system. Records of repairs based on the

inspections must also be kept.

If the System has... Then Inspect... And Report... Records of...

And Keep

Enclosure opening Visually inspect every 30 Any exceedences of the closed- All visual checks and

days to ensure closed and vent standard in quarterly any repairs

sealed reports. If no exceedences

occur, submit semi-annual

reports.

Annually demonstrate Same as above All pressure tests

negative pressure

Closed-vent system Visually inspect every 30 Same as above All visual checks and

days for visible defects repairs

Positive pressure Annually demonstrate no Same as above All leak tests

closed-vent system detectable leaks (less than

500 ppmv)

Bypass line valve Inspect every 30 days to Same as above All visual checks and

ensure valve is in a closed repairs

position and vent stream is

not diverted through bypass

line

Note: These are the same requirements as for kraft mills (presented on

page 57).
99

Figure 25.

How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlorinated HAPs?

If a Mill Chooses This

Technique to Comply

With This Alternative Continuously Monitor These

Emission Limit... Parameters... Report This Information... And Keep These Records for 5 Years...

Gas scrubber to reduce pH or oxidation/reduction potential of C Semi-annual emissions and continuous pH or oxidation/reduction potential of

chlorinated HAP effluent monitoring performance report effluent

emissions by 99% by C If exceedences occur, then quarterly

weight or to achieve an reports are required (40 CFR 63.10(e))

outlet mass emission

rate 0.002 pounds

chlorinated HAPs per

ton oven-dried pulp

Vent gas inlet flow rate Same as above Vent gas inlet flow rate

Scrubber liquid influent flow rate Same as above Scrubber liquid influent flow rate

Gas scrubber to achieve Same as above

an outlet concentration

of chlorinated HAPs

10 ppmv

Chlorine concentration at the outlet or Chlorine concentration or all of the

measure all three of the following

parameters

following

pH or oxidation/reduction potential of Same as above pH or oxidation/reduction potential of

effluent effluent

Vent gas inlet flow rate Same as above Vent gas inlet flow

Scrubber liquid influent flow rate Same as above Scrubber liquid influent flow rate

Any control device other Determine appropriate monitoring Same as above Parameters approved by the Administrator

than a gas scrubber or parameter values during the initial

process modifications performance testa

 As specified in 40 CFR Part 63.453(n) a

Note: This is the same figure as the one presented on page 73.
100

100

The Cluster Rules do

NOT represent all of

the air and water

pollution regulation

of the pulp and paper

industry.

Chapter 8 - Other Federal Regulations Affecting

Pulp and Paper Mills

The Cluster Rules do not represent all of the air and water pollution

regulation of the pulp and paper industry. Pulp and paper mills are subject

to additional air requirements under the CAA; additional water requirements

under the Clean Water Act; and other Federal, State and local laws not

associated in any way with the Cluster Rules.

Federal regulations affecting the pulp and paper industry include:

C National Ambient Air Quality Standards (NAAQS)

C Kraft Mill New Source Performance Standards (NSPS)

(40 CFR 60, Subparts B and BB)

C Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and

Dc)

C Gas-Fired Turbines NSPS (40 CFR 60, Subpart GG)

C Prevention of Significant Deterioration (PSD)/New Source

Review (NSR)

C National Pollutant Discharge Elimination System (NPDES)

Related Statutes and Regulations

C Spill Prevention Control and Countermeasure (SPCC) Plans

(40 CFR 112)

C Notice of Discharge of Reportable Quantities of Hazardous

Substances (40 CFR 116 and 117)

C Resource Conservation and Recovery Act (RCRA)

C Emergency Planning and Community Right-to-Know Act

(EPCRA)/Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA)
101

Chapter 8 - Other

Regulations

101

BACT = best

available control

technology

LAER = lowest 

achievable emissions

rate

8.1 What other Federal air regulations affect the pulp

and paper industry?

Federal air regulations affecting the pulp and paper industry are shown

below.

The Following Air

Regulation... Affects... By...

NAAQS Energy generation Controlling NO , PM,

at pulp and paper VOC, and SO as part

mills of the state

x

a

2

implementation plans

NSPS

40 CFR 60, Subpart B Kraft pulp mills Controlling PM and

TRS at existing

sources under state

regulations. State

regulations are based

on EPA guidelines.

40 CFR 60, Kraft pulp mills Controlling PM and

Subpart BB TRS

40 CFR 60, Subpart D, Industrial boilers Controlling PM, NO ,

Db, and Dc SO

x

2

40 CFR 60, Gas-fired turbines Controlling PM, SO ,

Subpart GG NO

2

x

PSD/NSR Pulp and paper Requiring a

mills installing new pre-construction

or modified permit that imposes

equipment emission limitations

based on BACT or

LAER for criteria

pollutants for which

there is a significant

increase
102

Chapter 8 - Other

Regulations

102

National Ambient Air Quality Standards (NAAQS) have been established

for six criteria pollutants. Pulp and paper mills are potential sources of

particulate matter (PM), ozone precursors (volatile organic compounds

[VOCs] and nitrogen oxides [NOx]), and sulfur dioxide (SO2). Each State

must develop a State Implementation Plan (SIP) to identify sources of air

pollution and to determine what actions are necessary to achieve attainment

with the NAAQS for all criteria pollutants. The SIP contains emission

regulations that may affect the pulp and paper industry, including emission

limitations and standards and pre-construction permitting requirements

(e.g., New Source Review [NSR], Prevention of Significant Deterioration

[PSD]).

Kraft Mill New Source Performance Standards (NSPS) (40 CFR 60,

Subpart BB). The majority of kraft mills in operation are currently

regulated under the kraft mill NSPS (40 CFR Subpart BB) or State

regulations for existing sources promulgated under Section 111(d) of the

Act (40 CFR 60, Subpart B). The kraft mill NSPS sets emission limits for

particulate matter and TRS for recovery furnaces, smelt dissolving tanks,

lime kilns, digester systems, brown stock washer systems, multiple effect

evaporators, black liquor oxidation systems, and condensate stripper

systems. See page 79 for a more detailed discussion of the kraft mill NSPS,

as this regulation applies to kraft mills only.

Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and Dc) and GasFired Turbines NSPS (40 CFR 60, Subpart GG). Almost all pulp and

paper facilities have boilers and turbines for generating electricity and steam. 

Newer combustion units may be subject to regulation under one of these

rules which set emissions limits for particulate matter, nitrogen oxides, and

sulfur dioxide.
103

Chapter 8 - Other

Regulations

103

NPDES = National

Pollutant Discharge

Elimination System

8.2 What other Federal water regulations affect the

pulp and paper industry?

Federal water regulations affecting the pulp and paper industry are shown

below:

The Following Water

Regulation... Affects... By...

NPDES: Technology and Direct-discharging of Setting effluent

water quality-based pollutants into limitations on pollutants

limitations navigable waters based on available

technology and intended

use of receiving

waterbody; also sets

monitoring and reporting

requirements

Pretreatment program Indirect-discharging Setting pollutant

of pollutants to discharge limits to

publicly-owned POTWs

treatment works

(POTWs)

Storm water permit Any facility Establishing pollution

application prevention plans and best

management practices

(BMP)

Section 110 of CWA Any facility Prohibiting oil discharges

(40 CFR 110)

Spill Prevention Control and Oil storing/ Requiring a spill

Countermeasure (SPCC) consuming facilities prevention and control

(40 CFR 112) plan, reporting, plan

updates, and training

obligations

Notice of Discharge of Any facility Requiring reporting of

Reportable Quantities of designated hazardous

Hazardous Substances substance discharges to

(40 CFR 116 and 117) U.S. government

following the Department

of Transportation

regulations
104

Chapter 8 - Other

Regulations

104

The acronyms are

defined on the next

page in Figure 26.

The applicability of

these standards is

explained on

page 106 in

Figure 27.

National Pollutant Discharge Elimination System (NPDES) Program

(Clean Water Act, Section 402). The NPDES program controls direct

discharges into navigable waters. The scope of this program is quite broad,

and most point source discharges associated with a pulp and paper mill will

be subject to NPDES permitting requirements. The effluent limitations

guidelines and standards and requirements for direct discharging mills are

presented in the table below. The applicability of these standards is more

fully explained in Figure 27.

These Clean Water Act Standards

Apply...

For These Mill Types or PSES, and BCT,

Production Operations... PSNS NSPS BMP

BAT, BPT,

Dissolving Kraft X X X

Bleached Papergrade Kraft and X X X

Sodaa

Unbleached Kraft X X X

Dissolving Sulfite X X X

Papergrade Sulfite X X X

a

Semi-chemical X X X

Mechanical X

Non-wood Chemical X X

Secondary Fiber Deink X

Fine and Lightweight Papers X

from Purchased Pulp

Tissue, Filter, Non-Woven, X

and Paperboard from

Purchased Pulp

 The effluent limitations guidelines and standards for these subcategories were revised in a

 the Cluster Rules.
105

Chapter 8 - Other

Regulations

105

Figure 26.

A Guide to the Acronyms for Technology-Based Water Standards

Acronym Definition Description of Standard

PSES Pretreatment Standards for Existing Industry-by-industry pretreatment a

Sources standards for existing sources that

discharge their wastewater indirectly

(i.e., to a POTW).

PSNS Pretreatment Standards for New Industry-by-industry pretreatment a

Sources standards for new sources that

discharge their wastewater indirectly

(i.e., to a POTW).

BPT Best Practical Control Technology A baseline standard, applicable in all

Currently Available circumstances

BCT Best Conventional Pollutant Control More stringent than BPT. Only

Technology applies if certain cost tests are met. 

Must be “cost-reasonable.” See

51 FR 24,974-24,976 (July 9, 1986),

for EPA’s BCT methodology.

BAT Best Available Technology A standard similar to BPT/BCT, but

Economically Achievable with cost concerns playing a lesser

role. A “best of the best” standard.

BMP Best Management Practices Designed to prevent or contain leaks

and spills of pulping liquor, soap, and

turpentine, and to control any

intentional diversions of these

substances.

NSPS New Source Performance Standards Applicable to new direct discharge

sources, as defined in 40 CFR 122.2.

Although the categorical standards in 40 CFR Part 430 cover kraft pulp mills, most kraft pulp mills are direct a

dischargers subject to NPDES permit requirements and not the pretreatment standards.
106

Chapter 8 - Other

Regulations

106

Figure 27.

Applicability of Technology-Based Standards

If a Mill That

Discharges These To These Direct And the Mill is Apply

Pollutants... Receivers Classified as an... are...

Then the

Required

Standards

Conventional Surface waters Existing source BPT or

pollutants BCT

Toxic and Surface waters Existing source BAT

conventional

pollutants

Any pollutants Surface waters New source NSPS

Any pollutants POTWs Existing source PSES

Any pollutants POTWs New Source PSNS

Source: 40 CFR 125.3

Spill Prevention Control and Countermeasure (SPCC) Plans

(40 CFR 112). This regulation applies to all facilities that store or use oil or

oil products, and which because of their location, could reasonably be

expected to discharge oil into navigable waters of the United States. Such

facilities are required to prepare a SPCC plan.

Notice of Discharge of Reportable Quantities of Hazardous Substances

(40 CFR 116 and 117). This regulation defines the discharges into

navigable waters of the United States that must be reported to appropriate

agencies of the U.S. Government. This requirement does NOT apply to

discharges covered by a facility’s NPDES permit.
107

Chapter 8 - Other

Regulations

107

TRI = Toxic

Release Inventory

8.3 What Federal hazardous wastes regulations affect

the pulp and paper industry?

Federal hazardous wastes and emergency planning regulations affecting the

pulp and paper industry are shown below:

The Following

Hazardous Waste

Regulation... Affects... By...

RCRA Black liquor at pulp Requiring reclamation and

mills reuse of black liquor

EPCRA/CERCLA Pulp mills C Requiring that air and

water discharges from the

mill be accounted for by

filing TRI Form R reports

for certain pollutants

C Requiring mills to provide

information on chemicals

used in the bleach plant

C Requiring mills to report

emergency spills or offsite releases (air, water, or

solid wastes)

Resource Conservation and Recovery Act (RCRA). Most RCRA

requirements are not industry specific but apply to any company that

transports, treats, stores, or disposes of hazardous wastes. The pulping

process generally does not generate significant RCRA-related hazardous

waste streams. However, handling of black liquor can create RCRA-related

concerns. Black liquor is exempt from regulation as a solid waste under

40 CFR 261.2(e) and Table 1, 261.4(a)(6), but only if the black liquor is

reclaimed in a recovery furnace and reused in the pulping process. 

Therefore, potential liquor spills that are not reused in the process, such as

leaks from surface impoundments used to store black liquor prior to

recovery will be an issue for RCRA compliance assessment.
108

Chapter 8 - Other

Regulations

108

Emergency Planning and Community Right-to-Know Act (EPCRA)/

Comprehensive Environmental Response, Compensation, and Liability

Act (CERCLA). EPCRA section 313 requires manufacturing facilities to

submit an annual toxic chemical release report. This requirement applies to

facilities in SIC codes 20 through 39, that have ten or more employees, and

that manufacture, process, or use specified chemicals in amounts greater

than threshold quantities. This report, referred to as the Form R, covers

releases and transfer of toxic chemicals to various facilities and

environmental media, and allows EPA to compile the national Toxic Release

Inventory (TRI) database.

Air emissions and water effluents of certain pollutants from pulping

processes must be accounted for in the annual TRI Form R report. Solid

waste discharges from the pulping area are not generally a significant issue

for Form R reporting purposes because these releases generally remain onsite. Pulp and paper mills must also report emergency “spills” or certain offsite releases that might occur as the result of process upsets or other

malfunctions. These releases could include abnormal air emissions, and in

some situations, water or solid waste discharges directly from the pulping

area.
109

Chapter 8 - Other

Regulations

109

More regulations

are coming!

Upcoming pulp mill

combustion sources

NESHAP scheduled

for 1999.

Five NESHAP for

combustion sources

are scheduled for

2000.

Effluent limitations

guidelines and

standards

scheduled for

2000-2002.

8.4 What upcoming regulations will affect pulp and

paper mills?

Pending regulations that will affect the pulp and paper industry include:

C Chemical Recovery Combustion Sources and Kraft, Soda,

Sulfite, and Stand-Alone Semi-chemical Pulp Mills

NESHAP (63 FR 18754, proposed standards, April 15,

1998). EPA plans to finalize and publish emission standards

that will affect recovery furnaces, lime kilns, and smelt

dissolving tanks.

C NESHAP for Combustion Sources. EPA plans to publish

five NESHAP that will affect power boilers, process heaters,

gas turbines, reciprocating internal combustion engines, and

incinerators.

C Effluent Limitations Guidelines and Standards. EPA plans

to publish revised effluent limitations guidelines and standards

for additional subcategories in the near future. These include: 

dissolving kraft; dissolving sulfite; unbleached kraft; semichemical; mechanical pulp; non-wood chemical pulp;

secondary fiber deink; secondary fiber non-deink; fine and

lightweight fibers from purchased pulp; and tissue, filter, nonwoven, and paperboard from purchased pulp.

Pending water regulations consist of EPA proposing effluent limitations

guidelines and standards for the pulp and paper industry subparts that were

not included in the Cluster Rules. And finally, EPA is considering whether

pulp mill wastewater treatment system sludges are to be considered a

hazardous waste and subject to RCRA Subtitle C. Since the effluent

guidelines address concerns about chlorine containing compounds, it is

expected that there will be no change in the exemption of pulp mill sludges

from being classified as a hazardous waste.